ENVIRONMENTAL COMPLIANCE PROGRAM

NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION

U.S. DEPARTMENT OF COMMERCE

Office of Procurement, Grants, and Administrative Services

Construction Staff

August 30, 1995
Revised: May 22, 1996
REVISED: August 5, 1996

BACKGROUND INFORMATION

The purpose of this document is to provide guidance to Line Offices, Office of NOAA Corps Operations (ONCO), Office of Finance and Administration (OFA) on estimating wastes and hazardous materials management (sometime referred to as "HazMat management") costs at NOAA facilities for budget purposes. HazMat management costs are necessary annual operation and maintenance (O&M) costs associated with environmental compliance activities. The HazMat management costs are a mandatory companion to two other components of NOAA's budget; which are, (1) pollution control and treatment project costs, (2) remedial environmental project costs. In addition and of secondary importance, the HazMat management costs also include Chief Financial Officers Act annual financial statement activities (such as: collecting cost information concerning contingent liabilities - environmental cleanup and capital expenditures for environmental control facilities) costs and environmental compliance audits costs & associated costs (see Table 4).

The U.S. Environmental Protection Agency (EPA) recognizes that O&M costs, like HazMat management costs, are an essential part of complying with environmental requirements. According to EPA, HazMat management costs are one element of "Program Management" costs, and EPA has designated these cost as "Class 0" (see Federal Agency Environmental Management Program Planning Guidance of October 1994, pages 2-12, 2-22 and 2-28).

For NOAA budget purposes, the portion of "Class 0" costs attributable to a specific Line Office or ONCO is designated as "Class A" costs. This means, the sum of all NOAA facilities' Class A costs is the HazMat management costs.

Class A costs are defined as those activities and items necessary to meet annual operation and maintenance (O&M) costs associated with wastes and hazardous materials management. In general, these annual costs include activities and items that are associated with (1) the safe, environmentally sound, and cost-effective: treatment, storage, transport, and disposal of wastes and hazardous materials resulting from NOAA activities; (2) the proper handling and day-to-day management of wastes and hazardous materials resulting from NOAA activities. Some examples of Class A cost activities and items are:

• Replacement supplies and materials utilized or consumed in managing wastes and hazardous materials (such as labels, markers, spill sorbant pads and materials, disposable protective clothing and equipment, chemical test kits);
• Annual service fees required to operate facilities is associated with pollution abatement (such as underground storage tanks operational permits, sewer charges);
• Operational costs associated with wastes and hazardous materials handling and management (such as treatment, storage, transport, and disposal costs; and annual underground tank tightness testing);
• Maintenance costs associated with wastes and hazardous materials facilities (such as maintenance for wastewater pre-treatment, oil-water separators, solvent distillation units associated with pollution prevention, alarms systems associated with pollution abatement);
• Annual operation and maintenance costs associated with hazardous waste minimization and pollution prevention;
• Mandatory training required by environmental, safety and health laws and regulations concerning the handling and management of wastes and hazardous materials;
• Any other necessary and reasonable costs associated with the day-to-day on-site managing of wastes and hazardous materials.

DETERMINING CLASS "A" COSTS

Ideally, for budget purposes Class A costs should come from each facility's records and past experience. This cost information can be collected in a format like Table 1 for each facility. These tables provide justification and documentation for the Line Office's or ONCO's budget needs.

In the absence of detailed facility cost information, the Line Office or ONCO may wish to estimate Class A costs. One method to estimate these costs is to follow these steps:

1. Group facilities into two, three or four major categories of facilities based on size and type of activities. Such as:

• for NMFS
  Group 1 = major laboratories
  Group 2 = field research stations
  Group 3 = administrative building
• for ONCO
  Group 1 = Pacific Marine Center and Atlantic Marine Center
  Group 2 = Aircraft Operations Center
  Group 3 = minor vessel berthing facilities
  Group 4 = vessels
• for NWS Group 1 = weather forecasting offices
  Group 2 = administrative installations

2. For each facilities group develop generic costs for a typical facility using Table 2 as a checklist of cost activities and items. Table 3 provides some suggested default cost estimates for various items.

3. Multiply the generic total cost for a facility by the number of facilities in the group to obtain the group total cost.

4. Sum all of the groups' total costs to obtain your Line or Staff Office's total costs.

TABLE 1

NAME OF LINE OR STAFF OFFICE _______________________

COSTS FOR (name of facility) _________________________

TABLE 2

NAME OF LINE OR STAFF OFFICE _______________________

COSTS FOR (name of facility) _________________________

TABLE 3

SUGGESTED DEFAULT COSTS

TABLE 4

OFFICE OF FINANCE AND ADMINISTRATION
COSTS FOR CHIEF FINANCIAL OFFICERS ACT ACTIVITIES AND ENVIRONMENTAL COMPLIANCE AUDITS AND ASSOCIATED ACTIVITIES