Federal Facilities Compliance Act Table

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Requirement	Description & EPA Responsibility
Waiver of Sovereign Immunity	States have the ability to sue the Federal government and collect fines and penalties.
Section 3008(a) Order Authority	EPA shall initiate administrative enforcement actions against the Federal government in the same manner and under the same circumstances as actions would be initiated against any other person. No administrative order shall become final until the Federal government has had the opportunity to confer with the Administrator.
Comprehensive Environment Inspections	The EPA Administrator is required to undertake inspections at all Federal treatment, storage, and disposal facilities for hazardous waste. The owner or operator shall reimburse the EPA for costs of the inspections.
Groundwater Inspections	The EPA Administrator shall conduct a comprehensive groundwater monitoring evaluation at Federal facilities.
Mixed Waste	DOE must submit two inventory reports within 180 days of October 6, 1992: 1) a national inventory of all its mixed wastes regardless of the time they were generated on a state-by-state basis; and 2) a national inventory of its mixed waste treatment capacities and technologies. Both EPA and the state have 90 days to comment. DOE will then develop a plan for developing treatment capacities and technologies to treat all the mixed wastes to standards in RCRA. Upon approval of the plan, EPA, or the delegated state, shall issue an order requiring compliance with the approved plan. OFFE has convened a workgroup to address the various requirements of the mixed waste provisions of the FFCA. States will be major players in this process.
Munitions as Hazardous Waste	The EPA Administrator shall propose, after consulting with the Secretary of Defense and appropriate state officials, regulations identifying when military munitions become hazardous waste and providing for safe transportation and storage of such waste. Within 24 months of the April 6, 1992, EPA shall promulgate the regulations.
Federally Owned Treatment Works (FOTW)	Federal government is now eligible for domestic sewage exclusion provided that the exempted material meets pretreatment standards of Section 307 of the Clean Water Act. OFFE has formed a workgroup to develop guidance in order to implement this new FOTW provision. Moreover, OFFE may propose a rulemaking to ensure proper monitoring of the FOTW by the Federal agency.
Public Vessels Provision	Public Vessels are not subject to RCRA requirements until the waste is transferred to shore. This exemption disappears if the waste is stored on a vessel for more than 90 days when the vessel is placed in reserve or the waste is transferred to another public vessel within the territorial waters of the United States for more than 90 days after the date of transfer. This new amendment appears to be self-implementing.