Environmental Protection

Agency

Compliance Assurance

(2261A)

Summer 1997

EPA ORDERS CEASE-FIRE 

ON CAPE COD BASE

Printed on Recycled Paper

ISSUE #4 an environmental bulletin for federal facilities

E PA ordered a c e a s e - fire, effective May

19, 1997, at one of the largest National

Guard training areas in the Northeast in

an effort to protect Cape Cod’s drinking

water from contamination. On April 10,

1997, EPARegion 1 ordered Army National Guard to suspend all training activities

at Camp Edwards on the Massachusetts

Military Reservation (MMR) that could

release contaminants to the air, soil, and

water on Upper Cape Cod. This is the fir s t

time that EPA has ever stopped military

training to protect human health. EPA

also ordered the National Guard to immediately begin cleanup of lead and unexploded ordnance from firing ranges and

impact areas on base.

“This is a home run day for EPA, but

more especially for the citizens of the

Cape,” said EPA Regional A d m i n i s t r a t o r

John DeVillars. “Their air will be cleaner,

their drinking water more secure, and

their health better protected as a result of

this action.”

CRAIG HOOKS

The United States Government has

embarked on a long and costly voyage in

coming to grips with its own environmental legacy. The federal government represents the single largest environmental

program in the world, with the largest set

of problems and challenges in the western hemisphere.

For some time the federal government

has claimed that it intends to be a leader

in environmental protection. At the same

time, the federal government historically

has resisted attempts to hold itself

accountable to environmental laws to the

same extent that municipalities, state

governments, and the private sector are

held accountable. These two messages

are inconsistent. Until the federal government accepts voluntarily the concept

of a “level playing field” for all environmental laws, it will only be a pretender to

the leadership throne. 

One step towards achieving this leadership and reestablishing faith in the government is to assure the public that the

federal government is accountable to the

citizens, states, and the Congress for its

environmental record. In a previous column, I talked about trust and whether

Continued on page 11

2 Guest Spot: Sherri W. Goodman

3 TRI Drops for Feds’ Second 

Year of Reporting 

4 In the Field: Groundwater 

Testing in Nebraska, 

Washington Navy Ya r d

6 The Hammer

7 Congratulations to Pollution 

Prevention Environmental 

Challenge Wi n n e r s !

8 Reports and Regulations

1 0 C o n f e r e n c e s

1 2 C a l e n d a r

Continued on page 1 0

Contractors search for buried unexploded ordnance in the impact area at Camp Edwards

on Cape Cod using a magnometer device.
PAGE 2

It has become i n c r e a singly clear to me that preserving our Nation’s natural heritage requires a

commitment, and teamwork. A commitment to

conducting business in an

environmentally sustainable manner, and

teamwork to make that vision a reality. 

To protect people and environment,

and to promote economic development

across the globe, all sectors of society

must integrate environmental considerations into their activities. The Department of Defense (DOD) is making an

extremely important contribution to what

has become a global effort to balance environmental protection and development.

This global effort, often framed in the context of “sustainable development” emphasizes managing growth, developing technologies to prevent pollution from the

outset, protecting air and water quality,

as well as historic sites and natural areas,

and strengthening communities. 

These same underpinnings form the

basis for DOD’s environmental program.

The Office of Environmental Security is

responsible for protecting and maintaining

our access to land, sea and air so that we

can sustain the military mission. This

involves managing the natural and cultural resources under our stewardship, cleaning up sites that have been contaminated

in the past, developing programs and technologies to prevent pollution from the outset, protecting the safety and health of our

troops, and complying with the law. 

DOD manages over 25 million acres, is

subject to environmental laws and regulations, and invests nearly 2% of its budget in environmental security. Our 435

installations operate like small cities, facing many of the same challenges. Base

commanders play a leadership role in

their community, setting policy in every

area, from infrastructure development

and maintenance (roads, schools, housing, etc.), to waste management, environmental protection and community development. 

Our environmental commitment was

well expressed by the Secretary of Defense

William Cohen who issued an Earth Day

Proclamation which stated, “Environmental protection is our responsibility as good

citizens, neighbors, and managers.” He

proclaimed that “...environmental protection is critical to the Defense Department

mission and environmental considerations

shall be integrated into all defense activities.” That is an excellent summary of

what we are trying to achieve with DoD’s

environmental program. To d a y, environmental factors are in the mainstream of

DoD activities.

Environment, safety and health activities now enhance, rather than burden,

productivity and competitiveness. Our

strategy is to reduce operational costs,

increase operational fle x i b i l i t y, and

reduce liabilities. Efforts have focused on

looking for ways to substitute existing

materials or processes with environmentally sound alternatives, or to treat and

dispose of contaminated emissions and

e f fluents in a safe and environmentally

sound manner. About 80% of the hazardous materials used by DOD is attributable to the acquisition process. So it’s

the acquisition process, from the research

and development, to production, to actual

operations and support, that can benefit

the most from eliminating pollutants. It’s

a simple concept: pollution is waste, and

waste is wasted money. Below is a snapshot of our progress to date: 

(1) The number of enforcement actions

are down 80% even though the number of

inspections by regulators has remained

the same. (2) This year DOD made substantial progress toward meeting its goal

to reduce disposal of hazardous waste by

50% by 1999 from a 1992 baseline. DOD

already reduced hazardous waste 50%

between 1985 and 1992. (3) DOD completed its second Toxic Release Inventory

public data report and toxic release

reductions are down 30% in the fir s t

reporting year (1994/95). (4) Environmental considerations and costs have been

integrated into the design of new

weapons systems. For example, the

N a v y ’s New Attack Submarine is reducing its future hazardous waste generation

90% below levels currently generated by

submarines. (5) DOD now purchases only

recycled content copier paper as long as

the cost is below that of virgin paper.

DOD use of recycled paper will save

150,000 trees each year, and 60 million

gallons of water—the amount one million

Americans use in a day. (6) DOD has completed 62% of all biological inventories of

plants and animals found on lands under

DOD jurisdiction.

These successes are the result of systematic efforts to integrate environmental education and training at every level

of the work force and throughout our military academic institutions, by establishing policy for aggressive self-assessment

programs, and by creating incentives for

environmental stewardship. 

A common thread runs through our

best programs. That common thread is

partnership. We have strong programs to

jointly develop constructive solutions to

common challenges — both environmentally and economically. Meaningful communication and cooperation with Federal,

State and local agencies, tribal nations and

communities near our installations is key

to ensuring that we are operating effic i e n t

installations, promoting effective military

training and protecting the environment. 

Achieving sustainablity requires all

individuals and organizations to adopt a

new view toward the environment and

the way we live and do business. We have

found that making these changes is helping us to fulfill the military mission while

improving the quality of life for our Service men and women.

SHERRI W. GOODMAN

Deputy Under Secretary of Defense for Environmental Security
Federal facilities reported to EPA’s

Toxics Release Inventory (TRI) for the second time in 1995, and the data show nearly a 25% decline in total amounts of toxic

chemicals released in 1995, and nearly a

35% decline in transfers, compared to

1994. However, the source of the decreases is not yet clear. It may be due to the

adoption of pollution prevention measures or to the fact that fewer facilities

reported in 1995 (144 rather than 193).

The most recent TRI data for federal

agencies are summarized in the accompanying table. Half of the 2-million-pound

reduction in releases is due to the A i r

F o r c e ’s efforts, while nearly 80% of the 3.4-

million-pound reduction in transfers

comes from the A r m y. Note that the percentage changes between 1994 and 1995

shown in the table relate only to chemicals

reported in both those years, not to the

actual 1995 release and transfer numbers.

Information on obtaining TRI data is

available from EPA’s EPCRA hotline at 1-

800-535- 0202 (703-412-9810 in the Wa s hington, D.C. area) or online from the TRI

home page at h t t p : / / w w w. e p a . g o v /

o p p t i n t r / t r i . TRI data can also be

accessed through the Right-to-Know

Computer Network ( h t t p : / / w w w. r t k . n e t ) .

PAGE 3

FEDERAL FACILITIES REPORT SIGNIFICANT

DROP IN TRI RELEASES

Over the past few years, FFEO has

been attempting to integrate considerations of environmental justice into policies and guidance governing federal facilities, in particular linking voluntary

pollution prevention activities with environmental justice. “Environmental justice” is a response to the disproportionate

environmental impacts faced by many

communities made up predominantly of

people of color and/or low income. A n e w

report discusses the preliminary results

of FFEO’s Federal Facilities Environmental Justice Enforcement Initiative

which is aimed at identifying federal

facilities that may pose environmental

justice concerns and emphasizing

enforcement efforts at such facilities. 

The initiative highlighted 44 facilities

as potential environmental justice sites.

The majority of them are located in

Regions 4, 6, and 9. Of the 44 sites, 77%

belong to DOD, 18% to DOE, and 5% to

civilian federal agencies. Twelve of the

sites have recent violations, 13 are in sign i ficant noncompliance, and 17 are listed

on the National Priorities List (Superfund). FFEO used four criteria for targeting sites: relative health risks posed by

the facility to populations in the immedi1995 TRI DATA FOR FEDERAL FA C I L I T I E S

Federal A g e n c y 1995 Releases 1994-1995 1995 Tr a n s f e r s 1994-1995 

Change (%) Change (%)

A g r i c u l t u r e 4 7 4 . 9 - 0 -

D e f e n s e 5,615.3 - 2 6 . 7 5 , 6 9 4 . 1 - 3 8 . 9

Air Force 3 , 6 5 1 . 8 - 2 5 . 5 1 , 0 6 5 . 0 - 2 3 . 3

A r m y 9 1 7 . 6 - 2 9 . 1 3 , 6 7 2 . 7 - 4 2 . 3

Army Corps of Engineers 2 2 . 4 0 . 2 0 . 3 -

Defense Logistics Agency 5 . 3 - 8 3 . 1 2 . 8 - 8 2 . 3

M a r i n e s 3 7 5 . 0 - 2 6 . 5 5 6 0 . 6 - 2 8 . 4

N a v y 6 4 3 . 1 - 2 8 . 9 3 9 2 . 7 -48.1 

E n e r g y 5 8 1 . 9 - 7 . 7 1 0 3 . 1 2 2 . 8

Health & Human Services 0 - 1 0 0 . 0 5 5 . 1 - 6 0 . 6

I n t e r i o r 4 . 8 3 1 6 . 5 2 5 . 8 - 1 0 0 . 0

J u s t i c e 3 2 . 5 - 6 4 . 8 0 -

Tr a n s p o r t a t i o n 1 6 . 5 - 3 0 . 7 6 . 3 0 . 0

Tr e a s u r y 3 7 . 6 4 9 3 . 3 4 4 1 . 7 11 9 . 4

Veterans A f f a i r s 0 — 9 1 . 0 -

E PA 0 - 4 5 . 0 0 -

N A S A 4 7 4 . 0 - 1 3 . 7 7 8 . 1 - 2 5 . 2

Tennessee Valley A u t h o r i t y 1 3 . 6 - 1 0 0 . 0 0 - 1 0 0 . 0

U.S. Enrichment Corp. 6 7 5 . 7 - 11 . 7 0 - 

To t a l 7 , 9 2 7 . 0 - 2 3 . 6 6 , 4 9 5 . 3 - 3 4 . 7

Releases and transfers reported in millions of pounds.

Source: E PA, 1995 Toxics Release Inventory: Public Data Release (EPA 7 4 5 - R - 9 7 - 0 0 5 ,

April 1997).

ate vicinity (using the TRI Indicator

Model); compliance history; community

and other reports of EJ concerns; and

geographic distribution. To determine

whether the 44 facilities listed in the

report are in fact EJ sites, further investigation is needed. FFEO is encouraging

each EPA Region to include at least one

targeted facility in its annual multimedia inspections and to engage regional

EJ coordinators and federal facility coordinators in joint targeting efforts.

For more information or a copy of the

report, contact Darlene Boerlage, FFEO,

202- 564-2593.

ENVIRONMENTAL JUSTICE AT FEDERAL

FACILITIES: A NEW INITIATIVE
PAGE 4

ary 7, 1997. Negotiations are ongoing to

resolve these complaints. The other two

actions were for violations of RCRA S u btitle C (hazardous waste) involving sites

that were contaminated,which assessed

penalties in the amount of $302,000 for

the Washington Navy Yard and $310,000

at the Anacostia Naval Station. The

Region and the Navy are working together as a team to resolve these counts.

On March 6, 1997, EPA Region 3 and

the Department of Navy signed a RCRA

7003 cleanup order. This order requires

comprehensive hazardous and solid

waste cleanup at the installation. As part

of a team effort, EPA Region 3 has

assigned both a Superfund and RCRA

(hazardous waste) project manager to the

facility to fully integrate the cleanup of

the site once it becomes final on the

National Priorities List. Meanwhile, the

Navy has been conducting cleanup activities at the installation.

Under the Clean Water Act, the Navy

has applied for a National Pollution Discharge Elimination System (NPDES)

permit for management of its stormwater

and discharges into the Anacostia River.

At last check, the District of Columbia

has not concurred on the NPDES permit.

Under requirements of the National

Environmental Policy Act, the Navy held

a public meeting on January 23, 1997, to discuss the

draft Environmental

Impact Statement for the

relocation activities proposed at the facility. The

Washington Navy Ya r d

will be receiving approximately 4,100 new personnel transferring from a

location in Arlington, Vi rginia. Reportedly, community members and the

Sierra Club Legal Defense

Fund focused on the ongoing cleanup at the Navy

Yard as well as the need

for more accessible inforTHE WASHINGTON NAV Y

YARD: EPA’S MULT I -

MEDIA ENFORCEMENT 

IN THE DISTRICT OF

C O L U M B I A

by Darlene Boerlage

The Washington Navy Yard, a 66-

acre facility in Southeast Washington on

the banks of the Anacostia River, has

been working with EPAfor the expedient

cleanup and return to compliance of the

f a c i l i t y. Due to its 150 years of naval

industrial activities the Navy Yard is on

track to be listed on the Superfund

National Priorities List within the next

several years. 

E PA Region 3 issued four signific a n t

enforcement actions on September 30,

1996, two at the Washington Navy Ya r d

and two at the Anacostia Naval Station.

Multi-media inspections had previously

been conducted at the facilities as part of

the Region’s Anacostia River Initiative.

Two of the complaints were the first ever

issued under the Underground Storage

Tank program (RCRA Section 9006)

against a federal agency for violations of

federal underground storage tank regulations. The Navy answered the complaints and requested a hearing on Janumation from the Navy on the progress of

cleanup. The Navy has responded to the

community by forming a Restoration

Advisory Board comprised of community

members and other stakeholders to

advise the Navy on the cleanup process.

The Navy Yard remediation is part of a

broader community-based approach by

E PA Region 3 and the Navy to conduct

cleanup under the Anacostia River Initiat i v e .

Darlene Boerlage can be reached at

202-564-2593. 

E PA REGION 2 REVIEW OF

DOE BROOKHAV E N

N ATIONAL LABORAT O RY

E PA Region 2 conducted a major multimedia inspection of DOE’s Brookhaven

National Laboratory (BNL) in Upton, NY.

The inspection took place May 5-14, 1997,

with assistance from EPA’s National

Enforcement Investigation Center. Tw e nt y - five inspectors representing eleven

programs participated in the inspection.

B N L was identified as an inspection

candidate because of its size and complex

and variable operations. Of particular

interest to EPA was the controversy surrounding the waste management practices at the site, and the fact that numerous violations had been found during

E PA’s earlier multi-media inspection of

B N L in 1991.

To complement the multi-media

inspection, Region 2 will be conducting

two additional reviews of the facility.

First, an evaluation of BNL’s major

processes (both operational and research)

will be conducted to provide EPA a n d

B N L with a comprehensive understanding of all waste generation at the facility.

And second, an Environmental Management Review (EMR) will be conducted to

determine whether the facility’s management system is adequately designed to

sustain a viable environmental compliance program. Both reviews will begin

Washington Navy Ya r d this summer with NEIC assistance.
PAGE 5

effort of its own. Also, in 1997, USDA

completed a survey of its field offices in

Kansas and Nebraska and located 75

sites not previously identified. 

For additional information contact

Lance Elson at 202-564-2577.

REGION 6 REPORTS FIRST

TRANSFER OF BASE CLOSURE TO CIVILIAN USE 

On May 23, 1997, EPA Region 6

approved final transfer of NAS Chase

Field to the Beeville/Bee County Redevelopment A u t h o r i t y. This is the first base

closure in Region 6 that has been completely converted to civilian use.

NAS Chase Field was placed on the

Base Closure list in 1991 (BRAC II). To

speed the economic recovery of communities impacted by the closing of the base,

an innovative partnership was created

among EPA, the State of Texas, and Navy

environmental personnel. A g o a l - o r i e n t e d

process was established to fast-track

environmental cleanup and to ensure

that cleanup of old hazardous waste sites

at the base does not interfere with redevelopment of this property. Signific a n t

amount of solid waste management units

were identified and investigated at the

base. Major sites investigated and remediated include landfills, fir e fighting trainG R O U N D WATER 

SAMPLING UNDERWAY 

IN NEBRASKA AND

K A N S A S

E PA Region 7, the Kansas Department

of Health and Environment, and Nebraska Health and Human Services have

begun testing private wells and groundwater near USDA-operated grain storage

sites to identify possible carbon tetrachloride (CCl4) contamination. A history of

finding CCl4-contaminated groundwater

near former grain storage facilities in

Nebraska and Kansas has compelled

E PA to push for testing of approximately

400 still untested sites in these two

states. EPA has committed over half a

million dollars to support sampling at

these sites in order to ensure that private

well users nearby are not using contaminated water. The money is being contributed by the Federal Facilities

Enforcement Office, Region 7’s Superfund Program, the Office of Wa t e r, and

the Office of Emergency and Remedial

R e s p o n s e .

Sampling will take place over a period

of approximately 15 months, with the

states conducting much of the work. EPA

estimates that this effort will address the

approximately 400 sites that currently

need to be sampled in Kansas and

Nebraska, with about $200,000 needed to

complete sampling in these states. Grain

bin sites in Iowa, which appear to have a

s i g n i ficantly lower detection rate, may be

addressed in future sampling projects.

No sites have been sampled in Missouri.

The Commodity Credit Corporation,

an agency of USDA, operated approximately 4,500 grain storage sites nationally from the 1940s until 1970. Of these,

about 1,800 known sites are located in

Region 7 (Nebraska, Kansas, Missouri

and Iowa). USDA fumigated stored grain

at these sites with CCl4, a probable

human carcinogen. For some time, EPA

has sought to have USDA perform widespread sampling in order to identify

potential users of CCl4-contaminated

g r o u n d w a t e r. Recently, USDA h a s

expressed interest in sampling activities

and a willingness to contriubte $11 0 , 0 0 0

of its FY97 funds toward a sampling

ing areas, waste oil tanks, solvent tanks,

waste storage areas, and oil-water separators. 

The success of environmental cleanup

and reuse at NAS Chase Field is attributed to team work among staff from EPA ,

the Texas Natural Resource Conservation Commission, and the Navy, as well

as the direct involvement of the Base

Commander in promoting reuse of the

facility and a close working relationship

with the local Redevelopment A u t h o r i t y.

For further information, contact Mr.

Sing Chia, EPA Region 6, 214-665-8301.

ON THE INTERNET: ENVIRO$EN$E AND BEYOND...

A wide variety of information on federal facilities is available through EPA

sites on the Internet: 

To reach Enviro$en$e, EPA's environmental electronic information system: 

• Through EPA's server, go to h t t p : / / w w w. e p a . g o v / e n v i r o s e n s e

(No dollar signs!!)

• Through the INEL s e r v e r, go to h t t p : / / e s . i n e l . g o v

To go directly to Federal Facilities Information on Enviro$en$e, go to 

h t t p : / / e s . i n e l . g o v / o e c a / f e d f a c / f e d f a c _ i n f o . h t m l

To reach FFEO's home page (also the Federal Facilities Environmental Leadership Exchange home page), go to h t t p : / / e s . i n e l . g o v / o e c a / f e d f a c / f flex.html 

To reach EPA’s home page, go to h t t p : / / w w w. e p a . g o v

To read this or past issues of FedFacs on the Internet, go to http://es.inel. 

gov/oeca/fedfac/ann/index.html 

For information on FFLEX/Enviro$en$e, contact Isabelle Lacayo, FFEO, 

2 0 2 - 5 6 4 - 2 5 7 8 .

See you on the Internet! 

is published by EPA’s Federal Facilities

Enforcement Office. 

Joyce Johnson, E d i t o r

Gilah Langner, Wr i t e r

Robin Foster, L a y o u t

To receive FedFacs in the mail, contact:

Federal Facilities Enforcement Offic e

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

Washington, DC 20460

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

REGION 1:

Actions Against Veterans A f f a i r s

F a c i l i t y. On March 31, 1997, Region I

reached a settlement with the Department of Veterans Affairs (VA) Medical

Center in Westhaven, CT on a complaint

and compliance order under RCRA S e ction 3008(a). The penalty assessed in the

complaint was $82,375 with a settlement

penalty of $61,550. The VA will pay

$15,388 (25%) in cash and will perform

SEPs costing some $48,000. The VA w i l l

install and operate, as part of the x-ray

film processing operations, a closed-loop

silver recovery system and automatic

batch system for four x-ray developer

units. In addition, the VA will purchase

necessary computer hardware and hazardous materials software to be used by

the VA Safety Office personnel for hazardous materials and waste management information. 

The VA also will hire a consultant to

conduct an environmental compliance

audit at the facility. The audit will identify

opportunities to maintain compliance with

R C R A regulations, ways in which the

R C R Aprogram at the VAcan be improved,

e f ficient ways to manage hazardous waste

generated at the VA, and opportunities to

reduce the use, production, and generation

of hazardous materials and waste. The

audit will require a detailed inspection of

all chemical use areas, satellite accumulation areas, and the hazardous waste accumulation shed. Finally, the VA will provide

eight-hour RCRA hazardous waste management training to all members of the

Fire & Safety Office, appropriate members

of the Facilities Management Service, and

research laboratory principle investigators. 

Among the violations outlined in the

complaint was the failure to make hazardous waste determinations. EPA

inspectors found that the facility had

sent hazardous wastes off-site designated as nonhazardous wastes. The facility

also failed to operate so as to minimize

the possibility of a fire, explosion, or any

unplanned release of hazardous waste

constituents. EPA inspectors found containers holding acids and caustics that

could result in heat generation and violent reaction if mixed together or thrown

out in a trash barrel. A similar action was

settled earlier in the year against VA

medical facilities in Boston, MA. 

In September 1996 the Ve t e r a n s

Administration agreed to spend $16,800

to design and implement an environmental training program for all nine VAm e dical facilities throughout New England.

The training included instruction on

management of hazardous waste and recognizing opportunities for pollution prevention. The VA also agreed to pay a cash

penalty of $47,725 to settle an EPA c o mplaint regarding violations of federal and

state hazardous waste management laws

at the VA’s medical center on South Huntington Ave. in Boston, MA.

REGION 4:

Agreement with DOE on Paducah

Plant. Region 4 reached agreement with

DOE to clean up the NPL-listed Paducah

Gaseous Diffusion Plant. The interagency agreement (IAG) reflects an expectation that the groundwater at the site

will be cleaned up by 2010. The IAG was

issued for public comment in Spring 1997

and is expected to be finalized in the fall.

Final agreement on a major modific a t i o n

to the IAG covering cleanup at the DOE’s

Oak Ridge Reservation NPL site was also

reached. The modification provides for

milestones which are more enforceable

than those of the original agreement. 

R C R A Cases. Region 4 continues to

work toward resolution of administrative

complaints issued late in 1996 against

the A r m y ’s Fort Campbell in Kentucky,

where a $48,700 penalty was proposed,

and the Defense Logistics A g e n c y ’s (DLA)

Memphis Depot, which was assessed a

$20, 000 penalty.

The Fort Campbell violations included: failure to make hazardous waste

determinations, failure to correctly label

containers, failure to remove hazardous

waste from satellite accumulation areas

in a timely manner, and failure to maintain emergency equipment. 

The DLA Memphis, Tennessee facility

violated the conditions of its permit by

improperly storing incompatible wastes,

creating potentially dangerous conditions. 

Region 4 also took a RCRA e n f o r c ement action against Lockheed Martin

Energy Systems in late 1996, for failure

to adequately inspect hazardous waste

tank systems at DOE’s Oak Ridge, Te nnessee facility. The RCRA Consent A g r e ement and Consent Order imposed a

$22,500.00 penalty for improper inspection procedures. The tank inspections are

now being properly performed. 

REGION 9: 

Air Force Agreement to Pay Stipulated Penalty at McClellan A i r

Force Base in California. On A p r i l

25, 1997, the Air Force agreed to pay a

$15,000 fine and accepted full responsibility for exceeding effluent limitations

for its groundwater treatment system for

a three-day period, and discharging

groundwater contaminated with TCE,

1,1-dichloroethane, 1,1,-dichloroethylene

in greater concentrations than allowed in

the interim record of decision. In addition, the Air Force failed to sample the

e f fluent on a weekly basis (which would

have indicated that the carbon fil t e r s

needed replacing).

REGION 10:

R C R A Consent Agreement and

Consent Order Signed for Fort

Richardson and Fort Wa i n w r i g h t .

On April 29, 1994, EPA issued two complaints and compliance orders under

R C R A Section 3008(a) to the Army for

hazardous waste violations at Fort

Richardson and Fort Wainwright in A l a ska assessing $1.34 million and $650,000,

r e s p e c t i v e l y. On November 21, 1996, a

consent agreement and consent order

Continued on page 7
PAGE 7

was signed to settle the two complaints.

The settlement calls for the Army to pay

a penalty of $200,000 and to perform two

supplemental environmental projects

worth over $1.0 million. Under the SEPs,

the Army will obtain hazardous waste

storage lockers for use at US A r m y

installations in Alaska and establish a

Joint Regional Environmental Tr a i n i n g

Center making environmental training

available to federal and state agencies in

Alaska. 

R C R A Consent Agreement and

Consent Order Signed for Coast

G u a r d ’s Kodiak Facility. A C o n s e n t

On May 5, 1 9 9 7 ,

the second annual

Closing the Circle

award ceremony

was held, honoring

super environmental achievers in the

federal government. This year's

award ceremony

included the Environmental Pollution Prevention Challenge Awards which

were presented to individuals in federal

agencies for outstanding achievements in

implementing the provisions of the 1993

Executive Order 12856 on Federal Compliance with Right-to-Know Laws and

Pollution Prevention. The winners of

these awards were: 

Cathy Andrews, Department of the

N a v y, Naval Surface Warfare Center,

Crane, IN, for effective outreach to facility stakeholders and team-building

efforts, including a pollution prevention

"stand down" where over 3,000 Navy

employees learned about the environmental benefits of pollution prevention. 

Mary Jo Bieberich, Department of

the Navy, Carderock Naval Surface

Warfare Center, Carderock, MD, f o r

leadership in the Navy's Pollution Prevention A float Program which integrates

pollution prevention activities into shipboard activities at sea. Her "at sea"

opportunity assessments identified over

40 pollution prevention opportunities

while ships were deployed. 

Edward Cooper, Department of the

A r m y, Corpus Christi Army Depot,

Corpus Christi, TX, for designing a

broad range of process changes and modi fications, some of which include design

criteria requiring virtually zero pollution

from various chemical processes. 

Ronald Barnett, Department

of the A r m y, United States

Field Artillery Center and

Fort Sill, Fort Sill, OK. A s

Director of Environmental Quality for Fort Sill, Mr. Barnett provided unique pollution prevention

outreach and training materials

to facility personnel, the Fort Sill

c o m m u n i t y, and the public at

large. 

Ronald Robbins, U.S. Postal

Service Northeast Area Offic e ,

Wi n d s o r, CT.As Chair of the U.S.

Postal Service Pollution PrevenCONGRATULATIONS!! 

AWARD WINNERS MEET THE CHALLENGE OF POLLUTION PREVENTION

Agreement and Consent Order was

signed by the Region 10 Administrator on

January 23, 1997, for this Alaska facility,

settling a complaint and compliance

order issued on July 12, 1994. The complaint sought over $1 million in penalties

for violations of RCRA, including the failure to monitor groundwater and illegally

burning waste piles of debris. Apenalty of

$602,260 has been agreed to for the spec i fic violations alleged in the complaint. 

I N E E L Settlement for CERCLA

Agreement Vi o l a t i o n s . On March 18,

1997, a settlement was signed for violations of the CERCLA 120 Federal Facility Agreement/Consent Order for DOE’s

Idaho National Engineering & Environmental Laboratory. The violations involve

the cleanup of Pit 9 and groundwater in

the Test Area North of INEEL. Both sites

had remediation activities that DOE had

privatized, and significant delays in

remediation occurred because of management and other difficulties associated

with the contracting mechanisms and

cleanup. EPA and Idaho have worked

with DOE and the contractors to get the

projects in question back on track and to

minimize further delays. EPA and the

state have assessed DOE a total of

$970,000 in penalties of which $100,000

will be monetary and the remainder will

be a SEP involving the conservation of

environmentally sensitive land. 

tion Task Force, Mr. Robbins guided the

development of pollution prevention programs affecting the Postal Service

nationwide; at postal facilities in the

Northeast, his efforts resulted in a reduction of hazardous waste by over 90 percent. 

Russell P. Schaefer, U.S. Postal Service, Portland, ME, for establishing

effective pollution prevention programs

at District of Maine facilities and for

implementation of a highly effective hazardous waste amnesty plan. 

THE HAMMER

Continued from page 6

Continued on page 11

Sherri Goodman, Cathy Andrews, R. Adm.

Totusher (DOD), Fran McPoland (Federal Environmental Executive), Mike Stahl (EPA)
PAGE 8

EXECUTIVE ORDER 12856

ANNUAL REPORT 

S U M M A RY

FFEO is currently preparing the fir s t

report on federal agency performance

under Executive Order 12856, "Federal

Compliance with Right-To-Know Laws

and Pollution Prevention Requirements."

The report will cover the efforts of 13

agencies on community right-to-know

and pollution prevention activities.

Executive Order 12856 affirmed and

strengthened the federal government's

obligation as a responsible neighbor in

communities where federal facilities are

located by requiring federal agencies and

facilities to comply with chemical reporting and emergency planning provisions

of the Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA)

and the Pollution Prevention Act of 1990.

The Order set a new standard for federal

environmental excellence by extending

this compliance requirement to many

activities not currently monitored in private industry. 

Executive Order 12856 also established the Administration's vision for federal government leadership in pollution

prevention. The order directed that federal agencies and facilities take steps to

embrace pollution prevention as a government-wide ethic in the day-to-day

management of federal facilities. In part i c u l a r, E.O. 12856 set ambitious goals

for reducing or eliminating the release of

toxic and hazardous pollutants from federal facilities into the environment. Federal agencies were required to modify

their acquisition and procurement practices and adopt pollution prevention as

standard practice for government purchase of goods and services. Finally, E.O.

12856 supported the continuing federal

commitment to work with the private

sector in the development, testing, and

implementation of innovative pollution

prevention technologies. 

Section 402 of Executive Order 12856

directs federal agencies to report annually to EPA on the progress made in fulfil ling each of the provisions of the order. In

1995, EPA published Meeting the Challenge: A Summary of Federal Agency Pollution Prevention Strategies, which documented the first 18 months of activity by

federal agencies and facilities under the

executive order. EPA is now preparing a

second document which will summarize

progress reports provided by 13 federal

agencies. The document will be available

in late summer. 

For more information, contact Wi l l

G a r v e y, 202-564-2458.

HAZARDOUS WA S T E

COMPLIANCE DOCKET

U P D ATED WITH SECTION

3016 INVENTORY 

The Federal A g e n c y H a z a r d o u s

Waste Compliance Docket has been

recently updated. Update 10, published

on June 27, 1997, added 102 federal facilities, bringing the total number of facilities on the docket to 2,104. Four of the

new additions to the docket are facilities

that have reported to the National

Response Center the release of a

reportable quantity of a hazardous substance. Since the docket’s inception in

1988, the number of federal facilities listed has increased by nearly 80 percent,

from 1,094 to 2,104.

The docket includes the 1996 inventory of hazardous waste facilities mandated

by Section 3016 of RCRA. Section 3016

requires all federal agencies to compile,

publish, and submit to EPA an inventory

of all facilities they currently own or operate, or have previously owned or operated, at which hazardous waste is stored,

treated, or disposed of, or was disposed of

at any time. The inventory must be submitted every two years. EPA's Office of

Solid Waste conducted an initial inventory in 1986, and subsequently in 1988,

1990, 1992, and 1994. In 1996, responsibility for conducting the inventory was

transferred to FFEO. FFEO requested

inventory submissions from federal agencies in April 1997, and held a half-day

interagency training to help federal agencies respond to the request. 

For more information, contact Augusta Wills, FFEO, 202-564-2468. 

E PA/DOE COLLABORATIVE DECISION-MAKING

GUIDANCE FINALIZED

E PA's Office of Enforcement and Compliance Assurance, Office of Solid Wa s t e

and Emergency Response, and DOE's

Environmental Management Offic e

recently issued the final joint G u i d a n c e

on Improving Communication to Achieve

Collaborative Decision-Making at DOE

cleanup sites. The guidance places a

great deal of emphasis on greater use of

interagency project teams to improve and

expedite cleanup and regulator involvement in annual budget development.

The DOE/EPA communications guidance was approved as Interim Final by

Steve Herman, Elliott Laws, and Al A l m

at a joint signing ceremony in November,

1996, and finalized in June, 1997. The

f o u r-page document focuses on improving

communication to: (1) further the EPA

and state regulator role in establishing

project priorities at DOE sites; (2) encourage greater use of collaborative decisionmaking to improve and expedite cleanup

and compliance at DOE facilities; and (3)

improve the informal dispute/ issue resolution process to facilitate cleanup and

compliance. 

A variety of factors led to the development of this guidance. First, independent

observers highlighted the need for

improved communications both within,

and between, EPA and DOE. Second,

increasing fiscal constraints make it

important to have greater regulator

involvement in DOE budget planning.

L a s t l y, EPA and DOE saw the need to

jointly identify the steps to be taken to
PAGE 9

achieve the most suitable remedies. This

will save money, focus effort on appropriate actions, and accelerate cleanup.

The guidance describes a communication framework that should

improve compliance, accelerate environmental work, and

increase efficiencies. Improving communications is critical to achieving DOE's goal

of completing cleanup at

most sites with a decade.

Several Regions have successfully participated on

interagency teams and documented success in using collaborative decision-making

approaches to reduce costs at

federal cleanup sites. The

concepts outlined in the guidance can

strengthen EPA and state positions in

establishing priorities at DOE sites while

assisting DOE in accomplishing its expedited cleanup goals contained in DOE's

s i t e - s p e c i fic Ten Year Plans. 

A copy of the Guidance may be downloaded from FFEO's Web site at

h t t p://e s . i n el/o e c a / f e d f a c / p o l i cy/p o l i c y. h t ml.

For more information, contact David Levenstein at 202-564-2591.

REIMBURSABLE 

I N S P E C T I O N S

Section 104 of the Federal Facilities

Compliance Act (FFCA) requires EPA

Regions and delegated states be reimbursed for the costs of conducting certain

annual RCRA inspections at federal

t r a n s f e r, storage, and disposal (TSD)

facilities. Since 1994 EPA has had interagency agreements (IAGs) in place with

DOD and DOE (and more recently with

N A S A in 1996) to enable reimbursement

for the cost for these inspections.

FY97 agreements for DOE and NASA

are approved and in place. The DOD services are reviewing their FY97 packages

and it is expected that with some language changes, the agreements will be

signed and processed through the Headquarters grants office by the end of July.

DOD services have agreed that the IAGs

will be effective for a five-year period

(FY97-FY02) instead of

one to two years to help

speed up the IAG

process. This will avoid

using resources at the

end of a fiscal year to recharge appropriate

accounts for eligible

R C R A inspections costs.

Having the accounts

available at the beginning of a fiscal year will

allow the Regions to

charge eligible RCRA

inspection costs to the

applicable accounts as costs are incurred

during a fiscal year.

FFEO is responsible for coordination

of reimbursement to both EPA R e g i o n s

and the individual states for RCRA T S D

inspections required by the FFCA. EPA

has completed a management review

study of the first three years of program

implementation. 

For a copy of this study or for more

information, contact Susan We i n e r,

FFEO, 202-564-2471. 

I M P L E M E N TATION 

GUIDANCE AVA I L A B L E

FOR CEMP

E PA recently published an Implementation Guide for the Code of Environmental Management Principles (CEMP)

for Federal Agencies. The guide presents

s p e c i fic actions that agencies can take in

implementing CEMP, and encourages

agencies to consider other steps or to

adopt an environmental management

system (EMS) standard (such as ISO

14000) as the vehicle for implementing

C E M P. The guide also includes a "SelfAssessment Matrix" that describes the

stages an organization may go through in

implementing CEMP.

E PA's CEMP, published on October 16,

1996 (61 FR 54062), is a collection of fiv e

broad principles and performance objectives that can assist agencies in developing the necessary management infrastructure to support a proactive, fle x i b l e ,

cost-effective, and integrated environmental performance. Sixteen federal

agencies have endorsed CEMP and are at

various stages in implementing it at the

facility level. 

For more information, contact Andrew

C h e r r y, FFEO, at 202-564-5011. For

copies of the guide, fax a request to Priscilla Harrington, FFEO, 202-501-0069, or

download a copy from the Enviro$en$e

Web site at http://es.inel.gov/oeca/

c e m p / c e m p t o c . h t m l .

R E P O RT ISSUED ON

RCRA ADMINISTRAT I V E

ORDERS 

A report analyzing R C R Aa d m i n i s t r ative orders issued at federal facilities

between 1992 and 1995 is available from

E PA. The report analyzes data obtained

from EPA Regions and their counterpart

o f fices at the state level. Among the fin dings: 

• Federal orders took longer to settle

than orders issued by states. The average settlement time was 369 days for

federal orders and 196 days for state

orders. The average proposed federal

penalty was $321,921, while the average proposed state penalty was

$ 5 4 , 6 6 4 .

• Of the 701 violations cited in 105

administrative orders, 135 related to

storage and accumulation issues,

another 133 represented general operations and maintenance failures, 87

were labeling deficiencies, 68 were

safety violations, and 58 were defic i e ncies in records submissions.

To order copies of the report, contact

Kelly Conrad, 202-564-2459.

I N D E P E N D E N T

O B S E RVERS 

HIGHLIGHTED THE

NEED FOR IMPROVED

C O M M U N I C AT I O N S

BOTH WITHIN, 

AND BETWEEN,

E PA AND DOE
EMR PILOTS AVA I L A B L E

Environmental Management Reviews (EMRs) are evaluations of an individual facility's program and management systems to determine the extent to

which a facility has programs and plans in place that can ensure compliance and

progress toward environmental excellence. As described in the last issue of FedFacs, EMRs are not inspections, audits, or pollution prevention opportunity

assessments. Instead, they offer federal facilities an understanding of the underlying causes of current or potential compliance problems and develop suggestions for correcting them. EPA is offering to conduct EMRs at federal facilities as

part of a pilot program. For information on EMRs or to sign up for one, contact

your EPA Regional Federal Facility Coordinator: 

Region 1, Anne H. Fenn, 617-565-3927

Region 2, Jeanette Dadusc, 212-637-3492

Region 3, Eric D. Ashton, 215-566-2713

Region 4, David F. Holroyd, 404-562-9625

Region 5, Lee J. Regner, 312-353-6478

Region 6, Joyce F. Stubblefield, 214-665-6430

Region 7, Jamie Bernard-Drakey, 913-551-7400

Region 8, Dianne Thiel, 303-312-6389 or Connally Mears, 303-312-6217

Region 9, Sara Segal, 415-744-1569

Region 10, David Tetta, 206-553-1327

PAGE 10

Some 225 people attended the 11 t h

Annual Environmental Conference sponsored by EPA Region 4 (Environmental

Accountability Division, Federal Facilities) with the Department of Defense

(Joint Interservice Regional Support

Group) and several civilian federal agencies, held on May 11-14, 1997. The theme

was "Progress Through Partnering."

Keynote speakers were John Hankinson

(Regional Administrator for EPA R e g i o n

4), Phyllis Harris (EPA Regional Counsel), Curtis Bowling (Deputy to the A s s i stant Deputy Under Secretary of Defense,

Environmental Quality), Denzel Fisher

(Assistant to the Deputy Assistant Secretary of the A r m y, Environment Safety &

Occupational Health) and Elsie Munsell

(Deputy Assistant Secretary of the Navy,

Environment & Safety). 

Topics covered included state presentations and workshops, EPA/DOD Partnering, North Carolina/DOD Partnering,

Project XL & ELP, Risk Management,

Safe Drinking Water Act, Underground

Tanks & Underground Injection Control,

Munitions Rule, Range Rule, ISO 14000,

and the Coastal America Partnership

P r o g r a m .

For more information, contact David

Holroyd, EPA Region 4, 404-562-9625.

Information will be posted on the EPA

Region 4 EAD/AMB home page.

REGION 4 FEDERAL FACILITY

CONFERENCE The National Guard asked EPA H e a dquarters to overturn DeVi l l a r s ’ o r i g i n a l

c e a s e - fire order on April 10, warning that

it could “jeopardize the readiness of

National Guard units on the East Coast

and the lives of our soldiers on the battlefield.” Late on May 16, however, EPA

Deputy Administrator Fred Hansen

rejected the appeal, calling the fir i n g

ranges “an imminent and substantial

endangerment.” He said that only troops

that needed to be ready for deployment to

Bosnia or other hot spots should be

exempted from the cease-fir e .

The Cape Cod aquifer is the sole drinking water source for approximately

200,000 permanent and 520,000 seasonal

residents of Cape Cod. The MMR training

range and impact area is directly above

the most productive groundwater

recharge area of the aquifer, the Sagamore Lens. Groundwater flows radially

in all directions from the training range

and impact area. Four towns look to this

region in the northern part of MMR to

find new water supplies to replace those

already lost to groundwater pollution and

to fill the gap between supply and

demand (estimated at 11 million gallons

per day by 2020).

The Superfund cleanup at MMR has

i d e n t i fied plumes that have polluted

roughly 66 billion gallons of water — an

amount that could supply the drinking

water needs of all Cape Cod residents for

7.5 years. It is estimated that each day

another 6-8 million gallons of groundwater are contaminated because of rapid

movement of plumes through subsurface

soils. The unusually high cancer rate in

Upper Cape communities surrounding

MMR — 24% higher than the statewide

average — has heightened the public’s

concern about MMR. However, because

the impact area and training range are

active range and training sites, study and

remediation of these areas were not

required under the Superfund federal

facilities agreement.

On Feb. 27, 1997, EPA Region 1 issued

an Administrative Order pursuant to the

CEASE-FIRE ON CAPE COD

Continued from page 1
PAGE 11

Richard Peri, Department of Tr a n sportation, Aeronautical Engineering

Division at U.S. Coast Guard Headquarters, Washington, D.C., for integrating pollution prevention goals

throughout the Coast Guard aeronautical

community through such efforts as developing a pollution prevention chapter for

the Aeronautical Engineering Maintenance Manual and establishing aircraft

maintenance working groups.

Jane Powers, Department of Energy,

O f fice of Environmental Policy and

A s s i s t a n c e , Washington, DC, for her

efforts to include DOE in EPA's 33/50 toxics reduction program and to develop

clear and concise pollution prevention

guidance, training courses and workshops for DOE facility personnel. 

Arthur Benson, U.S. Department of

Agriculture, Beltsville A g r i c u l t u r a l

Research Center, Beltsville, MD, f o r

establishing ten pollution prevention

goals to ensure that the Research Center

meets and exceeds the pollution prevention goals of Executive Order 12856. 

Congratulations to all who contributed

their talents and energies towards

demonstrating federal leadership in preventing pollution!

Note: The Closing the Circle Award nomination form for this coming year will

include nominations for the individual

Pollution Prevention Environmental

Challenge Aw a r d .

emergency powers authority of Section

1431 of the Safe Drinking Water A c t ,

requiring the National Guard to (1)

undertake a comprehensive study of

groundwater related to the training

range and impact area; (2) provide information to EPA about possible contamination in the impact area; (3) develop a proposal for pollution control measures; and

(4) coordinate with a community- based

oversight group. 

National Guard officials in February

agreed to suspend the use of live ammunition until completion of a groundwater

s t u d y, expected to take 1-2 years. Howeve r, EPA, the communities, and elected

o f ficials remained concerned about potential impacts to the aquifer from activities

which the National Guard proposed to

continue, given the widespread groundwater contamination already emanating

from MMR. No study provided to EPA

evaluated possible migration of contaminants to groundwater from soil contamination associated with the use of propellants and “pyrotechnics” such as smoke

grenades. EPA called for a broader ceasefire on April 10, including live ammunition, but also the chemical propellants

used to fire dummy artillery and mortar

shells as well as pyrotechnics. EPA s a i d

that high levels of toxins in these devices

also had been found in base soil.

For more information, contact Bill

Frank, FFEO, 202-564-2584. 

CLOSING THE CIRCLE AWA R D S

Continued from page 7

the federal government had earned the

p u b l i c ’s trust. The public needs to know

that it will be protected through vigorous,

forceful enforcement by EPA and the

states for violations of environmental

laws and situations that put public health

and our natural resources at risk. This

type of accountability is the only way for

the federal government to gain the credibility it needs to effectively manage its

environmental programs.

E PA has strengthened the principle

that one federal agency can fine or penalize another agency. On numerous occasions EPA has had to defend EPA’s taking

penalty actions against other federal

agencies. Some view that as merely robbing Peter to pay Paul. Or, isn’t a penalty

action irrelevant since the federal government is not motivated by profits? This

debate should be over, though, because

the facts are straightforward and unassailable — penalties deter non-compliance. They create a powerful incentive for

agencies to comply — the incentive of not

getting caught and not being exposed to

the public and to one’s superiors as a viol a t o r. Congress charged EPA with providing that incentive and we have demonstrated our intention to do so and to

continue doing so in the future.

The 1992 Federal Facility Compliance

Act (FFCA) clearly established our RCRA

order authority against federal facilities

and placed it on a par with EPA’s authority against private companies and individuals. In enacting FFCA, Congress

sought to ensure that the incentives to

comply brought about by strong enforcement and penalties would apply equally

to federal facilities and those in the private sector. This level playing field is necessary to restore the faith of the A m e r i c a n

people that the protection of human

health and the environment on federal

facilities is a priority. The message is

c l e a r. Environmental enforcement is a

necessary incentive to ensure compliance

and must be applied with equal force to

the federal government. 

The trend toward equality among all

members of the regulated community is

growing. Congress amended the Safe

Drinking Water Act (SDWA) this fall and,

similar to FFCA, clarified EPA’s and the

s t a t e s ’ enforcement authorities under

S D WA against other agencies of the federal government. As a result of these amendments, there can be no doubt that federal

agencies are liable for penalties just like

private parties. In addition, although the

Clean Water Act did not pass recently,

there was bipartisan support for placing

the federal government on a level playing

field with the private sector with regard to

enforcement actions and penalties. 

Enforcement actions and penalties are

a deterrent to noncompliance. Citizens

expect EPA to act as an “honest broker”

within the federal government—an agency

that will oversee other agencies’ e n v i r o nmental compliance and take enforcement

when necessary. EPAwill continue to serve

as such a broker.

DIRECTOR’S WORD

Continued from page 1

D i r e c t o r, FFEO
S E P T. 3-4, 1997

REGIONAL FEDERAL FACILITIES/ 

M U LTI-MEDIA POLLUTION 

PREVENTION CONFERENCE

Dallas, TX

Free conference for environmental managers at federal facilities. Contact: Joyce

S t u b b l e field, 214-665-6430

S E P T. 15 - 18, 1997 

POLLUTION PREVENTION FAIR 

Aberdeen PG, MD

Contact: American Defense Preparedness

Association, tel: 703-522-1820, fax: 703-

522-1855. 

S E P T. 23 - 25, 1997 

7TH SOUTHERN STATES ANNUAL ENVIR O N M E N TAL CONFERENCE AND EXHIBITION: A CONFERENCE ON HOW-TO'S 

Biloxi, MS

Sponsored by Mississippi Dept. of Environmental Quality; MISSTAP; DOD

Joint Interservice Regional Support

Group South 2 Area; Tennessee Va l l e y

Authority; USAE Waterways Experiment

Station; U.S. EPA 4 and 6. Contact:

h t t p : / / w w w. d e . m s s t a t e . e d u / m i s s t a p / i n d e x

2.html. 

N O V. 18-20, 1997

THE NATIONAL MARKETPLACE FOR THE

ENVIRONMENT 

Washington, DC 

Conference and trade show devoted to the

marketing of environmental products,

programs, and services to federal, state,

and local governments. Contact: 800-334-

3 9 7 6 .

DEC. 3-5, 1997

3RD ANNUAL SERDP SYMPOSIUM

Washington, D.C.

Technical sessions and information on

FY99 solicitation process and funding

opportunities, for Strategic Environmental Research and Development Program.

Contact: SERDP Support Office, 703-736-

4 5 4 8 .

CALENDAR

United States Environmental 

Protection Agency (2261)

Washington, DC 20460

O f ficial Business

Penalty for Private Use $300

Forwarding & Return Postage Guaranteed

Address Correction Requested

BULK RATE

POSTAGE & FEES PAID

EPA

PERMIT NO. G-35

LIST OF ACRONYMS 

C E R C L A Comprehensive Emergency

Response, Compensation, and

Liability A c t

D O D Department of Defense

D O E Department of Energy

E PA Environmental Protection

A g e n c y

E P C R A Emergency Planning and

Community Right-To - K n o w

Act of 1986 

F F C A Federal Facilities 

Compliance A c t

F F E O Federal Facilities 

Enforcement Office (EPA )

N A S A National Aeronautics and

Space A d m i n i s t r a t i o n

N P L National Priorities List

R C R A Resource Conservation and

Recovery A c t

S D WA Safe Drinking Water A c t

S E P Supplemental 

Environmental Project

T R I Toxics Release Inventory

U S D A U.S. Department of 

A g r i c u l t u r e

FIRST “AMERICA RECYCLES DAY” 

NOVEMBER 15, 1997

The first “America Recycles Day” — based on the highly successful “Texas Recycles

Day” held in recent years — is being organized by a group of private and public

organizations and government representatives. The goal of “America Recycles

Day” is to ask the American public to continue recycling and to purchase recycled

and recycled content products. A federal steering committee will support “America Recycles Day” activities at government facilities. For more information, contact

George Mohr at 410-965-4387.