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Provide mechanisms and support i. Reassess information needs, technical architecture, and information dissemination mechanisms as both needs and technologies change, in order to continually improve and reduce the burden on information management. Track the authorization status of states and tribes according to authorization requirements for new regulations as they are developed and make this status information readily available to all stakeholders. Use processes, such as peer review, to obtain upfront stakeholder input on technical materials used to support regulatory development such as treatability studies, cost and performance data, mass-transfer studies for combustion, waste minimization studies, analysis of PBTs.
Work with internal and external governmental entities during regulatory development to develop recommendations and options for implementing program regulations and standards. Base decisions on high quality data and sound science. Incorporate peer and quality assurance procedures into all program activities. Collate prioritized information needs and data definitions including states, other program offices, and other federal offices to achieve consistent data definitions where feasible , determine core data elements, and identify the fundamental information needed by all stakeholders to facilitate the sharing of data and information of common interest.
Collect and manage records of core and non-core data and information currently required from regulated entities and managed in existing systems, such as the Biennial Reporting System BRS and RCRIS, until streamlining projects are completed and necessary system revisions can be completed. Comply with executive order to reduce recordkeeping burden by 25 percent. Conduct negotiations and settlements with counsel and the facility to reach a legal agreement on further actions to be conducted by the facility. Continue progress made on permit improvement projects to achieve streamlined permitting and investigate the use of pre-written permits, when appropriate.
Coordinate program development and implementation with federal, state, local, and tribal organization early on in the process. Coordinate with facilities, implementation partners, and enforcement officials to encourage them to agree to use existing flexibilities as incentives to allow for cost-effective or more expeditious voluntary actions as alternatives. Coordinate with partners states, regions, tribes regarding program responsibilities through such activities as strategic planning workgroups.
Determine appropriate enforcement actions to take considering all available options to achieve return to compliance without wasting time and resources, then proceed with court filings, if deemed necessary.
THE FAE LIAISON INITIATIVE DOCUMENT Original (PDF)
Determine penalties and fines to levy according to the Agency's Penalty Policy utilizing such information as the historical environmental track record of the facility, additional fines owed, alternative pollution prevention expenditures, and the facility's ability to pay. Develop and implement changes in program direction as a result of analyses of the trends in environmental indicators employing voluntary or non-regulatory approaches, when feasible, and revise regulations as appropriate. Develop data quality requirements for the technical architecture of the information systems for surveys and data collection in cooperation with the RCRA community and incorporate these requirements into OSW's Quality Management Plan.
Develop infrastructure, technical architecture, performance requirements, and data quality checks and build new information management systems that are developed through the IBM methodology i.
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Develop interface mechanisms with existing internal Agency information management systems e. Develop methods to build trust among stakeholders in RCRA program direction. Develop or use an existing tracking system that is reasonable in cost, efficient, and accurate. This tracking system should be accessible by facilities. Develop revised regulations based on feedback from stakeholders that are easier to understand, easier to comply with, and more cost-effective to implement for both the regulators and the regulated community that maintain the same level of environmental protection.
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Develop statutory recommendations, as needed, to change contentious portions of existing regulations e. Develop strategic, prioritized program plans that incorporate Agency environmental priorities e. Use Information Engineering Methodology IBM to determine the essential information needs so that the program drives the information instead of the information driving the program and to facilitate the sharing of information of common interest throughout the program offices.
Eliminate redundancy of data input between existing and developing data systems using such tools as relational databases, where possible, and electronic quality verification checks to increase quality and reliability of the data, to reduce the burden on data generators and managers, and to increase the timeliness of data submissions, review, and verification. Encourage public participation hi the permitting process to allow community-based decisions and consider risk reductions.
Encourage waste minimization as an alternative to permits on a multi-media basis and provide flexibility in existing permits for the facility to initiate waste minimization with a minimum of permit modifications. Ensure that industry and waste definitions e. Ensure that enforcement decisions are coordinated with the most up-to-date Agency policy and existing regulations, with due consideration of the potential of future regulations and policy that may damage the success of enforcement.
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Ensure that implementation decisions are coordinated with the most up-to-date Agency policy and are within the flexibility of existing regulations, with due consideration of regulations and policy hi the developmental stages. Ensure that shipments of hazardous wastes within the United States are properly accounted for i. Establish a team of technical and policy experts from RCRA programs that will coordinate with stakeholders and establish a set of acceptable and understandable national goals for improvements hi environmental indicators derived from the RCRA hazardous wastes.
Establish consistent definitions of data elements used by various RCRA information systems in order to facilitate information sharing and comparison of data obtained through different reporting mechanisms. Establish roles for headquarters and regions. Establish program and site-specific implementation plans that demonstrate a reasonable balance of resources between paperwork compliance and field compliance to produce a higher level of environmental protection and more timely reduction in risks.
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Exhibit leadership in program development and implementation, ensuring consistency with agreed upon approaches. Facilitate the adoption and effective implementation of the Waste Minimization National Plan by states and regions that incorporates a hierarchy of elimination, source reduction, recycling, treatment, incineration, and then disposal. Improve the science that underlies the basis of environmental protection.
Incorporate a philosophy of continuous improvement in all program development and implementation activities. Incorporate flexibility into programs while maintaining protection of human health and environmental goals.
Incorporate quality assurance controls and peer review into all program areas. Incorporate the precepts of ongoing regulatory re-invention projects into the ongoing development of new regulations and standards that are mandated or court-ordered for EPA to produce. Incorporate what the public and stakeholders would consider common sense into program development and implementation activities. Integrate cost considerations into all activities and attempt to maintain a balance of environmental protection with sustainable development of United States industries.
Integrate traditional and non-traditional enforcement and compliance tools. Investigate and develop new non-regulatory alternatives to either new or existing regulations that will achieve the underlying environmental goals driving the need for the specific regulation. Investigate the establishment of enforceable agreements with facilities or other facility-specific agreements to achieve environmental success in lieu of new regulations i.
Make full use of advanced technologies and design information systems that cut costs, boost productivity, enhance communications, speed the flow of information, are less resource intensive to maintain, and are adaptable to new and changing information needs. Make full use of advanced technologies to cut costs, boost productivity, enhance communications, and speed to the flow of information.
Obtain access and interface with other information and data systems managed by other stakeholders and partners e. Propose and promulgate revisions to regulations and policy to facilitate implementation. Provide and maintain cost-effective support services to information systems, database users, and non- automated information systems in daily and long-term problems, including access, passwords, authorized use of confidential business information, and software and hardware problems. Provide more empowerment and responsibility to stakeholders and less EPA command and control. Reduce potential for cross-media transfer of hazardous constituents from the management of hazardous wastes and develop multi-media approaches to program development and implementation.
Reduce the information burden on stakeholders, partners, and program implementation. Reinvent and streamline the RCRA program through revisions in regulations, permitting, corrective action, compliance, and enforcement procedures. Simplify enforcement documents, such as inspection reports to expedite enforcement response and followup.
Streamline and improve the effectiveness of the process of enforcement so that emphasis can be shifted from this process to achieving results i. Streamline the authorization process to make timely authorization decisions based on due consideration of available administrative resources and the effective transfer of national policy. Make any necessary regulatory changes to authorization procedures that would expedite the authorization process.
Streamline the RCRA program to account for decreasing budgets and resources by determining priorities and cost-effective solutions for both developing and implementing the program. Support the Office of General Counsel OGC in negotiating settlements with litigants in technical, policy, legal, and scheduling issues, in lieu of further interaction in the courts. Work with partners to establish the use of performance-based standards, where feasible.
Work with partners to move toward alternatives to the existing permit process and to develop ways to obtain compliance other than by permits. Collate and report information on success in reducing facility risks by using flexible alternatives of enforcement and compliance. Coordinate the ongoing findings of the WIN initiative with other ongoing Agency initiatives to determine a list of prioritized national environmental indicators that will be used to track environmental progress specific to the RCRA hazardous waste program.