NCD980602163_19970601_Warren County PCB Landfill_SERB C_Federal Facilities Environmental Justice Enforcement Initiative - An Anlysis of Toxic Release Inventory Reporters-OCR

&EPA
United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance
Federal Facilities
EPA 315-R-97-001
June 1997
Environmental Justice Enforcement
Initiative
(FFEJEI): An Analysis of Toxic Release Inventory
(TRI) Reporters
JUNE 1997
Internet Address (URL)• http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (20% Postconsumer)
ACKNOWLEDGMENTS
The Federal Facilities Enforcement Office (FFEO) gratefully acknowledges the many
offices and individuals who provided the support necessary to undertake this initiative and
complete this document. FFEO would like to thank the Office of Environmental Justice (OEJ),
the American Indian Environmental Office (AIEO), the Regional Federal Facility Coordinators,
and the Regional Environmental Justice Coordinators. Specifically, FFEO would like to thank
Dr. Steven M. Hassur and Dr. Nicholaas Bouwes, Sr., of the office of the Economics, Exposure,
and Technology Division of the Office of Pollution Prevention and Toxics (OPPT) for their
invaluable assistance with the TRI Indicator model, Dr. Clarice Gaylord and Lyndell Canty of
OEJ, and Catherine Fox of the Targeting and Data Divison of OECA. Thank you to Kevin Petrik
of Abt Associates for production of the Arc View GIS Maps. This report was prepared under
contract number 3002-101 by Alexis Hunter and John Smegal of Sci Comm, Inc., and Jeff
Gunnulfsen, formerly with SciComm, Inc. The project manager on this effort is Darlene
Boerlage, FFEO.
For more information or to provide comments on this document, please contact:
Darlene Boerlage
U.S. Environmental Protection Agency
Office of Enforcement and Compliance Assurance
Federal Facilities Enforcement Office
401 M Street, S.W.
MC-2261A
Washington, DC 20460
[phone]
[e-mail]
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EXECUTIVE SUMMARY
This report discusses the preliminary results of the Federal Facilities Environmental Justice
Enforcement Initiative (FFEJEI). It is intended to provide EPA Headquarters, EPA Regional
offices, and other Federal agencies with an overview of the initiative and to identify Federal
facilities that are potential environmental justice sites which may have significant environmental
issues present. In August of 1996, the Federal Facilities Enforcement Office (FFEO) initiated the
FFEJEI. FFEJEI is intended to increase enforcement targeting efforts at Federal facilities, and to
place emphasis on enforcement efforts in possible environmental justice communities. The
National Environmental Justice Advisory Council (NEJAC) Enforcement Subcommittee, which
was established to provide recommendations on how the Office of Enforcement and Compliance
Assurance (OECA) might integrate environmental justice into its programs, policies, and
activities, recommended that FFEO conduct a targeted enforcement effort at Federal facilities.
The goal of FFEJEI is to assist the Regions in identifying Federal facilities that may pose
environmental justice concerns to low income and minority communities surrounding the facilities.
This initiative employs several screens for evaluating the Toxic Release Inventory (TRI)
data. TRI data from 1994 was used as the baseline for evaluation for this initiative. In 1994, the
first year of reporting required by Federal agencies, 191 Federal facilities reported releases and
transfers of toxic chemicals under TRI. A series of data screens were used to filter sites based on
compliance, health, and demographic information. The first screen used on the 191 facilities was
a TRI Relative Risk-Based Chronic Health Indicator model. The second screen employed several
enforcement databases to evaluate the compliance records of the facilities. In addition, FFEO
relied on both community reports of environmental justice concerns and geographic distribution to
identify facilities posing potential environmental justice concerns. Lastly, Geographic Information
System (GIS) maps were generated for the 44 sites from these screens to illustrate the low income
and/or minority communities surrounding the facilities. FFEJEI can be used as a tool for planning
and targeting inspections and related enforcement activities at Federal facilities.
FFEJEI IDGHLIGHTS
• 44 facilities were identified as potential environmental justice sites.
•
•
•
•
The majority of the 44 facilities are located in Regions 4, 6, and 9 .
Of the 44 sites:
Compliance data:
77% are DoD
18% are DOE
5% are CFA.
12 sites have recent violations
13 are in Significant Noncompliance
17 are NPL sites.
Regions 3, 4, and 9 have the most TRI reporting sites .
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AIEO
AO
ARCVIEW
CAA
CFA
DoD
DOE
EJ
EO
EPA
EPCRA
FFC
FFEO
FIFRA
FFEJEI
FFERDC
FFfS
GIS
IDEA
NEJAC
NOV
NPDES
NPL
OECA
OPPT
POTW
P2
RCRA
SNC
TRI
TSCA
Federal Facilities Environmental Justice Enforcement Initiative
LIST of ACRONYMS and ABBREVIATIONS
American Indian Environmental Office
Administrative Order
A GIS mapping software
Clean Air Act
Civilian Federal Agency
Department of Defense
Department of Energy
Environmental Justice
Executive Order
Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act
Federal Facility Coordinator
Federal Facilities Enforcement Office
Federal Insecticide, Fungicide, and Rodenticide Act
Federal Facilities Environmental Justice Enforcement Initiative
Federal Facilities Environmental Restoration Dialogue Committee
Federal Facilities Tracking System
Geographic Information Systems
Integrated Data for Enforcement Analysis System
National Environmental Justice Advisory Council
Notice of Violation
National Pollution Discharge Elimination System
National Priority List
Office of Enforcement and Compliance Assurance
Office of Pollution Prevention and Toxics
Publicly Owned Treatment Works
Pollution Prevention
Resource Conservation and Recovery Act
Significant Noncompliance
Toxic Release Inventory
Toxic Substance Control Act
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TABLE OF CONTENTS
ACKNOWLEDGMENTS
EXECUTIVE SUMMARY ................................................ Page i
LIST OF ACRONYMS AND ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page ii
1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 1
A. Federal Facilities Environmental Justice Enforcement Initiative . . . . . . . . . Page 2
2. METHODOLOGY AND SOURCES OF DAT A . . . . . . . . . . . . . . . . . . . . . . . . . Page 3
A. Data Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 3
B. Methodology Overview ...................................... Page 3
C. TRI Facility Baseline List . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 3
D. Relative Health Risks ........................................ Page 4
E. Compliance History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 5
F. Community Based and Other Reports of Environmental Justice Concerns . Page 5
G. Geographic Distribution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 6
H. Demographics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 6
I. Exhibit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 7
3. PRELIMINARY RESULTS OF THE INITIATIVE ...................... Page 9
A. Analysis of Federal Facilities with TRI Releases . . . . . . . . . . . . . . . . . . . . Page 9
B. Analysis of Top 100 Sites ..................................... Page 9
C. Analysis of 44 Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 9
D. Statistical Charts Illustrating the Results . . . . . . . . . . . . . . . . . . . . . . . . Page 11
4. CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21
5. APPENDIX ................................................... Page 23
A. Prioritization of Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23
B. Example of Prioritization: U.S. DOE Savannah River Site . . . . . . . . . . . Page 24
C. Distribution Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 28
Site Listings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 29
GIS Map Categorization Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 30
44 GIS Maps ........................................... Page 32-75
D. Definition of Significant Noncompliance . . . . . . . . . . . . . . . . . . . . . . . . . Page 76
E. Regional Environmental Justice Contacts . . . . . . . . . . . . . . . . . . . . . . . . Page 78
F. Regional Federal Facility Coordinators . . . . . . . . . . . . . . . . . . . . . . . . . . Page 79
G. Regional TRI Contacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 80
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I: INTRODUCTION
Environmental justice is the equal and fair environmental protection of all people
regardless of race, ethnicity, religion, class, and economic status.
Traditionally, government agencies have set broad standards for hazardous pollutants and
assumed that all people would be equally protected by these standards. Recent studies indicate
however, that minority and low-income populations may face a disproportionate share of
environmental problems and higher levels of contamination of their air, water, and land.
The Clinton Administration mandated that the Environmental Protection Agency (EPA)
and other Federal agencies implement changes to ensure equal and fair environmental protection
for all people. These mandates call for changes with respect to the development, implementation,
and enforcement of all environmental policies.
Executive Order (E.O.) 12898 "Federal Actions to Address Environmental Justice in
Minority Populations and Low-Income Populations," was issued on February 11, 1994. The
Executive Order has greatly impacted the integration of environmental justice into the policy,
programs, and activities of Federal agencies. It requires Federal agencies to identify and address
situations where minority and low income populations are disproportionately affected by
environmental impacts, as well as to direct Federal agencies in developing environmental justice
strategies.
Federal agencies, like private entities, are required to comply with all Federal, State, and
local environmental regulations. E.O. 12898 specifically states that Federal agencies are
responsible for developing an environmental justice strategy that describes steps they will take to
meet these goals. An agency's environmental justice strategy should include revisions to their
environmental programs, policies, planning processes, enforcement strategies, and rulemakings.
The National Environmental Justice Advisory Council (NEJAC) was established to
provide public policy advice and recommendations to EPA for improving the implementation
of EPA' s environmental justice programs and initiatives. Specific NEJAC duties include
providing guidance on identifying environmental justice issues, stimulating cooperation
between agencies, coordinating research and data collection efforts, examining existing data
and studies on environmental justice, and maintaining a structure and schedule for agencies to
implement their environmental justice strategy.
EPA's Federal Facilities Enforcement Office (FFEO), as part of the Office of Enforcement
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Federal Facilities Environmental Justice Enforcement Initiative
and Compliance Assurance (OECA), oversees Federal facility compliance with requirements
related to environmental justice under E.O. 12898, pollution prevention standards under E.O.
12856, "Federal Compliance with Right-to-Know Laws and Pollution Prevention Requirements,"
and the requirements of other Executive Orders. In addition, FFEO is responsible for assisting
Federal facilities in developing and improving their compliance programs. FFEO has developed
several initiatives to assist Federal facilities in addressing environmental justice concerns. For
example, FFEO has prepared a Pollution Prevention (P2) Planning Guide, an Agency-Wide P2
Strategy, and a Multi-Media Guidance to assist EPA's Federal Facility Coordinators (FFCs) in
addressing multi-media compliance issues at Federal facilities. FFEO also has conducted 25
Environmental Justice Geographic Information System (GIS) Profiles of defense and civilian
Federal facilities covered under the Pollution Prevention Executive Order.
I. A Federal Facilities Environmental Justice Enforcement Initiative
In August of 1996, FFEO initiated the Federal Facilities Environmental Justice
Enforcement Initiative (FFEJEI). FFEJEI is intended to augment inspection and enforcement
targeting efforts at Federal facilities, and to place emphasis on enforcement efforts in
environmental justice communities. The NEJAC Enforcement Subcommittee, which was
established to provide recommendations on how OECA might integrate environmental justice into
its programs, policies, and activities, recommended that FFEO conduct such an effort. FFEO
believes the FFEJEI is one tool to help identify Federal facilities that may have enforcement and
compliance concerns. The goal of FFEJEI is to assist the Regions in identifying Federal facilities
that may pose environmental justice concerns to low income and minority communities
surrounding the facilities.
This report discusses the preliminary results of FFEJEI. It is intended to provide EPA
Headquarters, EPA regional offices, and other Federal agencies with an overview of the initiative
and to identify Federal facilities which may be potential environmental justice sites and may have
environmental issues present. The data provided in this report were compiled from various
Federal sources, such as the 1994 Toxic Release Inventory (TRI) Data Report, Federal Facilities
Tracking System (FFfS), Regional Environmental Justice (EJ) Coordinators and Federal Facility
Coordinators, the Office of Environmental Justice (OEJ), the American Indian Environmental
Office (AIEO), NEJAC reports, the Federal Facilities Environmental Restoration Dialogue
Committee (FFERDC), and several EPA hotlines.
The remainder of this report is divided into four sections, and an appendix. Section II of
this report discusses the methodology used to identify potential sites, and describes how the data
were categorized and compiled. Section III summarizes the results of the initiative. Section IV
contains concluding remarks and also includes recommended uses for FFEJEI. The appendix
contains the forty-four GIS maps of the Federal facilities targeted as potential environmental
justice sites, and also identifies regional EJ Coordinators, FFCs, and TRI contacts. The appendix
also contains a discussion of one of the site maps and a description of the features of the map.
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II: METHODOLOGY AND SOURCES OF DATA
II. A. Data Sources
The data contained in this report were compiled from a variety of sources: EPA databases,
Census Bureau data, community reporting, EPA hotlines, and NEJAC reports. These sources
were used to generate Federal facility compliance and enforcement data, identify the potential
health risks posed by Federal facilities, and determine the demographics of communities located in
the vicinity of the facilities discussed in this report.
FFTS contains multi-media Federal facility compliance and enforcement information
which FFEO used to identify facilities meeting the compliance criteria of FFEJEI (see Section
11.D. below). FFEO also reviewed the National Priorities List (NPL) and the quarterly
significant noncompliance (SNC) report to identify Federal facilities listed as NPL sites and/or in
SNC. The TRI Relative Risk-Based Chronic Human Health Indicator model developed in the
Office of Prevention, Pesticides and Toxics (OPPT) allowed FFEO to measure the relative health
risks associated with releases at Federal facilities.
To further identify facilities with potential environmental justice concerns, FFEO looked
to community reporting and information gathered from EPA hotlines, NEJAC reports, the
FFERDC, EJ Coordinators and FFCs. In addition, FFEO asked OEJ and AIEO to verify the
existence of any targeting initiatives or mapping of geographic areas of environmental concern.
Lastly, FFEO employed 1990 Census Bureau data which was used in combination with
ARCVIEW, a GIS mapping program, to evaluate the demographics of communities located in
the vicinity of the Federal facilities.
II. B. Methodology Overview
FFEO employed the following four criteria to assist in narrowing the scope of FFEJEI:
compliance history; relative health risks; community based and other reporting of environmental
justice concerns; and geographic distribution. FFEO researched and analyzed each of the criteria
and then used them to determine which sites posed potential environmental justice concerns.
Based on these four criteria, FFEO identified 44 facilities which may pose such concerns. FFEO
then generated GIS maps displaying the demographics of the community surrounding each site.
II. C. TRI Facility Baseline List
Before examining Federal facility compliance data FFEO needed to decide upon the
baseline of Federal facilities that would be used as the starting point for this initiative. The Toxic
Release Inventory was chosen as a starting point because it is community based, has known
transfers and releases of toxic chemicals, and is publicly available information. The 1994 TRI
Data Report of 191 Federal facilities with known releases of toxic chemicals was used as a
baseline. This list served as the universe of Federal facilities which FFEO based its subsequent
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analysis.
TRI reporting by Federal facilities was mandated under Executive Order 12856, signed by
President Clinton in August 1993. The latest report, published in June 1996, covers the 1994
reporting year, which was the first year of required reporting for Federal facilities. The goal of
the TRI reporting requirement is to ensure that the public has access to the most comprehensive
information possible on releases and transfers of toxic chemicals, to hold Federal facilities
accountable for their activities, and to encourage them in reducing their use of toxic chemicals at
the source.
II. D. Relative Health Risks
The first criterion used to identify potential environmental justice sites was the relative
health risks posed by a facility to populations in the immediate vicinity of the site. FFEO
employed the TRI Indicator Model, developed in OPPT, to measure these relative health risks.
The model used TRI reporting data for the calender year 1994.
The TRI Indicator Model tallies the
number of indicator "hits" for each facility. A
facility would be assigned an indicator "hit" if
the chemicals released were high in toxicity
and were released in sufficient amounts to pose
a threat to the surrounding community based
For 1994, 191 Federal facilities operated by
12 Federal agencies and located in 43 states
reported to EPA under TRI.
upon exposure pathways and medium of potential exposure.
exposures to the population beyond the facility fence line.
The TRI Indicator model addresses
Limitation of TRI Data
The total amount of TRI emissions reported by Federal facilities during 1994 was
approximately 10.1 million pounds. The total amount of off-site transfers reported by Federal
facilities was approximately 10.2 million pounds (excluding POTW transfers). However, the
TRI Indicator Model does not evaluate underground injection (approximately 500,000
pounds) or most on-site landfilling since such wastes are often sent to hazardous waste
landfills (approximately 1 million pounds). There also are a number of chemicals with
significant air releases which were not modeled because they have no assigned toxicity weight.
EPA first ranked all TRI Federal facilities based on the quantity of chemicals released. A
second ranking using the full model revealed there were considerable differences between the
simple quantity released ranking and the more sophisticated relative-risk based ranking. EPA
elected to use the full model to identify the top 100 facilities, then used the model to rank these
from one to one hundred. EPA analyzed the top twenty Federal facilities ranked by relative risk-
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based impacts to examine impacts on the five environmental media for this group (fugitive air,
stack air, direct water, landfill, and a publicly owned treatment work (POTW) transfer). Based on
its review, the Agency determined that on-site stack air releases have the most significant impact
on relative risk; although fugitive air and direct water releases also contribute to relative risk.
II. E. Compliance History
FFEO used compliance and enforcement information as the
second criterion to identify Federal facilities posing potential
environmental justice concerns. FFEO examined the following
factors: 1) whether a facility has been inspected in the last two years,
2) facilities where EPA or State enforcement actions are taking
place, and 3) whether a facility is a National Priority List (NPL) site
or in Significant Noncompliance (SNC). NPL sites were chosen
because of past practices and known contamination.
FFEO compared the 191 Federal facilities against the most
recent version of the 1996 NPL and the 3rd Quarter FY 1996 SNC
Report. Facilities in SNC are those having a violation of significant
magnitude and/or duration that warrants priority for review and/or
response by an agency. SNC applies to Federal facilities regulated
under the Resource Conservation and Recovery Act (RCRA), the
National Pollutant Discharge Elimination System (NPDES), Clean
Air Act (CAA), Toxic Substances Control Act (TSCA), Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA), and the
Emergency Planning and Community Right-to-Know Act (EPCRA).
Formal Enforcement
Actions:
• Notice of
Violations
(NOVs)
• State & Federal
•
•
Administrative
Orders (AOs)
Noncompliance
Penalty
Assessments
EPA Refe"al
Notices to States
Facilities in SNC are identified on the basis of certain data fields within the IDEA system. The
precise nature of these fields varies across statutes. (See appendix for listing of the SNC fields.)
II. F. Community Based and Other Reports of Environmental Justice Concerns
As the third criterion, FFEO used community reports and information gathered from EPA
hotlines, NEJAC reports and meetings, public meetings, FFERDC, several EPA offices, the
regional EJ Coordinators and FFCs. Federal facilities previously identified as environmental
justice areas of concern through community reporting efforts or information gathered from these
other sources were automatically selected for targeting by FFEJEI.
Federal facilities previously identified as environmental justice areas of concern
include: 1) U.S. Army Pine Bluff Arsenal, Jefferson County, Arkansas, 2) U.S. Navy
Pensacola, Escambia County, Florida, 3) U.S. DOE Sandia National Lab, Bernalillo County,
New Mexico, 4) U.S . DOE Savannah River Site, Aiken County, South Carolina, and 5) Kelly
Air Force Base Force Base, Bexar County, Texas.
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II. G. Geographic Distribution
The fourth criterion used to identify potential environmental justice sites was geographic
distribution. FFEO wanted to have at least one site represented in each of the 10 EPA regions.
Since no sites met the FFEJEI criteria in Region 1, the Defense Logistics Agency (DLA) facility
located in Portsmouth, Rhode Island was included in the initiative. Bolling Air Force Base in
Washington, DC was selected as a representative site in our Nations Capital.
II. H. Demographics
FFEO used the information derived from the evaluation criteria to identify the 44 sites
targeted under FFEJEI. For further analysis, FFEO then conducted a search on these sites to
evaluate the demographics of the population surrounding each site, generate GIS maps, and
ultimately determine whether these sites are likely to be environmental justice areas.
The demographic information was collected from 1990 Census Bureau data.
Demographic data are generally collected and organized by specific geographic regions, termed
census tracts. A geographic region is defined as a compilation of zip codes and counties
surrounding a site. The zip code is a common geographic factor used to identify the relationship
between the locations and demographics of a local population. For this initiative, FFEO identified
population composition and economic disparity of the population in the vicinity of a site as the
most important demographic statistics to investigate.
Once the demographic data of the 44 facilities were analyzed, GIS maps indicating facility
location, as well as economic and racial composition of the surrounding populations, were
generated. A map of each of the 44 targeted facilities was then created using ARCVIEW
mapping software.
Many Federal installations are large in size, therefore the environmental impacts they may
have on the surrounding community are potentially great. To define an area of investigation, EPA
established a radius around the center of each facility. A ten-mile radius was used for smaller
facilities, and a twenty-mile radius for larger facilities. Census Bureau data of the populations
located within the radii were then examined. Communities with zip codes inside the radius were
grouped into the following categories: 1) communities with greater than 25% minority,
2) communities with greater than 25% of families below the poverty level of $15,000, and 3)
communities with greater than 25% of all households with an income of $15,000 or less. The
data were then displayed as shaded regions on the GIS maps.
The process used to identify Federal facilities that potentially pose environmental justice
concerns may be summarized by the exhibit on the following page.
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FFEJEI Ev ALU A TI ON PROCESS
1994 TRI Federal Facility Report
191 Federal Facilities
Health Indic
Model
Top 100 Ranked Federal Facilities
44 Potential EJ Facilities
Prioritized EJ
Sites
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III: PRELIMINARY RESULTS OF THE INITIATIVE
FFEJEI provided EPA Headquarters and regions with a list of 44 Federal facilities that
pose potential environmental justice concerns to surrounding communities. While examining the
data from the initiative, FFEO gained valuable insight about the compliance history and health
risks associated with these 44 Federal facilities.
III. A. Analysis of Federal Facilities with TRI Releases
In 1994, 191 Federal facilities reported total TRI emissions of 10.1 million pounds. Of the
191 Federal facilities evaluated, 66% are Department of Defense sites, 21 % are Civilian Federal
Agency sites, and 12% are Department of Energy sites. The EPA Regions containing most of the
TRI reporting sites are Region 3, Region 4, and Region 9. Region 3 contains 25 TRI reporting
sites, while Regions 4 and 9 contain 41 and 35 sites respectively.
III. B. Analysis of Top 100 Sites
The TRI Indicator model ranked the top 100 facilities based on
relative risk-based impacts. Within the top 100 facilities, 71 % are DoD
sites, 15% are CFA sites, and 14% are DOE sites. The majority of the
facilities are located within Region 3, Region 4, and Region 6. Region 3
contains 13 facilities, while Regions 4 and 6 contain 25 and 16 facilities
respectively.
Analysis of the compliance data for the top 100 sites revealed that
Regions 3, 4, and 9 had the largest number of Federal facilities with
compliance indicator "hits". DoD had the sites with the most compliance
"hits" (47), followed by DOE (11) and CFAs (1). It is important to note
that 55% of the top 100 ranked sites had no compliance indicator "hits".
III. C. Analysis of 44 Sites
The majority of the
44 facilities
warranting further
evaluation to
determine if they
pose environmental
justice concerns are
located in Regions
4, 6, and 9.
Of the 44 facilities that were identified as potential environmental justice sites, 37 facilities
were selected because they met one or more of the FFEJEI' s evaluation criteria, five facilities
were included because they have previously been identified as environmental justice areas of
concern, and two facilities were selected for geographic distribution purposes.
Of these sites, 77% are DoD sites, 18% are DOE sites, and 5% are CFA sites. Further
analysis of the data revealed that 41 sites were assigned a toxicity ranking from 1 to 100, 12 have
recent violations warranting formal enforcement action, and 13 are presently in SNC. In addition,
17 are classified as NPL sites and four have not been inspected in the past two years. In terms of
regional distribution, the majority of the facilities are located within Region 4, Region 6, and
Region 9. Region 4 contains 12 facilities, while Region 6 contains 7 facilities and Region 9
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contains 6 facilities. The distribution of the remaining facilities is as follows: Region 1 ( 1 ), Region
2 (3), Region 3 (4), Region 5 (2), Region 7 (3), Region 8 (2), and Region 9 (4).
The following pages contain statistical charts illustrating the above information.
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~ ;::s ~ .... ~ 'I ~ ~ .... .... --12%DOE N = 191 Facilities 1994 FFEJEI TRI Universe by Agency 21% CFA -66%D0D oDoD 111DOE ■CFA
~ ~ .... ~ ? ::s "' .... ~ 'I N = 191 Facilities 1994 FFEJEI TRI Universe by Region 451( l 41 40-Hr-----35-H-----30-H"----25-Hi-----20 15 10 5 0 I II III IV V VI VII VIII IX X EPA Region so, b
a 2 Si a 2 22 as a a a & a 3 a a O a ----------. -. ~ ~ ? ::i ~ .... ~ "4 ~ °: .... w 1994 Top 100 FFEJEI Facilities by Agency 14%DOE 15% CFA 71%D0D oDoD ■DOE ■CFA N = 100 Facilities
? ;:: ~ ..... ~ "4 ~ ~ ..... ~ N = 100 Facilities 1994 Top 100 FFEJEI Facilities by Region 25 25 20-Mi-------15~ I 10 5 0 I II III IV V VI VII VIII IX X EPA Region ......illL..-----------
? ;: (,:, .... ~ ~ ~ ~ .... I.It N = 59 Hits Number of Compliance Indicator "Hits" for Top 100 FFEJEI Facilities 20 18 16 14 12 10 8 6 4 2 0 I' 20 by Agency DoD DOE CFA □Recent Violations ■SNC ONPL lilNo Inspection Activity
? ::: .,. .... ~ '-:i ~ °: .... . 0-. N = 59 Hits Number of Compliance Indicator "Hits" for Top 100 FFEJEI Facilities 9 8 7 6 5 4 3 2 1 0 l,da?t ,:J I by Region II III IV V VI VII VIII IX X I ■Recent Violations OSNC ■NPL ■No Inspection Activity I
~ ---·....-----... ◄ --·------cas -----------------------------------"'II■■■--------~----------------? ;:: II) .... ~ -...:i ~ ~ .... -...:i Distribution of Compliance Indicator "Hits" for Top 100 FFEJEI Facilities 33% □No Hits Iii 1 Hit N = 100 Facilities 10% (2 Hits) ■2 Hits 2% (3 Hits) (No Hits) D3 Hits
---.. ? ;: II> .... ~ ~ ~ ~ N = 44 Facilities .... Oo ---·--_ .. ----______ ............. ---~--The 44 Targeted Sites by Agency 18% DOE 77% DoD oDoD ■DOE ■CFA 5°/o CFA -----...__ ... --
~ --------. __...----------? ;::s ~ .... ~ ~ ~ ~ .... 'O N = 44 Facilities ----..---·-· ~----. -------. -----~ --~ ~ 45 40 35 30 25 20 15 10 The 44 Targeted Sites Meeting FFEJEI Selection Criteria 5 0-t<----fflll!Toxicity Ranking ■Recent Violations mSNC ONPL ■No Inspection Activity OEJ Concerns
Federal Facilities Environmental Justice Enforcement Initiative
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Federal Facilities Environmental Justice Enforcement Initiative
IV: CONCLUSION
The goal of FFEJEI was to identify Federal facilities that may pose potential
environmental justice concerns to nearby communities. Of the 191 Federal facilities that reported
releases of TRI chemicals, 44 have been identified as requiring additional investigation. Thus,
FFEJEI is only the first step in the process of targeting environmental justice enforcement efforts
at Federal facilities.
To determine whether these facilities are in fact environmental justice sites, further
investigation is necessary. FFEO is therefore disseminating this report to OEJ, the Regional EJ
Coordinators and FFCs, and the program offices within each region. With this information, FFCs
and single media program offices, can include them in regional inspection initiatives. For
example, FFEO will be issuing guidance for fiscal year 1998/1999 to its regional offices
encouraging them to include at least one targeted facility per region in their annual multi-media
inspections.
In addition, FFEO is encouraging regional EJ Coordinators and FFCs to engage in joint
targeting efforts. For instance, in the case of FFEJEI, FFCs can monitor and/or evaluate these
potential environmental justice sites through inspections, while EJ coordinators can monitor
facilities based upon information gained from community reporting and other efforts. Similarly, it
may be beneficial for EJ Coordinators and FFCs to combine their investigation and targeting
efforts with those of the National Enforcement Investigation Center (NEIC).
FFEO is also proposing that FFEJEI be made into an annual initiative to be used as an
evaluation tool by both EPA Headquarters and the Regions. The goal of FFEJEI, to identify
Federal facilities posing potential environmental justice concern would remain the same, however
emphasis could be placed on evaluating some of the 100 Top Ranked facilities not selected by this
initiative for further targeting, or on new sites as subsequent TRI reports are submitted.
FFEJEI also can serve as the catalyst for other Federal facilities inspection and
enforcement targeting initiatives. Environmental justice initiatives that target Federal facilities
located in specific geographic regions or belonging to specific Federal agencies such as DoD or
DOE can be launched. Additionally, emphasis can be placed on targeting Federal facilities that
are located on or near Native American lands or near specific racial/minority groups.
To ensure environmental protection for all, efforts to identify and address situations where
populations are disproportionately impacted must be made. FFEJEI, which attempts to focus
attention on the environmental and human health conditions of minority and low income
populations surrounding Federal facilities, is a tool that can be used to help ensure that equal
environmental protection for all people is achieved.
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Federal Facilities Environmental Justice Enforcement Initiative
V: APPENDIX
This appendix contains the GIS maps of the forty-four Federal facilities identified as
potential environmental justice areas of concern and identifies regional EJ Coordinators, FFCs,
and TRI contacts. In addition, the appendix contains a discussion of which facilities should be
given priority when evaluating them for environmental justice concerns, as well as a discussion of
the U.S. DOE Savannah River Site. A discussion of the U.S. DOE Savannah River Site is
included in order to illustrate how the forty-four sites were categorized and to better explain the
demographic data.
A. Prioritization of Facilities
The appendix contains a GIS map for each of the forty-four Federal facilities that have
been identified as facilities posing potential environmental justice concerns. Each map reveals the
facility's location, and the economic and minority composition of the surrounding populations.
Facilities were categorized according to their demographic data regarding low income,
minority, and poverty levels. Each facility was assigned a demographic rating of: High (H),
Medium (M), or Low (L). Facilities receiving the "H" rating, are considered most likely to be
environmental justice sites. The GIS maps of facilities receiving this rating revealed that most of
the area surrounding a facility is greater than 25% minority, greater than 25% of families are low
income, and greater than 25% of families live below the poverty level. Facilities receiving the
"M" rating are considered likely to be environmental justice sites. The GIS maps of these
facilities revealed that some of the area surrounding a facility is greater than 25% minority, greater
than 25% of families are low income, and greater than 25% of families live below the poverty
level. The final rating, "L", was assigned to facilities with GIS maps which revealed that a small
portion of the area surrounding each facility is greater than 25% minority, greater than 25% of
families are low income, greater than 25% of families live below the poverty level.
To determine which sites should be given priority for further evaluation, FFEO placed the
forty-four sites into one of the following three categories: A Priority, B Priority, or C Priority.
Facilities assigned an "A" Priority are those thought to warrant the highest priority for further
evaluation, those assigned a "B" Priority are thought to warrant medium priority, and those
assigned "C" Priority are considered to be lower in priority. Categorization of the facilities is
based upon the number of compliance indicators a facility has, its toxicity ranking, and
demographic data. Analysis of all these characteristics determined whether a facility was assigned
A, B, or C Priority.
Sites receiving an "A" Priority met all of the following characteristics: 1) a toxicity ranking
of under forty, 2) a minimum of two compliance indicators (i.e. NPL, SNC, etc.), and 3)
demographic information which revealed that much of the area surrounding the facility has more
than 25% of families living below the poverty level, more than 25% of all households are low
income, as well as more than 25% of the population is minority. Population composition both
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Federal Facilities Environmental Justice Enforcement Initiative
inside and outside of the 10-20 mile radii were examined. All of the sites assigned an "A" Priority
received a demographic rating of "H" or "M". However, the following five facilities: 1) U.S.
Army Pine Bluff Arsenal, 2) U.S. Navy Pensacola, 3) U.S. DOE Sandia National Lab, 4) U.S.
DOE Savannah River, and 5) Kelly Air Force Base, were placed in the "A" Priority category
because they had previously been identified through community reporting as environmental justice
sites.
A facility was considered a "B" Priority if it met the following characteristics: 1) a toxicity
ranking of fifty or less, 2) zero to two compliance indicators, and 3) demographic data that
revealed that a moderate area surrounding a facility is more than 25% minority, more than 25% of
all families live below the poverty level, and more than 25% of all households are low income.
Several of the facilities categorized as "B'' Priority, had minority and economically disadvantaged
populations located outside of the 10-20 mile radius. Analysis of the demographic data of the
sites assigned a "B" Priority revealed that the majority had "H" or "M" demographic ratings. A
few "B" Priority facilitie~ received a "L" demographic rating, since the GIS maps generated
indicated few areas where the population is greater than 25% minority, greater than 25% of
families live below the poverty level, and greater than 25% of households are low income. It
should be noted that Bolling Air Force Base, U.S. Army Fort Benning, and U.S. Army Longhorn
Ammunition, were assigned "B" Priority because they had at least one compliance indicator and
the GIS maps of the sites indicated that most of the area surrounding the facilities is greater than
25% minority, greater than 25% of families live below the poverty level, and greater than 25% of
households are low income.
The final category, "C" Priority, was assigned to Federal facilities with the following
characteristics: 1) no toxicity ranking or a ranking of ninety or less, 2) zero to one compliance
indicators, and 3) demographic data which revealed a small number of surrounding areas on the
map where the population is more than 25% minority, more than 25% of families live below the
poverty level, and more than 25% of all households are low income. All of the facilities assigned
"C" Priority are considered to be unlikely environmental justice sites.
B. Example of Prioritization: U.S. DOE Savannah River Site
The U.S. DOE Savannah River Site, located in Aiken, South Carolina, is used as an
example to demonstrate how a facility was categorized as either an A, B, or C Priority. The
Savannah River Site is one of the facility's identified by FFEJEI that meets all of the selection
criteria discussed in this report.
Upon examining the data, FFEO determined that the Savannah River Site had multiple
compliance indicators (3) and a very high toxicity ranking (i.e. ranked in the top ten). In addition,
past community reporting efforts and information gathered from other sources indicated that the
site was previously identified as an environmental justice area of concern. These factors resulted
in the targeting of the Savannah River Site by FFEJEI.
The entire area of the map is approximately thirty miles. The demographics data
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Federal Facilities Environmental Justice Enforcement Initiative
presented on the GIS map revealed that much of the area inside and outside of the established 20
mile radius have a population that is more than 25% minority. On the map, the areas surrounding
the facility that are greater than 25% minority are illustrated as striped regions. The demographic
data also revealed that there are numerous areas near the facility where more than 25% of the
households are low income. Regions on the map illustrating this data are shaded in yellow.
Additionally, the demographic data revealed areas surrounding the facility where more than 25%
of families are living below the poverty level. This data is illustrated as fuschia shaded regions on
the map.
The demographic data together with the compliance, community reporting, and TRI
Indicator model data, resulted in the Savannah River Site being characterized as an "A" Priority
potential environmental justice area of concern.
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C. DISTRIBUTION MAP, SITE LISTINGS, MATRIX, & GIS MAPS
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? :::s .,. .... ~ 'I ~ ~ N Oo Environmental Justice Targeting of Federal Facilities Seattle San Francisco , 40 -""· ~Hawaii Refer to accompanying table for facility name, city, county, state, and zip code. _,_ tfltr CO, a a ..... -.a '\ 25 New York 4
Environmental Justice Targeting of Federal Facilities -GIS Analysis
§jte Ei15'ili~ ,;~ ,su10~ §tgte ~jg
NASA MARSHALL SPACE FLIGHT FACILITY HUNTSVILLE MADISON AL 35812
2 U.S. AIR FORCE FACILITY KELLY AFB BEXAR TX 78241
3 U.S. AIR FORCE FACILITY TINKER AFB OKLAHOMA OK 73145
4 U.S. AIR FORCE FACILITY WASHINGTON DIST OF COLUMBIA DC 20332
5 U.S. AIR FORCE FACILITY WRIGHT-PATTERSON GREENE OH 45433
6 U.S. AIR FORCE FLIGHT TEST CENTER EDWARDS KERN CA 93524
7 U.S. AIR FORCE MCCLELLAN AIR SACRAMENTO SACRAMENTO CA 95852
~ 8 U.S. AIR FORCE OGDEN FACILITY HILL AFB TOOELE UT 84056
l 9 U.S. AIR FORCE PLANT 04 TX FORT WORTH TARRANT TX 76108
10 U.S. AIR FORCE PLANT 06 GA MARIETTA COBB GA 30063
11 U.S. AIR FORCE PLANT 44 AZ. TUCSON PIMA AZ. 85734
12 U.S. AIR FORCE PLANT 59 JOHNSON CITY BROOME NY 13790
13 U.S. ARMY FACILITY ANNISTON CALHOUN AL 36201
14 U.S. ARMY FACILITY KINGSPORT HAWKINS TN 37660
15 U.S. ARMY FACILITY LIMA ALLEN OH 45804
16 U.S. ARMY FORT BENNING COLUMBUS MUSCOGEE GA 31905
17 U.S. ARMY FORT HOOD FORT HOOD BELL TX 76544
18 U.S. ARMY FORT RILEY FORT RILEY GEARY KS 66442 i
t
19 U.S. ARMY HQ USAEC FACILITY FORT LEONARD WOOD PULASKI MO 65473
20 U.S. ARMY LAKE CITY FACILITY INDEPENDENCE JACKSON MO 64051 I 21 U.S. ARMY LETTERKENNY FACILITY CHAMBERSBURG FRANKLIN PA 17201 ~ I 22 U.S. ARMY LONGHORN AMMUNITION KARNACK HARRISON TX 75661
23 U.S. ARMY PINE BLUFF ARSENAL PINE BLUFF JEFFERSON AR 71602
24 U.S. ARMY WATERVLIET ARSENAL WATERVLIET ALBANY NY 12189
25 U.S. DEFENSE LOGISTICS AGENCY PORTSMOUTH NEWPORT RI 02871
26 U.S. DOE ENERGY TECHNOLOGY FACILITY SIMI HILLS VENTURA CA 91311
27 U.S. DOE IDAHO NATIONAL LAB SCOVILLE BUTTE ID 83415
28 U.S. DOE NAVAL PETROLEUM FACILITY TUPMAN KERN CA 93276
29 U.S. DOE OAK RIDGE Y-12 PLANT OAK RIDGE ANDERSON TN 37831
30 U.S. DOE ROCKY FLATS FACILITY GOLDEN JEFFERSON co 80402
31 U.S. DOE SANDIA NATL. LAB ALBUQUERQUE BERNALILLO NM 87185
32 U.S. DOE SAVANNAH RIVER FACILITY AIKEN AIKEN SC 29802
33 U.S. ENRICHMENT CORP. PADUCAH PADUCAH MCCRACKEN KY 42001
34 U.S. MARINE CORPS FACILITY BARSTOW SAN BERNADINO CA 92311
35 U.S. MARINE CORPS FACILITY CHERRY POINT CRAVEN NC 28533
~ 36 U.S. MARINE CORPS LOGISTICS FACILITY ALBANY DOUGHERTY GA 31704
• 37 U.S. NAVY PUGET SOUND FACILITY BREMERTON KITSAP WA 98314
I 38 U.S. NAVY FACILITY JACKSONVILLE DUVAL FL 32212
39 U.S. NAVY FACILITY NORFOLK NORFOLK CITY VA 23511
40 U.S. NAVY FACILITY PEARL HARBOR HONOLULU HI 96860
41 U.S. NAVY FACILITY PENSACOLA ESCAMBIA FL 32508
42 U.S. NAVY FACILITY PORTSMOUTH PORTSMOUTH VA 23709
43 U.S. NAVY KEYPORT FACILITY KEYPORT KITSAP WA 98345
44 U.S. TVA ENVIRONMENTAL FACILITY MUSCLE SHOALS COLBERT AL 35662
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-? ;:s "' ..... ~ "'-I ~ ~ ~ ~ Facilities U.S. Army Anniston, AL NASA Marshall Space Facility, AL U.S. TVA Environmental, AL U.S. Army Pine Bluff Arsenal, AR U.S. Air Force Plant 44, AZ U.S DOE Naval Petroleum, CA U.S. Air Force McClellan, CA U.S. Marine Corps Barstow, CA U.S. Air Force Flight Test, CA U.S. DOE Energy Technology, CA U.S. DOE Rocky Flats, CO Bolling Air Force Base, DC U.S. Navy Jacksonville, FL U.S. Navy Pensacola, FL U.S. Air Force Plant 06, GA U.S. Marine Corps Logistics, GA U.S. Army Fort Benning, GA U.S. Navy Pearl Harbor, HI U.S. DOE Idaho National Lab, ID U.S. Army Fort Riley, KS U.S. Enrichment Corp. Paducah, KY U.S. Army Lake City, MO U.S. Army HQ USAEC, MO U.S. Marine Corps Cherry Point, NC U.S. DOE Sandia National Lab, NM U.S. Army Watervliet Arsenal, NY U.S. Air Force Plant 59, NY Wright-Patterson Air Force Base, OH U.S. Army Lima, OH Tinker Air Force Base, OK U.S. Army Letterkenny, PA U.S. Defense Logistics Agency, RI U.S. DOE Savannah River Site, SC GIS MAP CATEGORIZATION Compliance Indicators Toxicity Ranking 2 0 0 1 0 1 2 1 0 1 2 1 3 3 1 1 1 1 1 2 1 1 1 2 0 1 0 0 0 1 2 0 2 15 24 18 28 2 40 23 5 13 8 21 0 30 51 37 12 0 49 7 39 33 31 32 6 22 9 47 1 45 3 20 90 4 H= Most Likely to be an EJ Site M= Likely to be an EJ Site L= Unlikely to be an EJ Site *Reported EJ Concerns ..... ftt -----------.~ Demographic Rating Overall Rating of Sites H A H B H B H A* H B M B M A H B M B L B L B H B M A M A* M B H B H B M B M B H A H B L B H B H A H A* L C L C M B L C M B L B L C H A*
____ ,..._, _____ .,.._. _..~----------·-,. _____ ....,._, ___ ..,•••--••--•••---..------------------~--~-----,•---,.r~-----------------? ::: ~ ..... ~ 'I ~ ~ ~ ..... Facilities U.S. Army Kingsport, TN U.S. DOE Oak Ridge Y-12 Plant, TN Kelly Air Force Base, TX U.S. Air Force Plant 04, TX U.S. Army Fort Hood, TX U.S. Army Longhorn Ammunition, TX U.S. Air Force Ogden Facility, UT U.S. Navy Portsmouth, VA U.S. Navy Norfolk, VA U.S. Navy Puget Sound, WA U.S. Navy Keyport Naval, WA GIS MAP CATEGORIZATION Compliance Indicators Toxicity Ranking 1 1 0 1 1 2 1 0 1 2 0 29 35 11 14 44 0 16 19 41 38 10 H= Most Likely to be an EJ Site M= Likely to be an EJ Site L= Unlikely to be an EJ Site *Reported EJ Concerns Demographic Rating Overall Rating of Sites H B M B H A* M B H B H B L C H B H B L B L C
? :::s ~ ..... ~ '-I ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding NASA Marshall Space Flight Facility, Huntsville Madison County, Alabama Enlarged Area Legend e Federal Facilities Zip Codes with : rz.21 >25% Minority ->25% of Families Below Poverty Level D >25% Households Low Income (<$15,000) 1B County Boundary l'i!il Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles ~----------------. -·--~-------------. -----. -·-·-.. . -----•--·-·
? ::: .,, .... ~ 'I ~ ~ \.,,I 0\ Low Income, Poverty Level, and Minorities Surrounding U.S. Air Force Facility, Wright-Patterson Greene County, Ohio Enlarged Area □Ohio Legend e Federal Facilities Zip Codes with : '2"'ZJ >25% Minority _>25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) jg County Boundary l'i!:il Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles -------------------~------------------------------------------------------------------
----------~----------_..,., __________________________ ....,.,....._,... __________ _ ? ;:: <I> .... ~ 'l ~ ~ ~ vi Low Income, Poverty Level, and Minorities Surrounding U.S. Air Force Facility, Washington D.C. District of Columbia Enlarged Area Legend e Federal Facilities Zip Codes with : (lZJ >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary l'!!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ::s "' .... ~ ~ ~ 0: ~ ,t,.. Low Income, Poverty Level, and Minorities Surrounding U.S. Air Force Facility, Tinker AFB Oklahoma County, Oklahoma Enlarged Area Oklahoma □ Legend e Federal Facilities Zip Codes with : 22d >25% Minority 111>25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary l!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles ________ ---------~ ____ .& • -... _, a en ·a •• m ct: 7 ,e, w .. .........._. ____ ~---
? ;::i ~ .... ~ 'I ~ ~ ~ y • -•► .. • a a us a ap: a cwz • • .. ◄ ~ -·--Low Income, Poverty Level, and Minorities Surrounding U.S. Air Force Facility, Kelly AFB Bexar County, Texas Enlarged Area Legend e Federal Facilities Zip Codes with : l22J >25% Minority _ >25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary llfiJ Stream Reaches/ Shore Lines Q 10 Mile Radius from Facility 0 5 10 Miles
---------------------.-•Wl!!!!_!"'•'!SS!W..--w -----------· Low Income, Poverty Level, and Minorities i Surrounding U.S. Air Force Flight Testing Center, Edwards .... ~ Kern County, California ~ 0: ..... 'I Enlarged Area Legend e Federal Facilities Zip Codes with : l'2'ZA >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000} B County Boundary ll!iJ Stream Reaches Q 20 Mile Radius from Facility 0 10 20 Miles
Low Income, Poverty Level, and Minorities ! Surrounding U.S. Air Force McClellan AFB, Sacramento ~ Sacramento County, California ~ ~ I., 0c, ---.. Enlarged Area Legend e Federal Facilities Zip Codes with : flZJ >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary lf!il Stream Reaches Q 1 O Mile Radius from Facility 0 5 10 Miles ---
? ::s ~ .... ~ 'I ;}' 0: w 'C ~ w • w;~ _.. Low Income, Poverty Level, and Minorities Surrounding U.S. Air Force Ogden AFB, Hill Tooele County, Utah Enlarged Area Legend e Federal Facilities Zip Codes with : (2'2a >25% Minority IED>25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary rl!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ;: ~ .... ~ ~ ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. Air Force Plant 04, Fort Worth Tarrant County, Texas -------i -----Enlarged Area Legend e Federal Facilities Zip Codes with : rlZJ >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) (B County Boundary rf!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? :::s ~ .._. ~ '-I ~ 0: ~ ◄ us wwwe -'"4' ._.. ------------.·----------......... -------·------~~~----------Low Income, Poverty Level, and Minorities Surrounding U.S. Air Force Plant 06, Marietta Cobb County, Georgia Enlarged Area Legend e Federal Facilities Zip Codes with : rz2i >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary l'l!il Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ::i ~ ..... ~ 'l ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. Air Force Plant 44, Tucson County of Pima, Arizona .. ---· cre4i _..,, ·---------..-... Enlarged Area Legend e Federal Facilities Zip Codes with : rlZJ >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) B County Boundary ll!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles ___ ___.__.._ .... _______ ..... .._ __ . --£------~ -------------------~
? ;: fl, ... ~ --.:i ~ ~ ~ .. a ea a; a p '*" c -== ---·-..... ---·-Low Income, Poverty Level, and Minorities Surrounding U.S. Air Force Plant 59, Johnson City Broome County, New York --------------Enlarged Area Legend e Federal Facilities Zip Codes with : P'Z2J >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary ll!il Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ::s ~ ..... ~ 'l ~ ~ t -Low Income, Poverty Level, and Minorities Surrounding U.S. Army Facility, Anniston Calhoun County, Alabama ce-atr« od • b -----Enlarged Area Legend e Federal Facilities Zip Codes with : ~ >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary rf!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles -----.....
____ ....,,......... ....... -'i::' ;:i "' .... ~ 'I ~ ~ ~ 1·-~~ ~-----------------------Low Income, Poverty Level, and Minorities Surrounding U.S. Army Facility, Kingsport Hawkins County, Tennessee Enlarged Area Legend e Federal Facilities Zip Codes with : rz21 >25% Minority ->25% of Families Below Poverty Level D >25% Households Low Income (<$15,000) 1B County Boundary rl!ij Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ;:s ~ .... ~ '-l ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. Army Facility, Lima Allen County, Ohio Enlarged Area Legend e Federal Facilities Zip Codes with : ~ >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary l'i!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles , ......_ ____ ........... --►• ----............. ..-..--.-----------------
......---·------------1-? ;:i ~ .... ~ 'I ~ ~ ""' 'I Low Income, Poverty Level, and Minorities Surrounding U.S. Army Fort Benning, Columbus Muscogee County, Georgia Enlarged Area Legend e Federal Facilities Zip Codes with : rz2J >25% Minority ->25% of Families Below Poverty Level D >25% Households Low Income (<$15,000) 1B County Boundary rl!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ::s ~ .... ~ 'l ~ ~ t Low Income, Poverty Level, and Minorities Surrounding U.S. Army Facility, Fort Hood Bell County, Texas ..... Enlarged Area Legend e Federal Facilities Zip Codes with : l22J >25% Minority __ >25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) jg County Boundary lffil Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles ---I tr ms --
? ::i .,. .... ~ 'I ~ °: ~ • WWW CSU\ Low Income, Poverty Level, and Minorities Surrounding U.S. Army Facility, Fort Riley Geary County, Kansas Enlarged Area Legend e Federal Facilities Zip Codes with : l2"Z.a >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary li!iJ Stream Reaches Q 20 Mile Radius from Facility 0 10 20 Miles
? ::s ~ .... ~ 'l ~ 0: ~ Q Low Income, Poverty Level, and Minorities Surrounding U.S. Army HQ USAEC, Fort Leonard Wood Pulaski County, Missouri Enlarged Area Legend e Federal Facilities Zip Codes with : 1?'221 >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) B County Boundary l'i!iJ Stream Reaches Q 20 Mile Radius from Facility 0 10 20 Miles • .,. >rf
's:' ;:s ~ .... ~ ~ ~ °: u, .... Low Income, Poverty Level, and Minorities Surrounding U.S. Army Lake City Facility, Independence Jackson County, Missouri Enlarged Area Legend e Federal Facilities Zip Codes with : rz21 >25% Minority ->25% of Families Below Poverty Level D >25% Households Low Income (<$15,000) 1B County Boundary ll!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ::: "' .... ~ '-:i ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. Army Letterkenny Arsenal, Chambersburg Franklin County, Pennsylvania Enlarged Area Legend e Federal Facilities Zip Codes with : rlZJ >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) B County Boundary ll!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
-...... 1 -... ,w -( ~ a • •-• a----.....·-Low Income, Poverty Level, and Minorities i Surrounding U.S. Army Longhorn Ammunition, Karnack ..... ~ Harrison County, Texas ~ ~ ~ Enlarged Area Legend e Federal Facilities Zip Codes with : rz..21 >25% Minority _ >25% of Families Below Poverty Level 0>25% Households low Income (<$15,000) IE:J County Boundary li!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ;:s "' ..... ~ 'l ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. Army Pine Bluff Arsenal, Pine Bluff Jefferson County, Arkansas Enlarged Area Legend e Federal Facilities Zip Codes with : ~ >25% Minority __ >25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary rl!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles ..._ ____ ..........__ ,eee a m ~ • • t· -t -____...._ ..
-~ Low Income, Poverty Level, and Minorities ~ Surrounding U.S. Army Watervliet Arsenal, Watervliet .... \0 ~ Albany County, New York ~ ~ ~ Enlarged Area Legend e Federal Facilities Zip Codes with : (2"ZJ >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) (B County Boundary rl!iJ Stream Reaches Q 1 O Mile Radius from Facility 0 5 10 Miles
? ;:s ~ ... ~ 'I ~ ~ I.Ii 0'I Low Income, Poverty Level, and Minorities Surrounding U.S. Defense Logistics Agency, Portsmouth Newport County, Rhode Island Enlarged Area Legend e Federal Facili1ies Zip Codes with : l'lZa >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) l!::3 County Boundary ri!ij Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles f 2 0 ·---.......
/ ? ;: ~ .... ~ "' ~ 0: (Ji "' .... we "' -... -• w:wsa a w -• a -a a io: • Low Income, Poverty Level, and Minorities Surrounding U.S. DOE Energy Technology Facility, Simi Hills Ventura County, California Enlarged Area Legend e Federal Facilities Zip Codes with : l?ZJ >25% Minority _ >25% of Familie-s Below Poverty Level 0>25% Households Low Income (<$15,000) l!::3 County Boundary ll!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
' ? ::s ~ ... ~ 'I ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. DOE Idaho National Lab, Scoville Butte County, Idaho ... ft ... • mt e to a -• ,eee,, ,_ a ts -c .--Enlarged Area Legend e Federal Facilities Zip Codes with : ~ >25% Minority ->25% of Families Below Poverty Level D >25% Households Low Income (<$15,000) 1B County Boundary ll!il Stream Reaches Q 20 Mile Radius from Facility 0 10 20 Miles & a re - • :ftp 'tt
I Low Income, Poverty Level, and Minorities ! Surrounding U.S. DOE/Navy Petroleum Facility, Tupman ~ Kern County, California ~ ~ ~ Enlarged Area Legend e Federal Facilities Zip Codes with : rz2J >25% Minority ->25% of Families Below Poverty Level D >25% Households Low Income (<$15,000) 1B County Boundary ll!il Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
'\ ? ::i .,. .... ~ ~ ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. DOE Oak Ridge Plant Y-12, Oak Ridge Anderson County, Tennessee Enlarged Area Legend • Federal Facilities Zip Codes with : rz2I >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) (B County Boundary 11!:iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles ~.--~-----
? ::s ~ .... ~ "-.I ~ ~ ~ -.......-----Low Income, Poverty Level, and Minorities Surrounding U.S. DOE Rocky Flats Facility, Golden Jefferson County, Colorado Enlarged Area Legend e Federal Facilities Zip Codes with : ~ >25% Minority _ >25% of Families Below Poverty Level D >25% Households Low Income (<$15,000) 1B County Boundary rl!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
Low Income, Poverty Level, and Minorities r Surrounding U.S. DOE Sandia National Lab, Albuquerque ... ~ Bernalillo County, New Mexico ~ ~ ~ __ ..... _..J ________________ ...,. __ ., ____________ .._. .. _________ _ Enlarged Area Legend e Federal Facilities Zip Codes with : (2"ZJ >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) IE:3County Boundary 11!:iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ::s ~ ..... ~ 'I ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. DOE Savannah River Facility, Aiken Aiken County, South Carolina Enlarged Area Legend e Federal Facilities Zip Codes with : ~ >25% Minority ->25% of Families Below Poverty Level D >25% Households Low Income (<$15,000) (B County Boundary l!iJ Stream Reaches Q 20 Mile Radius from Facility 0 10 20 Miles
? ;::s "' .... ~ 'I ~ ~ t Low Income, Poverty Level, and Minorities Surrounding U.S. Enrichment Corp, Paducah McCracken County, Kentucky Enlarged Area -____, Legend e Federal Facilities Zip_ Codes with : E'Z2J >25% Minority ->25% of Families Below Poverty Level D >25% Households Low Income (<$15,000) B County Boundary rl!iJ Stream Reaches o· 10 Mile Radius from Facility 0 5 10 Miles ----·--------------
? ;:s ~ .... ~ ~ ~ °: e: Low Income, Poverty Level, and Minorities Surrounding U.S. Marines Facility, Barstow San Bernardino County, California Enlarged Area Legend e Federal Facilities Zip Codes with : ~ >25% Minority _ >25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) B County Boundary l'i!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? :::i .,. .... ~ ~ ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. Marines Facility, Cherry Point Craven County, North Carolina --Enlarged Area Legend e Federal Facilities Zip Codes with : l2ZJ >25% Minority __ >25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) B County Boundary l!!:iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ;: ~ .... ~ ....... ~ ~ 0\ ....... Low Income, Poverty Level, and Minorities Surrounding U.S. Marines Logistics Facility, Albany Dougherty County, Georgia Enlarged Area Legend e Federal Facilities Zip Codes with : llZA >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) IE3 County Boundary l!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ::i ~ ..... ~ '-I ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. Navy Puget Sound Facility, Bremerton Kitsap County, Washington Enlarged Area Legend e Federal Facilities Zip Codes with : ~ >25% Minority _ >25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary IIEiJ Stream Reaches / Shore Lines Q 10 Mile Radius from Facility 0 5 10 Miles
? ::s ~ .... ~ '-l ~ ~ ~ ..,, WWW -'W◄UC W Low Income, Poverty Level, and Minorities Surrounding U.S. Navy Facility, Jacksonville Duval County, Florida Enlarged Area Legend e Federal Facilities Zip Codes with : rzzJ >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) B County Boundary l'l!:il Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ;::s ~ .... ~ '-l ~ ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. Navy Facility, Norfolk County of Norfolk City, Virginia Enlarged Area --......._ ............. -_ ....... ....__ Legend e Federal Facilities Zip Codes with : ~ >25% Minority ->25% of Families Below Poverty Level D >25% Households Low Income (<$15,000) 1B County Boundary l!EiJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ::: II> ..... ~ " ~ °: ~ Low Income, Poverty Level, and Minorities Surrounding U.S. Navy Facility, Pearl Harbor Honolulu County, Hawaii Enlarged Area Legend e Federal Facilities Zip Codes with : (2'ZJ >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) B County Boundary l!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ::s (lo ... ~ ~ ~ ~ ;j Low Income, Poverty Level, and Minorities Surrounding U.S. Navy Facility, Pensacola Escambia County, FL Enlarged Area Legend e Federal Facilities Zip Codes with : 1?Z3 >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) [B County Boundary l'l!il Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
-. ...._.,,--· ~--... ...........--? ;:: ~ .... ~ ~ ~ ~ ;:;! Low Income, Poverty Level, and Minorities Surrounding U.S. Navy Facility, Portsmouth County of Portsmouth City, Virginia Enlarged Area Legend • Federal Facilities Zip Codes with : ~ >25% Minority __ >25% of Families Below Poverty Level D >25% Households Low Income (<$15,000) 1B County Boundary rl!iJ Stream Reaches/ Shore Lines Q 10 Mile Radius from Facility 0 5 10 Miles
? ::: ~ .... ~ ~ ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. Navy Facility, Keyport Kitsap County, Washington ____ . ____ -ans soc -• • n a e m-trdt Enlarged Area Legend e Federal Facilities Zip Codes with : l'l2'J >25% Minority _>25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) (B County Boundary ll!il Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
? ;:s ~ .... ~ ........ ~ ~ ~ Low Income, Poverty Level, and Minorities Surrounding U.S. TVA Environmental Facility, Muscle Shoals Colbert County, Alabama Enlarged Area Legend e Federal Facilities Zip Codes with : l22J >25% Minority ->25% of Families Below Poverty Level 0>25% Households Low Income (<$15,000) 1B County Boundary rl!iJ Stream Reaches Q 10 Mile Radius from Facility 0 5 10 Miles
Federal Facilities Environmental Justice Enforcement Initiative
D. Definition of Significant Noncompliance (SNC)
Federal facilities in "significant noncompliance" (SNC) are identified on the basis of
certain data fields within the Integrated Data for Enforcement Analysis (IDEA) system. As the
name suggests, IDEA integrates data from a number of media-and program-specific data bases.
Some of these data bases contain formal SNC indicators, while others do not have SNC indicators
per se, but instead rely on a combination of other data fields to identify SNC facilities. This
document summarizes how the concept of SNC applies to Federal facilities regulated under the
following environmental statutes/programs:
• Resource Conservation and Recovery Act (RCRA);
• National Pollutant Discharge Elimination System (NPDES);
• Clean Air Act (CAA); and
• Toxic Substances Control Act (TSCA), Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA), and Emergency Planning and Community Right-to-
Know Act (EPCRA).
Note: Although the condition that triggered SNC status for a particular Federal facility
may have been subsequently addressed from the facility's perspective; the facility may
remain in SNC within the relevant tracking system until EPA or appropriate State
authority determines that the underlying condition has been resolved. Such a determination
might involve a reinspection, submission of reports by the facility, or completion of a corrective
action.
RCRA
The RCRA Information System (RCRIS) does not use the term SNC to track compliance,
but instead uses a numerical prioritization system for violations. IDEA combines this
prioritization system with a violation resolved date to derive a SNC measure. Thus, Federal
facilities are considered in SNC with RCRA for a given quarter if they:
• have a Violation Priority = 9 (High Priority Violation) and
• have no date in the violation Actual Resolved Date field or a date after the end of
the last month of the quarter in question.
NPDES
Under the NPDES program, a facility may be classified as SNC if it has a violation of
significant magnitude and/or duration to be among the Agency's priorities for review and/or
June1997 Page 76
Federal Facilities Environmental Justice Enforcement Initiative
response. IDEA classifies a NPDES facility as being in SNC for a given quarter if the facility: ( 1)
is operating, (2) is a major facility, and (3) is classified with a Noncompliance Status of one of the
following:
"T" SNC for compliance schedule reporting;
"S" SNC for compliance schedule violation;
"E" SNC for effluent violations; or
"D" SNC for non-receipt of a Discharge Monitoring Report.
CAA
The Aerometric Information Retrieval System (AIRS) tracks compliance status of CAA
facilities; however, AIRS does not use the term SNC. IDEA classifies a Federal facility as being
in SNC with CAA for a given quarter if for the last month of the quarter: (1) an enforcement lead
has been determined or is pending, and (2) the facility has a Compliance Status of one of the
following:
"B" In violation with respect to emissions and procedural compliance;
"W' In violation with respect to procedural compliance;
"1" In violation for failure to have a schedule for return to compliance;
"6" In violation for failure to meet a schedule for return to compliance;
"7" In violation status unknown with regard to schedule for return to compliance.
In addition, the facility is still considered in SNC if at the end of the last month of the
quarter in question, an enforcement lead has been determined and the facility changed its
Compliance Status from either "1" or "6" to either "7" or "5", where "5" means "Meeting
compliance schedule."
TSCA, FIFRA & EPCRA
Under TSCA, FIFRA, or EPCRA, SNC status is triggered by a violation for which the
level of enforcement action is, at a minimum, an administrative complaint in accordance with the
appropriate enforcement response policy. Drawing upon the National Compliance Data Base
(NCDB) system, which tracks compliance for the aforementioned statutes, the IDEA system
classifies a Federal facility in SNC for a given quarter if it:
• has a SNC Indicator= Y (Yes) and
• has no date on the violation Closed Date field or a date after the end of the quarter
in question.
June 1997 Page 77
Region I
Rhona Julien
E.
One Congress Street, 10th Floor
Boston, MA 02203-0001
Tel: [phone]
Fax: [phone]
Region II
Melva Hayden
290 Broadway, 26th Floor
New York, NY 1007
Tel: [phone]
Fax: [phone]
Region III
Reginald Harris
841 Chestnut Building
Philadelphia, PA 19107
Tel: [phone]
Fax: [phone]
Region IV
Connie Raines
100 Alabama St., SW
Atlanta, GA 30303
Tel: [phone]
Fax: [phone]
Region V
Karla Johnson
77 West Jackson Blvd., T-17J
Chicago, IL 60604-3507
Tel: [phone]
Fax: [phone]
June 1997
Federal Facilities Environmental Justice Enforcement Initiative
Regional Environmental Justice Contacts
Region VI
Shirley Augurson
First Interstate Bank, at Front Pl.
1445 Ross Ave., 12th Floor
Suite 1200
Dallas, TX 75202-2733
Tel: [phone]
Fax: [phone]
Region VII
Althea Moses
726 Minnesota A venue
Kansas City, KS 66101
Tel: [phone]
Fax: [phone]
Region VIII
Elisabeth Evans
999 18th Street, Suite 500
Denver, CO 80202-2405
Tel: [phone]
Fax: [phone]
Region IX
Willard Chin
75 Hawthorne Street
San Francisco, CA 94105
Tel: [phone]
Fax: [phone]
Region X
Joyce Crosson-Kelly
Planning and Evaluation Branch
1200 Sixth Avenue (MD-142)
Seattle, WA 98101
Tel: [phone]
Fax: [phone]
Page 78
AnneH. Fenn
US EPA Region I
Mail Code: SFF
F.
John F. Kennedy Federal Bldg.
Boston, MA 02203
Tel: [phone]
Fax: [phone]
Eric Ashton
US EPA Region III
841 Chestnut St.
Philadelphia, PA 19107
Tel: [phone]
Fax: [phone]
Lee Regner
US EPA Region V
Mail Code: E-19J
77 West Jackson Blvd
Chicago, IL 60604
Tel: [phone]
Fax: [phone]
Jamie Bemard-Drakey
US EPA Region VII
Mail Code: ECO/RGAD
726 Minnesota Ave.
Kansas City, KS 66101
Tel: [phone]
Fax: [phone]
Sara Segal
US EPA Region IX
75 Hawthorne St., E-3
San Francisco, CA 94105
Tel: [phone]
Fax: [phone]
June 1997
Federal Facilities Environmental Justice Enforcement Initiative
Regional Federal Facility Coordinators
John Gorman
US EPA Region II
290 Broadway-28th Floor
New York, New York 10007-1866
Tel: [phone]
Fax: [phone]
Dave Holroyd
US EPA Region IV
100 Alabama St., SW
Atlanta, GA 30303-3104
Tel: [phone]
Fax: [phone]
Joyce Stubblefield
US EPA Region VI
1445 Ross Ave.
Dallas, TX 75202
Tel: [phone]
Fax: [phone]
Dianne Thiel (8P2-P2) &
Connally Mears (8ENF-T)
US EPA Region VIII
999 18th St., Suite 500
Denver, CO 80202-2466
Tel: [phone]
303-312-6217
Fax: [phone]
303-312-6409
David Tetta
US EPA Region X
1200 6th Ave., WD-125
Seattle, WA 98101
Tel: [phone]
Fax: [phone]
Page 79
G.
Region I
Dwight Peavey (SPT)
Assistance and Pollution Prevention Office
One Congress Street
Boston, MA 02203
Tel: [phone]
Fax: [phone]
Region II
Nora Lopez (MS-105)
Pesticides and Toxics Branch
2890 Woodbridge Avenue, Building 10
Edison, NJ 08837-3679
Tel: [phone]
Region III
Bill Reilly (3A T31)
Industrial Domain Section
841 Chestnut Street Bldg.
Philadelphia, PA 19107
Tel: [phone]
Fax: [phone]
Region IV
Ezequiel Velez
EPCRA UnitB
100 Alabama St, SW
Atlanta, GA 30303
Tel: [phone], ext. 6984
Fax: [phone]
Region V
Thelma Codina (DRT-14J)
Pesticides and Toxics Branch
77 West Jackson Blvd.
Chicago, IL 60604
Tel: [phone]
Fax: [phone]
June 1997
Federal Facilities Environmental Justice Enforcement Initiative
Regional TRI Contacts
Region VI
Warren Layne (6PDT)
Toxics Section
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Tel: [phone]
Fax: [phone]
Region VII
Jim Hirtz (ARTD/fSPP)
Toxic Substances Prevention and
Planning Branch
726 Minnesota A venue
Kansas City, KS 66101
Tel: [phone]
Fax: [phone]
Region VIII
Bruce Cooper (8P2-TX)
Office of Pollution, Prevention, State
and Tribal Assistance Toxics Program
999 18th Street, Suite 500
Denver, CO 80202
Tel: [phone]
Fax: [phone]
Region IX
Adam Browning (CMD4-2)
Toxics Management Section
75 Hawthorne Street
San Francisco, CA 94105
Tel: [phone]
Fax: [phone]
Region X
Christina Colt (WCM-128)
Office of Waste & Chemicals Mgmt.
Solid Waste & Toxics Unit
1200 Sixth Avenue
Seattle, WA 98101
Tel: [phone]
Fax: [phone]
Page SO
&EPA United States Environmental Protection Agency (2261A) Washington, DC 20460 Official Business Penalty for Private Use $300