• December 2011 - EPA Releases Final Health Assessment for TCE and the November 2011 RSLs
    EPA TCE NEWS RELEASE

    The U.S. Environmental Protection Agency (EPA) has released the Final Health Assessment for trichloroethylene (TCE), and it has been incorporated into the Integrated Risk Information System (IRIS), a primary source for the risk-based screening values in the EPA Regional Screening Level (RSL) database.  The RSLs are a primary resource for standards set by states and EPA for safe drinking water, air emissions, and contaminated property cleanups. TCE is one of the most common man-made chemicals found in the environment and is frequently found at Superfund sites.  It is a volatile chemical and a widely used chlorinated solvent.

    WHY IS THIS IMPORTANT?

    The final assessment provides federal, state, local and other policy makers with the latest scientific information to make decisions about cleanup and other actions for protection of human health. It will be used to establish cleanup goals for all affected environmental media, and specifically for groundwater and vapor intrusion pathways that may be risk-drivers for site cleanups.

    This assessment characterizes TCE as carcinogenic to humans, and also as a significant noncarcinogenic health hazard.  However, it also goes further than previous assessments by designating TCE as a mutagen; therefore, increased early-life susceptibility and special calculations are required to develop screening levels for land uses that include exposure to children. Based on the revised TCE risk assessment, more stringent cleanup and remedial activities are expected.

    The revised TCE toxicity values will affect a variety of regulatory programs including:

    • Superfund and RCRA sites where TCE has been identified as a contaminant
    • Vapor intrusion sites that include TCE vapors moving from contaminated groundwater and soil into the indoor air of overlying buildings
    • Revising EPA’s Maximum Contaminant Level for TCE as part of the carcinogenic volatile organic compounds group in drinking water, as described in the agency’s drinking water strategy
    • Developing appropriate regulatory standards limiting the atmospheric emissions of TCE – a hazardous air pollutant under the Clean Air Act

    In addition, because TCE is such a ubiquitous chemical, there is the potential for a site to be “reopened” and subject to additional investigation and remediation. The reopener action varies by state and federal agency involved, but there is always a possibility that a no further action can be rescinded and additional risk assessment and/or cleanup required. This is especially true for sites where vapor intrusion was not considered or not fully evaluated, and where the updated toxicological evaluations of certain hazardous substances like TCE result in regulatory agencies revisiting sites long since closed.

    In an evaluation of the EPA TCE news release by BNA, Rizzuto (2011) indicates that there is uncertainty on cost consequences and impacts, such as on the vapor intrusion standards. Overall impacts will vary by state and site.  Furthermore, specific regulations that would be affected by the final IRIS TCE document have not been described (Rizzuto, 2011). Importantly, the EPA Offices for water, air, and solid waste have all indicated that their regulatory programs will be addressing the new risk assessment results.

    EPA RSLs

    The EPA RSLs are used as risk-based screening tools for many federal and state programs to determine if there is a potential need for further investigation and/or a site-specific risk assessment regarding cleanup of a site. Based on the current revisions, changes to the RSLs will be both chemical specific and based on individual chemical toxicities and risk drivers (i.e., carcinogenic versus noncarcinogenic), or will be universal and incorporate changes in the major exposure pathways.  For example, dermal exposure to tapwater equations will now follow the Risk Assessment Guidance for Superfund Part E guidance, and noncarcinogenic tapwater RSLs will now be calculated based on a child exposure scenario instead of an adult.

    For more information on the EPA Final Health Assessment for TCE and the updated EPA RSLs, please contact Amy Bauer at 251-533-6949 and amy.bauer@ehs-support.com, or Chrissy Peterson at 412-925-1385 and chrissy.peterson@ehs-support.com.

    Rizzuto, P. (2011, September 29). Trichloroethylene causes human cancer, harms fetal development, EPA says.  BNA.  Retrieved October 7, 2011, fromhttp://www.bna.com/trichloroethylene-causes-human-n12884903636/

    EPA.  (2011, September 28).  EPA Releases Final Health Assessment for TCE. Retrieved October 7, 2011, from            http://yosemite.epa.gov/opa/admpress.nsf/0/B8D0E4D8489AD991852579190058D6C3

    EPA. (2011, September 28). IRIS Summary of Trichloroetheylene (CASRN 79-01-6). Retrieved December 6, 2011, from http://www.epa.gov/iris/subst/0199.htm.
  • November 2011 - Top 10 OSHA Citations in FY 2011

    The Occupational Safety and Health Administration (OSHA) has published data summarizing the 10 most frequently cited standards, as well as highest penalty amounts for fiscal year (FY) 2011 (October 2010 through September 2011).

    What are the results?

    The “Top 10” most frequently cited standards make up almost 44 percent of the citations issued.   Fall protection and scaffolds (construction standards 1926) remain at the top of the list of cited standards; lockout/tagout violations (general industry 1910 standards) was the highest penalty levied.
    Fall protection and scaffolding (construction), hazard communication, respiratory protection, and control of hazardous energy (lockout/tagout) (general industry) rounded out the top five most frequently cited standards.
    FY 2011 Top 10 most frequently cited standards:

    1. Duty to have fall protection, construction (29 Code of Federal Regulations – CFR 1926.501).
    2. Scaffolds, general requirements, construction (29 CFR 1926.451).
    3. Hazard communication standard, general industry (29 CFR 1910.1200).
    4. Respiratory protection, general industry (29 CFR 1910.134).
    5. Control of hazardous energy (lockout/tagout), general industry (29 CFR 1910.147).
    6. Electrical, wiring methods, components and equipment, general industry (29 CFR 1910.305).
    7. Ladders, construction (29 CFR 1926.1053).
    8. Powered industrial trucks, general industry (29 CFR 1910.178).
    9. Electrical systems design, general requirements, general industry (29 CFR 1910.303).
    10. Machines, general requirements, general industry (29 CFR 1910.212).


    FY 2011 Top 10 highest penalties:

    1. Duty to have fall protection, construction (29 CFR 1926.501).
    2. Scaffolds, general requirements, construction (29 CFR 1926.451).
    3. Control of hazardous energy (lockout/tagout), general industry (29 CFR 1910.147).
    4. Machines, general requirements, general industry (29 CFR 1910.212).
    5. Ladders, construction (29 CFR 1926.1053).
    6. Excavations, requirements for protective systems, construction (29 CFR 1926.652).
    7. Powered industrial trucks, general industry (29 CFR 1910.178).
    8. General duty clause (Section 5(a)(1) of the OSH Act).
    9. Electrical, wiring methods, components and equipment, general industry (29 CFR 1910.305).
    10. Electrical systems design, general requirements, general industry (29 CFR 1910.303).

    How does this compare to last year?
    Not surprisingly, the top ten most frequently cited standards and highest penalty standards for FY 2011 are consistent with FY 2010.  Workers play an important role in program implementation and  proper employee instruction and, for this reason, guidance is crucial: hence OSHA’s scrutiny.  A comprehensive health and safety program should be the goal of every company; however, while we do not encourage too great a reliance on this list, it is a great tool to identify standards that are chronic problems at other facilities to ensure that adequate resources are provided in those areas at your own.

    Where can we find this information?
    OSHA maintains a website that provides resources to help employers and workers understand OSHA requirements.  In addition to the most cited standards, the website also provides the most asked questions, frequently requested publications, and other resources.  Go to http://www.osha.gov/dcsp/compliance_assistance/index.html for OSHA compliance assistance/outreach, or contact Amy Bauer at 251-533-6949 and amy.bauer@ehs-support.com for more information.

  • August 2011 - EHS Support, Inc. is proud to announce the promotion of Nigel Goulding to Chief Technical Officer.
    In this capacity, Nigel will take on the management of our rapidly expanding Remediation Services group.  Nigel has over 18 years of experience dealing with environmental remediation in the United States, Asia Pacific, and Europe and has been integral to the rapid growth we have experienced in 2010 and 2011. Our remediation staff has more than tripled in the last year and a half to meet our clients’ requests and we are focusing on hiring industry technical leaders who are client-focused to continue the quality and level of service that you have come to expect from EHS Support. Nigel’s inclusion in the management team will be used to ensure our continued focus on development of the Remediation Services group as a market leader which provides quality, value, and a level of service unparalleled in the market.“2010-2011 has been an exciting year and a half working with our clients on a variety of challenging projects.  EHS Support is truly blessed with both great clients and staff and our growth in 2010-2011 and key hires should ensure that 2012 is as equally memorable.”-Nigel Goulding, Chief Technical Officer, EHS Support Inc. • nigel.goulding@ehs-support.com
  • July 2011 - The Importance of Thorough Diligence for Environmental Risk

    The importance of thorough diligence for environmental risk was highlighted in a recent Kentucky federal court decision for 500 Associates, Inc. v. Vermont American Corporation that involved the cleanup of a former saw blade and hand tool manufacturer.   Simply completing due diligence is not sufficient to meet the “due care” obligations under the “innocent landowner” defense in Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 U.S.C. §§9601 et seq.

    Background

    During its extensive operating history from 1949 to 1986, the manufacturer generated various hazardous wastes associated with its electroplating and heat treatment operations (500 Associates, 2011).  When the manufacturing facility closed in 1986, a group of commercial real estate developers entered into a contract to purchase the property and retained an environmental consultant to perform a cursory environmental audit.  The audit found chromium contamination existed at the site; however, soil samples were collected and the auditor did not recommend further testing or review of publically available records to determine the extent of potential contamination.  This review would have revealed that the manufacturer released untreated wastewater and hazardous substances on numerous occasions during its ownership (Rubrecht, 2011).

    In 1990, after the developer purchased the site, it demolished a portion of a building in the area of the former electroplating and waste treatment operations, and moved concrete and exposed impacted soils in the process (500 Associates, 2011).  The same year, the developer agreed to sell the property to an advertising agency, which hired its own consultant to conduct an environmental audit.  This audit included a review of public records, and sampled soil and groundwater.  The audit revealed various contaminants in soil and groundwater including the presence of hazardous substances below the concrete floors that the developer demolished.  In 1991, a third consultant was hired by the developer, only this time when soil and gas samples confirmed hazardous substances, the consultant concluded that the source was another property.  The advertising agency ultimately withdrew from the purchase agreement.

    Outcome

    The developer did not report any of the audit results to the Kentucky Department of Environmental Protection (DEP) and failed to take remedial action (Rubrecht, 2011).  A four year investigation of the property was initiated by the DEP in 1994, which subsequently filed an enforcement action against the developer and manufacturer.  After a lengthy legal process, almost 20 years after the initial contract between the developer and the manufacturer, the Kentucky Court of Appeals issued a final decision in the enforcement action finding substantial evidence to uphold the determination that the developer failed to exercise “due care” in the management of the property and thus, was not entitled to the benefit of an “innocent purchaser” defense based the inadequate initial investigation (Rubrecht, 2011).  Furthermore, the developer failed to exercise due care when it demolished structures on the site and then took no action to remedy the property once it knew of the contamination.  Two years later, the DEP issued a final cleanup order, which determined that the manufacturer was completely responsible for characterizing and remediating the release of contaminants.

    As for the developer, in a cost-recovery action pending in federal district court in Kentucky, the court concluded that the developer could not recover its costs because CERCLA “does not sanction willful or negligent blindness.”  While the developer was not required to characterize or remediate the site, it was civilly fined and denied recovery of its costs associated with environmental investigation of the site (Rubrecht, 2011).  This penalty does not include the inconvenience of time and expense of consulting and attorney fees to defend their actions from the contract to purchase the site in 1986 until the district court rendered a decision in 2011.

    The developer’s failure to exercise due care is an important lesson to be learned for purchasers and developers of distressed properties, licensed remediation specialists, environmental consultants preparing Phase I reports, lending institutions requesting or relying upon Phase I reports, and anyone involved in brownfields transactions (Rubrecht, 2011).  The court concluded that a corporation was not entitled to recover costs under the CERCLA of 1980, 42 U.S.C.S. § 9607(a)(4)(B), because the costs could not be shown to have furthered the response cleanup of property, rather the costs were incurred for the corporation’s own business purposes or were incurred in the course of attempting to convince the DEP that the corporation had no liability (500 Associates, 2011).  The extra expense to complete thorough due diligence as during a real estate transaction reduces risk and cost.

    References

    Rubrecht, G.L. (June 1, 2011). Federal Court Denies Cost Recovery, Finding Purchaser Acted With Willful Blindness. Retrieved June 23, 2011, from http://eem.jacksonkelly.com/2011/06/page/2/

    500 Associates, Inc. v. Vermont American Corporation, 3:96CV-847-S (M.D. Ken. 2011)

    For more information about reducing your risk, contact Amy Bauer at 251-533-6949 or amy.bauer@ehs-support.com.

  • June 2011 - Basic Requirements of the Spill Prevention, Control, and Countermeasure (SPCC) Rule

    THE FACTS:

    The Spill Prevention, Control, and Countermeasure (SPCC) rule includes requirements for oil spill prevention, preparedness, and response to prevent oil discharges to navigable waters and adjoining shorelines. The rule requires specific facilities to prepare, amend, and implement SPCC Plans. The rule is part of the Oil Pollution Prevention regulation at 40 Code of Federal Regulations (CFR) Part 112, which was amended in the past few years, most recently in November 2009.
    This summary describes how a facility may be subject to Part 112 and outlines the basic requirements of the SPCC rule.

    IS MY FACILITY AFFECTED BY THE SPCC RULE?

      • The definition of oil is very broad and includes both petroleum and non-petroleum oils, such as animal and vegetable, synthetic, and soluble oils.
      • Must be a non-transportation-related facility:
    • Engaged in drilling, producing, gathering, processing, refining, transferring, distributing, using, or consuming oil and oil products.
    • For example, operations may include vehicle maintenance and refueling; bulk storage (drums, tanks); wastewater treatment; oil-filled equipment; loading racks, transfer hoses, and loading arms, highway vehicles and railroad cars, and pipeline systems all within confines of non-transportation-relate facility.
      • Must also store oil or petroleum products in greater than threshold quantities:
    • A total aboveground storage capacity (not actual amount stored) of 1,320 gallons.
    • More than 42,000 gallons of underground storage capacity (excludes tanks regulated under federal or state underground storage tank program).
    • Use containers 55-gallons or greater to calculate SPCC storage capacity.
    • There are some exceptions, such as permanently closed containers/tanks.
      • Facility is regulated if, due to location, a discharge in harmful quantities could reasonably be expected to reach a waterway:
    • Harmful discharge may cause a sheen or discoloration to surface water or adjoining shorelines; sludge or emulsion beneath surface water or adjoining shorelines; or violates applicable water quality standard.
    • Consider location of facility in relation to a stream, ditch, gully, or sewer; the volume of material likely to be spilled; drainage patterns; and soil conditions.
    • Do not consider man-made features such as dikes in making this determination.

    HOW DO I COMPLY WITH THE SPCC REQUIREMENTS?

    If subject to the SPCC rules, there are two basic requirements:

    • Provide adequate secondary containment for oil or petroleum product storage and transfer areas to contain releases.
    • Prepare and implement a written SPCC Plan that must be updated at least every 5 years.
    • SPCC Plan must be certified by professional engineer (PE) familiar with facility unless you meet the requirements to self-certify the plan (i.e., Tier I and II Qualified Facility – see below):
      • Have 10,000 gallonsor less in aggregate aboveground oil storage capacity.
      • For the three years prior to plan’s certification date, had no discharges of oil to waters of the state that exceed:
        • A single discharge of 1,000 gallons of oil.
        • Two discharges of more than 42 gallons of oil in a 12 month period.
    • If Tier I Qualified Facility meets the aforementioned requirements and has no individual aboveground oil container greater than 5,000 gallons, can complete and self-certify Plan template in lieu of full PE-certified Plan or other self-certified SPCC Plan. The Tier I plan template can be found at http://www.epa.gov/emergencies/content/spcc/tier1temp.htm#ext1
    • If Tier II Qualified Facility meets the aforementioned requirements, but has individual aboveground oil container greater than 5,000 gallons, can prepare a self-certified Plan in accordance with §112.7 and subparts B or C of the rule in lieu of PE-certified Plan.
    • If using alternative methods that provide equivalent environmental protection, or determine that secondary containment is impracticable, then a PE must review and certify only those aspects of the plan (i.e., hybrid plan)

    A facility, including a mobile or portable facility starting operation…

    Must…

    On or before August 16, 2002

    • Maintain existing SPCC Plan, revise every 5 years
    • Amend and implement the amended SPCC Plan no later than November 10, 2011

    After August 16, 2002 through November 10, 2011

    Prepare and implement an SPCC Plan no later than November 10, 2011

    After November 10, 2011 (excluding production facilities)

    Prepare and implement an SPCC Plan before beginning operations

    After November 10, 2011 (production facilities)

    Prepare and implement an SPCC Plan within six months after beginning operations.

    For more information on the SPCC Rule, or cost-effective assistance with preparing a plan, please contact Amy Bauer at 251-533-6949 and amy.bauer@ehs-support.com or Kate Gibson 732-598-3293 and kate.gibson@ehs-support.com

  • March 2011 - EPA Extends Deadline for GHG Reporting to September 30, 2011

    The U.S. Environmental Protection Agency (EPA) announced they are extending the deadline for reporting 2010 greenhouse gas (GHG) emissions data to September 30, 2011.

    EPA is working on finalizing a user-friendly online reporting platform – an XML reporting schema provided through the e-GGRT (Electronic Greenhouse Has Reporting Tool). This tool will allow facilities to directly upload their data in lieu of using web forms.

    The extension will allow EPA to further test the system and give industries the opportunity to test the tool, provide feedback, and have sufficient time to become familiar with the tool before the reporting deadline.

    This action also extends the online registration deadline to August 1, 2011, 60 days before the reporting deadline.  If your company has already registered with e-GGRT there is no need to register again.

    HOW WILL MY COMPANY BE AFFECTED?

    Companies that must report GHG data for facilities and suppliers covered by 40 CFR 98 will now directly upload their data into the e-GGRT system rather than submitting through web forms.

    WHAT CAN I DO TO PREPARE?

    For more information on the EPA’s mandatory GHG reporting program, or for assistance with your reporting, please contact Amy Bauer at 251-533-6949 and amy.bauer@ehs-support.com or Jessica Tierney at 412-779-1094 and jessica.tierney@ehs-support.com.

  • January 2011 - EHS Support Corporation is proud to announce the promotion of Andy Patz to President.
    This position reflects Andy’s dedication and commitment to our company, clients, and employees and his critical role in the day-to-day operations of the business. Andy has over 16 years of experience in the environmental consulting industry, which has focused on remediation, financial risk management, and mergers and acquisitions.  His past management experience and his active involvement in EHS Support’s management team over the last 5 years have uniquely prepared him for this position. Andy’s daily role with our clients will not change; he will remain committed to ensuring your satisfaction and bringing you the quality and service that you have come to expect from EHS Support. His additional responsibilities will include close interaction with EHS Support’s management team to guide and focus our ongoing growth and ensuring our clients’ needs are met and expectations exceeded.“We developed a responsible growth plan over 5 years ago for EHS Support that focused on working with the best clients, attracting and retaining the industry’s finest consultants, and providing service and responsiveness that is unparalleled.  Our clients have provided us with the opportunity to continue to grow to meet their needs and we are excited for the opportunity to exceed their expectations in 2011.”-Andrew Patz, President, EHS Support Inc.

    andy.patz@ehs-support.com

  • January 2011 - EHS Support, Inc. is proud to announce the promotion of Nigel Goulding to Chief Technical Officer.

    In this capacity, Nigel will take on the management of our rapidly expanding Remediation Services group.  Nigel has over 18 years of experience dealing with environmental remediation in the United States, Asia Pacific, and Europe and has been integral to the rapid growth we have experienced in 2010 and 2011. Our remediation staff has more than tripled in the last year and a half to meet our clients’ requests and we are focusing on hiring industry technical leaders who are client-focused to continue the quality and level of service that you have come to expect from EHS Support. Nigel’s inclusion in the management team will be used to ensure our continued focus on development of the Remediation Services group as a market leader which provides quality, value, and a level of service unparalleled in the market.“2010-2011 has been an exciting year and a half working with our clients on a variety of challenging projects.  EHS Support is truly blessed with both great clients and staff and our growth in 2010-2011 and key hires should ensure that 2012 is as equally memorable.”-Nigel Goulding, Chief Technical Officer, EHS Support Inc.

    nigel.goulding@ehs-support.com

  • January 2011 -EPA Releases FY 2011-2015 Strategic Plan

    The plan is intended to provide a blueprint for accomplishing priorities over the next five years. It identifies five strategic goals that sets the Agency’s direction, advances the Administrator’s priorities, and will be used routinely by the Agency’s senior leadership as a management tool.

    How Will These Goals Impact My Company?

    Various industries may see increased enforcement, particularly with air, water, cleanup activities, and chemical management, which were all areas highlighted in the plan. The impact will be realized as each of the strategic goals is implemented. Some of the components for each goal have already become legislation and are now underway, such as the GHG Rule, which was part of EPA’s efforts in 2010 to cut carbon emissions. Some goals or objectives may prompt new legislation, such as developing new drinking water standards, or promote EPA-sponsored resources such as the ToxRefDB, a web-based chemicals database, which was developed earlier this year to allow anyone to search and download toxicity testing results on hundreds of chemicals in an effort to support EPA’s policy of increasing the transparency of chemical information.

    EPA’s 5 Strategic Goals:
    The five goals are listed below with the objectives for each goal and an example of how the EPA plans to implement each goal.

    Goal 1: Taking Action on Climate Change and Improving Air Quality
    Objectives:

    • Address Climate Change. Reduce the threats posed by climate change by reducing greenhouse gas emissions and taking actions that help communities and ecosystems become more resilient to the effects of climate change.
    • Improve Air Quality. Achieve and maintain health-based air pollution standards and reduce risk from toxic air pollutants and indoor air contaminants.
    • Restore the Ozone Layer. Restore the earth’s stratospheric ozone layer and protect the public from the harmful effects of ultraviolet (UV) radiation.
    • Reduce Unnecessary Exposure to Radiation. Minimize unnecessary releases of radiation and be prepared to minimize impacts should unwanted releases occur.

    Example:

    • Reduce greenhouse gas (GHG) Emissions and Develop Adaptation Strategies to Address Climate Change.

    Goal 2: Protecting America’s Waters
    Objectives:

    • Protect Human Health. Reduce human exposure to contaminants in drinking water, fish and shellfish, and recreational waters, including protecting source waters.
    • Protect and Restore Watersheds and Aquatic Ecosystems. Protect the quality of rivers, lakes, streams, and wetlands on a watershed basis, and protect urban, coastal, and ocean waters.

    Exmaple:

    • EPA has established two Priority Goals for the revision of drinking water standards to strengthen public health protection and the development of state watershed implementation plans in support of the Chesapeake Bay total maximum daily load (TMDL) called for in the Chesapeake Bay Protection and Restoration Executive Order.

    Goal 3: Cleaning Up Communities and Advancing Sustainable Development
    Objectives

    • Promote Sustainable and Livable Communities. Support sustainable, resilient, and livable communities by working with local, state, tribal, and federal partners to promote smart growth, emergency preparedness and recovery planning, brownfield redevelopment, and the equitable distribution of environmental benefits.
    • Preserve Land. Conserve resources and prevent land contamination by reducing waste generation, increasing recycling, and ensuring proper management of waste and petroleum products.
    • Restore Land. Prepare for and respond to accidental or intentional releases of contaminants and clean up and restore polluted sites.
    • Strengthen Human Health and Environmental Protection in Indian Country. Support federally-recognized tribes to build environmental management capacity, assess environmental conditions and measure results, and implement environmental programs in Indian country.

    Example:

    • To reduce the risk posed by underground storage tanks (USTs) located at nearly a quarter of a million facilities throughout the country, EPA and states are working to ensure that every UST system is inspected at least once every three years.

    Goal 4: Ensuring the Safety of Chemicals and Preventing Pollution
    Objectives:

    • Ensure Chemical Safety. Reduce the risk of chemicals that enter our products, our environment, and our bodies.
      Promote Pollution Prevention. Conserve and protect natural resources by promoting pollution prevention and the adoption of other stewardship practices by companies, communities, governmental organizations, and individuals.

    Example:

    • In 2009, the Administration announced principles for modernizing the Toxic Substances Control Act (TSCA) to help inform efforts underway in Congress to reauthorize and significantly strengthen EPA’s ability to assess the safety of industrial chemicals and adequately protect against unreasonable environmental or public health risks.

    Goal 5: Enforcing Environmental Laws
    Objective:

    • Enforce Environmental Laws. Pursue vigorous civil and criminal enforcement that targets the most serious water, air, and chemical hazards in communities. Assure strong, consistent, and effective enforcement of federal environmental laws nationwide.

    Example:

    • EPA is revamping enforcement and working with state permitting authorities under the Clean Water Act Action Plan to make progress on the most important water pollution problems. This work includes, as a Priority Goal, increasing enforcement actions in waters that do not meet water quality standards.

    The progress of the five goals will be tracked through annual performance measures, which are presented in EPA’s Annual Performance Plans and Budgets. The plan also includes five “cross-cutting fundamental strategies” aimed to focus EPA’s work over the next five years, which are listed below:

    • Expanding the Conversation on Environmentalism.
    • Working for Environmental Justice and Children’s Health.
    • Advancing Science, Research, and Technological Innovation.
    • Strengthening State, Tribal, and International Partnerships.
    • Strengthening EPA’s Workforce and Capabilities.

    If you have any questions regarding the EPA Released FY 2011-2015 Strategic Plan, please contact Amy Bauer at 251-533-5949 and amy.bauer@ehs-support.com
    For more information, go to http://www.epa.gov/ocfo/plan/plan.htm