.. ,.. .~ 

. I 

! United States Office of Enforcementand EPA300-N-95001A 

Environmental Protection Compliance Assurance April 1995 

Agency I53051 

.. ., 

ISSUE #1 an environmental bulletin for federal facilities 

*," TWO FEDERAL 

INSTALLATIONS CHOSEN AS 

cic , ENVIR0NMENTAL LEADERS 

EPA has announced the first selection 

of 12 pilot projects for the Agency's 

Environmental Leadership Program. 

Among the pilots are two federal installations that have volunteered to test the 

design of specific elements of the program. They are McClellan Air Force Base 

in Sacramento and the Puget Sound 

Naval Shipyard in Bremerton, Washing2 ton. Pilot participants receive public 

recognition as environmental leaders and 

the opportunity to inform and directly 

participate in EPRs effort to reassess its 

environmental auditing policy. 

3 Pollution Prevention Facility .: The Environmental Leadership 

Planning Guide Aims at .. Program is aimed at exploring ways that 

Meeting December Deadl&e , ; 

EPA and States might encourage indus­

::v trial and federal facilities to develop inno. 7 ,

'L' 4-5 Introducing FFEO and 'I ,.,);/ vative auditing and compliance programs 

FFRRO :

. 

i 

1

,: 1 and reduce the risk of non-compliance 

. . through pollution prevention practices. 

6 EPA Issues New A-106 I -;'$..' 1 Each pilot project will work toward 

Guidance , t achieving one or more of the following -i,.I key principles or goals: '. Encironmental management systems. 

the credibility of facility-generated 

data. 

Public accountability. EPA is committed to developing performance measures which are accurate and meaningful to the public, and which allow 

comparisons of one facility's performance with others. 

Community inuoluement. EPA is committed to "place-based" solutions to 

Continued on page 8 

BARRY BREEN 

Dear Reader: 

Welcome to the fust issue of FedFacs! 

Depending on how useful you and others 

tell us it is, we plan for FedFacs to be a 

regular update on our work and to offer 

you an avenue for sh&g progress on 

your own work. 

Elsewhere in these pages you willfind 

specific coverage of our work on a wide 

variety of projects. Those of you who 

know FFEO already realize this is a talented, high energy group. What's more, 

much of what we accomplish is in partnership with others. For example, EPA 

Regions and the National Enforcement 

Investigations Center deserve much of 

the credit for the Multi-Media 

Compliance and Enforcement Initiative. 

The Guidance on Accelerating CERCLA 

Environmental Restoration at Federal 

Conlrnued on page 9 

7 Log On, Sign Up, Join In! ., _i,! /.'.c ':I , 

9 Multi-Media Inspection , ,: . '8 

Initiative =el& Multiple ': 

Benefits . .:L 

4- > 

12 Calendar of Events '. .I . .. .T ,? .%",

-: ,. f ..*_ .. 

EPA is interested in encouraging 

facilities to adopt management systems that both prevent violations and 

assure continuous environmental 

impmvement. 

Multi-media compliance assumnce. 

EPA is interested in developing and 

sharing inspection protocols with 

industry which can be integrated into 

corporate environmental management systems. 

Third party certification. EPA w&ts 

to explore the use of an independent 

verification of compliance audits 

enhance mmpliance assurance and 
Federal Facilities Enforcement Actions under 

FFCA and RCRA, FY 1994: 

EPA state TOW 

Administrative 

Orders 10 30 40 

Proposed 

Penalties $5,722,978 $791,311 $6,514,289 

- Actions under CERCLA, FY 1994: 

Interagency Agreements 2 .' 

Stipulated Penalties Assessed $1,270,000 ,' ~, ' 

Proposed Supplemental 

Environmental Projects $2,150,000 

. CASE HIGHLIGHT9 .. 

US.Air Force, Myrtle Beach AFB,South ' '1 

Carolina, September 19,1994.Region 4 

issued a unilateral RCRA section 3008(h)cor- ' ~ 

rective action order following months of unsuc- '. ' 

cessful attempts to negotiate an order on con- .

':.' 

sent for timely cleanup of the closing base. 

Fort Dh New Jersey, July 15,1994.Region 

2 issued a Notice of Violation for a Clean Water 

Act violation for interim limitson biological 

oxygen demand. 

US.Coast Guard Kodiak Support Center, 

KO&& AL, July 14,1994.EPA Region 10 " sought $1,018,552 in penalties for two RCRA 

violations: failure to properly monitor ground- I 

water in an area where cleaning solvents had 

been dumped on the ground, and illegal storage 

of hazardous waste without a proper permit. 

U.S. Navy, Naval Construction Battalion 

Center (NCBC), Rhode Island, June 6, 

1994. Region 1settled a RCRA penalty order 

against the Navy. The Navy agreed to pay a 

penalty of $57,223 for violations including 

falure to provide training, failure to label hazardous waste containers, and failure to conduct 

weekly container inspections. 

STEVE HERMAN 

It is a pleasure for me 

to have 

been invited to provide the 

first guest 

column in 

this inaugural issue of FedFacs. I am 

encouraged by the increasing 

attention that many federal agencies are giving to environmental 

issues. I do not have to tell you 

that this has not always been the 

case. In many respects we are 

playing catchup and are paying 

for the sins - of omission and 

commission -of those who came 

before us. Today, however, we 

have no choice but to confront the 

legacy of past abuse and neglect of 

our environment. The public 

demands it, and our laws requiring federal cleanup and compliance with environmental standards reflect these demands. 

We have seen the federal environmental restoration and compliance budget increase to over 

$12 billion in FY 1995. And the 

greatest challenges are yet to 

come, as we move from studying 

sites to remediating them. Annual 

needs in the years ahead could go 

up to $16 billion per year. And 

these budget demands come at a 

time when downsizing, streamlining, and reinventing government 

have placed even greater 

demands on limited agency 

resources. 

In my past life, I had the honor 

of defending the President and 

the Secretary of Defense in legal 

disputes involving the deployment of the Mx missile system 

and the Navy's ELF submarine 

system. Now, I find myself in a 

somewhat different position. I 

was honored to have been chosen 

by President Clinton and 

Administrator Browner to be the 

EPA Assistant Administrator for 

Enforcement and Compliance 

Assurance. As 'such, my office is 

responsible for ensuring that our 

environmental laws are complied 

with hy the regulated community...and that includes the federal 

government. 

Now, what is EPA's perspective 

on all this? By enhancing EPA's 

enforcement authorities -most 

recently in the 1992 Federal 

Facility Compliance Act - Congress sought to ensure that 

EPA would provide an independent force to keep environmental 

compliance and cleanup a high 

federal government priority. The 

general public also lwks to EPA to 

play a distinct and independent 

role in federal facilities compliance. In various forums and meetings, citizens have repeatedly 

stressed to us that they expect 

EPA to act as an "honest broker" 

within the federal government, 

both to oversee other agencies' 

compliance actions and to take 

enforcement action when necessary. And we have been doing so. 

In the first two years of implementing the Federal Facility 

ComplianceAct, for example, EPA 

and the states have issued over 

100 administrative orders and 

assessed $12 million in penalties 

against federal facilities. 

Sometimes federal agency stalf 

are outraged or mystified at the 

nution of one federal agency fining 

or penalizing another federal 

agency. They ask 'Why are you 

Continued on pmge 3 
Facility Planning Guide Aims at 

Meeting December Deadline 

To help federal agencies meet the plan should define how the facility will 

requirements of a number of recent contribute to the agency's overall polluExecutive Orders, EPA's Federal tion prevention reduction goals. 

Facilities Enforcement Office has devel- The guide includes a review of releoped a Federal Facility Pollution vant Executive Orders and federal and 

Prevention Planning Guide. The guide state legislation; steps in the develop 

provides detailed,.step-by-step assistance ment of plans; guidance on public particin developing facility-specific pollution ipation, developing a measurement 

prevention plans. process; and lists of publications, prw 

Under E.O. 12856,each covered facili- grams, and contacts. 

ty must develop a written pollution pre- For-copies of the guide, see the ordervention plan by December 31,1995. The ing information on p. 11 below. 

- .. ~, . .. .. 

FEDERALFACILITY .,;.,,'. ' /. .. ~' . .. . ., ,. .. . .. . .. 

,... '. :. , ., 

POLLUTION PRRlENnON PLANNING WORKSH0P.S ..: ,. .. . . .' . ; 

,. ,I, .i ; 

,. :. 

i , . . . , . , . .. . . . .,, .. . , , . , . (. .~

~; 

FFEO is &okOling worl&hops at six different locations on how cility-specific pollution . . prevention plan. 

Small pup sessions-willoffer hands-on experience. . ...~ .. .. . . \ ., ., Date . . ' hation -.Co-Sponsor . I . 

March 21-22 New York, NY . . ,. ... '. ' USCG .. .. , . . April%-26 ;. . Gulfport;MS .' ' ~ I . 

. 3 '. I . NASA '. : ,' ' .. . . . . May 9-10 ... Lakewood, CO . . . "' .' ' , . . ,*., ',.' ' 3,. EPANETI , . ~' ..; . I , , ' 1 

May . . 1617 Alameda,.CA USCG' 

June 13-14 Potomac, MD . .~ , USPS ., 

June 2627 ' Norman, OK USPS 

7b obtain a registration form or more information, far a request to 202-260-9437 or call 703-821-4630. 

GUEST SPOT 

Continued fmm page 2 

lining us?" "Why are you embarrassing 

us?" "Why don't you just help us?" "Show 

us how to do it right." The simple, truthful answer is that the enforcement action 

and penalty are a deterrent tononcompliance. Congress has charged EPAwith the 

means to swing the "hammei' and we 

will continue to use it in appropriate circumstances. 

While our enforcement efforts pmvide 

il strong incentive for compliance, this is 

not the only set of responses being used 

by EPAfor achieving this goal. By provid­

. ing compliance assistance tools which 

promote pollution prevention. EPA is 

helping to build the capacity of federal 

facilities to move toward cleaner, cheaper 

and smarter methods of environmental 

management. 

One primary area we are targeting our 

compliance assurance efforts is pollution 

prevention, much of it related to implementation of the President's Pollution 

Prevention Executive Order (#12856). 

Appropriate federal implementation of 

E.O. 12856 is key to changing the central 

premise of environmental protection from 

treatment and disposal to pollution prevention. 

In closing, I would like to stress again 

that EPA's role in federal facilities 

cleanups and compliance is a unique and 

sometimes difficult one. On the one hand, 

we are committed to working with our 

sister agencies to address the enormous 

environmental challenges confronting 

the federal government. On the other, we 

are charged by law with being the federal 

government's principal environmental 

regulator and enforcer. Although EPRs 

role is sometimes misunderstwd, we 

intend to persevere because it is in all of 

our mutual interests to do so. I look forward to continue working with those of 

you in the federal sector and thank you 

for the opportunity to share my thoughts 

in FedFacs. 

Steven A. Herman is EPAs Assistant 

Administrator for Enforcement and 

Corndiance Assurance. 
NTRODUC NG ... FFEO, EPA's Federal 

Faci ities Enforcement Office 

FFEO is EPA's front-line office for - Developing, cwrdinating, and trackensuring that federal facilities take all ing federal facility compliance assurnecessary actions to prevent, control, and ance and assistance efforts; improv- ',' Federal 

Facilities abate environmental pollution. FFEO ing environmental management and Enforcement Compliance

participates in enforcement negotiations, auditing programs; and managing ' mce(EFEO) - oversees enforcement activities under- FFTS and other enforcement and B-Bmn, . , 

taken by the Regions, and is responsible compliance databases. , .Dimtor 

, Craig Hwks, for resolving enforcement disputes Prmnoting pollution prevention and 'AssociateDirectoi between EPA and other agencies. On environmental justice goals through (Acting)

nationally sigmiicant cases, FFEO coor- implementation of E.O. 12856 and 

dinates with the Regions on issuing com- other Executive Orders. 

pliance orders and agreements. Actions Managing the Federal Facilities against federal agencies include notices Multi-Media EnforcementJCompli- ... . 

of violation, IAGs, orders, and agree- ance Program, the "A-106" environSite Remediation 

;; 

.. 

and Enforcement ments under all relevant environmental mental management program that 

statutes. 

oversees federal agencies' environ- FFEO is divided into two groups: mental compliance budget requests. 

The Site Remediation and Facilitating the use of innovative 

Enforcement 

works with federal agencies and other 

offices in EPA (including FFRRO) to 

streamline enforcement and cleanup at 

prevention, compliance, and cleanup 

goals. 

Revention and 

Compliance sa 

Jim Edward, Director 

federal facilities. Specific SRES responsibilities include: 

Reviewing, coordinating and participating in the negotiation and implementation of CERCLA IAGs and MONTHLY ROUNDTABLE KEEPS 

Memoranda of Understanding. COMMUNICATIONS FLOWING 

Staff (SRES) primarily environmental technologies to attain 

Plarlnkz, ., 

Coordinating development of CER- FFEO's monthly roundtable meetings offer federal agency staff a.'steady. 

CLA enforcement policy with EPA stream of fresh information to keep them up-to-date with EPApolicy, exkting and' 

Regions through the Federal Facility pending standards and regulations, and the latest in envimnmentali research: .' 

Leadership Council. Fifty federal departments,and agencies' participate in the EPA/FederdAgen& 

Developing regulations, policies, guid- Environmental Roundtable. 

ance, and strategies for federal facili- The Roundtable also provides a forum for^ the exchange of information on polties enforcement under the Resource lution prevention and contml techniques as well as innovative cleanup technoloConservation and Recovery Act gies. Other topics include: information. needed to prepare the annual.federal­

(RCRA) and other environmental agency pollution abatement and prevention plans required by E.O. 12088, OMB 

statutes. Circular A-106, and OMB Circular A-11; the hazardous waste docket; technical 

information systems; and high profile topics,suchas the National Priorities Gst, 

and base closure.

The Planning, Prevention and The Roundtable was established under authority of Executive Order 12088;to- Compliance StatT(PPCS)is responsible fulfill the consultative and technical assistance mandate envisionedbetween EPA.

for initiatives to prevent noncompliance and other federal agencies. The Roundtable has heen in continuous operation atat federal facilities and overseeing com- EPAfor over 10 years. pliance and enforcement activities. Contact: Don Franklin, EPAFFEO, 202-260-5908.

Activities include: 

PAGE4 
and FFRRO, EPA's Federal 

Facilities Restoration & 

Reuse Office 

Assistant ' , '. , Jim Wmlford, ' . Administmtor ' , Director , ,

amothvFie1ds: . , 

Deputy;\sst. ' . . Administmtor ... I - Baseclosure 

Team 

Fed& . ' ' 

-, Facilities: ', . " 

Policy Team 

Stakeholder

- Enhancement ' 

EPA's Federal Facilities Restoration 

and Reuse Office is the primary office 

charged with responsibilities toward 

restoration and reuse of closing and 

decommissioned federal facilities. 

Military base closures, cleanup streamlining, and stakeholder involvement are 

the primary focus of the FFRROs efforts. 

Highlights of projects in these areas are 

described below. 

Military Base Closure. President 

Clinton's Five Point Plan to speed the 

economic recovery of communities 

where military bases are slated for 

closure is built on a partnership 

between EPA, DOD, and the States. 

The Fast Track Cleanup program 

focuses on cleanup efforts to facilitate 

reuse of closing bases. The program 

includes identifying clean parcels, 

accelerating cleanup, facilitating leasing agreements, encouraging removal 

actions, technical assistance at nonNPL bases, enhanced community 

involvement, and integration of 

cleanup with economic development. 

In conjunction with DOD and EPAs 

regional offices, the FFRRO develops 

long-range environmental policies, 

ph and programs to expedite the 

cleanup and transfer of closing militaryinstallations. 

Cleanup Streamlining. FFRRO 

has several projects underway to 

improve the cleanup process at federal facilities. Working with the goal of 

enhancing the cleanup process to 

restore sites and facilities to productive use, FFRRO has built strong 

partnerships with DOD and DOE to 

improve cleanup guidance, streamline oversight, and promote innovative technologies 

StakeholderInvolvement. FFRRO 

manages the Federal Facilities 

Environmental Restoration Dialogue 

Committee, which provides the 

Federal government advice on how to 

improve stakeholder involvement at 

federal facilities, priority setting, and 

management of the cleanup programs. In conjunction with FFEO, 

FFRRO provides major contributions 

to the national debate on Superfund 

Reform and efforts to improve,thefederal government's overall approach to 

environmental management. FFRRO 

has teamed with DOD and DOE as 

they build community advisory 

boards at their sites. FFRRO also 

works with states, local governments, 

Native American tribes and community representatives to ensure that 

social and economic factors are considered in cleanup priority-setting 

and decision-makingat federal facilities. 

EPA REGIONAL 

FEDERAL FACllrrv 

COORDINATORS 

FFC's are responsible for coordinating the implementation of FFEO 

policies and programs at the Regional 

level. Regional FFCs coordinate with 

EPA Regional media program statf to 

implement federal facilities enforcement programs; manage tracking, 

oversight, and compliance planning 

activities; coordinate and train federal facilities in developingenvhnmentAl management program plans; pm 

vide program as'siStance, training, 

and outreach forfederal facilities; and 

encourage pollution prevention at federal facilities. 

REGION 1 REGION6 

(CT,ME, MA, (AK LA, NM, 

MI, RI,W) OK, Tx) 

Anne Fenn, Joyce Stuhhl&eld, 

617-565-3927 214-665-6430 

REGION2 REGION7 

(NJ.Nu,PR,Vn (I& KS, MO,NE) 

Laurafi%+?Etan, Craig Berastein, 

212-6373494 913-551-7688 

REGION3 R"8 

(DE, DC,MD, KO, MT, ND, 

PA, VA,wv) SD,UT WY) 

Eric Ashton, Dianne Thiel, 

215597.9857 303-294-1059 

REGION4 REGION9 

(AL,FL, GA, KY, (Az,CA, HAw, 

MS, NC,SC, TN) her. Samoa, 

ArthurLinton, Guam, 'IT) 

404-341-3776 Sara Sed 

415-744-1483 

REGION5 

(IL. IN,MI, MN, REGION 10 

OH, WI) (AL,ID,OR,WA) 

Regner, David Tet@ 

312-353-6478 206-553-1327 
EPA ISSUES NEW 

A-I06 GUIDANCE 

Federal Agency Environmental 

Planning Process Revitalized 

An InteragencyAdvisory Committee 

formed by EPA to examine the OMB 

Circular A-106 pollution abatement and 

prevention planning process has completed its work and made recommendations for revitalizing the system. The 

committee included members from EPA, 

OMB, DOI, DOE, FAA, DOT, DOD, 

Army, Navy, Air Force, USMC, DLA, 

USACE, NASA, USDA, and Treasury 

The recommendations in the committee's final draft report (issued in August 

1994)proposed the largest changes in the 

A-106 process in the last 15 years. The 

committee recommended that EPA issue 

more detailed guidance on the A-106 system to other federal agencies, include 

pollution prevention project information 

in the system, change both the timing 

and type of EPA review of federal agency 

pollution abatement and prevention 

plans, and change the timing of the submission of the annual report to OME. 

Following up on these recommendations, Steve Herman, EPA Assistant 

Administrator for Enforcement and 

Compliance Assurance, authorized the 

distribution of new guidance to other federal agencies, entitled Federal Agency 

Environmental Management Program 

Number of buildings owned by the 

Federal Government: 

over 450,m 

Number of installations owned or 

operated hy the Federal 

Government: 

31SO 

- Number of acres in the United States 

owned or managed by the Feds: 

over 662million 

Planning, issued under authority of 

Executive Order 12088 and OMB 

Circular A-106. This new guidance outr 

lines the major procedures to be followed 

by all federal agencies in planning and 

budgeting for environmental compliance. 

The purpose of this planning process, 

now called FEDPLAN, is to ensure that 

federal agencies identify all environmental requirements and target adequate 

resources to address them. 

EPA's FFEO, which manages the 

FEDF" process, has developed a new 

PC-based management information 

database, called FEDPLAN-PC, that contains all federal agency environmental 

project information that supports the 

review process. FEDPLAN-PC will be 

fully implemented during this fiscal year. 

The database provides a powerful data 

analysis capability to regional media pm 

gram review personnel and regional 

Federal Facility Coordinators. EPA stafF 

will be able to perform relational analyses between the project level compliance 

and budget information contained in 

FEDPLAN-PC and the inspection and 

compliance information contained in the 

new ~~ Federal Facilitv Trackinn Y~ Svstem

coming on-line. 

Contact:Don Franhlin, EPA FFEO, 202-

260-5908. For a copy of the new A-106 

Guidance, far your request to Vicki 

Nelson at 202-260-9437. 

Number of federal facilities listed on 

the National Priorities List 

of hazardous waste sites: 

154final. 8pmposd 

Number of military installations 

scheduled to be closed that are 

listedon the NPL: 

23 

Source: LIS. EPA, Office of Enforcemenf. '"The 

SfateofFedem1 Facilities" (EPA 300-R-94-001, 

February 19941 

ENVIRONMENTAL 

JUSTICE PROJECTS 

Final environmentaljustice strategies are due to the President from all federal agencies on April 11,1995. FFEO is 

reviewing draft EJ strategies of other 

agencies pertinent to FFEOs mission, as 

required by Executive Order 12898. 

EPA's Office of Enforcement and 

Compliance Assurance .has developed a 

detailed series of workplans outlining EJ 

projeds underway Gd planned in OECA, 

which were presented to the National 

Environmental Justice Advisory 

Council's Enforcement and Compliance 

Subcommittee in January 1995. FFEO 

also is developing GIS (geographic information systems) Environmental Justice 

Profile reports for 25 federal facilities in 

all 10 EPA Regions which are due to be 

issued in April. 

For more information, contact Darlene 

Bcerlage, FFEO, 202-260-0413. 

BENCHMARK STUDY 

IDENTIFIES BEST IN 

CLASS BEHAVIORS 

Study Shows Civilian Federal 

Agencies Lagging Behind Priuate 

Sector Leaders and Defense 

Related Agencies 

A new studv released bv EPA's Officeof 

Enforcement and Comdiance Assurance 

evaluates the environmental management systems in place in 17 civilian federal agencies, 3 private corporations, and 

four defense-related agencies. The purpose of the study was to evaluate how private and government organizations perform against a benchmark considered to 

be stateof-the-art environmental management performance. 

The study comparedCFAresponses on 

a 1993 survey questionnaire to private 

sector and defense-related agency practices in six areas of evaluation: organizaContinued on page 7 
BENCHMARKSTUDY 

Continued from page 6 

tional structure; management commit 

ment; implementation of programs; information collection, use, and follow-up; 

internal and external communications; 

and personnel management. 

On most of the six areas and associated benchmark criteria, the civilian federal agencies lagged significantly behind 

industry leaders (Chevron, Xerox, and 

3M) as well as their counterparts in 

defense-related agencies (Departments of 

Energy, Army, Navy, and Air Force). For 

example: 

Only 5 of 17 CFAs report a management commitment to go beyond compliance with environmental requirements, in terms of resource allocation, 

training, and support; 

Only 3 CFAs report having well-publicized channels for employees to raise 

environmental concerns; 

Only 5 CFAs reported that facility 

managers have environmental compliance as part of their performance 

evaluations; 

While a majority of CFAs report that 

agency employees receive formal 

guidance on environmental require 

ments associated with their jobs, only 

5 CFAs report utilizing formal training programs for compliance staff. 

By contrast, the private and defenserelated respondents rated sigmfxantly 

better on all key indicators of “Best in 

Class” performance. 

An EPA-led interagency Civilian 

Federal Agency Task Force is scheduled 

to release a strategy for improving CFA 

environmental compliance within the 

next few months. Also smn to be released 

is a study of CFAenvironmental auditing 

issues by the U.S. General Accounting 

Office. 

To order a copy of EPKs Benchmark 

Report, see ordering information on p. 11. 

For more information, contact Richard 

Satterfield. FFEO, 202-260-9759. 

LOG ON, SIGN UP, 

JOIN IN! 

EPA Bulletin Boards Offer Full 

Spectrum Services for Federal 

Facilities 

EPA has joined the information revolution with electronic bulletin board systems (BBS)and databases to serve federal facilities’ environmental needs. 

Currently in operation is the FFLEX 

(Federal Facilities Environmental 

Leadership Exchange) system, which 

features information on pollution prevention and other innovative technologies, 

contacts, case study documents, Federal 

Register documents, training opportunities, laws, executive orders, regulations, 

and guidelines. 

Just waiting ha1 approval is the 

merger of FFLEX with Enviro$ense, a 

new full-service EPABBS just coming on 

lie in Spring 1995.Enviro$ense will mntain a series of directories exclusive to 

federal facilities. Included will be all of 

the FFLEX data, several on-line databases, and on-line access to other agencies’ 

BBSs and databases. Enviro$ense also 

includes information on: 

Recycling, controls and disposal 

Base closure and cleanup 

Alternate chemicals and solvents 

- Other federal and state agencies

Industry, universities, environmentalists 

ShowcaseYour Achievements! 

State, federal, and environmental organizations: You are invited to establish your 

own directories on Enviro$ense, at no 

cost to you! FFEO is aware that a BBS 

can only reach its full potential with a 

large amount of high-quality data and 

timely information. FFEO is mmmitted 

to providing a value-added service to help 

agencies comply with environmental regulations at the lowest possible cost. 

To widen the electronic information 

available to the federal community, 

HOW TO ACCESS FFLEX 

(Until June 19951 

Until June 1995, FFLEX is 

accessible only by modem (4 lines). 

Call 202-401-5930 and set your system to: 

Data Bits: 8 

Parity: None L

Stop Bits: 1 

Emulation: Vl-I00 or ANSIBBS . ” 

Speed 2,400-14,400 baud 

’ ,, 

HOW TO ACCESS 

ENVIRO$ENSE . . 

BeginningApril 15,1995, : 

Enviro$ense is accessible both by 

modem and via the World Wide 

Web on the Internet. 

By modem (28 lines): 

Call 703-908-2092 

Data Bits: 8 

Parity:None 

Stop Bits. 1 

Emulation: VT-100 or ANSI 

Speed 2,400-14,400 baud 

By Internet: (WorldWide Web) 

httpUwastenot.intel.gov/ 

envirosense 

I. 

FFEO invites you to showcaseyour organization’s successes and accomplishments. This can be done in several ways: 

either by starting your own directory and 

placing your information directly into it, 

or by uploading your data into one of the 

existing directories. 

Either way, FFEO staff will be happy 

to help you make the best possible use of 

BBS services to meet your needs. 

Contact Louis Paley at 202-260-4640or 

via the Internet at:paley.ly.louis~pamail. 

epa.gou. 
ENWRONMENTAL LEADERS 

Continued from page 1 

pollution problems, and to environmental justice for all communities 

regardless of race or income. 

Mentoring. Large corporations or 

agencies can help small ones understand and comply with envimnmental regulations and new technologies. 

The 12 projects selected were chosen 

from a pool of 40 projects submitted, 10 of 

which were federal facility applicants. 

the selection process was a cooperative 

effort of EPARegional Offices,State environmental agencies, and EPA OECA 

offices. 

For more information, contact Tai-Ming 

Chang, ELP Project Director; Tel: 202-

260-6777, Fax: 202-260-8511; or Lmis 

Paley at 202-260-4640. 

PUGET SOUND NAVAL 

SHIPYARD 

The Puget Sound Naval Shipyard 

in Bremerton, Washington employs 

about 18,000 military and civilian personnel. The facilitfs proposal is to conduct a pilot project that goes a step 

beyond compliance audits by conducting pollution prevention opportunity 

assessments through a partnership 

with EPA and the Washington State 

Department of Ecology The assess: 

ments will be directed at idenhfymg 

and improving regulations whose 

unanticipated consequence is to harm 

human health or the environment. A 

model program will be outlined on 

computer disk that will encourage 

other facilities to operate beyond compliance in a similar fashion. 

LEADERS INACTION 

McClellan Air Force Base 

Located on 3700 acres in 

Sacramento, California, the 

15,500 employees of 

McClellan AFB are involved 

in depot maintenance and 40 

associated units. McClellan 

has shown its leadership in 

pollution prevention with 

TheF-22Aduanrrd %tical Fighterifor the Over 150 projects 

underway, managed through first time,engineers and designers am working 

together to build and maintain amaircmfl a computeri=d tracking SYS- without using hazardous materials, tern. McClellan’s other track- - .. ing systems provide daily accounting of the disposition of hazardous materials:;’:, 

and track hazardous waste containers from the time they are issued for use until.,: 

they are turned in for disposal. Sice 1985, McClellanhas reduced its hazardous 

waste by 78 percent; an additional 14%reduction is planned by 1996. .. 

, 

Approximately 40% of Puget 

Sound Shipyards current 

workload inuolues bll ship 

recycling. Here, the sails of 

seueml submarines are being 

readied for recycling in dry 

dock aper removal from 

their submarine hulls. 

USINGEPA’s FEDERALFACILITIES 

COMING UP r-7C.?,/T,,T, TRACKING IN THE NEXT :_=L,,&,. .:- SYSTEM 

ISSUE OF : ,.:L 

,..? r 

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ENVIRONMENTALAUDITPROTOCOL 

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Multi-Med a Inspection Initiative 

Yields Multiple Benefits 

With 41 multi-media inspections of 

federal facilities under its belt, the F&d 

Facilities Multi-Media Enforcement/ 

Compliance Initia- , 

snapshot of the status of federal facilities and prospects for 

multi-media inspections in the future. 

Analysis indicates 

that EPA and state 

utilization of multimedia inspections 

can he effective, 

regardless - of the size

of the federal facility 

or its operating 

and CWA. agency. 

Established in FY 

1993, the initiative was designed to 

assess compliance of federal facilities 

with environmental laws, using multimedia inspections and enforcement to 

address areas of non-compliance. 

Coordinated team inspections were conducted by all ten EPA Regional Offices, in 

with state officials.Federal fadities were selected based on their compliace records and potential risk. Most of 

the facilities selected were DOD facilities 

(33 out of 41); the remainder were DOE 

installations (21, USDA facilities (21, and 

DIRECTOR’S WORD 

Continuedfroqpmge I 

Facilities was a joint project with DOD, 

DOE, key EPA Regions, and the Office of 

Solid Waste and Emergency Responsgs 

Federal Facilities Restoration and Reuse 

Office. Implementing President Clinton’s 

pollution prevention executive order is a 

joint effort with the Office of Prevention, 

Pesticides and Toxic Substances’ 

Environmental Assistance Division. 

Indeed, this last project has participation 

fmm over a dozen other agencies besides 

EPA. To our partners, thank you. I expect 

facilities operated by DOT, DOJ, NASA, 

and DO1 (1 each). Pollution Prevention 

Opportunity Profiles were prepared for 

all targeted facilities. These profiles 

were used by 

EPAlstate teams 

during the process 

and provided to the 

inspected facilities. 

Pollution. Prevention Opportunity 

Profiles were prepared for all targeted facilities. These 

profiles were used 

by EPAistate teams 

during the process 

and provided to the 

inspected facilities. 

RESULTS 

firstyear ofthe initiative 

were as follows: 

Just over half of the facilities inspeded violated more than one statute. 

EPA and the States together issued 

75 enforcement actions at 31 facilities. The actions ranged from warning 

letters (15)to formaladministrative 

orders (18)with proposed penalties of 

SZ1 million. 

we’ll be approaching you again swn. 

These and other specific efforts grow 

out of the mission the President has laid 

out for us: help other agencies “ensure 

their cost effective and timely compliance” in meeting “the same substantive, 

procedural, and other requirements that 

would apply to a private person,” through 

technical advice and assistance, reviews 

and inspections, review of proposed hudgets, ,and,sometimes, direct enforcement. 

Longtime friends of our program will 

see that the specific tools we use have 

evolved over the years. But one theme 

The average time to issue an enforcement action ranged from 2 weeks for 

a field citation to 14 months for a 

Federal Facility Compliance 

Agreement. 

Of, the facilities inspected, 24% 

received no formal enforcement 

action. 

Regional Offices pakcipating in the 

initiative reported-goodcoordination with 

state officials and a strengthening of 

EPA-state working relationships. 

Facilities involved were considered professional and cooperative in the inspection, even in cases where the “facilities 

initially responded with shock to the 

arrival of inspection teams!” Despite 

some difficultieswithallocating resources 

and coordinating schedules, the Regions 

found that multi-media inspecting provided multiple benefits, including the 

desired comprehensive review of a facility’s environmental compliance status, 

and the attention of top-level managers to 

the facility’s compliance. 

For a copy of the interim report, “Federal 

Facilities Multi-Media Enforcement I 

Compliance Znitiatiue,”see p. 12. For 

more information, contact Jim Edward 

1202-260-8859)or Reggie Cheatham 

1202-260-4641). 

remains constant We help the government earn the trust of its citizens by living up to its environmental promises. As 

you will read in the column from 

Assistant Administrator Steve Herman, 

our efforts parallel EPAs larger themes. 

For me, there is special meaning in applying these themes to the federal government itself. 

Barry Breen, Director: FFEO 

PAGE 9 M&Y&* 
Federal Agency

HazWaste 

CompIiance 

Docket 

Section 120(c)of CERCLA, as amended by SARA, requires EPA to establish a 

Federal Agency Hazardous Waste 

Compliance Docket. The purpose of the 

docket is toidentify federal facilities that 

manage hazardous waste or from which 

hazardous substances may he or have 

heen released. The docket is updated 

with new information every six months. 

Agencies are notified that one or more of 

their facilities has heen considered for 

inclusion on the docket, and upon venfication by the federal agencies, the facilities are listed in the Federal Register. 

The first docket published in 1988,listed 

840 facilities. The latest update, puhlished in the Federal Register as Updak 

#9, lists 2,070 facilities. 

For more information, contact Augusta 

Wls, 202-260-2686. 

EPA and Army Agree on 

Pollution Prevention Technical 

Assistance Project 

Following months of negotiations 

EPA's FFEO and the Army have reached 

agreement on establishing a pollution 

prevention technical assistance pilot pro 

ject. The Memorandum of Agreement 

was signed by EPA Assistant 

Administrator Steven A. Herman and 

Army Under Secretary Joe R. Reeder in 

March 1995. 

The Agreement sets up a partnership 

effortunder which EPA and the Army will 

conduct pollution prevention assessments 

at three Army installations: Rock Island 

Arsenal, IL; Fort Benning, GA; and 

White Sands Proving Ground, NM. 

EPNs Risk Reduction Engineering 

Laboratory in Cincinnati will fund and 

conduct a pollution prevention opportunity assessment at each facility, to include 

an on-site visit, consultation with Army 

personnel, and a written report which 

will be made public. The report will contain a range of pollution prevention 

options and recommendations, to which 

the Army has agreed to respond within 

four months of receipt of the assessment. 

DraR pollution prevention assessments 

will be completed by June 1,1995so that 

the Army can use them in preparing pollution prevention plans for these installations (as required by Executive Order 

12856). 

The Army has agreed to share the 

results of the pollution prevention opportunity assessmems with other similar 

Army installations as applicahle. In addition, the Office of the Deputy Assistant 

Secretary of the Army (Environment, 

Safety, Occupational Health) will review 

this pilot program, including the assessments and the installations' responses, 

and will comment on the appropriateness 

of adopting any of the assessment procedures and recommendations Army-wide. 

The review document will he made available to the public. 

For more information, contact: Bill 

Frank, 202-260-5074or Reggie 

Cheatham, 202-260-4641. 

New Audit Protocol 

Goes Online 

A newly-released Generic Protocol for Conducting 

Environmental Audits of Federal Facilities is available online on 

Enviro$ense (see p. 7 for access information) for use hy federal 

agencies.Prepared as a collaborative effortby the member agencies of the Federal Audit Protocol Workgroup for the Federal 

Community (EPA,DOE, DOD, USPS, NASA, DOL USDA, and 

FAA), the protocol is meant to assist in the conduct of environmental audits and environmental management assessments. 

Because of its size -920 pages! -the protocol is being made 

available to federal agency staffon computer diskette and via 

NTIS, as well as online. Federal agencies are encouragedto LWStomize the protocol to their own needs before issuing it to auditors. 

- For more information. contact Richard Satterfield, 202.26'0-

9759. The next issue of FedFacs will have a detailed article 

about the content,yand uses nf'theauditprotocol. 

Six Committees Set Up 

to Promote E.O. 12856 

EPA's Office of Enforcement and Compliance Assurance and 

Office of Prevention, Pesticides and Toxic Substances are cochairing an Interagency Pollution Prevention Task Force. The 

Task Force has just established six committees to help the 

Federal Government comply with the Executive Order 12856 

(TRIreporting & P2 compliance) requirements, and foster inn* 

vative technological P2 solutions. The six committees are: 

P2 Language for Federal Acquisition Regulations; 

P2 R&D and Technology Diffusion; 

Information Transfer and Technical Assistance; 

* Standardized Material Safety Data Sheet Reporting; 

Outreach and Publicity for the Federal Government 

Executive Order and P2 Progress; and 

Substitute Chemicals and Alternative Processes. 

Contact: Louis R. Poley, 202-260-4640or via Internet at: 

paley.louis~paniai1.epa.gou. 

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To Read FedFacs Electronically: 

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To Receive FedFaa in the Mail or to Order Documents 

Mentioned in the Newsletter: 

Q Please include me on the FedFacs mailing list (no charge) 

0 Please send one copy of the following documents (no charge): 

0 “Federal Facilities Multi-Media EnforcemenffCompliance 

Initiative” (EPA 300-R-94-007,November 1994). 

“Federal Facility Pollution Prevenih Planning Guide” 

(EPA 300-B-94-012,November 1994) 

0 “FederalAgency EnvironmentalManagement Program 

Planning Guidance” (EPA 300-B-95-001,October 1994) 

0 ”EnvironmentalManagement System Benchmark Report” 

(EPA 300-R-94-009, December 1994). 

Complete the following: 

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Organuahon 

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or Fax this page to: 202-260-9437 

is puhlished by EPA’s Federal Facilities Enforcement Office 

Jim Edward, Joyce Johnson, Editors 

Gilah Langner, Writer 

Paine Bluett Paine, Design 

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CAA CleanAirAct ’ 

CERCLA CompreheFive Emergency 

Response, Compensation, 

and Liability Act 

CFA Civilian Federal Agency :” 

CWA Clean Water Act 

DLA . Defense Logistics Agency 

DOD Department of Defense a 

DOE DepartmentafEnergy , . 

DO1 .’ Department of the Interior ’’ 

DOT Department of 

Transportation 

EJ Environmental Justice 

EO Executive Order 

EPA Environmental Protection’ 

Agency .. . 

FAA FederalAviation ’ . ’ . 

’, Administration ,. . 

FFC . . FederalFacility ~ .. 

,. Coordinator , . FFCA Federal Facilities . . ComplianceAct ,. 

FFEO ’ FederalFacilities ’ ’ ’ 

.’ Enforcement Office(EPA). 

FFLEX Federal Facilities ., 

Environmental Leadership , . 

.‘I. Exchange 

FFRRO Federal Facilities 

.’ RestorationandReuse . , . 

ORce (EPA)’ . 

IAG ’ InteragencyAgreement 

NASA National Aeronautics and 

SpaceAdministration 

NET1. National Enforcement 

Training Institute (EPA) 

NPL National Priorities List 

OECA Office of Enforcement and 

ComplianceAssurance 

(EPAI 

OMB ‘Officeof Management and 

Budget 

P2 Pollution Prevention 

RCRA Resource Conservation and 

Recovery Act 

TSCA ‘ToxicSubstances Control 

Act 

USMC U.S. Marine Corps 

USACE U.S. Army Corps of 

Eugineers 

USCG US.Coast Guard 

USDA U.S. Department of 

Agnculture 

USPS U.S. Postal Service 
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