Summer 2004 ISSUE #17

FedFacs

an environmental bulletin for federal facilities

Working Toward Environmental 

Compliance and Sustainability in 

the Federal Government

The U.S. Environmental ProtectionAgency’s Federal Facilities Enforcement Office (FFEO) is responsible for

ensuring that federal facilities comply

with environmental laws and take actions

to prevent, control and abate environmental pollution. Over the years, the ways in

which FFEO performs this task have

evolved from reliance on traditional EPA

tools, such as enforcement and compliance

monitoring, to include newer, more innovative approaches to more completely

address the complexities of environmental

problems facing government agencies.

This issue profiles FFEO and its program. We will look briefly at the U.S. government sector and its compliance record

with environmental laws. In this and

related articles, we will look at EPA’s federal facility program and its efforts to

develop and integrate a range of tools and

strategies to ensure facility compliance

with environmental laws, and foster

greater environmental stewardship

within government agencies. 

Inside

3 US and Israel Joint Management Systems

Project

5 President’s Management Council 

Compliance Initiative

8 Update on E.O. 13148 Implementation

9 EMS Mentoring Program and other EMS

News

13 P2 and Environmental Stewardship News

19 EPA’s “Buying Green Online”

20 EPA’s Self­Disclosure Policy

21 EPA’s Inspection Initiative, and other

Enforcement and Compliance Montitoring

News

24 “Closing the Circle” and other awards

25 Upcoming Events

26 EPA’s Federal Facility Program Managers

Environmental Compliance

Challenge

The U.S. government owns over 674 million acres of land – nearly one third of the

United States, and owns or leases over

480,000 buildings.1 Federal facilities are

buildings, installations, structures, land,

public works, equipment, aircraft, vessels, and other vehicles and property

owned by or constructed or manufactured

for the federal government. The government’s approximately 30 agencies,

bureaus and departments control over

32,000 facilities, over 7,800 of which are

engaged in a broad range of activities regulated under U.S. environmental laws.2

Collectively, the U.S. government is the

nation’s largest consumer of natural

resources and power, and generates significant amounts of pollution and harmful wastes. Federal agencies, like private

parties, are required to comply with all

federal environmental requirements,

including those of states, localities and

tribes. U.S. government agencies must

also comply with additional requirements

set out in Presidential Executive Orders. 

Since 1993, FFEO has monitored federal agency progress in meeting statutory

and regulatory requirements. In its most

recent report on compliance, which covers

fiscal years 2001 and 2002, FFEO reports

compliance rates for Continued on page 5

ABOUT THIS ISSUE...

Environmental

Spotlight

NEW ENFORCEMENT CHIEF

ENCOURAGES GOOD STEWARDSHIP

BY FEDERAL FACILITIES

By Tom Skinner

Acting Assistant Administrator, 

EPA’s Office of Enforcement and 

Compliance Assurance

I

am pleased to have

this opportunity to

introduce myself, and

also share with you

some thoughts about

the future direction of

OECA’s federal facility

program.

As EPA’s chief enforcement and compliance assurance officer, I want to

improve the federal government’s environmental performance through facility

compliance with environmental requirements, pollution prevention, and environmental stewardship. 

This is especially important for the

U.S. government. Government facilities

must not only comply with regulatory

requirements, but I believe they can also

be role models and mentors for innovation, sustainability and environmental

stewardship.

The strategies for achieving these

goals, first outlined by my predecessor J.P.

Suarez as “Smart Enforcement,” embrace

a “common sense” approach, and are the

foundation for the program managed by

OECA’s Federal Continued on page 2

In this issue, we spotlight the U.S. EPA’s federal facility enforcement and compliance assurance

program, and its changing approach to achieving environmental compliance and stewardship in

the federal government. Traditional core program functions, like enforcement and compliance

monitoring are discussed, and also new strategies and tools designed to address the complex

and changing nature of environmental protection throughout the government. 

Printed on Recycled Paper
ENVIRONMENTAL SPOTLIGHT

Continued from page 1

Facilities Enforcement Office. Put simply,

our federal facility program will use the

most appropriate enforcement and compliance tools to address the most significant problems to achieve the best outcomes. 

For our federal facility program, this

means several things. First and foremost,

we will continue to be a strong enforcement presence in the field. We are also

exploring and embracing new environmental compliance tools uniquely suited

for the federal community, and encouraging innovators and leaders in environmental management and stewardship.

This and past issues of FedFacs can be

gov/compliance/resources/newsletters/

civil/fedfac/index.html

FEDFACS ON THE WEB

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

FedFacs

is published by EPA’s Federal

Facilities Enforcement Office. 

EPA #300­N­04­004

Marie Muller, FFEO, Editor

Robin Foster, 

Legin Group, Layout

Federal Facilities Enforcement Office

Office of Enforcement and Compliance 

Assurance

U.S. EPA (2261A)

1200 Pennsylvania Ave, NW

Washington, DC 20460

Phone: 202­564­2510

Fax: 202­501­0069

Internet: www.epa.gov/compliance/

resources/newsletters/civil/fedfac/

index.html

Often, a combination of tools, or an “inte­ ronmental Stewardship and Compliance

grated strategy” is the best approach. Assistance Center, slated for launch this

We also recognize that partnerships year. EPA hopes that federal agencies

and collaborative efforts – at both the working together and combining their

national and regional level – are critical collective knowledge, experience and

to furthering environmental compliance, resources, will result in more environinnovation, and information exchange. mental compliance and innovation

We have had success in realizing greater throughout the government.

environmental benefits through As the former Regional Administrator

increased cooperation for EPA Region 5 and manager

between agencies. We are embracing of the Great Lakes Program, I

For example, EPA understand the value and neces­ new environmental

and the Office of the sity of programs and initiatives

Federal Environmen­ compliance tools tailored to address regional or

tal Executive have suited for the federal local issues. EPA has a wide

joined together to help community, and range of innovative regional fedother federal agencies eral facility programs and partmeet Executive Order encouraging  nerships, and I look forward to

13148’s mandate for innovators and leaders new opportunities in the future.

appropriate federal in environmental  Finally, I congratulate federal

facilities to implement agencies and facilities that are

environmental man­ management and not only meeting their environagement systems, and stewardship.  mental requirements, but going

make the federal gov­ beyond them to incorporate susernment a leader in environmental man­ tainable practices in their facility operaagement. The Office of the Federal Envi­ tions. I look forward to guiding EPA’s fedronmental Executive and I share a eral facility enforcement and compliance

common vision that facilities can mitigate assurance program, and being a vital

and sometimes eliminate environmental part of the federal government’s progress

problems by integrating environmental toward its environmental goals.

considerations into all aspects of facility Thomas Skinner was appointed Acting

operation. Assistant Administrator for the Office of

EPA’s partnership with the Veterans Enforcement and Compliance Assurance

Health Administration (VHA) is a tem­ of the U.S. Environmental Protection

plate for collaborative efforts between Agency on April 2, 2004. Mr. Skinner was

EPA’s federal facility program and other Regional Administrator for the EPA

federal agencies. By helping agencies Region 5 in Chicago and previously Direcsuch as the VHA identify and address its tor of the Illinois Environmental Protecenvironmental problems, EPA hopes to tion Agency before joining the U.S. EPA in

enable them to design and implement 2001. He holds a juris doctorate degree

internal environmental programs that from Northwestern University School of

address their specific needs. Law and an undergraduate degree from

EPA is creating a forum for collabora­ Lawrence University. Mr. Skinner will

tion and information exchange with the remain the Great Lakes National Pronew full service Federal Facilities Envi­ gram Manager for the Agency. 

FEDERAL ENVIRONMENTAL EXECUTIVE 

JOHN HOWARD RESIGNS 

John Howard submitted to President Bush his resignation as Federal Environmental Executive,

effective June 11, 2004. He and his family will be returning home to Austin, Texas. He stated, “It

has been a privilege and an honor to have served with so many in working to improve the Federal

government’s (and America’s) environmental stewardship, and I believe we have made substantial progress. I wish all of you the best as you continue this important work with OFEE, through Ed

Pinero, Dana Arnold, and the OFEE team.” 

2 FEDFACS
US and Israel Work on Management Systems 

for Environment and Security

The United States­Israel Science andTechnology Foundation (USISTF),

Civil Infrastructure Security (CIS) Network, and Office of the Federal Environmental Executive (OFEE) conducted a

stakeholder meeting in March 2004 to

initiate an effort to identify the approach,

procedures, outcomes and metrics necessary to integrate environmental and

security management systems. 

The goal is to develop a blueprint for

U.S. and Israeli private, public and governmental entities to develop integrated

systems using the Environmental Management System (EMS) model (particularly the ISO­14001 standard). Particular emphasis will be placed on the following elements: risk identification and

assessment; risk prevention through

process improvement and the introduction of new technologies; emergency

response; and continual improvement of

processes and operations. 

Pilot sites will be identified to test

the draft tools. At the conclusion of the

pilots, finalized guidelines, protocols

and lessons learned, as well as any

other information on the non­sensitive

aspects of the demonstration project

and collected non­confidential materials

will be published. 

This effort supports the Administration’s commitments to EMS, collaborative efforts with the non­federal community, and leadership in international

technology development. Other federal

entities involved in the project include

the Department of Homeland Security,

National Institute of Standards and

Technology, the U.S. Postal Service and

Environmental Protection Agency.

For additional information please

contact: Ed Piñero, Deputy Federal

Environmental Executive in the Office

of Federal Enviromental Executive

(202) 564­1297, or Edwin_pinero@ceq

.eop.gov.

VHA Launches Green Environmental 

Management Systems

The U.S. EPA and the Department of

Veterans Affairs (VA) Veterans Health

Administration (VHA) are partnering to

improve environmental compliance at VA

facilities.

At the VHA’s request, EPA conducted

or will conduct environmental management reviews (EMRs) at 17 VA medical

centers across the nation. Final reviews

will be conducted in 2004. EMRs help

individual facilities improve facility operations and minimize impacts on the environment. 

They also enable VHA to design and

implement national changes to address

common environmental issues found at

the VA medical centers. 

The EMRs also evaluated environmental management systems (EMSs) at VA

facilities, and were a good foundation for

Green Environmental Management Systems (GEMS) – a program the VA

launched in April to meet requirements of

Executive Order 13148, “Greening the

Government Through Leadership in Environmental Management.” 

The GEMS Guidebook, which lists the

steps a facility must take to develop

GEMS on­site, proposes a top­down and

bottom­up approach for VA medical centers. A key component of GEMS is the

requirement of periodic environmental

compliance audits which should identify

many environmental problems while they

can be easily corrected. 

The GEMS program includes nine

steps: 1) appoint GEMS coordinator and

GEMS committee; 2) train GEMS committee; 3) conduct initial GEMS gap

analysis; 4) identify significant environmental aspects; 5) establish operational

controls; 6) set objectives and targets; 7)

train staff on GEMS policies and standard operating procedures; 8) conduct

environmental compliance baseline and

periodic follow­up audits; and 9) issue

annual program effectiveness review

and report.

GEMS follows the “plan­do­check­act”

model, making integration with Joint

Commission on Accreditation of Healthcare Organizations (JCAHO) Environment of Care programs easy at healthcare facilities. In fact, many of the

requirements for GEMS are already in

place. During the EMRs, this was a consistent finding. 

With EPA’s assistance, the VHA continues to develop and deliver environmental training programs. The VA’s medical

center top management and safety managers also received GEMS training. VA

staff also received RCRA hazardous waste

compliance training, and EPA Region 1

(Boston) delivered environmental training in May. Many training programs were

videotaped and will be re­broadcast, while

the VA is also developing more in­depth

technical training. A joint Chief Engineer/Safety Conference in September,

with part of the agenda devoted to GEMS

and environmental training, is under

development.

For further information visit: http://

www.epa.gov/compliance/assistance/

sectors/federal/epavha.html or contact:

Diane Lynne, lynne.diane@epa.gov. See

related articles in past issues of FedFacs

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

/resources/newsletters/civil/fedfac/index.

html.

FEDFACS 3
Fort Chaffee and Sheppard AFB Ready for Reuse

Ready for Reuse determinations wereissued to two facilities in U.S. EPA

Region 6 (Dallas). In November 2003,

Region 6 and the Arkansas Department

of Environmental Quality (ADEQ)

issued a Ready for Reuse determination

to Fort Chaffee, Ark. In March 2004,

Region 6 and the Texas Commission on

Environmental Quality (TCEQ) issued

its determination to Sheppard Air Force

Base (AFB) in Wichita Falls, Texas. 

The Ready for Reuse determination

verifies that environmental conditions

on affected portions of these facilities

are protective of human health and the

environment based on their anticipated

use as commercial/industrial and residential properties. Determinations provide specific information about a site,

including the nature and extent of contamination, cleanup work performed,

and status with state and federal

requirements.

The Fort Chaffee determination, the

first awarded to a U.S. Army facility,

applies to approximately 7,000 acres of

land declared excess by DoD. Ownership was transferred under the Base

Realignment and Closure (BRAC) Program to the Fort Chaffee Redevelopment Authority. The property was used

for military training and had troop barracks, a hospital, administrative offices,

maintenance/supply buildings, a golf

course and an airstrip. Fort Chaffee

closed in 1997.

The Ready for Reuse ceremony was

held at “Fantasies at the Fort,” a former

Army administration building now

being reused as a wedding banquet hall.

In addition to local dignitaries, Army

representatives from the Pentagon and

the Hampton, Va. BRAC office attended

the event.

The Sheppard AFB determination

applies to Installation Restoration Program Site FT003. The site was used for

fire protection training exercises from

approximately 1957 to 1992. A variety of

materials, primarily waste fuels, were

burned at the site during the exercises. 

Pictured from left to right: Marcus Devine, ADEQ Director; Jerry Stewart, M.D., Ft.

Chaffee Redevelopment Authority Chairman; Richard Newsome, Assistant for

Restoration, Office of the Deputy Asst. Secretary of the Army for Environment, Safety

and Occupational Health; and Carl Edlund, EPA Region 6 Multimedia Planning and

Permitting Division Director.

Pictured from left to right: Laurie King, EPA Region 6 Federal Facilities Section Chief;

Brigadier General Arthur Rooney, Jr., Commander, 82nd Training Wing; and Allan

Posnick, TCEQ DSMOA Manager. 

Sheppard AFB is the largest and

most diverse training facility in the Air

Force’s Air Education Training Command (AETC). The determination is the

first awarded to an AETC base. The

Ready for Reuse ceremony was attended

by local dignitaries, as well as officials

from AETC Headquarters at Randolph

Air Force Base in San Antonio, Texas. 

Additional information about the

Fort Chaffee and Sheppard AFB ready

for reuse determinations is available at

www.epa.gov/earth1r6/ready4reuse and

www.epa.gov/earth1r6/ready4reuse,

respectively.

4 FEDFACS
inspected federal facilities regulated

under the Resource Conservation and

Recovery Act (RCRA) and the Clean Air

Act (CAA) remain near or above 90 percent. Similarly, compliance rates remained

above 90 percent for federal facilities

inspected under the Safe Drinking Water

Act (SDWA). In contrast, the compliance

rate for major federal facilities regulated

under the National Pollution Discharge

and Elimination System (NPDES) of the

Clean Water Act (CWA) decreased from 94

percent to 52 percent between fiscal years

1993 to 2001. It increased in fiscal year

2002 to 67 percent, but remains comparatively low. [See Article Notes, p. 7 for more

information on this report]

An Integrated Approach

FFEO, a Headquarters office under EPA’s

Assistant Administrator for the Office of

Enforcement and Compliance Assurance

(OECA), and Federal Facility Program

Managers and other staff in EPA’s ten

regional offices around the country work

together to ensure federal facilities take

all necessary actions to prevent, control

and abate environmental pollution.

FFEO, currently headed by David

Kling, and regional staff are an interdisciplinary group of attorneys, engineers,

scientists and program analysts. FFEO

works closely with other EPA offices and

staff on the variety of issues affecting federal facilities.

The sheer size, breadth and diversity

of federal activities impacting the environment creates enormous regulatory

compliance challenges not only at the

facility level, but also for EPA in designing a program to match the complexity

and sometimes disparate needs of this

diverse universe. One size clearly does

not fit all. 

Over the years, EPA’s federal facility

program evolved a strategy to meet these

challenges, and integrated it into its new

program agenda. The strategy is guided

in part by OECA’s “Smart Enforcement”

policy, which uses the most appropriate

enforcement and compliance tools to

address the most significant problems to

achieve the best outcomes.

The policy focuses on five key areas: 

1) addressing significant environmental,

human health and compliance problems;

2) using data to make strategic decisions

to better utilize resources; 3) using the

most appropriate tool to achieve the best

outcome; 4) assessing the effectiveness of

program activities to ensure continuous

program improvement and desired program performance; and 5) communicating the environmental, public health and

compliance outcomes of EPA activities to

enhance program effectiveness. 

Often the best approach to solving

environmental problems is a combination

of tools – an “integrated strategy.” While

EPA’s federal facility program rests on

the foundation of “smart enforcement”

principles, which relies on traditional

regulatory tools such as enforcement and

compliance monitoring, it also includes

other approaches designed to take advantage of the full range of possible solutions

for environmental problems at government facilities. 

An integrated strategy embraces and

encourages compliance assistance, pollution prevention and environmental management systems as ways for federal

agencies to achieve or maintain compliance – and go beyond by institutionalizing sound environmental stewardship

policies and sustainable practices into

facility operations. Preventing pollution

in the first instance minimizes the need

for pollution controls or compliance assistance, and in some cases may take facilities out of regulatory regimes altogether.

This more “holistic” approach to environmental problems also includes new

partnering and cooperative efforts within

EPA and with other federal agencies and

offices. Partnering fosters cooperation

and understanding between agencies as

they work jointly on practical and sustainable solutions to complex issues.

Partnering also enables the government

to leverage valuable resources and expertise among agencies.

FFEO’s current program agenda identifies specific strategies EPA will use to

address federal facility compliance problems, and specific projects and initiatives

to forward these goals and efforts. These

strategies are described

FEDFACS 5

PRESIDENT’S MANAGEMENT COUNCIL 

COMPLIANCE ASSURANCE INITIATIVE

In April 2003, the President’s Management Council (PMC) and the Office of Management and Budget (OMB) asked the President’s Council on Environmental Quality (CEQ) and the Office of the Federal Environmental Executive (OFEE) to identify how federal agencies assure environmental compliance and offer recommendations for improvements. In the summer of 2003, OFEE and the

Interagency Environmental Leadership Workgroup established under Executive Order 13148 conducted the first-ever survey of federal agencies’ environmental compliance management. The survey reflected ongoing efforts to incorporate environmental management system (EMS) principles

into federal agency programs. Questions were presented regarding compliance auditing programs,

allocation of resources for compliance monitoring and level of management engagement in the

compliance process. 

OFEE received responses from 63 departments, agencies, services and bureaus. Responses are

under review by the Interagency Workgroup, and compilation and analysis of the results is nearly

complete. The effort will culminate in identification of best practices and a series of recommendations to improve federal agency compliance programs at the facility and agency level. Reflecting

the ongoing federal efforts to implement EMSs at federal facilities by the end of 2005, compliance

management recommendations will be made in the context of the EMS framework. In addition, consideration will be given to enhancements in compliance support mechanisms across the federal

community. 

The final report will be issued to the PMC and OMB for their review and consideration. Based

on recommendations and feedback from the PMC and the OMB, CEQ, the Interagency Workgroup,

with OFEE guidance, will develop action plans and milestones.

For additional information contact: Will Garvey, EPA (202) 564-2458 or Ed Pinero, OFEE (202) 564-

1297.

ENVIRONMENTAL COMPLIANCE AND 

SUSTAINABILITY 

Continued from page 1

Continued on page 6
CERL TO MANAGE COMPLIANCE ASSISTANCE CENTER

EPA’s Federal Facilities Enforcement Office recently signed an inter­governmental agreement with

the Army Corps of Engineers Construction Engineering Research Laboratory (CERL) to develop,

launch and manage the new Federal Facilities Environmental Stewardship and Compliance Assistance Center. CERL, located in Champaign, Ill., has experience operating similar interactive compliance assistance centers for the military. In addition, for the past decade, CERL assisted a number of federal agencies develop compliance audit protocols through the TEAM process.

EPA’s existing compliance assistance center, FedSite (http://www.epa.gov/fedsite) will be

expanded. The new Center’s interactive capabilities will be used to meet the growing environmental compliance needs of the federal community. Eventually, the new independent Center will be

governed by member agencies which will direct the Center and its future activities. Launch of the

new Center is expected later this year.

For more information concerning the Federal Facilities Environmental Stewardship and Compliance Assistance Center, please contact: Mike Shields (202) 564­9035 or shields.mike@epa.gov. 

ENVIRONMENTAL COMPLIANCE AND 

SUSTAINABILITY

Continued from page 5

briefly below:

1.  Maintain Compliance and

Administer Enforcement:  Compliance

monitoring and enforcement remains the

backbone of EPA’s regulatory program,

and FFEO and its regional counterparts

will continue to be the “cop on the beat.”

EPA performs single and multi­media

inspections, and will take all necessary

enforcement actions, especially when no

other appropriate solution to non­compliance exists.

In 2003, EPA had 34 formal enforcement actions against federal facilities,

representing over $920,000 in penalties

and another $1.8 million in supplemental

environmental projects (SEPs). Currently, EPA’s multi­media inspection initiative is underway and the Agency is

inspecting facilities meeting certain criteria to maximize its impact. [See related

article in this issue, p. 21]

FFEO is also looking to align, where

appropriate, its priorities with other

Agency enforcement and compliance priorities, particularly in regard to Clean

Water Act wet weather and stormwater

issues. EPA will also encourage facilities

to “self­audit” for environmental violations and report these violations under

EPA’s self­disclosure policy. [See related

article in this issue, p. 20]

2. Directed Strategies at Specific

Compliance Problems or Sectors:

Complex environmental problems or

facility operations often require a combination of tools and approaches to attain

the best results. For instance, in the

course of a broader effort to address environmental problems at hospital facilities,

EPA identified Veterans Health Administration (VHA) hospitals as good candidates for a national integrated strategy

approach. 

EPA and the VHA embarked on a cooperative partnership to further identify and

address these problems. Currently, EPA is

completing a series of environmental management reviews at VHA facilities across

the country and providing other compliance assistance such as training and workshops. EPA will be looking for other opportunities to partner with federal agencies in

similar ways in the future.

3. Cleaning up Federal Facilities:

EPA continues to oversee Comprehensive

Environmental Response, Compensation,

and Liability Act (CERCLA) and RCRA

remediation and cleanup activity at

Superfund and other sites at federal facilities. FFEO coordinates closely with

EPA’s Federal Facility Restoration and

Reuse Office (FFRRO) within the Office of

Solid Waste and Emergency Response

(OSWER), OECA’s Office of Site Remediation and Enforcement and EPA’s

Regions on these issues. FFEO and other

EPA offices must oversee a federal

cleanup program which costs nearly $10

billion a year at federal energy and military facilities alone. The office, in conducting its oversight responsibilities, also

endeavors to work cooperatively with federal agencies as they improve project

management and increase cost­efficiency.

Recently, EPA and the Department of

Defense (DoD) resolved a nearly threeyear dispute on post­Record of Decision

(ROD) issues regarding oversite and

institutional controls at cleanup sites.3

This agreement is particularly important

as cleanup activity is completed, and EPA

and DoD look towards long­term maintenance of sites.

4. Championing EMS: EPA’s federal

facility program is advancing, particularly in partnership with the Office of the

Federal Environmental Executive

(OFEE) and EPA Regions, the development and implementation of environmental management systems (EMSs) at federal agencies. This effort coincides with

Executive Order 13148 requirements for

“appropriate” federal facilities to have

EMSs in place at their facilities by

December 31, 2005. EPA and OFEE cochair an Interagency Workgroup to facilitate implementation of these requirements. This federal work group has

contributed significantly to increased

communication and coordination at federal facilities across the country.

EMS training, supported by FFEO

staff and funds, has been offered nationwide by EPA regional staff, and educates

federal facility and environmental managers on more effective, efficient and

enduring stewardship approaches. 

EPA also conducts environmental

management reviews, a collaborative

effort between EPA and a federal facility

to evaluate the facility’s environmental

program and management systems.

EMRs are voluntary and initiated by an

agency or facility; they are not compliance assessments, audits or inspections. 

5. Forging Beneficial Partnerships:

FFEO believes that developing and cultivating new partnerships is vital to EPA’s

federal facility program and its continued

success at ensuring federal facility stewardship and compliance with environmental laws. Partnering is active on the

national Headquarters and regional

level, and several efforts are detailed here

and in past issues of FedFacs. EPA looks

for new partnering opportunities in the

future. 

EPA is not the only government entity

interested in monitoring and fostering

environmental compliance within the

government. Last year the President’s

Management Council (PMC) launched

Continued on page 7

6 FEDFACS
ENVIRONMENTAL COMPLIANCE AND 

SUSTAINABILITY

Continued from page 6

the Compliance Assurance Initiative to

improve the environmental compliance

and performance of federal agencies.

FFEO and OFEE have been working

closely with the PMC in this effort. [See

related article in this issue, p. 5] 

EPA also shares a common vision for a

sustainable government with OFEE, and

is partnering with them on various

efforts towards this goal. EPA and OFEE

are working to institutionalize good environmental stewardship with the widespread use and implementation of effective environmental management systems

and other practices. Ultimately, this will

minimize the amount of energy and

resources the U.S. government expends,

the amount of pollution it produces, and

provide an example for others to emulate. 

6. Improving Data Quality and

Accessibility:  FFEO is also designing

and deploying better information systems to track federal facility compliance

with environmental laws. FFEO’s new

generation of compliance and other environmental information on federal agencies is used to better inform Agency management, federal government officials,

and the public of environmental progress.

This information is particularly valuable

in EPA’s enforcement and inspection targeting initiatives, and for identifying serious violators. 

One system, the Federal Agency Compliance Tracking System (FACTS) is

accessible to federal agencies and enables

users to research, track and monitor the

environmental compliance history and

current status of individual facilities.

[See related sidebar in this issue, p. 22]

7. Creating a New Federal Facility

Compliance Center: FFEO continues to

develop an enhanced web­based, full­service, environmental stewardship and

compliance assistance center for federal

facilities. The existing compliance assistance center for federal facilities, FedSite4

, will be expanded and all federal

government compliance assistance

resources integrated into one independent site. The site will be maintained by

the Army Corps of Engineers Construction and Engineering Research Laboratory (CERL), which managed the DoD’s

environmental web site DENIX. EPA

plans to enable this new center so that all

federal government compliance assistance resources are integrated into one

site eventually supported and directed by

member agencies. 

8. Enhancing Communications and

Outreach:  FFEO is improving its outreach mechanisms, and also hopes to foster and encourage greater information

exchange among federal agencies and

facilities. FedFacs, published twice a year

by FFEO, informs its audience about

environmental issues, activities and

events impacting the federal community.

Federal agencies are encouraged to share

their experiences by contributing articles

for publication. The last two issues featured government efforts on the implementation of Executive Order 13148 and

environmental management systems,

and pollution prevention and environmental stewardship5

. 

FedEnviroNews is the federal facility

program’s electronic newsletter. It is sent

approximately once a month and contains

short news items and events of interest to

the federal community. The federal community is also invited to contribute news

items for dissemination to the over 2,300

primarily federal government subscribers.

Looking Towards the Future

EPA’s FFEO will continue to maintain

core program functions, while incorporating new approaches and initiatives which

meet the changing needs of the federal

community. FFEO will evaluate program

effectiveness and make adjustments as

appropriate to work towards these goals.

Federal agencies are invited to share

their ideas on new strategies.

EPA applauds the many federal facilities already busy at work institutionalizing sustainable facility operation and

environmental practices, and encourages

them to be mentors to others in the federal community. FFEO supports, and

hopes to cultivate, new programs which

will shape the entire federal community

into a model of environmental stewardship.

[1]  General Services Administration Real Property

Profile, September 30, 2002

[2]  As reported on EPA’s Online Tracking System

database: http://www.epa.gov/Compliance

/planning/data/multimedia/aboutotis.html

[3]  An article on the Post­ROD resolution appeared

in the Winter 2003­4 issue of FedFacs.

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

/newsletters/civil/fedfac/index.html

[4]  FedSite is located at: www.epa.gov/fedsite

[5]  Past issues of FedFacs are found at:

http://www.epa.gov/Compliance/resources/newsle

tters/civil/fedfac/index.html

Additional Article Notes

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’s website at: www.ofee.gov for

more information on how to prevent pollution

at your facility and incorporate sustainable

practices into its operation.

EPA’s Federal Facilities Restoration and

Reuse Office The EPA’s Federal Facilities

Restoration and Reuse Office (FFRRO) works

with the Department of Defense, Department

of Energy, and other federal entities to develop

creative, cost­effective solutions to their environmental problems. FFRRO’s overall mission is

to facilitate faster, more effective, and less

costly cleanup and reuse of federal facilities.

By focusing on partnering and public involvement, FFRRO, and its counterpart offices in

Headquarters and EPA regions, have made

great strides in improving federal facilities

cleanup. You can learn more about FFRRO on

its website at: http://www.epa.gov/fedfac

State of Federal Facilities ­ An Overview of

Environmental Compliance at Federal Facilities, FY 2001 ­ 2002 presents information on the

federal government’s compliance assessment

(inspections), compliance assurance (enforcement actions), and environmental performance (compliance rates). The current report,

as well as past biennial reports from 1993, can

be found on EPA’s website at:

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

/federal/crossmedia.html

FEDFACS 7
EMS

Update on E.O. 13148 Implementation

The Executive Order (E.O.) 13148 “Greeningthe Government Through Leadership in

Environmental Management” Interagency

Environmental Leadership Workgroup

has been busy working through issues,

and implementing several Order requirements. Below is an update on the

progress of several areas: 

TRI: E.O. 13148 calls for a 40 percent

reduction in on­site releases and off­site

transfers for treatment and disposal of

Toxic Release Inventory (TRI) Chemicals

by December 31, 2006, from a baseline

year of 2001. The most recently available

data for TRI shows that reported figures

for federal facilities for 2001 totaled about

79 million pounds. The reduction target

for the entire federal community is therefore approximately 32 million pounds.

Data for reporting year 2002 is not yet

available.

Section 503 Chemicals: E.O. 13148 calls

for a 50 percent reduction in the use of

certain chemicals for identified applications and purposes by the end of 2006.

The chemicals are to be identified by EPA

in coordination with the Interagency

Workgroup. In May of this year, EPA, in

coordination with the Office of the Federal Environmental Executive, affirmed

that five chemicals and associated applications should be included for the purposes of this effort. The chemicals are:

mercury, lead, cadmium, naphthalene

and polychlorinated biphenyls (PCBs)

with associated uses of switches and

measuring devices, electroplating

processes, soldering, pesticide use and

insulating materials (dielectric fluids).

Next steps in this process include providing field level personnel with information

on implementation of this effort.

EMS: E.O. 13148 requires implementation of environmental management systems (EMS) at federal facilities by the

end of 2005. There has been considerable

activity at the field level to meet this

requirement. Training has taken place

through EPA Regional offices as well as

within federal agencies. EMS training

has also been provided to senior leadership at several agencies to ensure their

support and commitment towards successful implementation. In addition, EPA

has provided assistance in the form of

facility­level Environmental Management Reviews.

Annual Reports: E.O. 13148 requires

that each federal agency submit an

annual report to EPA outlining that

agency’s progress towards meeting the

goals in the E.O. Guidance for each year’s

annual report is developed by the E.O.

13148 Interagency Workgroup. The

report focuses on various reduction goals

in the E.O. and agency and facility level

progress in implementing EMS. Reports

for calendar year 2003 were due to EPA

by March 31, 2004. Twenty­three agencies provided annual reports. Information

in these reports will be used to prepare

the Office of the Federal Environmental

Executive biannual Report to the President on Federal Energy and Environmental Management as well as the Federal Agency EMS “Scorecard” and the list

of “appropriate” facilities developing

EMSs under the E.O.

EPA’s GreenScapes program has additional

information on environmentally beneficial

landscaping. GreenScapes provides costefficient and environmentally­friendly 

solutions for large­scale landscaping.

It encourages entities to make more 

environmentally beneficial and sustainable 

decisions regarding waste generation and 

disposal and its associated impacts on land,

water, air and energy use. GreenScapes is

located at: http://www.epa.gov/greenscapes/

Beneficial Landscaping

Guidance to be Revised

I

n 1995 the Federal Environmental Executive released guidance on environmentally beneficial landscaping which requires

federal agencies to consider using environmentally sensitive

landscaping practices and native plants. Executive Order 13148

supports these goals, and also calls for a review and update of

this guidance.

Currently, a small inter­agency discussion group adjunct to

the E.O. 13148 Workgroup is reviewing the 1995 guidance. The

group will likely recommend the guidance be updated to incorporate a more holistic multi­media (i.e. waste, water, air, etc.)

approach to landscape construction and maintenance which

ensures pollution prevention and resource conservation.

For more information, please contact Will Garvey at EPA, garvey.will@epa.gov. The current guidance can be found at:

http://www.epa.gov/docs/fedrgstr/EPA­GENERAL/1995/August

/Day­10/pr­664.html

8 FEDFACS
EMS

EMS Mentoring Program: 

Partners for Environmental Performance

T he Office of the Federal Environmental Executive (OFEE) is sponsoring a new, voluntary mentoring program, “Partners for Environmental

Performance,” that matches private

entities that have successful environmental management systems (EMS)

with federal facilities currently developing their own EMS. This program will

enhance federal EMS implementation,

required under Executive Order 13148,

and provide opportunities for participants to learn from shared experiences. 

The private sector’s experience with

EMS is a valuable resource for the federal government. Companies began

implementing EMSs in the 1980’s and

started using the ISO 14001 model in

earnest in the mid­1990’s. Currently,

over 5000 entities are ISO 14001 certified in the United States. Nearly all are

in the private sector, compared to only a

few hundred EMSs in the federal government, of which only 21 are certified.

Worldwide there are over 70,000 certified entities. 

Both the federal government and private entity mentor will benefit. A federal

agency or facility will learn from the

hands­on experience its mentor has in

developing, implementing and maintaining an EMS. Mentoring will help

the private entity meet its own EMS

requirements, improve its public goodwill, and give it a role in making the

government more efficient and a better

environmental steward.

Mentors must have robust, fully

operational EMSs, and are restricted to

entities that do not provide related consulting services. To help identify the

best candidates, state environmental

offices, trade associations and individual companies will be contacted and

encouraged to act as facilitators and

champions. Candidates may also

include other entities such as non­profits or local governments.

Partnerships will be determined in

Mentoring provides private

entities and federal facilities

opportunities to learn from

shared experiences.

large part by matching the available

and interested participants according to

interests, geography, desired EMS

model, and status of implementation. 

Selected participants will sign an

informal, non­binding Memorandum of

Understanding (MOU) that defines project­specific details such as timelines,

milestones, and expectations. The MOU

will address potential legal issues such

as conflict of interest, non­endorsement

of products, and protection from compensation for services claims.

As the project progresses, OFEE may

ask participants for brief status reports

so it can monitor the success of the program. At the conclusion of the project,

participants will receive formal

acknowledgement from OFEE.

For more information about this program contact: Ed Piñero, Deputy Federal Environmental Executive in the

Office of the Federal Environmental

Executive (202) 564­1297, or

Edwin_pinero@ceq.eop.gov, or visit:

http://www.ofee.gov

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 9
EMS

Park Service Partnership Assists Businesses in Parks

On your last visit to a national park, didyou buy a trinket in a gift shop, purchase a soda in a restaurant, or stay

overnight in a lodge? If so, you may have

supported one of the 584 businesses

authorized under National Park Service

(NPS) concession contracts to provide

lodging, retail, food and beverage,

marina, and other commercial visitor services within 127 national parks. 

Last year, the EPA National Center for

Environmental Innovation partnered

with the NPS Concession Environmental

Management Program (CoEMP) to promote environmental management systems and identify cost­effective and

appropriate best management practices

(BMPs) for concessioners. This partnership enables EPA to reach a business sector with high visibility to the general public – the tourism industry. 

EPA and NPS are first concentrating

on improving the environmental performance of national park concessioners.

They also hope to assist other federal

agencies which contract with concessioners, as well as the tourism industry at

large, in identifying appropriate strategies to advance environmental performance.

With its mission of “provid[ing] assistance and guidance that advances the

environmental performance of businesses

offering visitor services in national

parks,” the NPS CoEMP, since its inception in 1999, has developed numerous

assistance tools and serves as a national

clearinghouse for all matters relating to

concessioners and the environment. 

The CoEMP provides technical assistance to concessioners and also conducts

environmental audits, required by Executive Order 13148. The environmental

audits cover multiple environmental topics, such as compliance, BMPs, and environmental management systems.

opportunity for environmental criteria

and standards to be included. The NPS

CoEMP assists NPS staff in incorporating

environmental management standards

and criteria into concession contracts. It

also educates NPS staff about concessioner activities that may potentially

affect park resources. 

Finally, one of

NPS CoEMP’s main

goals is to increase

NPS staff and concessioner knowledge of

potential environmental impacts stemming from day­to­day

concessioner operations, and how these

impacts can be

avoided and/or mitigated. The EPA complements the

Houseboat and marina operations at

Glen Canyon National Recreation Area,

Arizona and Utah.

The NPS CoEMP faces some challenging, but exciting times ahead with

approximately 85 percent of NPS concession contracts expiring within the next

three to five years. NPS staff faces a

heavy workload that involves writing and

publicizing concession contracts that

emphasize resource protection, environmental compliance, and environmental

BMPs. Since concession contracts last

typically for 10 to 20 years, now is the

EPA ANNOUNCES E.O. 13148 PRIORITY CHEMICALS 

EPA announced five priority chemicals used by the federal government that are targeted for

reduction in accordance with Executive Order 13148 “Greening the Government Through Leadership in Environmental Management.” The E.O. directs EPA to develop a list of priority chemicals

used by the federal government that may result in significant harm to human health or the environment and that have known, readily available, less harmful substitutes for identified applications and purposes. Federal agencies are to develop and support goals to reduce the use of these

chemicals by 50 percent by December 31, 2006. For more information visit: http://www

.ofee.gov/wpr/chemical.htm

CoEMP’s concessioner assistance efforts in many ways,

including providing federal, state, and

local resources that describe applicable

environmental requirements and BMPs.

This EPA/NPS partnership provides a

growing network of environmental contacts that NPS staff, concessioners,

tourism and hospitality businesses can

turn to for questions and discussion.

Other resources available for both

NPS staff and concessioners include:

• A GreenLine Phone Number, (303)

987­6913

• A dedicated GreenLine Email

(NPS_GreenLine@nps.gov) 

• The GreenLine Newsletter, a 

bi­annual publication

• The GreenLine Compact Disc

• The CoEMP website (www

.concessions.nps.gov/program3.cfm)

• Numerous concession­specific compliance and BMP assistance resource

documents

For more information on the NPS

CoEMP, contact: Wendy Berhman,

CoEMP Team Leader (303) 987­6913.

10 FEDFACS
EMS

TVA Improves EMS with Lead Auditor Training

The Tennessee Valley Authority (TVA)environmental audit team participated in U.S. EPA Region 4 (Atlanta)

sponsored Federal Facility Lead Environmental Auditor training given in

New Orleans in March. This training

provides federal agencies the information necessary to design and implement

Executive Order 13148 Environmental

Management System (EMS) requirements. 

The Registrar Accreditation Board

(RAB) accredited ISO 14001 Lead Auditor class was taught by EPA RAB certified instructors, and participants were

able to take the RAB certification exam

and apply for RAB EMS auditor certification following the course. 

TVA’s EMS, in place for several

years, is modeled after ISO 14001. It

includes a corporate level EMS and

tiered EMS implementing procedures at

the major organization and facility

level. An EMS self­declaration program

will be implemented to comply with the

requirements of E.O. 13148. TVA will

first self­declare the corporate EMS,

and then offer each facility the opportunity to self­declare conformance to the

ISO 14001 standard. Interagency participants at the EMS Lead Auditor Training

The TVA corporate environmental

audit team has reviewed EMS audits at For more information about TVA and

their facilities for the last three years, its EMS audit program contact: Myron EMS MANAGERS GUIDE but this EPA sponsored training pro­ Iwanski, TVA (865) 719­3718 or visit vided them with opportunities to fur­ TVA’s web site: http://www.tva.com. For NOW ONLINE 

ther sharpen their skills and learn more information on EPA classes con­ The Office of the Federal Environmental about other continuous improvement tact: Anthony Shelton, EPA Region 4 opportunities for their EMS and audit Executive (OFEE) and the U.S. EPA have (404) 562­9636 or Joyce Stubblefield,

program. EPA Region 6 (214) 665­6430. adapted the Army’s Environmental ManThese included conducting a gap

analysis of TVA's corporate level EMS, agement System guide for managers and

designing a self­declaration program, tailored it for other agencies to use. This is

and revising the corporate EMS audit a useful tool to help educate senior man­ For more information about  protocols. Facilities were also advised agement about their leadership role in EMS. on how to continually strenghten their Environmental Management

EMS and improve the audit team credi­ Systems visit:  This and other useful EMS tools and guides

bility inside and outside TVA. The are available on the OFEE website:

training also provided an opportunity www.epa.gov/ems or http://www.ofee.gov/ems/training/facts. for TVA to network with other federal www.ofee.gov/ems/ems.htm agency EMS auditors. htm#guide

FEDFACS 11
EMS

Fort Polk Integrates Workshop Results into EMS

On April 27­29, 2004, the Joint Readiness Training Center (JRTC) and

Fort Polk, La., hosted a Sustainable

Water Resources Workshop. Colonel

Thomas McClung, Garrison Chief of Staff

welcomed regional stakeholders to the

conference and sought their perspectives

and thoughts on a regional, sustainable

water resources management strategy. 

Conference participants represented

a broad, cross­section of interests.

Among the attendees were: Louisiana

State Rep. William Daniel; Karen

Gautreaux, Deputy Secretary, La.

Department of Environmental Quality;

Bill Alley, HQ U.S. Geological Survey

(USGS); Charles Demas, USGS, Baton

Rouge, La.; Lisa Lewis, U.S. Forest Service; and Dr. Charles Allen, Professor of

Bog Ecology, Louisiana State University.

They were joined by others representing

local communities, the Army Installation Management Agency (Southwest

Regional Office), Louisiana regulatory

agencies, and JRTC and Fort Polk

Directorates.

Conference attendees agreed to “provide Fort Polk flexibility to meet future

mission requirements for water

resources and achieve the above without

any unacceptable environmental, economic or social consequences.” This

strategic objective is comprised of three

key components: sustainable water use,

water resource protection, and resource

restoration (if warranted). 

Attendees also agreed that both

additional baseline monitoring and

method analysis are required. For

example, increases in demand could be

supplied by reducing consumption via

conservation methods and/or increased

water supply rate, but additional information is required to determine the

optimal method or methods to employ. 

Fort Polk is incorporating these

results into its EMS. Quantifiable targets to improve current baseline data

and analysis are being developed for the

next EMS review. Water use is one of six

areas the JRTC and Fort Polk plans to

discuss with regional stakeholders in

several months, within the context of its

EMS.

WOULD YOU LIKE 

AN EMR?

An EMR is generally coordinated out of one

of the U.S. 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 

4. Internal and external communications 

5. Program evaluation, reporting and corrective action 

6. Environmental planning and risk management formality of environmental

programs.

To learn more about EMRs and how your

facility may schedule one, please contact

the EPA Federal Facility Program Manager

(FFPM) in your region. A list of FFPMs

appears on page 26 of this issue.

EPA Conducts EMRs at Temple VAMC

and Camp Stanley 

U.S. EPA Region 6 (Dallas) conducted

environmental management reviews

(EMRs) at two federal facilities, the Veterans Administration Medical Center

(VAMC) in Temple, Texas and U.S. Army

Camp Stanley Storage Activity (CSSA)

in Boerne, Texas. The EMRs included a

review of each facility’s environmental

programs and management system to

determine the extent protection programs and plans have been developed

and implemented. 

Because the Temple VAMC is committed to making continuous environmental

improvements at its facility, it was an

early volunteer and participant in the

EPA/VHA cooperative partnership.

The EMRs were based upon the ISO

Environmental Management System

14001 “model, plan, do, check and act.”

Prior to the EMRs, EPA regional staff

worked with each facility and designed

the parameters and scope of the review.

Temple VAMC has received EPA’s draft

report of its review, which took place in

December 2003. The CSSA Boerne onsite review was completed in February

2004, and a draft report was recently

submitted to CSSA for review and comment.

The EMRs were well received by

staff. Temple’s VAMC Safety Manager

facilitated a flawless scheduling of tours

and interviews, and Paul E. Batterton,

Administrator for the Waco VAMC, participated in the EMR out­brief. The

CSSA Environmental Coordinator provided valuable assistance in executing

the EMR and helped to clarify the intricate dynamics of Camp Stanley. 

For more information, contact: Joyce

Stubblefield, EPA Region 

stubblefield.joyce@epa.gov

12 FEDFACS

6 
P2 and Environmental Stewardship

The Army Environmental Strategy: A Sustainable Army

Raymond J. Fatz 

Deputy Assistant Secretary of the Army

for Environment, Safety and Occupational Health

I

n November 2003, the Army initiated a

process to develop a bold, new strategic

approach for addressing its relationship

with the environment. We have commenced on a path that will better support the Army mission with environmental principles and practices for years to

come: to “Sustain the Mission–Secure

the Future.” 

We will be a sustainable Army – one

that simultaneously meets mission

requirements worldwide, protects human

health and safety, enhances quality of life,

and safeguards the natural environment.

This is a significant commitment, made

with full knowledge of the complete

redesign that our equipment, operations

and installations require — a transformation that has already begun, but still has

far to go. This is a long­term commitment,

to radically change the way we design,

build, buy, transport, and otherwise perform our mission, as we transform our

weapons systems, tactics, and installations over the coming decades. This is a

necessary commitment. Senior Army leadership is keenly interested in adapting the

successful business model of balancing

“the triple bottom line of people, profit,

planet” for long­term military viability. 

Sustainability is the paradigm that

the Army is using to focus our thinking

and efforts to better address present and

future needs of our installations, our relationships with communities, as well as

impacts to our ability to equip, train, and

deploy our Soldiers. By applying the principles of sustainability, we are creating

installations that are “flagships” capable

of supporting Army operations throughout the world.

The quest for installation sustainability in the Army

received special recognition by the governor as a leader in the state. Fort Hood,

Texas and Fort Carson, Colorado both

began sustainability programs in 2002

with Fort Campbell, Kentucky kicking off

their sustainability initiative in 2003. In

2004, we are seeing other installations

eagerly stepping forward on the road to

sustainability. 

The Army expects sustainability to

play a key role in shaping the culture on

our installations and in local communities. As such, we will soon release a new

Army environmental

began in By applying the principles strategy with sustainearnest in 2001

but has rapidly of sustainability, (the Army) is  ability as its underlying

framework. It is an

gained momen­ creating installations that are exciting time for the

tum with Army as we take the “flagships” capable of senior leadership support. supporting Army operations next step toward a sustainable future.

Sustainability throughout the world. [Editor’s Note: The

easily appealed

to Army leadership because it is directed

at “senior­level decision­making” and

illustrates that the Army can, in fact,

accomplish its mission, safeguard people’s quality of life, and protect human

health and the environment. Sustainability also appeals to the troops and civilians

in the field, the ones on the ground, as

they become essential players in the goalsetting processes. This in turn motivates

them to use and champion sustainable

principles. Finally, sustainability appeals

to the many stakeholders and regulatory

communities since it focuses their collective efforts and resources to balance

requirements that keep everyone more

viable far into the future. 

Since 2001, Army installations across

the country have embarked on the journey towards sustainability and the balance of this discussion spotlights their

progress in three short years. Fort Bragg,

North Carolina, was the first installation

to quantify their pursuit of sustainability.

Fort Lewis, Washington followed soon

after seeking to harness the power of

their newly certified ISO 14001 Environmental Management System and

U.S. EPA invites other

government agencies and departments to

present their views in FedFacs. The

above article contains those views of

Raymond Fatz, Deputy Assistant Secretary of the Army for Environment, Safety

and Occupational Health, and are not

necessarily those of the EPA.]

JOINT SERVICE P2

OPPORTUNITY 

HANDBOOK

The Joint Service P2 Opportunity Handbook

identifies "off­the­shelf" pollution prevention

technologies, management practices, and

process changes that reduce hazardous and

solid waste. The handbook was prepared

jointly by the Naval Facilities Engineering

Service Center, the Air Force Center for Environmental Excellence, the Army Environmental Center, Headquarters Marine Corps,

the Defense Logistics Agency, and the Coast

Guard. This tool is found at: http://p2

library.nfesc.navy.mil/p2_opportunity_

handbook/introduction.html

FEDFACS 13
P2 and Environmental Stewardship

P2 and Sustainability Programs at Fort Bliss

Hazardous Waste Curbside

Service

Fort Bliss, Texas, implemented a service

unique to the Army – one that revolutionized hazardous waste management at the

installation. The Hazardous Waste Curbside Service  (Curbside) saves Fort Bliss

hundreds of thousands of dollars each

year, and minimizes accidents, exposure

to hazardous substances and non­compliance.

This program is the brainchild of

Environmental Engineer, Ismael Delgado

and began as a pilot program in 2000.

Curbside now serves customers at 127

waste accumulation points in Texas and

New Mexico. Curbside is a reimbursable

service for soldiers, civilians, and tenants,

protects human health and the environment, and returns soldiers to the military

mission. 

The program includes paperwork

(waste profile and Material Safety Data

Sheets, requests for sampling/analysis,

etc.), pickup and transport of wastes to

the hazardous waste storage facility, container replacement, and courtesy inspections. Customers are served by appointment within 72 hours by a team of

hazardous waste professionals. 

Without Curbside about 250 people

would be tasked, in addition to their

other duties, with the waste management

activities listed above. Curbside also

includes a tracking database that provides customers with reports of items

recycled, wastes processed, and disposal

costs. The reports are produced annually

or at the customer’s request.

As a large­quantity generator and the

owner of a RCRA­permitted storage facility, Fort Bliss is required to reduce the

volume and toxicity of hazardous waste it

generates.  To that end, the Directorate of

Environment combined Curbside with

pollution prevention initiatives to launch

the Installation’s Sustainability Center. 

In 2003, the following processes were

implemented at the Sustainability Center: parts­washer solvent distillation and

maintenance; antifreeze recycling; oily

rag compaction; soil consolidation contaminated soil; fluorescent bulb crushing;

oil and fuel filter crushing/recycling;

aerosol can puncturing; spill kit specification and assembly; and drum washing

and reuse.

These processes save disposal costs

and are beneficial to the environment.

The parts­washer solvent distillation

process alone saves Fort Bliss about

$250,000 a year for disposal of old solvent

and purchase of new solvent for the

Installation’s 135 parts washers. 

At the beginning of the calendar year,

commanders and directors receive a

detailed report of the wastes turned in by

each of their waste­generating activities.

Curbside costs for the new year are based

on quantities of waste generated during

the previous year.

The popularity of Curbside is evident:

100 percent of Fort Bliss waste generators voluntarily subscribe to the service,

and speak favorably about the service

they receive.

Submitted by: Pat McKernan, 

Fort Bliss Directorate of Environment;

patricia.mckernan@us.army.mil.

Oil Water Separator 

Maintenance Program

In an effort to save precious water

resources, minimize waste, maintain

compliance, and support the military mission, Fort Bliss implemented its Oil

Water Separator (OWS) maintenance

program. 

Fort Bliss initiated its OWS maintenance contract with Enviremedial Services Inc. (ESI) to correct a long history of

poor OWS maintenance, preclude future

Environmental Performance Assessment

System wastewater deficiencies, and promote pollution prevention, water conservation and waste minimization. 

ESI’s on­site treatment technology

uses a package plant on “wheels” which

separates oil from water through a centrifugal gravitational and inertial force

process. Oil separation is achieved

through a five­stage process and reusable

filters made from the ash of burned sugar

cane stalks are used. The unit can handle

100,000 gallons of contaminated water in

an eight­hour day. The treatment process

also includes a wash cycle for OWS collected sediments which are used as landfill daily cover.

Clean treated water is returned to the

OWS, instead of recharging the OWS

with fresh water and disposing of this

dirty waste water and sludge off­site.

This contributes directly toward the DoD

Measure of Merit for the continuous

reduction of waste. Moreover, it allows for

inspection of each OWS during the treatment process, where problem areas can

be identified and addressed quickly.

The contractor is also piloting a program which uses clean sediments in

adobe pavers. Combined with cement

materials, sediment is formed into adobe

bricks, further reducing waste. These

pavers may soon be used in xeriscape

landscaping and post beautification projects at Fort Bliss.

Among the other benefits of the OWS

process are that industrial pre­treatment

standards are maintained thereby avoiding exceedances fixing the cost for OWS

cleaning. Also the volumes of waste

removed, recycled, treated and disposed

are measured and reported to the environmental office and waste disposal offsite is reduced. Transportation and disposal liabilities are also reduced.

From May 2002 through October

2003, Fort Bliss calculates it minimized

this waste by 99.9 percent. The OSW

treated 15,785,200 pounds of water (previously sent as waste), recycled 66,800

pounds oil/fuel (previously sent as waste)

and cleaned 8,158,426 pounds of sediment (previously sent as waste). The

amount of oil sludge sent as waste was

2250 pounds. 

Submitted by: David Jevons, Wastewater Program Manager, Fort Bliss;

david.jevon@us.army.mil.

14 FEDFACS
P2 and Environmental Stewardship

White Sands Test Facility Reduces CFCs and Wins Award

Employees who work in the Chemistryand Component Services Laboratories of the NASA White Sands Test

Facility (WSTF) near Las Cruces, N.M.,

have been reducing use of ozone­depleting cleaning solvents like chlorofluorocarbon (CFC) 113 since 1991. 

WSTF, a satellite facility of the Johnson Space Center, eliminated CFC­113

(commonly known as Freon) in the final

cleaning and cleanliness verification of

critical spacecraft parts and components. 

Employees began implementing an

aqueous cleaning and verification process

in 1997. This cleans as well as or better

than CFC techniques used previously and

reduces to zero the use of CFC­113 and

the solvent once used for cleanliness verification in aerospace systems.

The test facility is an industry leader

in the development of alternatives for

cleaning aerospace and oxygen systems.

Oxygen systems pose special cleaning

challenges because organic contaminants and particulates can be ignition

hazards. 

Ultra­clean systems and component

parts are essential to the WSTF’s mission: the safe exploration of space.

Award winners (back L to R) Mark Leifeste, HTSI Program Manager; Stephen C.

Nunez, Manager of the White Sands Test Facility, Richard McCarson for Mark

Stevens, Mike Padilla, Mike Kirsch, Deputy Manager of the White Sands Test Facility

(Front L to R) Harold Beeson, Steve Hornung, and Jose Lopez

The WSTF team developed the aqueous cleanliness verification using ultrasonic agitation followed by total organic

carbon analysis to test for residual

organics and filtration for particulate

Flight and develop­ count in the clean­ The test facility is a leader mental systems in developing alternatives  ing process. The

from propulsion to team then establife support are for cleaning aerospace  lished detectability

tested at WSTF for of flight hardware and oxygen systems. performance and contaminants, verireliability. Support

systems need to be as clean or cleaner

than the flight test systems to which

they are attached. This ensures the test

systems will not be contaminated.

The test facility’s approach to eliminating CFC­113 included conservation, alternative water­based processes, ozonefriendly solvent alternatives, and

advanced processes to reduce solvent

usage and conserve supplies. New

processes and solvent alternatives eliminated annual usage of 3,870 gallons of

CFC­113. 

fied part configuration for aqueous application and verified

material compatibility for aqueous

application. The team then started the

cleaning operations using the cleanliness verification process.

The team measured results through

WSTF­developed technology, and this

data was used to gain approval to incorporate the new processes in NASA procedures.

Harold Beeson and Mike Kirsch of

NASA, and Mark Stevens, Steve Hornung, Jose Lopez, Mike Padilla,

Raphael Delgado of Honeywell, were

recognized for their efforts by the U.S.

EPA at the Stratospheric Ozone Protection Awards ceremony in Washington,

D.C. This year, EPA awarded seven corporate and governmental awards, eight

individual awards and two team and

organizational awards, selecting among

a global field of entrants.

Mike Kirsch, Deputy Manager of the

White Sands Test Facility summed up

the impact of the EPA award. “NASA

takes thousands of pictures from space

that help us appreciate how wonderful

and fragile our planet is, and how

important it is to protect our environment. NASA’s mission is to understand

and protect our home planet and to

empower future generations to continue

space exploration in search of new frontiers.”

Submitted by: Cheerie R. Patneaude,

NASA White Sands Test Facility. For

more information about NASA’s White

Sands Test Facility visit: http://www

.wstf.nasa.gov

FEDFACS 15
P2 and Environmental Stewardship

Working Towards Sustainability at USDA Beltsville

Over the past decade, Beltsville Agricultural Research Center (BARC)

staff and management have worked diligently to make the Center as environmentally friendly and sustainable as possible. As a result of their efforts, BARC

received four White House “Closing the

Circle” Awards and a “Business for the

Bay Award.” 

The BARC is part of the Agricultural

Research Service (ARS), U.S. Department of Agriculture (USDA), is located

just outside Washington, D.C., and

encompasses approximately 6,600 acres.

The facility is comprised of laboratories,

offices, wooded areas, research farm

plots, forage production land, barns, pastures and associated infrastructure for a

large complex. 

Several initiatives have improved environmental quality in the research and forage areas of the agricultural production

program. For instance, two certified nutrient management specialists ensure comInBrief

pliance with all state and federal regulations. As a result, BARC exceeded its

nutrient reduction goals and also implemented a phosphorus management program prior to any state mandates. 

To reduce the amount of pesticide and

manure run­off to the Chesapeake Bay,

precision agriculture and site­specific pinpoint placement of nutrients techniques

are used. BARC also uses no­till farming

methods in approximately 90 percent of

its farming efforts. 

Integrated pest management is used

on a regular basis. Only when the pest

population reaches an action level is pesticide applied, and then is limited to areas

over the threshold. 

Sustainable agricultural practices are

incorporated into day­to­day farming

activities. Fall­seeded legumes act as natural mulch and release nitrogen into the

soil. This, along with cover crops, reduces

weeds and herbicides. 

BRAC produces all mulch used in

EPA ISSUES PLUG­IN TO E­CYCLING GUIDANCE

EPA has released new, voluntary guidance to its Plug­In To eCycling partners, who will test its provisions to determine the most effective and practical methods for safely managing used electronic

equipment. The Plug­In To eCycling partnership, formed in 2002, aims to increase the safe recycling

of used electronic products by providing recognition and other incentives to partners. The new

guidance, “Plug­In To eCycling Guidelines for Materials Management,”spells out preferred waste

management practices for used electronic products and defines partner eligibility. In addition to

ensuring environmentally safe recycling of old electronics, this guidance promotes and maintains

adequate markets for the reuse and recycling of electronic equipment. For more information, go to:

http://www.epa.gov/epaoswer/osw/conserve/plugin/index.htm

REVIEW AND COMMENT FOR PURCHASING GUIDES

On June 30th, EPA published a Federal Register notice announcing the availability for public review

and comment of four draft Environmentally Preferable Purchasing (EPP) Guides. These guides provide information to federal procurement officials making EPP decisions that can help protect

human health and the environment. The four guides cover purchasing for “greener” carpets, cleaning products and copiers, and for making meetings and conferences more environmentally friendly.

The 60 day public comment period ends August 30, 2004. Stakeholders can access these documents and submit comments through EPA’s internet site for Federal Register Dockets at:

http://www.epa.gov/edocket/. The guides are also available on EPA's EPP website at

http://www.epa.gov/epp/documents/pfs.htm. For more information contact EPA’s Terry Grogan (202)

564­6317 or grogan.terry@epa.gov.

landscaping. Animal waste is combined

with leaves and other materials to make

the compost – this reduces the amount of

materials for disposal and also saves

money.

Landscape practices at BARC were

also significantly changed to help the

environment. “No mow” areas near

streambeds allows natural growth,

reduces stream bank erosion and cools

the water — a benefit for the fish. Previously mowed areas were reforested and

provide habitats for other wildlife. 

BARC uses American produced biodiesel fuel in approximately 150 vehicles

and equipment. B­20 fuel (20 percent biobased and 80 percent diesel) reduces sulfur content, unburned hydrocarbons, and

carbon monoxide by 20 percent, and particulate matter by 15 percent. BARC also

uses biodiesel for its heating plant operations and for fueling generators that provide backup power. 

BARC uses all environmentally  and

worker friendly or biobased products for

cleaning and elsewhere in the facility. All

paper products are made of recycled content, and new carpet is made of soy material. Hydraulic fluid, two­cycle engine oil,

chain saw bar oil, hand cleaners, lubricating oil and motor oil are also biobased. BARC also replaced slate roofs

with recycled Royale Polymore material,

which looks like slate but is less expensive.

Recycling is a major initiative at

BARC. All paper, magazines and cardboard are recycled. Research scientists

work together to utilize chemicals and

reduce the amount of chemical waste.

Several chemicals are maintained at a

dispensary, and scientists take what they

need rather than buy a large quantity.

BRAC recycles effluent from its wastewater treatment plant by pumping it to

one of the boiler plants and producing

steam. This method saves approximately

$40,000 per year on water. 

For more information contact: John

Van de Vaarst: vandevaj@ba.ars

.usda.gov

16 FEDFACS
P2 and Environmental Stewardship

GSA Brings Solar Power to Downtown Los Angeles

The U.S. General Services Administration’s (GSA) Pacific Rim Region completed installation and start­up of the

largest photovoltaic system in the GSA

inventory, at the Federal Building located

at 300 North Los Angeles Street, Los

Angeles, Calif. Over the life of the system,

the solar generated electricity will reduce

emissions of carbon dioxide by 2,842 tons,

nitrogen oxide by 5,064 lbs and sulfur

dioxide by 1,544 lbs. These emission

reductions are equivalent to planting

over 800 acres of trees or removing 568

cars from the roads of Los Angeles.

In addition to generating clean solar

energy, the solar modules, which use a

thick layer of polystyrene foam underneath the tiles, provide significant insulation. This reduces heating and air conditioning costs and extends the life of the

roof by protecting it from the damaging such as chillers, are not operating. The system consists of 2,054 Powereffects of weather. Ancillary benefits, not The total project cost was $2.4 million. Guard TL modules with rated capacities

considered in payback calculations, Through the Pacific Rim’s use of state of a 308 KW peak DC (245 KW usable

include an estimated roof cooling of and local incentive programs, only 15 per­ AC). This is a tilted, ballasted system

around 20­25 degrees Fahrenheit. cent, or $369,000 of the total cost was that requires few roof penetrations. 

The solar system is tied directly to paid by GSA. Rebates were received from For additional information contact:

the building’s lighting and power the Los Angeles Department of Water Roston Manoukian, Electrical Engineer,

switchgear, taking full advantage of free and Power and the Southern California P.E., roston.manoukian@gsa.gov. The

solar power during the weekends and Gas Company. Payback for this project is above statements do not necessarily repholidays when the major heating venti­ 5.6 years, making it a very economical resent that of the U.S. Government.

lation and air conditioning equipment, photovoltaic project. 

InBrief

CAMP PENDLETON SOLAR INITIATIVE SAVES LIVES AND HELPS ENVIRONMENT

Marine Corps Base (MCB) Camp Pendleton has one of the largest appli­ The base energy team first piloted a renewable/solar energy project

cations of solar­powered light in the federal government. Solar­powered on Basilone Road, and later installed more than 200 additional photostreetlights and traffic beacons were installed to enhance driver safety voltaic (PV)­powered streetlights, flashing warning signs, and force proand base security, promote renewable energy, and reduce installation tection/anti­terrorism lighting to support base safety and meet force proand operating costs.  tection and anti­terrorism requirements. Marine Corps Tactical Systems

MCB Camp Pendleton, located in southern California about 40 miles Support Activity also installed PV lights to reduce their grid­connected

north of San Diego, has over 125,000 acres of varied terrain and 17 miles energy consumption and meet force protection requirements. 

of shoreline. When auto accident rates increased on a stretch of Basilone The solar­powered lights’ reliability, ease of installation and costRoad, nicknamed “Dead Man’s Curve,” the base energy team was asked effectiveness make it an ideal choice for base safety, security, and force

for innovative ways to light this dangerous strip of road. Many locations protection needs. These lights also help Pendleton minimize green­house

were more than a mile from the nearest power connection and would gas emissions and meet Executive Order 13123.

require electric lines to be trenched and power poles to be installed and For more information contact: Randy J. Monohan, Tetra Tech EM Inc.,

maintained. An environmental impact study also would be required for a MCB Camp Pendleton, Facilities Maintenance Department (760) 725­0566,

grid­connected system.  or monohanrj@pendleton.usmc.mil

FEDFACS 17
P2 and Environmental Stewardship

USPS Sacramento Continues Recycling Efforts

Since the United States Postal Service(USPS) Sacramento District

launched a recycling program in 2001 at

its Royal Oaks Drive facility, it has generated additional revenue, saved money

and reduced waste.

The Royal Oaks Drive facility was

formerly the collection point for UndeInBrief

liverable Standard Mail (USM). Since

1999 the USM has grown from 86 tons

per month to nearly 149 tons per month

in 2001. In 2002 the USM program was

modified so that materials (e.g.,

newsprint, magazines and office pack)

were collected at individual facilities

and recycled. Revenues exceeding

OKLAHOMA DEQ PROMOTES P2

Oklahoma’s Department of Environmental Quality’s pollution prevention (P2) program, with the

support of partners in both the public and private sectors, is promoting two voluntary programs

designed to demonstrate that organizations can profit from sound environmental performance. 

The Environmental Performance and Recognition Program provides an integrated EMS tied

to leadership, planning, information usage, employees, customers, suppliers, market requirements, performance and key business indicators. 

The Oklahoma Star Incentive Program provides recognition for facilities that may not be

ready to explore EMSs but go beyond minimal compliance to protect the environment and

worker health and safety. 

The P2 Program and partners will work together with facilities that participate in the OK Star

Incentive Program to promote compliance, waste reduction, energy efficiency, environmentally

preferable purchasing, and resource conservation. 

For additional information contact: Dianne Wilkins (405) 702­9128 or (800) 869­1400, or dianne.

wilkins@deq.state.ok.us.

ONLINE P2 VIDEO LIBRARY

The Pollution Prevention Regional Information Center (P2RIC.org), with funding from the

Nebraska Dept. of Environmental Quality, has created an online video library to make pollution

prevention and waste reduction videos easily accessible to P2 specialists, waste reduction educators and service providers. This collection complements the document library of the Pollution

Prevention Resource Exchange (http://www.P2Rx.org). Videos can be viewed online or downloaded for use in PowerPoint presentations, and can be accessed at http://www

.p2ric.org/video/index.cfm. If your organization has P2 videos it would like included in this library,

please contact: Dan O’Dell, (402) 595­1823, or dpodell@mail.unomaha.edu. 

EPA ISSUES DESIGNATION FOR SEVEN RECYCLED

PRODUCTS 

In the April 30 Federal Register, EPA issued the final designation and recommendations for seven

recycled content products: modular threshold ramps, non­pressure pipe, roofing materials,

office furniture, rebuilt vehicular parts, bike racks, and blasting grit. EPA also revised the designations for cement and concrete, railroad grade crossing surfaces (new recycled content

options), and polyester carpet (revised designation of polyester carpet for moderate end­uses

only). The requirement to buy these products containing recycled materials starts May 2, 2005.

For more information visit: http://www.ofee.gov/wpr/cpg4.pdf or http://www.ofee.gov/

wpr/rman4.pdf.

$73,500 were generated in 2001 and

more than $100,000 was saved through

this recycling program. While revenue

decreased in 2002 and 2003, cost avoidance increased, and the work hours necessary to prepare and backhaul the mail

decreased. 

In 1999, the District reduced waste

by over 1,033 tons of mixed paper (an

average of over 86 tons per month). By

2003, this increased to 3,000 tons (an

average of 250 tons per month).

Recycling up to 250 tons of

newsprint, magazines and office pack

per month diverted this tonnage from

landfills and saved the District more

than $250,000.

Backhauling of cardboard is collected

at the Sacramento Postal Distribution

Center and the cardboard comes from

post offices in Sacramento County. The

cardboard recycling program has

expanded to USPS Marysville, Modesto,

Stockton and Redding facilities. USPS

Marysville also has an USM program.

The Sacramento District is also a

member of EPA Wastewise and the EPA

Wastewise Electronic Challenge. In

2003, hundreds of diskettes and videotapes were reused, and hundreds of

printer toner cartridges and electronic

equipment (e.g., CRT, computers,

copiers, etc.) were recycled. While revenue from these is minimal, landfill

space is saved and disposal costs are cut.

Vehicle, building and equipment

maintenance management personnel

have worked to reduce chemical use,

identify less toxic chemicals and reduce

waste. The Vehicle Maintenance Facility

recycles all fluids removed from fleet

vehicles and purchases re­refined motor

oil, recycled antifreeze, retread tires and

rebuilt motor parts.

For additional information contact:

Michael Young, Manager Maintenance,

Sacramento Main Office, michael.d.

young@usps.gov.

18 FEDFACS
Green Procur ement

EPA Buying Green Online With a New Agreement

L

ike many federal agencies, the U.S.

EPA buys most office supplies from a

variety of sources using individual purchase cards. Unfortunately, this prevents

EPA from receiving group discounts and

makes it difficult for it to track and manage purchases. It is also challenging to

train purchase card holders to buy

“green” products in accordance with federal requirements, ensure they will ask

about the environmental product attributes, or get the answers from vendors in a

timely fashion. 

As the agency responsible for administering the Environmentally Preferable

Purchasing (EPP) and Comprehensive

Procurement Guidelines (CPG) Programs, EPA decided to “green” its office

supplies blanket purchase agreement

(BPA). 

EPA launched an effort to purchase all

non­electronic office supplies via an

agency­specific e­catalog, an online directory of products and services, available

for sale under a pre­negotiated BPA with

a commercial vendor, Corporate Express.

EPA purchase card holders use the EPA ecatalog to select from a large array of

According to federal agency staff interviewed for Buying Green Online: Greening

Government E­Procurement of Office Supplies the benefits of buying office supplies

through BPAs include:

• Cost savings through group discounts.

• Reduced time spent on routine processing of orders.

• Improved tracking and monitoring

capabilities.

• Increased availability of up­to­date

product information.

• Ease of use.

• Increased ability to meet mandatory

source­of­supply requirements. 

• Increased ability to meet agency­specific purchasing goals.

• Improved satisfaction of customers and

procurement professionals.

JUST HOW POPULAR ARE PURCHASE CARDS?

• In 2002, government agencies charged over $15 billion dollars on more than 400,000 purchase

cards.

• EPA estimates annual office supply expenditures of $5 million, or about 14 percent of its $35.8

million total purchases via 2,000 purchase cards.

• The Army spends approximately $100 million on office products each year, or about 6 percent

of its $1.7 billion in purchases via 100,000 purchase cards. 

office supplies, including those meeting purchase and use of green products, other

CPG requirements for recycled­content agencies limited the products available in

and the Executive Order 13101 mandate their e­catalog to those meeting EPA’s

to purchase environmentally preferable recycled content guidelines. 

products and services.  Although other government agencies

EPA developed its e­catalog by identi­ have successful programs for encouraging

fying and interviewing procurement and online purchase of green office products,

environmental staff from several govern­ EPA’s green purchasing criteria, located

ment agencies that already have e­cata­ in Appendix A of the Buying Green

logs for purchasing office supplies. This Online Report noted above, are more

information is contained in the report comprehensive. EPA will modify and aug­

“Buying Green Online: Greening Govern­ ment these criteria as new green prodment E­Procurement of Office Supplies.” ucts become available. EPA’s BPA also

It includes federal agency success stories, requires recycling of all used toner carEPA’s green criteria for office supplies, tridges and batteries. Vendor evaluation

EPA’s Request For Proposal language for criteria used in the award of the BPA

its BPA, and a chart describing a range of included having an Environmental Manfederal office product e­catalogs.  agement System (EMS) in place or in

To improve tracking purchases and development, and having green fleet purensure requisite group discounts, some chase and maintenance programs.

agencies made their e­catalogs the only For more information contact: Holly

authorized mechanism for office supply Elwood of EPA, (202) 564­8854 or

purchases. In an effort to increase the elwood.holly@epa.gov.

P2RX NEWS UPDATE

Now you can get environmental news from five P2Rx (Pollution Prevention Resource Exchange)

centers every morning when you open your browser. The news features regional environmental

news, activities and publications from state and other regional programs, plus news stories of

interest to pollution prevention and technical assistance professionals. Currently, the Pollution

Prevention Resource Information Clearinghouse (P2RIC) in region 7, Northeast Waste Management Officials Association (NEWMOA) in regions 1&2), Pollution Prevention Resource Clearinghouse (PPRC) in region 10, Peaks to Prairies in region 8, and Great Lakes Region Pollution Prevention Roundtable (GLRPPR) in region 5 all have news feeds at "my yahoo." Additionally,

ChemAlliance, the National Compliance Assistance Center Clearinghouse, and the National Pollution Prevention Roundtable provide news. To see a list of environmental news providers and

learn how to set up this service for yourself, go to http://www.p2ric.org/EnvNews/newsRSSdirectory.cfm. For more information on news feeds and P2Rx, contact Jean Waters of P2Rx at 

jwaters@mail.unomaha.edu or 402­595­1826 or visit http://www.p2rx.org.

FEDFACS 19
Enforcement & Compliance Monitoring

EPA’s Self­Disclosure Policy: A Complementary Tool for EMS

T he U.S. Environmental ProtectionAgency’s environmental self­audit

policy (65 FR 19618, April 11, 2000) can

eliminate or greatly reduce penalties for

noncompliance found during self­audits.

Under the policy, federal facilities that

voluntarily discover, promptly disclose,

correct violations and take active steps

to prevent recurrence may not face

gravity­based penalties. 

Self­audits and disclosures provide

facilities an opportunity for self

directed, proactive environmental comSelf­audits and 

disclosures provide 

facilities an 

opportunity for self 

directed, proactive 

environmental 

compliance.

pliance. When compared to EPA inspections, information requests, subsequent

enforcement proceedings, penalties and

supervised corrective action, self­disclosure can be a preferred course of action.

Self­disclosure is also a way to avoid

additional transactional costs and negative press associated with adversarial

litigation.

To encourage prompt disclosures of

noncompliance discovered through a

regular program of self­auditing, EPA

will waive up to 100 percent of the gravity penalty associated with the violation. In addition, EPA will not refer the

noncompliance to the Department of

Justice for criminal prosecution.

Of course, no policy is without its

exceptions. Each of the policy’s requirements must be met in order for facilities

to obtain its incentives. Moreover, a

facility cannot use the policy if the violations caused real or potential endangerment to public health and the environment, or if disclosure is involuntary,

untimely, or made independent of government or third parties. Supplemental

environmental projects may also be

used to further reduce cash penalties

from noncompliance.

Self­audits are a critical element of

any well thought out environmental

management system (“EMS”) geared

towards regulatory compliance. As the

United States government continues

implementing EMS throughout its facilities, environmental noncompliance

may be encountered. 

A more detailed examination of the

policy and its threshold requirements

are discussed below:

• Environmental noncompliance must

have been discovered through a systematic self­audit. For noncompliance discovered outside of the selfaudit process the gravity penalty

may be mitigated by 75 percent.

• Reporting noncompliance as

required by permit or a state audit

process is not considered voluntary

and does not fall under the policy.

However, the policy does allow noncompliance reported as part of a

Clean Air Act Title V permit annual

compliance certification.

• The most recent policy expands the

time for disclosure from 10 to 21

days from the time of discovery. This

may be challenging for federal facilities since disclosure may require

review through the chain of command, briefings, meetings, etc.

Meeting this requirement may be

accomplished if the facility has considered self­disclosure beforehand

and developed a process to use the

policy prior to discovering its noncompliance. A facility’s early communication with EPA during the period

it is considering using the policy

may also help its case.

• Independent discovery and disclosure is required by the policy. Once

EPA sends a facility an information

request letter or received a thirdparty complaint of suspected noncompliance, the policy’s incentives

are no longer available to the facility. 

• The policy requires correction of the

noncompliance within 60 days.

Given the federal budget cycle, government contracting rules, and the

internal mechanics of each agency,

this policy requirement may seem

challenging or even insurmountable.

As a means of addressing the 60­day

remediation deadline, a facility’s

submission to EPA of a corrective

action plan containing proof of obligated funding and contract initiation

within the 60­day time period may

be sufficient to meet this requirement.

• The policy requires facilities prevent

recurrence of noncompliance. EPA

will require facilities to demonstrate

and certify that corrective action has

been implemented. Ideally, an EMS

will address the root cause of the

environmental noncompliance. 

• The policy will not accept self­disclosure of noncompliance similar to

that which was subject to an

enforcement action in the previous

three years, or which fits into a pattern of organization­wide noncompliance in the previous five years.

In order to maximize efficiency and

protect the environment, EMSs should

be designed to seek out and correct conditions which may cause harm to

human health and the environment.

The EPA self­disclosure policy, like

EMSs, can also be used by senior management to guide their facility to environmental compliance. 

For more information about EPA’s selfaudit policy or how to disclose, contact:

Andrew Cherry, EPA (202) 564­2589 or

cherry.andrew@epa.gov. The policy can be

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

.gov/compliance/resources/policies

/incentives/auditing/auditpolicy.pdf 

20 FEDFACS
Enforcement & Compliance Monitoring

EPA Addresses Stormwater Violations as 

Part of National Strategy

I

n 2003, the U.S. EPA issued a national

strategy for storm water compliance and

enforcement. The purpose of the strategy

is to improve compliance with storm

water requirements and to protect our

nation’s waters from the harmful effects

of polluted storm water. 

These storm water requirements have

been in effect for more than ten years, but

EPA and state storm water inspection

data show that a majority of facilities

inspected over the last ten years do not

have a Clean Water Act (CWA) National

Pollutant Discharge Elimination System

(NPDES) storm water permit. In addition,

even at permitted sites the regulators are

finding significant noncompliance. 

Storm water run­off is a major cause of

water quality impairment. Storm water

run­off can carry high levels of pollutants

such as sediment, oil, grease, suspended

solids, nutrients, heavy metals, pathogens,

toxins and trash into sewer systems and

ultimately into our streams, rivers, lakes,

wetlands, estuaries and oceans. 

The strategy includes a number of elements for EPA and states to address this

noncompliance problem. One element of

the strategy is a storm water expedited

settlement offer (ESO) program. An ESO

should provide “real time” enforcement in

situations where violations can be corrected quickly and a penalty assessed

within a short amount of time. The purpose of expedited settlements is to supplement, not replace traditional enforcement options.

Recently, EPA Region 10 (Seattle) used

the ESO approach to address storm water

violations found at the U.S. Naval Air

Station, Whidbey Island, (Whidbey)

Wash. EPA found that the Navy’s contractor, Rockford Corporation, did not meet

General Permit for Storm Water Discharges from Construction Activities

(CGP) requirements for its P­157 Direct

Aircraft Refueling Station Construction

Site. The Navy also failed to file a Notice

of Intent under the CGP during this construction project. 

EPA gave the contractor an ESO with

a penalty of $6,850 to resolve its violations. In April 2004, EPA Region 10

issued Whidbey a CWA Notice of Noncompliance for its failure to file the

required Notice of Intent. 

For more information contact:

Melanie Garvey, EPA HQ, (202) 564­2579

or Kristine Karlson, EPA Region 10, (206)

553­0290. 

FEDERAL FACILITIES COMPLIANCE AGREEMENT 

TERMINATED AT PANTEX 

On January 23, 2004, the Department of Energy’s (DOE) Pantex facility certified it was compliant

with requirements of its Federal Facility Compliance Agreement (FFCA). On February 2, 2004, a termination notice was filed closing out the FFCA and the associated administrative order in accordance with the agreed terms. 

Located in Amarillo, Texas, Pantex has had a FFCA for Clean Water Act (CWA) violations in

place for some time. For the past two years, Pantex sought termination of the FFCA and wanted a

written acknowledgment from EPA of its narrowed CWA jurisdiction based on the Supreme Court’s

decision in the “Solid Waste Authority of Northern Cook County” case. 

Pantex invoked the dispute resolution clause of the FFCA to force EPA resolution of issue.

Under the schedule established by the FFCA, Pantex completed its obligations. A settlement was

recently reached in which Pantex agreed to the administrative closure of the FFCA under the

terms and conditions of its CWA NPDES permit.

For additional information contact EPA Region 6’s Jana Harvill, (214) 665­8369 or William

Puplampu, (214) 665­8591 or Andrew Cherry (HQ), (202) 564­2589.

EPA’s Inspection 

Initiative 

Continues

The U.S. EPA’s Federal FacilitiesMultimedia Inspection and

Enforcement Initiative (“Initiative”) is an EPA compliance monitoring effort to inspect federal facilities and take appropriate

enforcement response nationwide.

Currently in its fourth year, the Initiative is coordinated by the Federal Facilities Enforcement Office

(FFEO) and follows the Office of

Enforcement and Compliance

Assurance’s “Smart Enforcement”

principles.

The Initiative, which FFEO

developed in conjunction with its

ten regional offices, targets civilian

and military government facilities

which meet certain criteria, and is

intended to address significant

environmental, public health, and

compliance problems. 

In particular, EPA is inspecting

facilities with low compliance rates,

such as Clean Water Act (CWA)

National Pollution Discharge System (NPDES) majors, and those regulated by under­inspected programs

under the Clean Air Act, Safe Drinking Water Act and other CWA programs. EPA is also partnering with

state and local agencies when appropriate, and also evaluating environmental justice considerations in its

targeting assessments. 

For additional information contact EPA’s Federal Facility Enforcement Office’s Lance Elson, (202)

564­2577, David Levenstein, (202)

564­2591 or Rich Satterfield, (202)

564­2456.

FEDFACS 21
Enforcement & Compliance Monitoring

EPA Releases Superfund 120­Day Study

F

or the past several years, EPA and study failed to include a federal facilitiesmembers of Congress have expressed specific focus, many of its recommendaconcern about EPA’s difficulty funding tions could have an impact on cleanup at

long­term cleanups at Superfund sites. federal facilities. 

Due to funding constraints, EPA’s Acting The study team made a total of 102

Deputy Administrator, Stephen Johnson, recommendations for improving program

directed an internal workgroup to study efficiencies. Many apply specifically to

ways to improve Superfund’s efficiencies fund­lead cleanups and private party

in order to fund the backlog of long­term enforcement actions, but would likely

cleanups using current apply to federal facility

resources. The study cleanups. For instance,

emphasizes ways to federal agencies curimprove how Super­ The study empasizes  rently submit certain

fund expends resources remedy decisions to ways to improve how  and communicates its EPA’s National Remsuccesses.  Superfund expends  edy Review Board

On April 22, 2004, (Board). The workthe workgroup released resources and  group recommends

a report entitled communicates successes. expanding the jurisdic­

“Superfund: Building tion (e.g., possibly lowon the Past, Looking to ering the remedy cost

the Future.” The group threshold for review) of

found that Superfund “is a complex, the Board to improve cost effectiveness. 

viable cleanup program with an effective Another suggested remedy is to reenforcement component.” However, the visit older decisions and consider applyteam made a number of recommendations ing new ideas such as innovative techfor the continued improvement of the pro­ nologies and the most cost­efficient

gram. These recommendations typically cleanup approach. Other suggestions

suggest ways to better implement a impacting remedy selection include

strong and evolving program. While the expanding the presumptive remedy guidFEDERAL AGENCY COMPLIANCE TRACKING SYSTEM 

EPA’s Federal Agency Compliance Tracking System (FACTS), formerly known as the Online Environmental Compliance Status Report (ECSR), enables users to research, track and monitor the

environmental compliance history and current status of individual regulated federal facilities. 

EPA employees, registered federal, state, local and tribal government agencies can view and

analyze inspection, enforcement and compliance data in EPA’s national database systems, and

query data by federal agency, EPA region and state. 

FACTS is available as a partner site on EPA’s Online Tracking Information System (OTIS). Nonregistered users can obtain instructions and register at: http://www.epa.gov/idea/otis/register 

by selecting the link: Obtaining Gov’t Access/Registering for OTIS. To visit FACTS, go to:

http://www.epa.gov/idea/fedfac.

Questions or comments about FACTS can be directed to EPA’s Richard Satterfield

satterfield.richard@epa.gov. Questions or comments pertaining to OTIS or access problems during

registration should be directed to Rebecca Kane, kane.rebecca@epa.gov.

ance to add more technical designs, and

developing more standardized methodology for selecting remedies.

For the placement of sites on the

Superfund National Priorities List, the

workgroup recommends keeping an

active listing process to help ensure EPA

prioritizes its work properly, and that

there is incentive for other parties to work

effectively under other federal or state

cleanup programs. 

The report also makes recommendations affecting all facets of the program

such as improving contract management,

de­obligating excess money from contracts so that it can be spent elsewhere,

developing regional expertise, performing

benchmarking studies to improve performance, and considering shifting resources

among regions based on workload. 

The 120­Day Study provides a very

thorough report of ways to improve

Superfund program performance. The

workgroup consisted of Superfund­experienced EPA regional and headquarters

staff who work in the Superfund program or had in the past. To review the

study, visit EPA’s website: http://www

.epa.gov/superfund/news/120daystudy

.pdf

Got an Article?

If you have an article about an environmental activity or program at your

agency or facility, and you'd like us to

consider it for publication in the next

FedFacs, please contact: Marie Muller

at muller.marie@epa.gov. FedFacs is

published twice a year; articles should

be 500 words or less. The U.S. EPA

reserves the right to edit or decline any

article.

22 FEDFACS
Enforcement & Compliance Monitoring

2002 Toxics Release Inventory Online

EPA issued its 15th annual Toxic

Release Inventory (TRI), the annual

report on the amount of toxic chemicals

released into the environment by

reporting facilities for calendar year

2002. Almost 25,000 facilities reported

on nearly 650 chemicals.

A total of 315 federal facilities reported

for 2002, an increase of 10 percent from

the 286 facilities reporting in 2001. Total

production­related waste managed

decreased by six percent. The data also

show total on and off­site disposal or

other releases from federal facilities

increased by nine percent, attributed primarily to higher coal usage by one facility.

For all facilities, the TRI Public Data

Release shows a 15 percent decrease in

total disposal or other releases into the

environment from 2001 to 2002. That

decrease is largely attributable to a

court decision which required reporting

by the metal mining sector. Without

metal mining, there was a five percent

increase from 2001 to 2002,

primarily due to increases

reported by one facility. Since

the inception of TRI in 1988,

trends analysis shows chemical releases decreased 49 percent.

EPA provides the public

with data on chemical emissions and releases in many

formats from many different

databases. TRI tracks the chemicals

and industrial sectors specified by the

Emergency Community Right­to­Know

Act of 1986 and its amendments. EPA's

efforts to improve TRI data quality and

to make data publicly available sooner

has been made possible by increased

electronic reporting from the TRI community. Over 23 percent of

TRI reports this year were

submitted electronically

through EPA's Environmental Information Exchange

Network.

The TRI data and background information are

available at http://www.epa

.gov/tri. Facilities (including

federal facilities) and chemical releases can be identified by using

the TRI explorer mapping tool available

at: http://www.epa.gov/triexplore.

Screening and Analysis Tool Evaluates 

Environmental Impact 

EPA’s Geographic Information System

Screening and Analysis Tool (GISST),

developed by EPA Region 6 (Dallas),

evaluates environmental vulnerability

and impact using over 100 different

types of environmental resource and

stressor “criteria” developed by EPA.

GISST is Geographic Information

System (GIS)­driven, and combines

EPA’s technical assessments into a

mathematical algorithm. This weighs

environmental information or criteria of

a specific geographic area, and identifies

and maps environmental concerns.

EPA is using this expanded analysis

capability to evaluate potential environmental impacts resulting from highway

construction activities. The application

facilitates NEPA section 309 reviews,

and enables EPA to provide quick and

early notification of environmental

impact statement (EIS) and assessment

(EA) concerns. The tool also helps EPA

identify and develop alternatives (e.g.,

study corridors, alignments) to best

avoid adverse environmental impacts.

EPA Region 6 developed GISST originally as an enforcement targeting and

environmental justice tool to assess and

flag a variety of single and multi­media

environmental concerns. EPA Region 6

is expanding GISST to better support

NEPA transportation needs – from

planning and scoping phases to Final

EIS and RODs (Record of Decision). 

Examples of specific assistance

include identification of sensitive areas

(e.g., endangered species habitat, wetlands, parks, streams and rivers, cultural resources, air nonattainment

areas), environmental assessment of

alternatives to support decisions on

selection, and locations of potential borrow, disposal and fill materials for construction sites.

GIS­driven analysis tools have a

long history within EPA. More recently,

other federal and state agencies, such

as the Federal Highway Administration

(FHWA), began to recognize and advocate its utility. Much of this focus is also

in response to environmental streamlining requirements per the Transportation Equity Act of 2001 (TEA­21). 

EPA Region 6 has found the GISST

to be an excellent tool for cutting NEPA

review time in responding to transportation or other NEPA­related activities. Transportation agencies using similar GIS technology cut total processing

time by 30 to 50 percent (from pre­scoping to ROD).

For more information contact EPA

Region 6 staff: David Parrish (214) 814­

5810, Dominique Lueckenhoff (512)

916­5012, Dr. Gerald Carney (214) 665­

6523, Rob Lawrence, (214) 665­8150,

Dr. Sharon Osowski (214) 665­7506.

FEDFACS 23
In the Spotlight

Champions for Environmental

Leadership and Green 

Government Awards

U.S. EPA Region 10 (Seattle) announced

its second annual “Champions for Environmental Leadership” and “Green Government Innovation” awards, which recognize federal agencies going beyond

compliance and promoting pollution prevention, sustainability, and EMS. Region

10 congratulates all facilities nominated

for this award. 

The recipients for 2004 are:

Federal Aviation Administration (FAA) Fuel

Cell Test Site – Fuel Cell Development and

Deployment ­ Department of Defense,

Avista Labs, Inc., and the Northwest

Mountain Region partnered to test the

Proton Exchange Membrane fuel cell.

The first fuel cell was commissioned at

McChord Air Force Base, Remote Transmitter Receiver, and was the first at a

FAA facility.

Naval Air Station Whidbey Island – P2

Hazardous Waste Reduction Project ­ The

Aviation Intermediate Maintenance

Detachment reduced or eliminated hazardous waste. This P2 project eliminated approximately 192,000 pounds of

hazardous waste and enhanced personnel safety, as well as efforts to meet the

requirements of Executive Order 13148.

Hazardous waste disposal cost savings

were $28,850.

NAS Whidbey Island Solid Waste Reduction – Solid Waste­Recycling – In FY04,

Whidbey’s wastewater treatment plant

will be upgraded, and the lagoon closed.

This will be the first Navy­owned composting facility, and will reduce annual

shipping and disposal costs by almost

$42,000.

National Park Service (NPS), Pacific West

Region (PWR) ­ Development of Sustainability

Tools – The Facility Management and

Contracting teams of the NPS PWR is

developing sustainable products, practices, tools, and guides to aid park programs meet sustainability commitments

in Region 10’s Greening the Parks program. 

National Parks Service (NPS), Bonneville

Power Administration (BPA), and General

Services Administration (GSA) Berkeley

Lamp/Watt Stopper Islet Project – Updated

lighting for NPS in the Old Federal

Building in Seattle. Updated lighting

eliminating hundreds of fixtures, lamps,

ballasts and other solid waste. Occupancy controlled power strips reduce

power consumption in the office. BPA

assisted in product procurement

through negotiated bulk purchase

actions. Since the employees have

portable light sources, future office

moves will not require significant

changes in overhead lighting fixture

placement switch placement or

rewiring.

2004 Closing the Circle

Awards 

The Office of the Federal Environmental Executive (OFEE) is pleased to

announce the winners of this year’s

White House Closing the Circle (CTC)

Awards, which recognizes outstanding

environmental stewardship through

pollution prevention, recycling, green

purchasing, sustainable building, and

the use of environmental management

systems. Thank you to all agencies that

submitted nominations this year. The

2004 Closing the Circle Award Winners

are:

Environmental Management Systems

• Dept. of Defense (DoD), Fort Bragg,

NC: The Right Way, The Green Way,

All the Way! 

• Dept. of Energy (DOE), Battelle

Memorial Institute, Lab Ops Group,

Ohio: Corporate Commitment to

Environmental Stewardship and

Environmental Management Systems.

Waste/Pollution Prevention

• DoD, Robins Air Force Base, Ga.:

Environmental Management Directorate, Taking Strides Forward in

Pollution & Waste Prevention at

Robins AFB. 

• Dept. of Homeland Security, Federal

Law Enforcement Training Center,

Ga.: Green Ammunition. 

• New Mexico Veterans Affairs Healthcare Systems, NM: Mr. Mark Boyers,

Hazardous Waste Reduction at the

NM VA Healthcare System

Recycling

• DoD, Tinker Air Force Base, Okla.:

Solid Waste/Recycling Team, Rejuvenation of Base Recycling Program at

Tinker AFB. 

• DoD, Vandenburg Air Force Base,

Calif.: Mr. Patrick Maloy, Vandenberg

AFB QRP Exceeds 90% Diversion

Rate. 

• Dept. of Justice, Federal Correctional

Complex, Coleman, Fla.: Recycling

Program.

Green Purchasing

• DoD, Homestead Air Reserve Base,

Fla.: Environmentally Friendly Products Section at Homestead Air

Reserve Base Store. 

• DOE, Sandia National Laboratories,

NM: Five Keys to Success: Continuous Improvement for Construction

Purchases. 

Sustainable Design/Green Building: 

• DoD, U.S. Army  Yuma Proving

Ground, Ariz.: YPG Energy Efficient

Model Home. 

• Dept. of the Interior, Chincoteague

National Wildlife Refuge, Va.: Going

Green Over Buildings at Chincoteague NWR.

The summer issue of “CTC News”

spotlights these success stories more

extensively, and is found at:

http://www.ofee.gov/ctc/ctcspr04.pdf

24 FEDFACS
InBrief

New Rules For Hazardous Air Emissions

The U.S. EPA announced four new rules which require certain

facilities to install Maximum Achievable Control Technologies

(MACTs). The MACT rules cover: Industrial, Commercial and

Institutional Boilers and Process Heaters; Plywood and Composite Wood Products; Stationary Reciprocating Internal Combustion Engines (RICE); and Automobile and Light Duty Trucks

Manufacturing (Surface Coating). For more information, visit:

http://www.epa.gov/ttn/oarpg/.

ings in early April 2004 in Waco and Temple, Texas. The final

report is available at: http://www.swf.usace.army.mil

/links/ppmd/perchlorate/index.html. For more information contact: Wayne Elliott, USACE (817) 886­1666.

Waste Reduction and Recycling Report 

EPA released its first annual report on the Resource Conservation Challenge (RCC), a cross­agency initiative which identifies

and uses innovative ways to conserve natural resources and

energy. The report, entitled “The Resource Conservation Challenge: A Year of Progress,” shows how federal and state governments, tribes and industry are achieving significant results in

waste reduction and recycling. The report is available on the

RCC website at: http://www.epa.gov/rcc.

E.O. 13327 on Federal Real Property Asset 

Management

On February 4, President Bush signed Executive Order 13327

“Federal Real Property Asset Management” to promote efficient

and economical use of federal real property resources. Of particular note are the statements regarding application of life cycle

costing and environmental concepts, and the requirement for

conformance with Executive Order 13148 (Section 3(b)(iii) and

(vi), as well as 4(b) and 4(b)(v)). For more information visit:

http://www.ofee.gov/whats/eo_asset_management.html.

Corps Study Concludes Water Sources Safe For

Central Texas 

Congress directed the U.S. Army Corps of Engineers, Fort Worth

District (USACE) to assess the impact of perchlorate associated

with the former Naval Weapons Industrial Reserve Plant at

McGregor, Texas. The three year, $5.5 million study, begun in

2001 to investigate possible perchlorate impacts to the watersheds and raw water sources for 500,000 people in Central Texas,

is now complete. 

According to the study results, data indicate there is no risk

of exposure to perchlorates in Lakes Belton and Waco, however,

some springs and streams in the area have been impacted, and

consumers are cautioned that they could potentially be exposed

by consuming plants and small animals from these areas. 

The Army Corps discussed these results at two public meetUpcomingEvents

August 8 ­ 11 2004 

Energy 2004 

Rochester, NY

7th Annual workshop of federal, state, local and private sector energy managers, service companies, utilities, procurement officials, engineers and other energy

professionals. Sponsored by U.S. DOE Federal Energy

Management Program; co­sponors are DoD and U.S.

General Services Administration. For more information

please visit: http://www.energy2004.ee.doe.gov/ 

August 14­15, 2004

CleanMed 2004

Philadelphia, PA

For more information visit:

http://www.cleanmed.org/2004/overview.html

August 16 ­ 19, 2004 

9th Annual Joint Services

Environmental Management

Conference(Formerly P2&HWM Conference)

San Antonio, TX

“Sustaining the Force: Optimizing Readiness

Through the Prevention of Pollution” For more information visit: http://www.jsemconference.com

August 28­ September 3, 2004

World Renewable Energy 

Congress VIII

Denver, CO

For more information, visit:

http://www.wrenuk.co.uk/wrenviii.html

September 20­22, 2004

Brownfields Conference 2004

St. Louis, MO

The national Brownfields Conferences bring together

key experts from all levels of government, business,

and finance and from local communities to share

ideas and experiences in the field of urban and environmental development. For More information, visit:

http://www.epa.gov/swerosps/bf/bfconf.htm Or

http://www.brownfields2004.org

(Note regarding non­EPA conducted or sponsored

events: EPA is providing this information because it may be

useful or interesting to FedFacs readers. However, EPA cannot attest to the accuracy of information provided by event

organizers, nor does this constitute an endorsement by EPA

or any of its employees of the sponsors of the site or the

information or products presented.)

FEDFACS 25
EPA’s Federal Facility Program Managers

I

n addition to its Washington, D.C.

Headquarters staff, EPA’s federal facility enforcement and compliance assurance program is implemented in large

part through its 10 regional offices

throughout the country. Each region has

a Federal Facility Program Manager

(FFPM) who acts as a point of contact on

many environmental issues for federal

facilities located in their region. FFPMs

also coordinate many of the region’s federal facility activities and initiatives.

Below is a map which identifies U.S.

EPA regions, and the states belonging to

each region. A brief profile for each

region, and Federal Facility Program

Managers and Superfund contact information is also provided.

EPA’s Regional Federal 

Facility Programs 

EPA New England­ Region 1

Toxics, Pesticides and Federal Programs

Office of Environmental Stewardship  

One Congress Street, Suite 1100

Boston, MA 02114 

States: MA, NH, VT, CT, RI, ME

FFPM: Anne H. Fenn, 617­918­1805;

fenn.anne@epa.gov

Other Contacts: Bryan Olson (Superfund)

617­918­1365

Regional Initiatives: EMRs; EMS Tutorials;

Qrt Information Seminars; Conferences;

EPCRA & Facility Security; Sustainability;

P2; Compliance Training (VHA, DOI/NPS);

Multimedia Inspection.

Regional Resources: Additional information

about Region 1 is found at:

http://www.epa.gov/region1

EPA Region 2

Compliance Assistance Section

290 Broadway, 21st Floor

New York, NY 10007­1866

(212) 637­3000

States: NJ, NY, PR, Virgin Islands

FFPM: Kathleen Malone; 212­637­ 4083; 

malone.kathleen@epa.gov

Other Contacts: John Malleck (Superfund);

212­637­4263

Regional Resources: The region’s federal

facility website is found at:

http://www.epa.gov/Region2/ff/index.html

EPA Region 3

Office of Enforcement, Compliance and 

Environmental Justice (3EC00)

1650 Arch Street 

Philadelphia, PA 19103 

States: PA, DE, MD, DC, VA, WV

FFPM: José J. Jiménez; 215­814­2148,

jimenez.jose@epa.gov

(Compliance assurance, compliance assistance, and EMS)

Other Contacts: Paul Leonard (Superfund);

215­814­3350

William Arguto (NEPA and EMRs); 215­814­

3367

Regional Initiatives: Region is focusing on

VA Hospitals, U.S. Post Office Vehicle Maintenance Facilities, and facilities with NPDES

problems. Region offers NPDES training, targeted to DoD facilities, and EMS workshops

for federal sector.  

Regional Resources: Federal Facilities

Compliance Kit (compilation of compliance

documents, checklists, and EMS information

about federal facilities on CD). Region’s website contains more information about upcoming training. Visit: http://www.epa.gov

/reg3ecej/federal_facilities.htm. 

Other: The Region partnering with U.S.

Navy, Air Force, Army and GSA, and also

with states PA and VA to host the 2005

EPA/DOD/State Colloquium. Please contact

Region for more information, or to participate

in program agenda. Region also provides

training “7 Habits of Highly Effective People.” 

EPA Region 4

61 Forsyth Street, SW 

Atlanta, GA 30303

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

FFPM: Mark Robertson (DoD, DOE) 404­

562­9639; robertson.mark@epa.gov

Anthony Shelton (civilian agencies) 404­562­

9636; shelton.anthony@epa.gov

Other Contacts: Jon D. Johnston (Superfund) 404­562­8527

Anne Heard (RCRA//UST/OPA) 404­562­9521

Regional Initiatives: CWA SPCC Compliance Assurance Initiative ­ Region 4 will provide compliance assistance to selected federal

facilities on SPCC compliance issues, and

encourage selected federal facilities to use

EPA’s Audit Policy to self­disclose violations.

Region will also inspect selected facilities.

Regional Resources: EPA co­sponsors an

annual June con­ Continued on page 27

26 FEDFACS
4669

EPA’S FEDERAL FACILITY PROGRAM MANAGERS

Continued from page 26

ference with the U.S. Army Environmental

Center­Southern Regional Environmental

Office, for federal facilities in the southeast.

More information is found at: http://aec.army

.mil/usaec/reo/region4/index.html. Region also

provides various training. Additional information about Region 4 generally is found at:

http://www.epa.gov/region4

EPA Region 5

77 West Jackson Boulevard

Chicago, IL 60604

States: IL, IN, MI, MN, OH, WI

FFPM: Lee J. Regner; 312­353­6478;

regner.lee@epa.gov

Other Contacts: Gary Schafer (Superfund

and BRAC); 312­353­8827 

Phil Kaplan (Pollution Prevention); 312­353­

Regional Initiatives: Region 5 is conducting

environmental management reviews (EMRs).

Facilities interested in having an EMR at

their facility should contact the region.

Regional Resources: Additional information

about Region 5 generally is found at:

http://www.epa.gov/region5

EPA Region 6

Compliance Assurance and Enforcement 

Division

Office of Planning and Coordination 

(6EN­XP)

1445 Ross Avenue

Dallas, TX 75202

States: AR, LA, NM, OK, TX

FFPM: Joyce Stubblefield; 214­665­6430;

stubblefield.joyce@epa.gov

Gabriel Gruta; 214­665­2174;

gruta.gabriel@epa.gov

(Compliance assistance, P2, EMS)

Other Contacts: Gus Chavarria (Superfund

NPL); 214­665­3162; 

George Malone; 214­665­ 8030; and Michael

Barra; 214­665­2143 (Superfund Legal Counsels) 

Walt Helmick (Superfund QA); 214­665­8373

Laurie King (Permits and BRAC); 

214­665­6785

Regional Initiatives: Environmental management reviews; Federal Interagency EMS

training(s); 

Regional Resources: Geographical Information System Screening Tool (GISST) website:

www.epa.gov/earth1r6/6en/xp/enxp2a3.htm

Please contact FFPM Joyce Stubblefield if

interested in this environmental screening

tool. Additional information about Region 6

generally can be found at:

http://www.epa.gov/region6

Other: Federal/State partnerships, Leadership and P2 Programs. (Please contact Joyce

Stubblefield for specific state contacts)

EPA Region 7

Enforcement Coordination Office

901 North 5th Street

Kansas City, KS 66101

States: IA, KS, MO, NE

FFPM: Kris Goschen; 913­551­7027;

goschen.kris@epa.gov

Other Contacts: Gene Gunn (Superfund);

913­551­7776

Regional Resources: Additional information

about Region 7 is found at:

http://www.epa.gov/region7

EPA Region 8

999 18th Street Suite 300

Denver, CO 80202­2466

States: CO, MT, ND, SD, UT, WY

FFPM: Dianne Thiel (Mail stop: 8P­P3T); 

303­312­6389; thiel.dianne@epa.gov (EMS,

EMRs, P2, environmentally preferable purchasing, greening government)

Elisabeth Evans (Mail stop: 8ENF­T); 

303­312­6217 evans.elisabeth@epa.gov 

(Compliance assistance, inspections and

enforcement)

Other Contacts: Terry Anderson (Superfund); 303­312­6244

Marie Zanowick (P2 and EMS) 303­312­6403

Regional Initiatives: EMRs; EMS ­ training,

Leadership Opportunities for Senior Managers; module environmental policy development; environmental compliance and P2

training presented at annual DOI conference.

Regional Resources: “Permitting Stormwater Discharges from Federal Facility Construction Projects” (posted on Region’s website

in June); “Cleaning National Parks: Using

Environmentally Preferable Janitorial Products at Yellowstone and Grand Teton National

Parks.” Found at: http://www.epa.gov/Region8

/conservation_recycling/yellowstone.pdf. Additional information about Region 8 is found at:

http://www.epa.gov/region8.

EPA Pacific Southwest Region ­ Region 9

75 Hawthorne Street

San Francisco, CA 94105

States: AZ, CA, HI, NV, Guam, American

Samoa and Northern Mariana Islands; 147

tribal nations. 

FFPMs: Larry Woods Federal Facilities Coordinator (Mail Stop: CMD­1); 415­972­3857;

woods.larry@epa.gov

Tom Kelly, Federal Facilities Coordinator (Mail

Stop: CMD­1); 415­972­3856;

kelly.thomasp@epa.gov

Other Federal Facility Contacts: Kathleen

Johnson (Superfund); 415­972­3873

Lisa Hanf (EIS/NEPA review); 415­972­3854

Regional Resources: Region 9 assists federal

facility compliance through partnership activities, such as training, recognition programs

like Champions of Green Government, and

EMRs for gap analysis assistance for EMS

implementation. More information about these

activities is found on Region 9’s Federal Facility Compliance Program website:

http://www.epa.gov/Region9/cross_pr/fedfac/

Other: Map of Federal and Tribal Land in

Region 9: http://www.epa.gov/Region9/cross

_pr/fedfac/fedmap.html

Region 9 Library: http://www.epa.gov/Region9

/library/ 

Region 9 Environmental Management 

System: http://www.epa.gov/Region9/cross_pr

/ems/index.html

The Federal Network for Sustainability, a

Region 9 FFCP Partner: http://www.federal

sustainability.org/ 

EPA Region 10

1200 Sixth Avenue, 

Seattle, WA 98101

States: AK, ID, OR, WA

FFPM: Michele Wright; 206­553­1747;

wright.michele@epa.gov

Other Contacts: Nancy Harney (Superfund);

206­553­6635

Nick Ceto (Hanford); 509­376­9529

Regional Initiatives: EMRs, EMS training

and other assistance; Champions of Environmental and Green Government Innovation

Recognition program.

Regional Resources: Region’s website is

located at: http://www.epa.gov/region10. For

enforcement and compliance information visit:

http://yosemite.epa.gov/R10/ENFORCE.NSF

/Homepage/OCE+Main+Page

Other: The West Coast Federal Network for

Sustainability, and the newly created Seattle

Federal Executive Board subgroup (Interagency Environmental Leadership Council) 

FEDFACS 27
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