100R86101
Agency
Operating Guidance
FY 1987
March 1986
-------
PREFACE
The FY 1987 Agency Operating Guidance updates the FY 1986-87
Operating Guidance published in February 1985. It reflects the
Administrator's Management Plan and the Agency's FY 1987 Priority
List, which follow, as well as the priorities of each of the
Assistant Administrators. The Guidance highlights the changes in
direction and emphasis since last year and provides the Regions
and States directions for planning and executing environmental
programs.
The Guidance was compiled by the Office of Policy, Planning
and Evaluation with the Headquarters media program offices and
the Office of External Affairs preparing individual sections.
Valuable input and comments were received from the Headguarters
program and staff offices, Regions and States. Our sincere thanks
to the many individuals who helped develop the final document.
-------
TABLE OF CONTENTS
I. INTRODUCTION
A. Administrator's Overview
B. Agency Priority List
II. PROGRAM OPERATING GUIDANCE
A. Office of Air and Radiation
B. Office of Water
C. Office of Solid Waste and Emergency Response
D. Office of Pesticides and Toxic Substances
E. Office of External Affairs
III. APPENDIX: STRATEGIC PLANNING AND MANAGEMENT SYSTEM
FY 1987 MEASURES
-------
ADMINISTRATOR'S OVERVIEW
Administrator's Management Plan
Over the last year, I have developed a six-point management
plan for the Agency. The plan contains the management goals I
have set for my term as EPA Administrator. While I have fre-
quently discussed these goals over the past year, I want to re-
affirm them here. Along with the FY 1987 Priority List, which
follows, they form the basis for the FY 1987 Agency Operating
Guidance.
First and foremost, we must continue implementation of EPA's
basic programs with a focus on achieving environmental results.
We will continue to use the management system developed in recent
years to help us identify our most significant problems, decide
how to resolve them, and measure our success. We want to refine
the system, however, to improve our ability to link our activities
to environmental results. In the past year, we initiated a stra-
tegic planning process to help us develop long-term plans for
resolving environmental problems. Through the process we hope to
broaden our traditional Headquarters and media-specific perspective
on environmental problems and solutions. We are currently develop-
ing plans to address wetland, hazardous waste, air toxic, estuary
and near coastal water, and agricultural chemical in ground water
problems. Over the next several years, we will develop strategic
plans for all our major environmental problems. In the future,
these strategies will significantly shape our annual operating
guidance and budget priorities. Our management system will track
our success in implementing our plans and solving our environmental
problems.
My second goal is to ensure a strong enforcement presence in
all of our Agency programs. It is extremely important that we
maintain a vigorous enforcement and compliance program which is
fully integrated into each media program and which addresses
localized environmental problems. We should make balanced use of
all our enforcement tools—administrative, civil, and criminal
actions—and follow-up to determine how effective we have been in
achieving compliance. The Regions should continue to make up-front
State/EPA enforcement "agreements." These agreements should in-
clude expectations for timely and appropriate enforcement response,
the appropriate use of penalties and other sanctions, and essential
communications among all parties involved in enforcement. We
must also work with the regulated community to encourage voluntary
compliance and to improve environmental management through such
initiatives as environmental auditing. Where other efforts fail,
EPA must, of course, be ready to step in as needed to take the
aggressive enforcement steps necessary to protect public health
and the environment.
-------
-2-
Third, we must continue to decentralize our programs and
delegate authority to the Regions and States and others where it
makes sense to do so. Over the last couple of years, the Regions
have made significant strides towards managing for environmental
results. Last year, we began working with several States to
analyze environmental problems using advanced risk assessment and
analytic tools. We must continue to work with the Regions and
States to help them develop and implement innovative programs for
achieving environmental results as quickly and efficiently as
possible. We must also change longstanding practices that impede
delegation and adopt policies that are supportive of Regional and
State initiatives to manage for environmental results. We must
also remember our responsibility to work with tribal governments
to develop programs to address environmental problems on Indian
lands.
It is important to recognize, however, that properly imple-
mented decentralization does not diminish the Federal role. Ef-
fective decentralization provides a clear definition of roles to
be played by Regional, State and other authorities. It promotes
efficiency and a system of mutual support. We must provide timely
guidance and technical assistance to those to whom we delegate
authority. We must also constructively oversee their efforts to
make sure they have the necessary legal and regulatory authorities
and are carrying out their responsibilities.
My fourth goal is to maintain our scientific credibility and
identify research priorities as part of our program planning. We
need to establish and maintain a strong quality assurance program
for our extensive environmental data collection activities in order
to ensure that our environmental data are of known and reliable
quality. An aggressive quality assurance program will strengthen
the scientific and technical underpinnings of our program and
regulatory decisions. Also critical to our success is our ability
to attract and keep good scientists. To the extent possible, we
need to provide opportunities for promotion and scientific recog-
nition as well as necessary state-of-the-art equipment.
My fifth goal is to reach out to the public and interested
parties. The American people have made clear they want to be
involved in critical environmental debates. We need to explain
to them what we are trying to do and why. We must listen and
respond to their concerns. We must earn their confidence. Our
continued success is dependent upon strong public support. The
Agency has made progress in reaching out to concerned citizens
and affected parties such as small businesses, but needs to
expand these efforts in the future.
My last goal is perhaps the most important. We must invest
more in the human resources that are so essential to the performance
of our programs. Any progress we make rests on the successes of
-------
-3-
individuals. The people at EPA and in -State and local governments
who are dedicated to achieving our environmental goals must be
given the necessary support and opportunity to achieve their very
best. Too often in the government we give short shrift to personnel
matters. I will do all I can to improve and enhance individual
growth and career opportunities through professional development,
individual mobility, and opportunities to participate in the
decision-making process.
Finally, as we implement ray six-point environmental management
plan, we must continue to look beyond our national boundaries. We
have always been a leader with respect to environmental programs.
We must continue to give attention to our work with other nations
to promote sound environmental practices worldwide. We will
cooperate with our neighbors to correct border difficulties and
will participate in multinational organizations to address global
threats like ocean and air pollution or dangers to the stratospheric
ozone layer. We will exchange with other nations regulations,
standards, management techniques, technologies and research.
Furthermore, EPA will attempt to harmonize pollution control
standards so as to prevent trade barriers or "pollution havens"
where manufacturers might compete unfairly with U.S. firms who
often, at great expense, comply with EPA regulations.
Agency Priority List
As Administrator, I have to decide what programs come first
among the many significant programs we are responsible for
implementing. For the third year in a row, we have developed an
Agency Priority List (see tab) to communicate to EPA, State and
local program managers those problems and activities which deserve
most of their time, energy and resources. The list relects the
recommendations of Headquarters, the Regions and States. It
identifies the work I consider most important for EPA and our
State and local partners if we are to achieve our environmental
goals.
The operating guidance identifies what Headquarters, Regions
and States should do in the priority areas and translates those
activities into Strategic Planning and Management System (SPMS)
measures. I endorse the priorities on the 1987 Agency Priority
List and will track progress against the SPMS measures for those
areas very closely.
The Agency Priority List is not intended to include everything
EPA and its State and local partners must do to fulfull various
statutory or judicial requirements. In fact, a number of those
nondiscretionary activities are not included on the list. The
Regions and States should address those other activities in accor-
dance with each Assistant Administrator's program guidance.
-------
Priority List
-------
AGENCY PRIORITY LIST FOR FY 1987
1. Reduce risks from exposure to existing pesticides and toxic
chemicals.
a. Reduce risks from existing pesticides. Accelerate the review
of existing pesticides through the registration standards
process. Conduct Special Reviews when the potential for
unreasonable adverse effects is present.
b. Reduce risks from existing toxic chemicals. Emphasize the
review of categories of chemicals and an exposure-based
program to identify, test and control existing chemicals
posing significant risk.
c. Improve ground water protection. Support the development of
State programs and methods to address uncontrolled sources
of contamination. Give priority to contamination from
hazardous waste, underground storage tanks and agricultural
chemicals.
d. Control drinking water contaminants. Implement VOC NPDWRs,
monitor unregulated contaminants, and promulgate additional
standards. Expand the health advisory program in support of
RCRA waste banning decisions, Superfund cleanup activities,
and control actions for agricultural chemicals. Work with
the States to ensure compliance with existing standards.
2. Reduce risks from disposal of hazardous waste and stabilize
imminent threats from uncontrolled hazardous waste sites.
a. Require proper management of permitted hazardous waste
facilities. Continue to promulgate RCRA regulations and
guidelines, take corrective action at solid waste management
units, and issue Part B permits. Increase enforcement actions
to obtain compliance. Give highest priority to enforcing
against Class I violations at land disposal facilities.
b. Control releases of uncontrolled hazardous waste. Stabilize
imminent threats, complete Superfund RI/FS and RCRA Corrective
Action plans, and initiate site clean-up. Pursue cost recovery
where Fund expenditures are involved.
c. Support development of additional hazardous waste treatment
and disposal capacity. Promulgate regulations and issue
permits that encourage alternatives to land disposal.
Address public concerns about the siting of these facilities.
d. In coordination with the States, focus underground injection
control permits and enforcement efforts on existing facilities
that present the greatest threat to underground sources of
drinking water. Undertake a review of underground injection
of hazardous wastes and initiate appropriate control actions.
-------
-2-
3. Reduce exposure to unhealthy air quality conditions, both indoors
and outside, giving highest priority to the control of hazardous
air pollutants.
a. Control air toxics. Continue to implement the national
strategy to improve preparedness and response capability
to accidental emergency releases. Increase State and local
agency capacity to address air toxics problems. Accelerate
Federal development of NESHAPs, controls for toxic fuel
additives and diesel vehicles, and controls for TSDFs.
b. Coordinate with the States to take necessary actions,
including enforcement against significant VOC sources, to
reduce ozone levels in areas that will not meet the 1987
attainment deadline.
c. Continue development and implementation of an assessment and
mitigation program for radon.
d. Overhaul national air pollution controls for particulate
matter. Implement the PM^g standard designed to protect
against the most severe particulate health impact. Adopt
strong State implementation Plans to control these particles.
e. Strengthen technical assistance and support development of
State contractor licensing and certification programs to
promote effective remedial actions for asbestos in schools
and public buildings. Implement and enforce asbestos NESHAPs.
4. Maintain and improve water quality by addressing point and
nonpoint sources of pollution.
a. Take every possible action with the States to meet the July
1, 1988 deadline under the National Municipal Policy. Fully
implement and enforce pretreatment requirements.
b. Focus on critical water quality problems. Implement nonpoint
source programs and develop and incorporate toxics criteria
into State water quality standards. Work through the States
to reissue NPDES major and environmentally significant
minor permits. Enforce permits and use whole effluent toxicity
monitoring and limits where necessary.
c. Protect near coastal waters. Design and implement a program
to protect these waters from further degradation. Restore
the most valuable estuaries to acceptable water quality.
Address the impacts of sludge disposal and ocean dumping
beyond the estuarine zone.
-------
-3-
5. Reduce damage to sensitive environmental areas.
a. Protect wetlands. Implement aggressively the Section 404
program. Enforce against unpermitted dischargers, expand
the use of Advanced Designation for priority wetlands, and
take other steps as appropriate.
b. Address acid deposition and other issues concerning the
long range transport of air pollutants. Evaluate damage
to lakes and forests through the acid deposition research
and analysis program. Complete work with the States on
standby regulatory mechanisms to control sources. Evaluate
the stratospheric impacts of chlorofluorocarbons (CFCs).
-------
Office of
Air and Radiation
-------
TABLE OF CONTENTS
I. INTRODUCTION 1
II. STRATEGY FOR THE AIR QUALITY PROGRAM
A. Major Program Goals and Objectives 1
B. Program Strategy for FY 1987 2
III. GUIDANCE FOR THE AIR QUALITY PROGRAM
A. Air Toxics 7
1. National Regulations 7
2. State and Local Air Toxics Programs .... 10
3. Multi-media, Multi-source Problems .... 12
B. National Ambient Air Quality Standards Attainment
1. State Implementation Plan Corrections . . 17
2. Stationary Source Compliance 17
3. Motor Vehicle Controls 19
4. New Particulate Plans 20
5. Revisions to Standards 21
C. State and Local Agency Programs
1. National Air Audit System 26
2. Grants Management 26
3. New Source Review 27
4. Air Monitoring 27
D. Acid Deposition, Ozone Depletion, and Indoor Air
1. Acid Deposition 31
2. Ozone Depletion 31
3. Indoor Air 32
-------
TABLE OF CONTENTS (CONT.)
E. Maintain Air Quality
1. New Source Performance Standards 33
2. Continuous Compliance Programs. ...... 34
3. Visibility Programs 34
IV. STRATEGY FOR THE RADIATION PROGRAM 36
V. GUIDANCE FOR THE RADIATION PROGRAM
A. Reduced Exposures 36
B. Surveillance and Emergency Response 39
VI. SUPPLEMENTAL GUIDANCE 41
-------
OFFICE OF AIR AND RADIATION
I.
INTRODUCTION
This FY 1987 guidance updates the national strategies, goals, and
objectives developed in FY 1986 for the air quality and radiation
programs. The guidance also identifies the actions that the
Environmental Protection Agency (EPA) and state and local agencies
must take in FY 1987 to implement these updated goals and objectives.
The FY 1987 guidance is based on overall EPA goals, the Administra-
tor's priority
FY 1987 budget
list and six-point
request for EPA.
management plan, and the President's
The FY 1987 guidance for the air quality program and the radiation
program consists of three parts. The first part identifies the up-
dated national goals and strategy for each program and summarizes
the changes from the FY 1986 strategy for meeting the revised goals.
The second part describes program objectives for each goal and
lists the specific actions that must be taken by EPA and by state
and local agencies in FY 1987 to carry out the national strategy.
Actions are divided into two tiers according to national priorities
and projected environmental results. Tier 1 actions are the
highest priority, followed by Tier 2. Some actions not listed in
either tier may be a high priority at the state or local level,
but not at the national level.
In carrying out the actions described in the FY 1987 guidance, EPA
will continue to ensure that its air and radiation programs are
conducted openly, accurately, and fairly. EPA will use the
Communications Strategy Plan process, coordinated by the Office
of External Affairs, to inform the public of all major regulatory
decisions and actions.
II. STRATEGY FOR THE AIR QUALITY PROGRAM FOR FY 1987
A. Major Program Goals and Objectives
The updated EPA strategy for the national air quality program in
FY 1987 is based on five major program goals. These goals are
listed below in the general order of priority.
0 Reduce the risk of exposure to air toxics. EPA will implement
a comprehensive national strategy, announced in June 1985, to
address the significant public health problem caused by toxic
compounds in the air.
0 Achieve National Ambient Air Quality Standards (NAAQSs) set to
protect public health.
achieving healthful air
EPA will place the highest
quality for the 80 million
priority on
people that
-------
-2-
1ive in 35 major urban areas that will probably not meet the
ozone standard by the December 1987 attainment deadline in the
Clean Ai r Act.
° Increase the capacity and improve the effectiveness of state
and local air quality agencies. EPA will continue to work
toward a stronger, more effective partnership with state and
local agencies and help them improve their capabilities to
address air quality problems.
° Determine the policy alternatives and strategy options available
to address acid deposition, stratospheric ozone depletion, and
indoor air pollution. EPA will provide federal leadership in
developing national policies to address these three major
environmental problems.
0 Develop and support programs to maintain improvements in air
qua!ity. EPA will carry out national standard-setting and
compliance programs to ensure that gains made in improving air
quality are not lost.
B. Program Strategy for FY 1987
1. Reduce risk of exposure to air toxics
In FY 1987 EPA will continue to better define the nature and
magnitude of the air toxics problem and to develop and strengthen
the regulatory options for dealing with the problem. In June 1985
EPA completed a comprehensive national strategy for addressing
both routine and accidental releases of air toxics. Also in 1985,
EPA began developing a Strategic Planning Initiative that will
provide a more detailed multi-year, Agencywide plan for addressing
air toxics. One of the objectives in developing the Strategic
Planning Initiative is to define the appropriate links between
programs for routine and accidental releases in both the near-term
and long-term. A second objective is to examine the roles of EPA
and state and local agencies in prevention and contingency planning
for accidental releases of air toxics. A third objective is to
identify the public outreach activities necessary to improve under-
standing of health effects, risk assessment, and existing law and
regulation.
This portion of the Agency Operating Guidance will deal with
routine releases of air toxics. Accidental releases are covered
in the portion of the guidance prepared by the Office of Solid
Waste and Emergency Response. The routine releases portion of
the EPA air toxics strategy includes three major elements: an
enhanced and refocused federal air toxics control program to
address problems that are national in scope, a new program to
help state and local governments strengthen their capabilities f
to deal with air toxics problems within their boundaries, and an ™
expanded effort to devise strategies to reduce risks from multi-
media, multi-source pollutants in specific geographic areas.
-------
-3-
Federal air toxics program. In FY 1987 EPA will use its authorities
under the Clean Air Act and other federal statutes to regulate air
toxics. EPA will carry out a more aggressive program for listing
and regulating toxic air pollutants under section 112 of the Clean
Air Act. In addition to publishing regulatory decisions for 8-12
individual pollutants, EPA will also decide whether to regulate
emissions by source category (e.g., incinerator emissions) for
sources that emit more than one toxic air pollutant.
In FY 1987 EPA will have National Emission Standards for Hazardous
Air Pollutants (NESHAPs) under development for 13 hazardous pollu-
tants, more than in any previous year. EPA will continue to give
high priority to administrative, civil, and criminal enforcement
of existing NESHAPs for asbestos and vinyl chloride. In FY 1987
EPA also will develop a compliance and enforcement strategy for
the benzene NESHAPs.
EPA will use its authorities under Title II of the Clean Air
Act to regulate air toxics from motor vehicles and vehicle fuels.
In FY 1987 EPA will develop test protocols for assessing the
health effects of alternative fuels and fuel additives as part of
EPA's fuels and fuel additives registration process. EPA will
also given high priority to technology assessments for particulate
controls for heavy-duty diesel engines to help ensure that manu-
facturers meet the technology-forcing standards that start becoming
effective with the 1988 model year.
EPA will also regulate air toxics under the Resource Conservation
and Recovery Act (RCRA). In FY 1987 EPA will continue development
of regulations required by RCRA for controlling toxic air emissions
from seven types of hazardous waste treatment, storage, and dispo-
sal facilities (TSDFs).
EPA's Regional air programs staff will continue to coordinate with
their counterparts in the Regional hazardous waste programs to
ensure proper consideration of air quality in the clean-up of
Superfund sites and the issuance of RCRA permits.
State and local air toxics program support. In FY 1986 EPA will
assist state and local governments in strengthening their existing
air toxics programs and in establishing programs where none exist.
EPA will provide guidance on the design and implementation of air
toxics programs and on technical aspects of programs, such as air
sampling, dispersion modeling, and emission inventories. In addi-
tion, EPA will provide guidance on how State Implementation Plan
(SIP) measures for control of volatile organic compounds (VOCs)
and particulate matter can be used to gain additional reductions
in air toxi cs.
-------
-4-
In FY 1987 EPA will work with states to complete evaluation and
control of the toxic air pollutants and high-risk source cate-
gories identified by EPA in FY 1986. EPA will also continue to
assist state and local agencies in assessing and controlling
other high-risk air toxics sources which they identify. In addi-
tion, EPA will help state and local agencies strengthen their
overall capabilities to assess and control high-risk sources.
To implement effective air toxics control programs, the staff in
some state and local agencies may have to develop new skills and
expertise. EPA will assist in staff development by providing
technical guidance and workshops and by facilitating the transfer
of experience among agencies.
Multi-media, multi-source strategies. EPA currently has underway
three studies in Philadelphia, Baltimore, and the Santa Clara
Valley of California to learn how best to consider multi-media,
multi-source interactions in controlling localized toxics problems.
In FY 1987 EPA will provide state and local agencies with financial
and technical support for follow-up studies in 8-10 additional
geographic areas.
2. Achieve NAAQSs nationwide
Nationwide, air quality has generally improved as a result of
federal technology-based standards for vehicles and stationary
sources and the control measures in SIPs. Despite these improve-
ments, air quality in many areas still will not meet the NAAQSs
for ozone, carbon monoxide, sulfur dioxide, particulates, or lead
in FY 1987.
Ozone reduction. Achieving the NAAQS for ozone is one of EPA's
highest priorities. In FY 1986 EPA will develop an aggressive
strategy for reducing ozone levels in the areas still remaining
nonattainment after 1987. The ozone strategy will not be com-
pleted until after the FY 1987 Agency Operating Guidance has been
published in March 1986. Supplementary guidance will be necessary.
In general, the strategy will consist of three elements: make
existing programs work, require new and tougher controls, and
implement a "reasonable extra efforts" program.
Make existing programs work. EPA will give high priority to
correcting deficient regulations in ozone SIPs, fully implementing
stationary and mobile source controls already included in ozone
SIPs, expanding compliance efforts to cover additional and smaller
VOC sources, and tracking progress in improving ozone levels and
reducing VOC emissions. EPA will increase the number of vehicle
inspection and maintenance (I/M) programs audited in FY 1987. EPA
will also aggressively implement its vehicle recall program, empha- |
sizing excessive exhaust and evaporative hydrocarbon emissions. *
In addition, EPA is considering a VOC compliance initiative that
would include more comprehensive inspections of VOC sources, with
appropriate enforcement follow-up, in nonattainment areas.
-------
•" y •"
Require new and tougher controls. EPA will tighten control of
vehicle refueling and evaporative emission losses and heavy-duty
exhaust emissions. States may also have to adopt and implement
new SIP measures, as well as tighten existing emission limits and
operating requirements and enhance existing I/M programs.
Implement a reasonable extra efforts program. As part of the ozone
strategy, EPA is considering applying the reasonable extra efforts
approach, developed by Region IX, to the worst ozone areas in other
parts of the country. The program includes more intensive evalua-
tion of the adequacy of existing control measures and the identi-
fication and testing of new measures.
New SIPs for particulates. In addition to focusing on reducing
ozone levels in FY 1987, EPA will also emphasize support to states
developing SIPs to attain the revised NAAQS for size-specific
particulate matter (PMio)- Approximately 100 areas will probably
not meet the revised standard, now scheduled for promulgation in
mid-FY 1987. The population for these areas totals about 20 million
people. EPA will give highest priority to the PMjQ nonattainment
areas with the most severe problems. States must submit full
SIPs for these areas within nine months of the promulgation of
the standards.
Other pollutants. Although the extent of nonattainment for the
ozone and PMjg NAAQSs is the most widespread nationwide, there
are areas which experience severe violations of other NAAQSs,
particular the standards for carbon monoxide and sulfur dioxide.
In these areas EPA will work with states to correct SIP deficien-
cies contributing to the violations and develop any additional
control measures necessary.
3. Strengthen state and local programs
EPA will continue to support state and local air pollution control
programs by identifying obstacles to program effectiveness, pro-
viding direct program assistance, facilitating information exchange,
and maintaining national monitoring and data management systems.
EPA will also continue active outreach and liaison with Indian
Tribes, assisting them in identifying and characterizing air
quality problems on Indian Reservations and supporting Tribal
governments in developing programs for dealing with these problems.
State and local program assessments. The National Air Audit
System, used to identify obstacles to state and local control
agency effectiveness and to help EPA define more efficient and
meaningful national programs, will continue on the biennial cycle
begun in FY 1986. During FY 1987, state and key local agencies,
with the support of EPA Regional Offices, will initiate the
actions necessary to address the major problems identified by the
FY 1986 audits. In providing support, EPA will give priority to
problems that adversely affect state and local programs for
reducing ozone levels and addressing air toxics.
-------
-6-
State and local financial support. EPA will continue to provide
financial support to state and local agencies through the section
105 grants program. EPA will also continue to carry out the
performance-based grants policy signed by the Administrator in
May 1985. In implementing the policy, EPA will involve state and
local agencies in setting national priorities and determining
the allocation of grant funds to support these priorities.
Monitoring air quality. EPA will continue to support the collec-
tion of accurate and complete air quality data through the opera-
tion of the National Air Monitoring System (NAMS) and State and
Local Air Monitoring System (SLAMS) networks. During FY 1987
EPA will begin the operation of the air quality element of the
Aerometric Information Retrieval System (AIRS). As the air
quality element of AIRS becomes operational, EPA will assist
state and local agencies in gaining direct access to the system.
4. Address acid deposition, stratospheric ozone depletion, and
i ndoor ai r polluti on
Acid deposition. In FY 1987 EPA will carry out an acid deposition
program that includes accelerated research and analyses of policy
and implementation issues. The EPA Office of Research and Develop-
ment (ORD) will continue to develop the scientific and technical
information required to respond to policy issues. The Office of {
Air and Radiation (OAR) will insure that research efforts are
focused on policy information needs and will review new research
results for their policy implications. EPA will continue in FY
1987 to identify and resolve possible imlementation issues through
the State Acid Rain (STAR) program.
Stratospheric ozone depletion. Section 157 of the Clean Air Act
requires EPA to issue regulations to reduce chlorof1uorocarbon
(CFC) emissions if the Administrator of EPA determines that the
emissions endanger public health and the environment. In response
to a suit brought by the Natural Resources Defense Council, EPA
developed and adopted a comprehensive CFC action strategy in FY
1985. To carry out this strategy, EPA will focus during FY 1986
on developing a national and international consensus on the
nature and magnitude of the CFC problem. In FY 1987 EPA will
announce a decision on the need for regulatory actions to control
CFCs.
Indoor air pollution. Research by EPA and others indicates that
health risks result1 from indoor exposure to air pollutants, as
well as ambient exposures. Some of the risks associated with
indoor air pollution may be substantial. Although more research
is needed to better characterize the contribution of indoor air
pollution to adverse health effects, EPA will begin in FY 1987 to
analyze the policy issues associated with addressing the problem. |
EPA will examine how existing EPA programs can be adjusted to "
reduce total exposure, indoor and ambient, to unhealthful air
quali ty.
-------
-7-
5. Maintain improvements in air quality
New Source Performance Standards. The establishment and review
of technology-based New Source Performance Standards (NSPSs)
are important elements of the national program to prevent air
quality problems from new sources by setting baseline controls
for major source categories. In FY 1987 EPA will continue to
give priority to developing standards for each source category
on the NSPS priority 1ist.
Continuous compliance programs. In FY 1987 EPA will continue to
give priority to improving the effectiveness of EPA and state
compliance monitoring inspections. EPA will support application
of the Model Surveillance Targeting Program, completed in FY 1986,
to provide more systematic and efficient inspection programs. EPA
will also continue to actively promote the integration of continuous
emissions monitoring (CEM) into the continuous compliance program.
During FY 1987 EPA will complete guidance for addressing malfunc-
tions of control equipment and process operations.
Visibility plans. In FY 1987 EPA will complete promulgation of
SIPs to protect visibility in pristine areas of those 34 states
that did not prepare their own plans.
III. GUIDANCE FOR THE AIR QUALITY PROGRAM
A. Program Goal: Reduce risk of exposure to toxic air pollutants
The program objectives for this goal are based on the Air Toxics
Strategy (as it applies to routine releases) announced in June
1985. One of the Agency's Strategic Planning Initiatives involves
air toxics and is being directed by OAR. Results of this effort
are expected in FY 1986 and may alter some of the activities
outlined in this guidance.
1. Program objectives: Accelerate national regulations;
enforce existing requirements.
Actions for meeting these objectives fall in two categories:
0 Implementation of section 112 of the Clean Air Act,
including publication of decisions on whether to regulate
pollutants or source categories.
0 Use of federal authorities other than section 112 to
regulate air toxics, including air toxics from vehicle
emissions and fuels and from hazardous waste TSDFs.
Implement section 112. EPA will continue to list pollutants
and establish standards under section 112. In FY 1987 EPA
will publish regulatory decisions for 8-12 potential hazardous
air pollutants and identify those requiring nationwide regulation
-------
-8-
through NESHAPs. Decisions on whether to list the emissions of
certain source categories (e.g., incinerator emissions) under
section 112 will begin to be issued in FY 1987. These decisions
will result from a study to be completed in late FY 1986 on the
risks caused by sources that emit more than one toxic air pollutant.
The EPA will also continue the development of data bases, risk
assessments, and listing decisions for other candidate compounds.
To assist in the identification and assessment of potentially
toxic air pollutants, ORD will develop and/or evaluate additional
monitoring methods; provide toxics air monitoring information
through an expansion of the Toxics Air Monitoring System (TAMS);
test individual pollutants and mixtures for a number of health
endpoints; and develop biological test methods to quickly identify
air toxics that cause the greatest health risk.
In FY 1987 EPA will propose changes to the current NESHAPs for
asbestos and promulgate NESHAPs for benzene and coke oven emis-
sions. NESHAPs development will be underway for 13 pollutants,
including 10 pollutants for which Intent to List decisions were
published in 1985. Proposals for a number of these NESHAPs will
occur in FY 1988. The research program will continue to develop
more efficient and cost-effective control technologies for air
toxics, particularly VOCs.
In implementing existing NESHAPs, EPA and states will give priority
to implementing the enforcement strategies for vinyl chloride and
asbestos demolition and renovation. EPA and states have also
agreed to extend the EPA guidance on timely and appropriate enforce-
ment response to NESHAPs sources in FY 1987. This will include
both resolving violations promptly and obtaining an appropriate
penalty. In addition, in FY 1987 EPA will complete the development
of a compliance and enforcement strategy for the benzene NESHAPs.
Regions will identify and refer to the Office of Criminal Investi-
gations (OCI) information relevant to enforcement of knowing vio-
lations of NESHAPs and will provide technical support for cases
reflecting program priorities. OCI and program personnel will
communicate (within limitations of the law) concerning the general
status of investigations, available enforcement options, antici-
pated resource requirements, and other matters of similar managerial
signi fi cance.
EPA will also conduct a pilot project to determine whether intensive
inspections of sources subject to current regulations for particu-
late matter and VOCs can result in significant reductions in air
toxi cs.
Use other federal authorities. The Air Toxics Strategy commits
the Agency to increased use of federal authorities in addition
to section 112. EPA will use other sections of the Clean Air
Act to control air toxics. For example, EPA will use the
-------
-9-
provisions of" Title II of the Act to reduce air toxics from vehicle
emissions and fuels. EPA will also emphasize implementation of
provisions of the Act which indirectly reduce air toxics. For
example, an NSPS for wood stove emissions that will be proposed
in FY 1987 will reduce particulate emissions, some of which are
toxic. Similarly, EPA will promulgate an NSPS for industrial
boilers in FY 1987 that will apply to municipal waste combustors
and reduce particulate emissions with potentially toxic components.
EPA will also use federal statutes other than the Clean air Act
to control air toxics. For example, in late FY 1987 or early
FY 1988 the air program will propose, under RCRA, regulations for
toxic air emissions from seven types of hazardous waste TSDFs.
In early FY 1987, EPA will complete a comprehensive assessment of
the regulatory authorities for controlling sources of methylene
chloride and will develop regulations as appropriate under the
Clean Air Act; the Toxic Substances Control Act (TSCA); the
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA); and
the Safe Drinking Water Act (SDWA). Similar studies are antici-
pated for other pollutants in FY 1987.
Control vehicle emissions and fuels. EPA expects the introduction
of a large number of vehicle fuel additives in response to the
phasedown of lead in gasoline. EPA also expects an increasingly
variable composition of all fuels due to a changing marketplace.
EPA will strengthen its registration of fuels and additives and
will develop test protocols for assessing the health effects of
alternative fuels and fuel additives prior to registration, as
mandated by the Clean Air Act. The enhanced fuels registration
program will lead to rulemaking to control toxic fuels and additives,
Lead phasedown presents a special problem to the owners of vehicles
which were designed to operate with leaded gasoline and which
have operating cycles different from those of cars and trucks
(e.g., farm equipment, antique cars, boats, off-highway vehicles).
If the lead phasedown program is to be sustained and/or a lead
ban adopted, the needs of these vehicle owners must be taken into
account without creating a new market for leaded fuel. Phasing
down lead use could be subverted by the existence of this market
for leaded fuel. EPA will study the effects on existing engines
of lead phasedown and the use of alternative valve lubricants,
and will take appropriate regulatory action.
EPA will continue the aggressive enforcement program started in
FY 1986 to ensure that the required reductions in the lead content
of gasoline take place and that all fuels marketed meet the
requirements of registration, waivers, and fuels regulations.
Diesel particulates constitute an important contributor to air
toxicity. The "six-month" study prepared by EPA attributes
approximately half of the air toxic health effects to mobile
sources. A significant portion of these effects result from die-
sel particulates. The recently promulgated rule for the control
-------
-10-
of diesel particulate emissions is expected to reduce the annual
incidence of cancer from this source by as much as 400 cases per
year. In addition, diesel particulate can act as the carrier to
the deep lung of substances formed or accreted in the air since
these particles remain suspended for long periods. Control of
this air toxic can be achieved with emission standards (which will
force the development of new technology) and fuel composition
regulations.
EPA will concentrate on technology assessment work to assure that
manufacturers meet the technology-forcing standards already in
place. The standards will present significant technological
challenges to engine maufacturers. The effectiveness of control
is predicated on the adoption of as yet undeveloped technology.
The standards are effective with the 1988 model year and are
tightened in 1991 and 1994. Maufacturers do not appear to be
engaged in active research programs for meeting the standards.
EPA must make sure that manufacturers either adapt technology
applied to light-duty vehicles or change to cleaner fuels (e.g.,
methanol) to comply with the emission standards.
EPA will also monitor diesel fuel composition and develop regula-
tory approaches to assure adequate control. The quantity and
toxicity of diesel particulates is affected by fuel quality.
Manufacturers have stated that trap technology cannot be adapted |
to control particulate emissions at the levels required by the
standards with sulfur in diesel fuel at current levels. To
achieve the expected reduction in the annual incidence of cancer
from diesels by as much as 400 cases per year, it may be necessary
to control the composition of diesel fuel. Control of sulfur,
aromatics, and heavy components of diesel fuel can directly reduce
particulates emitted by about half. Conversely, increases in
these substances in fuel can increase emissions of particulates.
Another significant contributor to air toxics is direct evaporative
hydrocarbon emissions, which involve a wide range of potentially
harmful substances. Extension of known controls to the degree
necessary to reduce these hazards is a high priority. Evaporative
emissions control rules will be developed and implemented. Spe-
cial attention will be given to recalling cars and trucks with
excessive evaporative emissions.
Research attention will be turned to the study of unregulated
toxic emissions from vehicles and the possibility that winter
temperatures affect the character of automobile emissions.
2. Program Objective: Establish and support effective state and
local programs in defining and addressing
toxic air pollutant problems.
The EPA in its air toxics strategy has formally recognized the *
importance of effective state and local programs. These programs
are necessary to address a diverse and complex health concern
which is often area specific. In addition, strong state and local
-------
-11-
programs complement the national standard setting process by
ensuring effective enforcement and by providing useful feedback
regarding the implementation of current standards and the
potential need for future standards.
In order to encourage further development of state and local air
toxics control programs, the Administrator established a goal to
have operative air toxics programs in all states by the end of
FY 1986. For purposes of FY 1986 program development where there
are no existing programs, state and local agencies may develop and
submit a multi-year plan for developing their air toxics programs.
Additional development of these plans and progress in implementing
them will occur during FY 1987. The activities to enhance state
and local programs also apply to existing programs as well. In
FY 1987 EPA will promote improvements for these programs in several
areas, such as expanding program coverage to include more aspects
of air toxics problems.
There are four principal ways that EPA will support the further
development and implementation of state and local air toxics
programs in FY 1987. These are:
(1) Techn i ca 1 A s s i s t a n c e. The EPA will again provide technical
assistance in several ways to evolving state and local air
toxic programs. First, EPA will continue to operate its air
toxics clearinghouse which allows states to share much of
their program design and implementation experience with one
another. The EPA will also continue to provide a considerable
amount of case-specific assistance upon request by state and
local agencies in their efforts to design and implement
effective programs.
EPA will take several actions to enhance the technical and
scientific bases for program development and implementation
by providing additional guidance on ambient sampling, including
quality assurance, and on emissions factors and emissions
inventories. EPA will also provide limited guidance and
assistance for dispersion modeling. In addition, EPA will
assist states in issuing permits for regulating toxic emissions
from new municipal waste combustors by publishing documents
which identify the lowest emission levels of organic compounds
(including dioxin), metals, acid gases, and particulate matter.
The documents will describe feed characteristics, operating
characteristics, and control techniques associated with such
levels. Finally, EPA will work witn states to improve their
technical capabilities in order to implement their air toxics
programs.
(2) Program Grants and Example Programs. Substantial FY 1987
grant dollars will be allocated for building state and local
programs. Detailed descriptions of successful example
programs beyond those documented in FY 1986 will be prepared,
and some additional workshops will be conducted to assist
-------
-12-
state and local agencies in the efforts to build upon their
current program. A state and local working group established
in FY 1986 will continue to define and set priorities among
state and local program needs and evaluate which practices
have been most effective in accomplishing risk reduction.
These actions will continue the FY 1986 efforts to stimu-
late and guide further state and local program development
using the collective wisdom gained from experience to date.
(3) Hi gh-Ri sk Poi nt Sources. EPA will work with states to improve
their capabilities to routinely address exposures from point
sources of toxic air polluants which cause high individual
health risks, but which are not appropriate for federal regu-
lation. In FY 1987 EPA and states activities will continue
to focus on pollutants and source categories identified in
FY 1986. EPA will provide guidance documents and conduct
workshops to help states address selected source categories
associated with high individual risks.
(4) SIP Development and Enforcement. Historically, implementation
of state plans for the attainment of NAAQSs has been the most
effective air quality management tool to reduce the risk of
adverse health effects from toxic air pollutants. In FY 1987
EPA will help identify and support SIP activities that also
reduce air toxics emissions.
3. Program objectives: Identify geographic area problems;
determine intermedia approaches to
control under existing authorities.
In FY 1987 EPA will support, through program grants and technical
assistance, state initiatives for the first phase of a two-year
program to prepare comprehensive air toxics inventories and
analyze exposures and risks in 8-10 geographic areas with signifi-
cant multiple source and pollutant interactions. Several of the
activities discussed in the above program objectives (e.g., expan-
sion of the TAMS, guidance on ambient monitoring, modeling,
emission factors and emission inventories) will be of great use
in implementing the geographic program.
OAR and the Regions and states will coordinate and provide input
to the geographic activities being implemented by the Office of
Policy and Program Evaluation (OPPE). These activities include
reports on the multi-media studies being conducted in the Santa
Clara Valley and Baltimore; follow-up work in Philadelphia, and
Phase I reports on one to two new multi-media study areas initiated
in FY 1986.
-------
-13-
Key FY 1987 Headquarters Actions to Implement Program Goal
Ti er 1 Acti ons:
(1) Continue pollutant assessment and evaluation program.
Publish regulatory decisions for 8-12 potential hazardous
air pollutants. Publish decisions on whether to regulate
source categories that emit multiple air toxics.
(2) Promulgate NESHAPs for coke oven emissions (charging topside
and doors) and benzene (coke by-product plants) and propose
revisions to current asbestos NESHAPs.
(3) Continue to develop NESHAPs for 13 pollutants.
(4) Publish documents which identify the lowest emission levels
of toxic pollutants from municipal waste combustors. (OAR,
OSWER, ORD)
(5) Develop and promote improved asbestos demolition and renovation
techniques.
(6) Develop a compliance and enforcement strategy for the benzene
NESHAPs.
(7) Develop rules requiring the testing of vehicle fuels and
additives combustion products for human health effects (using
bioassays). Publish an Advance Notice of Proposed Rulemaking
i n August 1987.
(8) Implement an aggressive program for registration of vehicle
fuels and additives. Provide for improved access and
analysis of data on the composition and concentration of
fuels and additives. Issue rules to control substances and
fuels found to present environmental problems.
(9) Ensure that manufacturers meet the already promulgated diesel
particulate standards through an aggressive program of
technology assessment and compliance program resolution.
(10) Set and enforce additional rules, such as fuel composition
rules, for effective control of particulate emissions from
vehi cles.
(11) Actively and aggressively enforce vehicle fuel composition
regulations already in effect.
(12) Continue development of regulations under RCRA to control
air toxics emissions from seven types of TSDFs: surface
impoundments, landfills, storage tanks, waste piles, land
treatment facilities, containers, and transfer operations.
Propose regulations in late FY 1987 or early FY 1988.
-------
-14-
(13) Propose an NSPS for residential wood stoves; initiate
development of a compliance strategy for the wood stoves
NSPS.
(14) Expand TAMS. Provide TAMS data on the presence and con-
centrations of hazardous air pollutants. (ORD)
(15) Develop and operate mechanisms (e.g., working groups and
national workshops) to focus, share, and expand the implemen-
tation experience (including example programs and practices)
in order to promote development of effective state and local
air toxics programs.
(16) Develop and implement procedures for providing oversight of
Regional and state and local activities for developing air
toxics programs in all states. Issue national report sum-
marizing status of air toxics programs.
(17) Continue operation of the air toxics clearinghouse, pro-
viding a primary referral service for obtaining information
and expertise on hazardous air pollution sources, emissions,
control technology, health effects, exposure, and ambient
concentrations.
(18) Assist state and local agencies in assessing and regulating |
air toxics sources, or source categories which result in
high individual health risks, but which are not appropriate
for federal regulation. Issue guidance and conduct workshops
to help state and local agencies address specific problems
and improve their overall capabilities to address high-risk
sources.
(19) Develop guidance to optimize current VOC and particulate
matter programs and control measures which also reduce air
toxics emissions. Consider adopting SIP control policies
which would concurrently make effective reductions in both
air toxics and the relevant criteria pol1utant(s ).
(20) Issue final report on Santa Clara and Baltimore studies.
(OPPE)
(21) Issue Phase I reports on one to two new multi-media site
studies initiated in FY 1986. (OPPE)
(22) Provide guidance on developing regulatory programs for
dealing with multi-source, multi-pollutant problem areas.
(23) Respond to requests from Regional Offices and state and
local agencies for: (a) information on health, exposure,
and control technology for specific toxic pollutants; (b) |
support regarding general program development and control ™
strategy options; and (c) assistance in evaluating and
mitigating specific local problems. (OAR and ORD)
-------
-15-
(24) Enhance the scientific basis for program development and
implementation by:
(a) Continuing the development of ambient measurement
methods for hazardous air pollutants. Provide guidance
on sampling and quality assurance to facilitate the estab-
lishment and/or upgrading of state and local monitoring
programs to better define air toxics problems. (ORD)
(b) Issuing guidance on ambient sampling and emission
inventories of air toxic pollutants. Provide technical
assistance to Regional Offices and state and local
agencies.
(c) Updating guidance on VOC speciation to include toxic
constituents.
(d) Developing emission factors and source characteri-
zation information for 8-10 substances.
Ti er 2 Actions:
(1) Complete report comparing the geographic variability of the
air toxics problems for a large number of counties. (OPPE)
(2) Update the monitoring strategy for toxic air pollutants.
(3) Issue summary report on available air quality data for air
toxi cs.
Key FY 1987 Regional Office and State Actions to Implement
Program Goal
Tier 1 Actions:
(1) Provide oversight to ensure states implement commitments for
developing air toxics programs in all states. (Regions)
(2) Provide guidance and assist state and local programs assess-
ing and regulating local air toxics problems, including the
specific pollutants and source categories identified in
FY 1986. Provide periodic information and reports concerning
state and local activities, including the status of program
development and specific regulatory actions. (Regions)
(3) Develop and implement programs for assessing and regulating,
if necessary, emissions of toxic air pollutants from high-
risk point sources and source categories which are not
appropriate for federal regulation. Initiate efforts to
enhance overall program capabilities to routinely address
high-risk sources. (States)
-------
-16-
(4) Give special enforcement attention to VOC and participate
matter sources in areas where emission reductions can signi-
ficantly reduce potential air toxics problems. (States/Regions)
(5) Implement agreements for developing state and local air
toxics programs. (States)
(6) Ensure compliance with NESHAPs, in accordance with the timely
and appropriate guidance. Implement EPA's enforcement
strategies for vinyl chloride and asbestos demolition and
renovation. (States/Regions)
(7) Promote improved asbestos demolition inspection and violation
detection techniques and encourage delegation of NESHAPs to
additional states. (Regions)
(8) For selected Regional Offices, implement an intensive inspec-
tion program directed at sources that contribute to air
toxic "hot spots." (Regions)
(9) Provide assistance to state initiatives to prepare comprehen-
sive air toxics emission inventories and analyses of exposures
and risks in 8-10 geographic areas. (Regions)
(10) Initiate analyses of emissions and risks for multi-source,
multi-pollutant problems in 8-10 geographic areas. Begin
development of control programs, as necessary, to address
problems identified by existing special studies in Philadel-
phia, Baltimore, the Santa Clara Valley, and the Kanawha
Valley. (States)
(11) Provide timely information and updates to the Air Toxics
Clearinghouse regarding state and local activities, helping
to maintain effective and current clearinghouse operation.
(States)
(12) In developing SIP revisions for new PM^g standards and
additional VOC measures in ozone nonattainment areas,
give priority to control measures that also reduce air
toxics emissions. (States)
Tier 2 Actions:
(1) Where ambient data on VOCs are routinely collected, submit
to EPA raw data or summaries of such data collected since
1980. (States)
-------
-17-
B. Program Goal: Achieve NAAQSs in areas currently not meeting
health related standards.
1. Program objectives: Correct ozone deficiencies, fully
implement existing SIP requirements,
and address post-1987 ozone nonattain-
ment problems.
In 1987 EPA will continue to give top priority to programs for
the development and implementation of SIPs necessary for the
attainment of the NAAQS for ozone. This involves the continuation
or completion of three major sets of activities. The first is
the continuation of the post-1982 policy for the identification
and correction of deficient SIPs necessary for the attainment of
the standard. The second is the implementation by states of the
various stationary and mobile source controls committed within
the approved SIPs for achieving the standard. The third is the
completion of the strategy and policies for addressing nonattain-
ment problems in areas which are not likely to attain by the statu-
tory 1987 attainment date.
The ozone nonattainment areas, which will be the focus of EPA and
state efforts during FY 1987, include both those where states
requested and received extensions to 1987 and those where states
did not receive extensions, but have subsequently been notified
by EPA during FY 1984 and FY 1985 of SIP deficiencies requiring
modifications and corrections. Corrective SIPs have been approved
for most of the extension areas, but deficiencies continue in
some areas requiring further state actions and approval by EPA.
In FY 1987 states will also continue to correct SIPs for any newly
identified ozone nonattainment areas where notifications of SIP
deficiencies have been provided by EPA.
SIPs approved by EPA, both within the extension areas and areas
where notifications of SIP deficiencies had been issued, contain
commitments to implement regulations and regulatory programs which
are essential to the attainment of the NAAQS. During FY 1987 EPA
and state attention will focus on completing fully remaining
commitments for implementing these regulations and programs
(including required adoption by appropriate governmental bodies)
consistent with national policy, guidelines, and schedules committed
in the SIPs. In 1987 EPA Regional Offices and states will review
and document progress toward meeting the NAAQS within the ozone
nonattainment areas.
EPA, through the efforts of an Ozone Task Force, is currently
formulating a major strategy for future ozone controls in areas
not demonstrating attainment by the end of 1987. This strategy
is expected to be completed by the end of FY 1986. This new
strategy will enhance and build upon the existing strategy appli-
cable to both the extension areas and the post-1982 areas.
The strategy will accelerate progress toward attainment in areas
with the more severe nonattainment problems. The strategy is
-------
-18-
expected to require the adoption and implementation of new and
additional measures as well as the enhancement of existing control
efforts. The additional measures are expected to address both
short-term and long-term actions with the number and type related
to the severity of the nonattainment problem. The implementation
of a reasonable extra efforts program similar to the program being
piloted in Region IX is being considered as a key element of the
new strategy for the particularly severe nonattainment areas.
Many of the new and additional measures required to reduce VOC
emissions will more directly affect the general public. More
extensive outreach programs will be needed to improve public under-
standing of the adverse health effects of ozone and the need for
additional actions.
A schedule for the implementation of the new strategy will also
be prepared by the end of FY 1986. The completion of the strategy
and the schedule for its implementation will likely require
specific EPA and state actions during FY 1987. Additional guidance
is anticipated to be needed at that time to more clearly define
the necessary activities and expectations for the Regional Offices
and states during FY 1987. Accompanying the strategy will be
guidelines concerning expanded monitoring programs and updates/
revisions to emissions inventories which will need to be undertaken
in FY 1987 and beyond in support of the new strategy and application
of specific measures.
Important to the new strategy is a more complete and credible
scientific basis for implementing additional ozone control measures.
Toward that end, several studies will be undertaken by ORD to
develop, evaluate, and test both monitors and modeling techniques,
and to improve source control technologies.
2. Program Objective: Implement key elements of the air
compliance program.
In FY 1987 EPA will give priority to three elements of the air
compliance program: the timely and appropriate guidance, the Post-
1982 Enforcement Policy, and the guidance that will be developed
in FY 1986 on defining a federally reportable violation. Together,
these key elements determine which violations are to be reported
to EPA, identify the relative roles and responsibilities of EPA
and state and local agencies in returning significant violators
to compliance, and establish important policy guidance for the
compliance programs.
Regions will identify and refer to OCI information relevant to
enforcement of knowing SIP violations and knowing false submission
of information under the Clean Air Act (subject to criminal enforce-
ment), and provide technical support for cases reflecting program
priorities. OCI and program personnel will communicate (within
limitations imposed by law) concerning the general status of
investigations, available enforcement options, anticipated resource
requirements or other matters of similar managerial significance.
-------
-19-
A major effort and the principal focus of the air compliance
program in FY 1987 is compliance monitoring and enforcement for
VOC sources in ozone nonattai nrnent areas. Emphasis will be on
identifying and addressing significant violators of VOC emission
requirements. During FY 1986, EPA will develop a strategy addres-
sing selected Class B VOC violators located in ozone nonattainment
areas. Implementation of this strategy will begin in FY 1987 and
will include developing inventories of Class B VOC sources that
impact ozone nonattainment areas, targeting many of these sources
for inspection, and conducting appropriate follow-up enforcement
acti ons.
As noted in the objective above, EPA has established an Ozone
Task Force to assess continuing ozone nonattainment problems and
to prepare a strategy for addressing problems within the more
severe nonattainment areas. The Task Force is considering as part
of the strategy an initiative to enhance the VOC compliance pro-
gram. In part, this initiative would involve an intensified over-
view program with more comprehensive inspections of VOC sources
in selected ozone nonattainment areas and appropriate enforcement
fol1ow-up.
Also, EPA will ensure that federal facilities meeting emission
limits remain in compliance and that the relatively few violating
facilities are returned to compliance. Federal facilities will
be inspected and provided with technical assistance, as needed,
in accordance with the revised guidance from the Office of Federal
Acti viti es.
c. Program Objective: Maintain an effective nationwide motor
vehicle emission control program
The federal motor vehicle pollution control program is a key
element in the strategy for achieving and maintaining primary
NAAQSs. Large parts of the population of the United States will
remain subject to unhealthful levels of ozone and carbon monoxide
even in the early 1990's without additional emissions controls.
Motor vehicles account for essentially all controllable emissions
of carbon monoxide and are the logical source for achieving
emission reductions. They also represent the source with the
greatest potential for the next increment in cost-effective
emissions control related to ozone. Control of the growth of
emissions of nitrogen oxides is also very cost-effective when
controls are applied to motor vehicles, especially the sources
that are less stringently controlled such as trucks and buses.
In FY 1987 the motor vehicle pollution control program will give
priority to controlling heavy-duty engine emissions to levels
comparable in stringency to those for automobiles and to ensuring,
through technology monitoring, support of state I/M and anti-
tampering/fuel switching programs and, through rigorous federal
enforcement, continued compliance by vehicles in-use with the
standards that they were designed to meet. Certain actions taken
for the control of toxic air pollutants are expected to bolster
-------
-20-
the attainment of the NAAQSs. Examples are the control of evapo-
rative hydrocarbons (which may have direct toxic effects and are
ozone precursors) and lead (lead in gasoline destroys emission
control systems, has a large range of direct health effects, and
its control directly contributes to the attainment of the primary
NAAQS for lead).
Two exhaust emission standards become effective during FY 1987:
lower hydrocarbon and carbon monoxide standards for light heavy-
duty engines and more stringent diesel particulate standards for
light-duty vehicles. The selective enforcement audit program,
which assures that newly produced vehicles and engines meet
standards, will be directed toward determining compliance with
these emission requirements. Furthermore, the recall program
will test heavy-duty engines from in-use vehicles for the first
time in FY 1987. These engines were required to comply with
tighter hydrocarbon and carbon monoxide standards in FY 1985 and
will have accumulated sufficient mileage by FY 1987 to enable EPA
to assess whether significant emission deterioration is occurring
i n-use.
Federal efforts alone cannot effectively address continued vehicle
compliance. Control of factors related to vehicle and fuel use
are within the purview of state and local governments. To ensure
that the considerable national investment in motor vehicle pollu-
tion control is not squandered by a minority of uninformed or
irresponsible individuals, state and local governments must main-
tain effective I/M programs, establish additional anti -tamperi ng/
fuel switching programs, and improve the operation and enhance the
effectiveness of the programs already in place.
Research in FY 1987 will focus on developing more information on
the impact of toxic mobile source emissions on the formation of
ozone. Methanol is a promising alternative fuel for motor vehicles
and may offer the added benefit of reducting ambient ozone levels.
To test this, a smog chamber is being developed and a study will
be done to compare the effects of gasoline and methanol combustion
on ozone formation.
4. Program objective: Complete SIPs to meet the revised NAAQS
for PM10.
EPA will promulgate the NAAQS for PMio in mid-FY 1987 and issue
the final implementation guidance for state development of PM^Q
SIPs. The actions that states must take will depend upon the
severity of the PM]_o problem. Areas are divided into three groups,
with Group I being the most polluted and Group III being the least.
States will need to continue to (1) expand their PM-JQ monitoring
activities in FY 1987 consistent with national guidance focusing
on Group I areas; (2) initiate efforts to modify their permit
systems for new or modified sources to account for the revised
PM-|Q NAAQS; and (3) begin development of PM-|Q emission inventories,
upgrading and converting total suspended particulate (TSP)
-------
-21-
inventories as necessary, to enable them to assess the impacts of
new sources subject to preconstructi on review, and to have the
data available for PM-|g control strategies, if required.
In Group I areas, based on guidance from EPA, states will also
need to (1) begin dispersion and receptor modeling to identify
and evaluate source contributions to PM-jg air quality levels,
(2) prepare control strategies to attain the PM-|Q NAAQS, and
(3) initiate development of PM-JQ SIPs.
Looking beyond PMiQ, ORD will continue studies for fine particu-
lates, soiling, and visibility impairment. Specific efforts will
be undertaken to develop, evaluate, or refine urban scale particu-
late, fine particulate, and visibility models.
5. Program objective: Ensure that NAAQSs are based on accurate,
up-to-date information.
In FY 1987 EPA will promulgate revised or reaffirmed NAAQSs for
PMig and for sulfur oxides. In addition, EPA will propose revised
or reaffirmed standards for lead. Depending on the results of on-
going studies on carbon monoxide and nitrogen dioxide, scheduled
for completion by January 1987, EPA may initiate accelerated
reviews of the NAAQSs for these pollutants. The review of the
ozone NAAQSs will be nearing completion, with a proposed revision
or reaf f i rmati on scheduled for FY 1988.
The research program will continue to conduct health effects
research for all of the NAAQSs pollutants. Studies will involve
epidemiology, controlled human (clinical) studies, and animal
experiments. Studies on particulate matter will involve specific
fractions such as acid aerosols.
Key FY 1987 Headquarters Actions to Implement Program Goal
Tier 1 Actions:
(1) Ensure timely and consistent implementation of EPA policy
and guidance for achieving NAAQSs in post-1982 nonattai nment
areas and for complying with the litigation settlement for
completion/promulgation of required lead SIPs in remaining
states.
(2) Provide, consistent with EPA policies and procedures, timely
review and final rulemaking for state-submitted (and Regional
Office-reviewed) corrections to deficient SIPs, state-submitted
regulations and programs required for attainment of standards
and, where necessary, Regional Office prepared promulgations
for implementing requirements of litigation settlements.
-------
-22-
(3) Continue to support the development and implementation of
effective and consistent state and local regulations for
control of VOC emissions by updating and maintaining the
VOC Clearinghouse and providing periodic reports to the
Regional Offices and the states. Assist in resolving
specific policy and technical issues which impact the
regulation of key VOC sources and source categories.
(4) Complete necessary guidance for implementing the new ozone
strategy and ensure timely and consistent implementation
of those strategy elements requiring Regional Office and
state actions during FY 1987.
(5) Evaluate and ensure consistent implementation of the timely
and appropriate guidance, guidance on defining a federally
reportable violation, and the Post-1982 Enforcement Policy.
Revise national guidance as necessary.
(6) Manage the Compliance Data System. Continue to inventory
VOC sources emphasizing the identification of Class B VOC
sources that contribute to ozone nonattai nment .
(7) Set and enforce standards for vehicle fuel characteristics
related to evaporative emissions.
(8) Operate aggressive mobile source enforcement and technology
assessment efforts to make sure that evaporative emission
standards are met by in-use vehicles.
(9) Reduce hydrocarbon emissions through improvements and enhance-
ments in state and local I/M programs. Audit state and local
programs and provide appropriate assistance to resolve prob-
lems, including technical assessments and effectiveness of
I/M for newer technology vehicles.
(10) Enforce heavy-duty vehicle emission standards through an
aggressive recall program.
(11) Monitor and assist, via the Regional Offices, state progress
in developing SIPs required to meet the PM^Q standard.
(12) Provide guidance and training on the application of various
receptor modeling techniques for PM^Q SIPs. Complete develop-
ment of example applications, provide PM^g dispersion modeling
techniques, and disseminate guidance.
(13) Issue emission factor reports on remaining PM^g source cate-
gories addressed by the program developed jointly with ORD
and provide consultation concerning the derivation and use
of the reports.
-------
-23-
(14) Provide management and technical consultation to Regional
Offices and states for operation and continued refinement
of the PMiu networks needed to develop SIP data bases. (OAR)
Determine precision and accuracy of PM^g monitoring methods
and provide technology transfer on operations and mainte-
nance of PM]Q samplers. (ORD)
(15) Promulgate revised or reaffirmed NAAQSs for PM^o and for
sulfur dioxide.
(16) Propose revised or reaffirmed NAAQSs for lead.
Tier 2 Actions:
(1) Conduct research to improve the accuracy of ozone air quality
model predictions and to incorporate improved scientific
knowledge into existing urban and regional scale models.
(ORD)
(2) Develop a simplified method for measuring nonmethane organic
compounds in ambient air for use by state and local agencies.
Conduct studies to determine optimal numbers and site locations
for nonmethane organic compounds and nitrogen oxides monitors
for providing city-specific input data for the EKMA model.
Operate a nationwide standard reference photometer network
assisting state agencies. (ORD)
(3) Conduct additional research into VOC control technologies to
improve the state of the art in reducing VOC emissions.
(ORD)
(4) Assist Regional Offices and states in reviewing current
ambient ozone monitoring networks. Manage the program for
monitoring nonmethane organic compounds in ozone nonattainment
areas. Support analyses to obtain improved data necessary
for development of required SIPs and revisions. Promote
national oversight of Regional Office and state planning for
enhancing ozone networks.
(5) Develop and improve emission factors for VOC sources for use
in emission inventories and photochemical modeling. (ORD/OAR)
Prepare guidance for the preparation of area source inven-
tories of VOC emissions. (OAR) Develop a VOC point source
model for reviewing new sources in urban and rural nonattain-
ment areas. (ORD)
(6) Provide guidance and software for the application of empirical
and grid ozone models, incorporating improved scientific
knowledge as it is developed, where these models are employed
by states in developing control strategies for ozone attainment.
(7) Evaluate Regional air compliance programs, focusing on activi-
ties and programs directed at ozone nonattainment problems.
-------
-24-
(8) Provide technical support to the Regional Offices for nationally
s igni fi cant cases.
(9) Provide technical support to the Regional Offices and states
for VOC compliance problems.
Key FY 1987 Regional Office and State Actions to Implement Program
Goal
Tier 1 Actions:
(1) Implement EPA policy and guidance for the correction and
implementation of SIPs in post-1982 nonattainment areas and
for meeting provisions of the litigation settlement for
completion/promulgation of required lead SIPs in remaining
states. Remedy as expeditiously as possible deficient SIPs
and address newly identified violations of the NAAQSs.
(States/ Regions)
(2) Implement the stationary and mobile source controls con-
tained within approved SIPs for ozone nonattainment areas,
including the adoption of additionally required regulations
consistent with Reasonably Available Control Technology
(RACT) for Group III and non control-technique guideline
(CTG) VOC sources. (States)
(3) Audit state and local I/M programs and provide appropriate
assistance to resolve problems. (Regions)
(4) Closely monitor state implementation of SIP schedules and
commitments contained in the corrected and extension area
SIPs. Work with states to put SIP implementation back on
schedule as quickly as possible if problems or delays arise.
Assist states in the preparation of VOC regulations consistent
with RACT and resolve specific policy or technical issues
which impact the adoption and implementation of regulations.
(Regions)
(5) Review and document state progress in attaining NAAQS for
ozone and carbon monoxide within the major urban nonattain-
ment areas. Focus reviews on those areas that experience
the more severe problems and are not likely to attain by
1987. Identify nonimplementation issues, SIP deficiencies,
and other problems needing corrections. (Regions)
(6) Assist, via the EPA Ozone Task Force (Regions) and STAPPA/
ALAPCO (States), in the completion of any remaining portions
of the new ozone strategy and implementation guidance.
Implement the strategy according to the schedule developed
in FY 1986. (States/Regions)
-------
-25-
(7) Review ambient ozone monitoring networks within each non-
attainment area, and as required by the new ozone strategy
and accompanying guidance, initiate steps to refine or
expand monitoring networks to fully characterize ambient
ozone levels. Replace worn-out or obsolete continuous
ozone analyzers and laboratory equipment identified in
the 1985 National Air Monitoring Audits. Identify areas
where additional ambient (e.g., nonmethane organic compounds)
or emissions data are most likely to be required to prepare
revisions to ozone SIPs or to develop additional control
measures (Regions/States). Assist states in preparing
plans and data quality objectives (and obtaining EPA Head-
quarters' support where necessary) for collecting needed
data during FY 1987. (Regions)
(8) Implement provisions within the EPA-approved or federally
promulgated lead SIPs consistent with the settlement agree-
ment with the Natural Resources Defense Council. (States)
(9) Implement the guidance on defining a federally reportable
violation and the timely and appropriate response guidance.
Resolve, consistent with EPA policies, violations of SIP
regulations by Class A and selected Class B sources. Give
priority to violating VOC sources in or affecting ozone
nonattainment areas. Also, provide support to the criminal
enforcement program. (States/Regions)
(10) Assure that appropriate violations are entered into the Com-
pliance Data System consistent with the new OAR guidance on
defining a federally reportable violation. Where compliance
schedules for sources have been established, track these
schedules to assure timely compliance. Assure that the
system contains acceptable compliance status information for
these sources. Assure that appropriate Class B VOC compliance
data are entered into the Compliance Data System. (States/
Regions)
(11) Initiate the development of required SIPs upon promulgation
of the NAAQS for PM]o« Prepare necessary data bases for
regulatory decisions in all areas. Revise existing monitoring
networks consistent with national guidance for collection of
ambient data on PM-|g levels in areas where control strategies
must be prepared. Begin area-specific analyses to determine
and quantify sources of PM-|Q in areas where control strategies
must be prepared. Initiate efforts to modify permit systems
in all areas to account for the revised PM]Q NAAQS. (States/
Regi ons)
-------
-26-
C. Program goal: Increase the capacity and improve the effective-
ness of state and local air quality programs.
1. Program objective: Use the National Air Audit System to
identify obstacles to program effectiveness.
In FY 1987 EPA will continue the National Air Audit System on the
biennial cycle initiated in FY 1986. The National Air Audit System
is the primary tool for assessing state and local program capabi-
lities and effectiveness and for identifying problems and needed
improvements. State and key local programs will be evaluated
using national criteria for major air pollution control activities.
State and local agencies, with the support of EPA Regional Offices,
will initiate the actions needed to correct program problems iden-
tified in the agencies audited during FY 1986. In providing support
EPA will give priority to problems that adversely affect state and
local progrms for reducing ozone levels and addressing air toxics.
Recommendations for correction of widespread or national problems
will be summarized and evaluated at a 1988 symposium. These will
be incorporated into future program planning activities, providing
both a closure on the problems identified in the audits and
improvements in EPA and state/local programs.
2. Program Objective: Improve the management processes for the
ai r grants program.
In FY 1987 EPA will continue steps to ensure effective use and
management of air grant funds appropriated under section 105 of
the Clean Air Act. Agency policy on performance-based grants
will be implemented ensuring aggressive negotiation with state
and local grantees of commitments for accomplishing national
priorities and activities, a continuing review of grantee progress
in meeting commitments, and the initiation of appropriate follow-up
where problems are encountered. EPA recognizes that state and
local agencies cannot assume substantial new responsibilities
and still continue all existing activities without accompanying
increases in resources. Regional Offices will allow grantees
to eliminate or delay activities that are mutually agreed to
be a lower priority.
The performace-based grant reporting system begun in FY 1986 will
be continued with modifications as necessary to improve its imple-
mentation and usefulness. The findings and recommendations
resulting from the review of the air grant program by the Office
of the Inspector General during 1985/86 will be reviewed and
appropriate steps taken to implement necessary changes and key
recommendations within the Regions and Headquarters.
-------
-27-
3. Program objective: Transfer implementation and enforcement
responsibilities for new source review
to state and local ayencies.
EPA will continue efforts to prevent future air pollution problems
through support of strong state and local programs to regulate
new sources. This support includes developing national policies,
standards, and regulations; promoting the transfer of new or addi-
tional new source program responsibilities to state and local
agencies; aiding state and local agencies in implementing new source
review and compliance programs; and assisting in the response to
litigation. During FY 1987 EPA is scheduled to complete develop-
ment of techniques that will be useful in conducting new source
reviews and other dispersion analyses involving complex terrain
and tal1 stacks.
Litigation actions continue to be an important part of new source
review activities. The issue of whether surface coal mine fugi-
tive emissions should be considered in determining prevention of
significant deterioration and nonattainment area new source reviw
applicability will likely be resolved in FY 1986, with implementation
following in FY 1987. In addition, final action on many of the
issues raised in the Chemical Manufacturers' Association (CMA)
settlement agreement should be resolved by FY 1987, but whatever
action EPA takes will likely result in continued litigation.
To support state and local permitting decisions, EPA will continue
to operate two clearinghouses. One clearinghouse helps state and
local agencies to determine best available control technology
(BACT) and the lowest achievable emission rate (LAER) for new
sources in a timely and consistent manner. The second clearinghouse
helps state and local agencies to identify appropriate air quality
models and procedures to use in reviewing the impact of new sources.
4. Program Objective: Maintain the National Air Monitoring System
(NAMS) and State and Local Air Monitoring
System (SLAMS) networks; maintain rigorous
quality assurance programs, and where
appropriate, incorporate enhancements;
implement the AIRS air quality system in
EPA Headquarters and in all Regional
Offices; provide support to state and
local agencies requesting direct access to
AIRS.
High quality data for assessing progress in improving air quality
and identifying emerging problems is essential to the operation of
effective state and local control programs. To obtain such data,
state and local agencies responsible for operating the NAMS and
SLAMS networks must maintain effective quality assurance programs
and replace worn-out monitoring instruments on a regular basis.
In FY 1987 state and local agencies will need to review their
-------
-28-
existing PMjg networks and, where necessary, procure additional
PM^o instruments as quickly as resources permit to provide the
data necessary for SIP networks.
EPA will continue to provide revisions to its technical guidance
series on quality assurance during FY 1986 and FY 1987. EPA and
the states should ensure that quality assurance program plans are
updated annually to reflect these revisions, as well as year-to-year
shifts and refinements in monitoring objectives within each state's
NAMS/SLAMS network. EPA and the states should continue to conduct
systems audits of their quality assurance programs and to periodi-
cally perform audits of the data quality of NAMS/SLAMS operations
and other SIP-related monitoring projects.
During FY 1987 the implementation of the AIRS air quality system
will be initiated and completed in EPA Headquarters and in all
Regional offices. States currently storing and retrieving their
ambient data via the EPA's Comprehensive Data Handling System
(CDHS) will be the initial group to be supported in converting to
direct access to AIRS. In late FY 1987 and in FY 1988, EPA will
assist additional agencies requesting direct access to AIRS in
data conversion and access arrangements. Efforts will be continued
during FY 1987 to develop an integrated system to replace the
National Emission Data System and the Compliance Data System with
one which will allow direct access, storage, and retrieval of
emissions and compliance data on all major facilities.
Key FY 1987 Headquarters Actions to Implement Program Goal
Tier 1 Actions:
(1) Using the National Air Audit System results for FY 198b and
FY 1986, supplement or modify, as necessary, EPA policies
and provide implementation support to better address the
state and local agency problems identified by the audits.
(2) Use the findings and conclusions of the national reports
from the National Air Audit System in developing the FY 1988
and FY 1989 budgets to focus resources on identified problems
and needs.
(3) Analyze the results of the FY 1986-1987 audits and begin
development of a national report summarizing the findings
and conclusions. Initiate the development of recommendations
for corrective actions on significant or widespread problems.
Prepare national recommendations through a symposium to be
held in early 1988, including recommendations for developing
and providing guidance and assistance to state and local
programs. Review the effectiveness of the audit process and
evaluate the need for future improvements.
(4) Issue the allocation of section 105 grant funds for FY 1988
and guidance for negotiation of FY 1988 grant awards.
-------
-29-
(5) Maintain a continuing forum with Regional Offices and state
and local air pollution control agency officials for assessing
and resolving air grant issues and problems.
(6) Provide support necessary to develop network descriptions and
implement prompt establishment of NAMS networks for PMjQ.
(7) Initiate imp!ementaion of the Air Quality Subsystem of AIRS
in all Regional Offices and in selected state/local agencies.
(8) Continue to develop and evaluate software needed to replace
tne National Emission Data System and the Compliance Data
System with a system which states can directly store and
retrieve both emissions and compliance data.
(9) Provide training opportunities, implementation-oriented
workshops, technical guidelines, and operating and procedural
manuals to help state and local agencies strengthen their
capabilities in key program areas.
Tier 2 Actions:
(1) Complete survey of Regional Office procedures and processes
for managing air grant funds. Focus on Regional activities
for negotiating grant commitments and for documenting state
progress and performance in meeting commitments. Prepare
summary report of findings and conclusions.
(2) Modify the performance-based grant reporting system as neces-
sary to accommodate FY 1987 priorities and guidance. Pilot
the reporting of negotiated funding levels for the major
functional work areas (Regulation and Program Planning,
Monitoring, Enforcement, Permitting, and Administration).
(3) Continue to develop and modify, as necesary, new source
program guidance and policies to keep state and local agencies
abreast of development and changing requirements.
(4) Update and maintain the clearinghouse for BACT/LAER determi-
nations. Provide timely updates to permitting agencies,
helping to ensure consistent and effective permitting decisions
(5) Operate the control technologies (modeling) clearinghouse to
ensure that technically correct and consistent modeling
procedures are applied in reviews of significant sources.
(6) Update the ambient monitoring strategy for criteria
pollutants.
(7) Continue litigation activities on CMA issues and other
challenges.
-------
-30-
(8) Complete development and issue computer codes and user's guide
for performing complex terrain dispersion analyses and for
analyzing air quality impacts from tall stacks. (ORD)
Key FY 1987 Regional Office and State Actions to Implement Program
Goal
Tier 1 Actions:
(1) Conduct biennial audits of state and key local air pollution
control programs. Complete on schedule the audit reports
for individual programs. (States/Regions)
(2) Initiate actions to correct deficiencies identified by the
FY 1986 audits of individual state and key local programs.
Include corrective actions in grant workplans. (States/Regions)
(3) Implement Agency policy and OAR guidance on performace-based
grants. Negotiate with state and local air grantees workplans
and agreements for continuing program support that addresses
national priorities, SPMS measures, and all Tier I actions
(if applicable to the state) identified in the Agency Operating
Guidance. Quantify workplan commitments that address national
priorities, SPMS measures, and Tier I actions and negotiate
funding levels for individual national priorities. Implement
performance-based grant reporting system providing complete
and timely reports on commitments, progress, and funding
levels. (Regions)
(4) Maintain effective state and local programs for new source
review, prevention of significant deterioration, and NSPS
implementation, with adequate enforcement response to
violations. Take direct enforcement action, as necessary,
when a state has not been delegated authority or a state
fails to take timely and appropriate action. (States/Regions)
(5) Maintain NAMS and SLAMS operations. Update quality assurance
programs to reflect revised technical guidance and program
requirements and carry out quality assurance system audits.
Review and revise networks, as appropriate, giving priority
to timely preparation and review of network descriptions for
PM1(). (States/Regions)
(6) Report all required air quality, quality assurance, emissions
and compliance data on schedule. (States)
(7) Continue programs to replace worn-out or obsolete continuous
analyzers and laboratory equipment in the NAMS network (as
identified in the 1985 National Air Monitoring Audits). Give
priority to replacing ozone analyzers in post-1987 nonattain-
ment areas. (States)
-------
-31-
Tier 2 Actions:
(1) Develop for the few remaining state and key local agencies
approvable programs for the prevention of significant
deterioration or agreements to accept delegation of the
federal program. Promote automatic delegation processes
for NSPSs and NESHAPs. (States/Regions)
(2) Support the BACT/LAER clearinghouse by submitting determina-
tions to EPA in a timely manner. Although clearinghouse
participation is voluntary, the clearinghouse does benefit
states and local agencies by providing a comprehensive data
base for new source permitting decisions. The extent and
quality of the data base depends on the degree of agency
participation. (States/Regions)
(3) Continue programs to replace worn-out or obsolete continuous
analyzers and laboratory equipment in the SLAMS network
(as identified in the 1985 National Air Monitoring Audits).
(States)
(4) If final rules include surface coal mine fugitive emissions
in determining whether sources are subject to new source
review, develop and implement this addition to the rules,
including the workshops, training, and reference materials
needed to delegate this portion of the program to state and
local agencies. (States/Regions)
D. Program goal: Determine the policy alternatives and strategy
options available to address acid deposition,
stratospheric ozone depletion, and indoor air
pol I uti on.
1.
Program objective: Identify policy implications of the results
of the National Acid Precipitation Assess-
ment Program (NAPAP); determine policy
information needs that must be addressed.
In FY 1987 EPA will place particular emphasis on the review of
research results from NAPAP. EPA's air program will actively
participate in the research planning processes of NAPAP and ORD
to ensure that policy information needs are being adequately
addressed by the national research program.
2. Program objective: Evaluate critical implementation and
policy issues in addressing acid deposition
and define options for their resolution.
EPA will continue a cooperative effort with states to examine
potential implementation issues associated with the enactment of
an acid rain control program. In FY 1987 EPA will emphasize the
development of specific options for resolving these issues. EPA
and the states will give special attention to ensuring that the
-------
-32-
1985 NAPAP emission inventory contains a thorough and accurate
characterization of the 1985 emissions in each of its specified
categori es.
3. Program objective: Determine the need for a CFC regulatory
program to reduce stratospheric ozone
depletion; coordinate the EPA position
with the international community.
In FY 1986 EPA will focus on developing a national and international
consensus on the nature and magnitude of the CFC problem. In FY
1987 these efforts will culminate in a decision on the need for
domestic regulation and on a United States negotiating position
on the development of an international protocol.
4. Program objective: Provide a coordianted EPA approach to
indoor air pollution policy analysis,
risk assessment, and strategy development.
In FY 1987 EPA will establish a policy development and analysis
capability to help guide and coordinate the Agency's response to
indoor air quality problems. EPA programs have in the past dealt
with indoor air as a normal portion of their activities (e.g.,
home use of pesticides). In FY 1987 EPA will provide more struc-
tured coordination of indoor air policy analysis, risk assessment
and strategy development. EPA will also continue working with
state and local agencies, other federal agencies, and private
organizations who have the interest and capacity to improve
i ndoor ai r quali ty.
ORD will place increased emphasis on more fully evaluating total
human exposure to air pollutants. In FY 1987 ORD will conduct
field studies to measure human exposure to indoor air pollutants,
evaluate the corresponding physiological and biochemical changes,
characterize the emission sources, and evaluate mitigation
techni ques.
Key FY 1987 Headquarters Actions to Implement Program Goal
Tier 1 Actions:
(1) Evaluate and synthesize results of FY 1986 STAR projects.
(2) Assist ORD and NAPAP in design and preparation of 1987
assessment.
(3) Complete draft of options of implementation issues of external
revi ew.
(4) Publish a decision on the need for regulatory actions to
reduce CFCs.
-------
-33-
Tier 2 Actions:
(1) Work with states on developing model implementation guidance.
Key FY 1987 Regional Office and State Actions to Implement Program
Goal
Tier 1 Actions:
(1) Submit comprehensive 1985 emission inventories for sulfur
oxides, nitrogen oxides, and VOCs. (Regions)
(2) Assist in the evaluation and synthesis of STAR projects.
(State/Regi ons)
(3) Provide procedural and technical guidance on verification of
1985 emission inventories. (Regions)
(4) Assist in the development of implementation options.
(States/Regions)
Tier 2 Actions:
(1) Assist in the development of the draft strategy implemenation
document. (States/Regions)
(2) Identify acid rain research needs of states and Regional
Offices and provide these to the Multi-media Energy Research
Committee. (States/Regions)
E. Program goal: Develop and support programs to maintain
environmental quality.
1. Program objective: Develop NSPSs for all source categories on
the priority list.
In FY 1987 EPA will continue to implement a three-part NSPS
program. EPA will give priority to part 1, the completion of at
least one NSPS for each source category on the NSPS priority list
for which the Agency has identified best demonstrated technology
(BDT).
Part 2 of the NSPS program is a longer-term effort, investigating
BDT for other pollutants and facilities on the priority list and
for 27 source categories identified before the priority list was
promulgated. Part 3 encompasses the continuing aspects of the
NSPS program: reviewing each NSPS on the four-year cycle required
by the Clean Air Act, revising an NSPS when appropriate, reevalu-
ating the status of the 21 source categories on the priority list
for which work has been suspended, and evaluating other source
categories not currently on the list.
-------
-34-
2. Program Objective: Implement and maintain effective continuous
compliance programs.
Continuous compliance will remain one of the major efforts of the
stationary source compliance program. EPA is committed to a variety
of continuous compliance studies and projects which will result
in improved compliance monitoring techniques and increased state
and Regional inspection and compliance determination expertise.
Many of these projects have already produced valuable results and
techniques.
The major thrust of the continuous compliance program is to
improve the effectiveness of compliance monitoring inspections
conducted by EPA and the states. In this regard, EPA issued in
FY 1984 guidance on the expanded use of unannounced inspections
to increase the likelihood of detecting noncompliance problems.
In FY 198b EPA revised its inspection frequency guidance for
FY 1986 to provide states with greater flexibility to target
inspections and, importantly, included a definition of a minimally
acceptable inspection. EPA will complete the Model Surveillance
Targeting Program in FY 1986. A result of this project, which
will be available in FY 1987, is a more systematic and efficient
method to target inspections.
Integrating Continuous Emissions Monitoring (CEM) into compliance
monitoring is a major effort within the continuous compliance
program. During FY 1985, EPA began a process to establish a base
CEM program in all Regions. The results of the Region VII CEM
pilot will be available in FY 1986 and will help promote broader
Regional Office and state CEM programs. To facilitate making
CEM a national program, EPA has issued guidance on the use of
excess emission report data and on using the CEM subset in the
Compliance Data System. In FY 1986 EPA will complete guidance
on using CEM data for direct enforcement. During FY 1987, EPA
will continue actively promoting the CEM program.
In FY 1987 EPA will complete development of guidance for states
and Regions on the major causes of malfunctions for the various
types of control equipment and for selected process operations.
A computer-based model data system to handle malfunction data
will be developed in conjunction with this project. These two
efforts will strengthen the capabilities of EPA and the states
to respond to alleged malfunction situations. Also, EPA will
develop a model recordkeeping system for major types of control
equipment, as well as guidance on records analysis procedures
to facilitate review of the data associated with the record-
keeping system.
3. Program objective: Protect visibility in Class I areas.
In a settlement agreement with the Environmental Defense Fund,
EPA agreed to promulgate visibility protection plans for 34
states that had not met Clean Air Act requirements. The EPA
-------
-35-
will complete the plans in a two-part promulgation that ends in
FY 1987.
FY 1987 Headquarters Actions to Implement Program Goal
Tier 1 Actions:
(1) Promulgate federal programs to correct deficiencies in
implementation control strategies, long-term strategies, and
integral vistas in state visibility protection plans.
(2) Approve state visibility plans for implementation control
strategies, long-term strategies, and integral vistas for
those states that submitted SIP revisions pursuant to the
provisions of the settlement agreement with the Environmental
Defense Fund.
Tier 2 Actions:
(1) Provide policy and technical guidance to Regional Offices
to implement the second part of the settlement agreement
with the Environmental Defense Fund.
(2) Provide policy and technical guidance on the federal visibility
monitoring programs established under the first part of the
settlement agreement with Environmental Defense Fund.
(3) Propose one NSPS and promulgate 15 NSPSs.
(4) Implement continuous compliance projects and studies.
Complete malfunction technical guidance, malfunction model
data system, and recordkeeping guidance. Promote the accep-
tance and implementation of recommendations and techniques
resulting from continuous compliance projects.
FY 1987 Key Regional Office and State Actions to Implement
Program Goal
Tier 1 Acti ons:
(1) Review and track the SIP revisions submitted by states to
avoid federal promulgation of visibility protection plans
according to the schedule contained in the Environmental
Defense Fund settlement agreement. (Regions)
Ti er 2 Acti ons:
(1) Assist states in improving their compliance monitoring
capabilities by upgrading their inspection and CEM/coal
sampling and analysis programs using techniques developed
in previous continuous compliance projects. (Regions)
-------
-36-
(2) Initiate SIP development efforts to correct deficiencies in
state visibility protection plans in states with federally
promulgated plans. (States)
IV. STRATEGY FOR THE RADIATION PROGRAM FOR FY 1987
The EPA strategy for the national radiation program is based on
two major program goals:
0 Reduce the risk of exposure to unhealthful levels
of radiation
0 Maintain comprehensive surveillance and effective emergency
response capabilities
There are a variety of sources of radiation exposure, and legis-
lative authorities to deal with radiation sources. EPA has
chosen to emphasize regulatory control over two general categories
which contribute to radiation exposure: airborne radionuclides,
and disposal of radioactive wastes. These categories have been
given priority because they represent the greatest health hazards,
legislative authority is available to remedy the problems, and
the radiation levels are amenable to reduction. The Agency also
continues to exercise its federal guidance role in the radiation
protection community.
In addition to implementing a regulatory and guidance program,
the Agency pursues three objectives of environmental assessment
in providing a radiation protection program to the public. These
objectives include: (1) maintain a capability to assess and quantify
existing and emerging radiation problems and the potential impact
of technologies under development, (2) be able to evaluate and
respond to issues of serious public concern and to identify the
organization responsible for corrective action, and (3) maintain
a capability to respond to emergencies and to aid development and
testing of state, local, and federal plans for emergency response.
This environmental assessment effort is concentrated in EPA field
facilities and Regional Offices.
V. GUIDANCE FOR THE RADIATION PROGRAM
A. Program Goal: Reduce the risk of exposure to unhealthful
levels of radiation
In an effort to address the health impacts of indoor radon exposure,
the Office of Radiation Programs (ORP), in conjunction with ORD,
O.PPE, and other Agency offices, has undertaken a strategy for
indoor radon assessment and mitigation. This strategy addresses
the elevated levels of indoor radon found in some homes on the
-------
-37-
Reading Prong in eastern Pennsylvania, New Jersey and New York;
assesses the national risks of exposure; and provides an integrated
approach to assist states and the private sector in dealing with
the problem.
In FY 1987 ORP will continue to provide technical assistance
related to radon to the states involved, disseminate information
to the public, and develop criteria for preventive measures in
construction. The Agency will also assist with the mitigation of
problems in existing homes through the development and application
of techniques to reduce radon in the homes.
As part of the national strategy on indoor radon, the design of
the national assessment and pilot testing of the methodology will
be completed in FY 1987. The design of a data handling system
will also be completed. Demonstrations of low cost remedial
techniques and preventive construction practices will be undertaken,
and cooperative projects with industry will be initiated. Develop-
ment of interim models for predicting the radon hazard potential
of land will be continued. Demonstrations of remedial actions in
cooperation with ORD and with state and local governments will be
continued.
The disposal of radioactive wastes in an environmentally sound
manner is a complex task that requires the collective efforts of
the Department of Energy, the Nuclear Regulatory Commission,
individual states, and private industry, in addition to EPA. The
Agency's principal role in this effort is to establish environmental
standards which limit exposure from the various categories of
radioactive wastes, so as to pose minimal public health risks.
Because of the different types and toxicities of waste being
considered, these problems are treated separately in the develop-
ment of standards for land disposal of low-level wastes, including
natural and accelerator produced materials and for residual radio-
activity at decommissioned nuclear facilities. The Agency expects
to promulgate final rulemaking for land disposal of low-level waste
in FY 1987. ORP will continue to provide technical assistance to
the Office of Water for the issuance of regulations governing the
ocean disposal of low-level waste. Technical work in support of
possible residual radioactivity regulations will continue.
Under Reorganization Plan #3 of 1970, the Agency was transferred
the authority of the former Federal Radiation Council to advise the
President with respect to radiation matters directly or indirectly
affecting health, including guidance for all federal agencies in
the formulation of radiation standards. A continuing role is
necessary in implementing the federal guidance covering radio-
frequency radiation and occupational exposure to radiation.
Protective action guides for relocation and resettlement will
-------
-38-
be completed and added to the Manual of Protective Action.
Continued support will be given to other federal agencies in the
implementation of existing federal guidance.
A determination will be made on the need for the regulation of
phosphogypsum piles under section 112 of the Clean Air Act.
EPA will also complete implementation of radionuclide NESHAPs in
EPA Headquarters and at the Regional Offices. A comprehensive
environmental assessment program pertaining to multiple sources
of radiation in two Idaho communities will continue, with surveys
of various pathways. Support to the Office of Drinking Water on
the review of drinking water standards will be completed.
Key FY 1987 Headquarters Actions to Implement Program Goal
Ti er 1 Acti ons :
(1) Complete pilot tests of the national radon assessment
methodology.
(2) Evaluate techniques for radon mitigation in existing homes
and prevention in future construction. (0 R P / 0 R D)
(3) Implement home mitigation training programs for contractors
on the Reading Prong.
(4) Develop interim models for predicting radon hazard potential.
(b) Publish final environmental standards for low-level waste
disposal. (ORP/OSWER)
Ti er 2 Acti ons :
(1) Continue technical work in support of a residual radioactivity
regulati on.
(2) Continue support to other federal agencies in the implementa-
tion of radiofrequency radiation federal guidance.
(3) Complete the implementation of radionuclide NESHAPs.
(4) Determine the need for regulation of phosphogypsum piles.
Key FY 1987 Regional Office and State Actions to Implement Program
Goal
Tier 1 Actions:
(1) Participate with Headquarters Offices on the implementation
of the indoor radon strategy.
-------
-39-
(2) Provide states with technical assistance and liaison for
guidance interpretation and radon measurement and mitigation
support.
(3) Participate with Headquarters Offices in the identification
and assessment of sites which are contaminated with radio-
acti vi ty.
Tier 2 Actions:
(1) Assist Headquarters Offices in the development of standards
by participating in Agency working groups.
B. Program Goal: Maintain comprehensive surveillance and effective
emergency response capabilities
The Environmental Radiation Ambient Monitoring System (ERAMS) is
the only national multi-media surveillance system which provides
timely measurements of ambient radiation levels in air, drinking
water, surface water, and milk. ERAMS also has the capacity for
rapid assessment of elevated radiation levels which may occur
because of natural or man-made incidents (such as the atmospheric
testing of a nuclear weapon). The 268 sampling locations are found
in every state. In FY 1987 EPA will continue to emphasize improving
the responsiveness of ERAMS in an emergency. EPA will also conduct
further explorations to determine if the system can be used to
collect environmental samples for analysis of nonradioactive pollu-
tants. Arrangements will be made to share environmental samples
collected through the ERAMS network with EPA program offices
that express a need for these samples.
The protocol for surface and drinking water sampling operations
will be modified to provide sequential sampling, consistent with
the needs of other EPA offices for these samples.
The two field facilities of ORP have the capability for designing
and conducting field studies to determine the nature and extent
of radioactive contamination in a variety of media. In FY 1987
ORP will again assess problems and recommend remedial actions to
OSWER to address sites on the National Priority List. ORP and
OSWER will work closely to ensure that appropriate remedial
actions are taken at sites contaminated by radiation.
ORP will also continue to investigate problems of elevated environ-
mental radiation levels which pose significant public health
hazards. The study initiated in cooperation with the State of
Idaho to investigate all sources of radiation exposure around
Pocatello and Soda Springs will continue with surveys of various
pathways. The unique capabilities for the assessment of electro-
magnetic radiation levels will be maintained, with emphasis
-------
-40-
placed on determining the extent to which populations may face
unnecessarily high exposures to radiofrequency radiation.
Construction of a new building for the Montgomery, Alabama, field
facility will proceed.
Key FY 1987 Headquarters Actions to Implement Program Goal
Tier 1 Actions:
(1) Continue the study of radiation sources around two Idaho towns.
(2) Address problems at sites listed on the National Priority List,
in coordination with OSWER.
Tier 2 Actions:
(1) Complete update of ERAMS air monitoring stations.
(2) Publish on a quarterly basis the results of analyses taken
from environmental samples collected at 268 ERAMS stations.
(3) Continue dialogue with other EPA offices to extend collection
of environmental samples to meet the needs of other program
offi ces.
(4) Provide support to federal, state, and local requests for
assistance in resolving problems involving ionizing and
nonionizing radiation, where significant public health risks
may be involved.
(5) Participate in Federal Emergency Management Agency (FEMA)
and EPA exercises as a means of maintaining and improving
emergency response capabilities.
Key FY 1987 Regional Office and State Actions to Implement Program
Goal
Tier 1 Actions:
(1) Assist in continued coordination of the Idaho Study.
(2) Participate in identification, assessment and remediation of
National Priority List sites contaminated by radioactivity.
Ti er 2 Actions:
(-1) Participate in the review, testing, and critique of state and
local emergency response plans for nuclear facilities.
(2) Participate in FEMA and EPA sponsored emergency response
exercises conducted within respective regions.
-------
-41-
OAR SUPPLEMENTAL GUIDANCE SCHEDULE
FOR ISSUANCE IN FY 1986
Guidance
Scheduled Completion
0 AIR TOXICS: Strategic
PIanni ng
Initi ati ve
Q 4
OZONE ATTAINMENT: Strategy
ENFORCEMENT: Federally
reportable
vi ol ati on
Q 4
Q 3
0 GRANTS: Allocation policy
Q 3
-------
Office of
Water
-------
TABLE OF CONTENTS
I. GUIDANCE OVERVIEW
A. New Program Thrusts and Priorities for FY 1987 1
B. Water Program Performance - Based Assistance Policy 3
II. WATER PROGRAM GUIDANCE 6
A. SAFE DRINKING WATER ACT PROGRAMS 7
1. Public Water System Supervision Program 7
2. Drinking Water Standard Setting and Health Advisories 10
3. Underground Injection Control Program 11
B. GROUND-WATER PROTECTION PROGRAM 13
1. State Ground-Water Protection Activities 13
2. Sources of Ground-Water Contamination 14
3. Guidelines for Ground-Water Protection 14
4. EPA Ground-Water Focus and Coordination 15
C. MARINE AND ESTUARINE PROTECTION AND GREAT LAKES PROGRAM 16
1. Ocean Disposal Program 16
2. Programs for Chesapeake Bay, Estuaries and Great Lakes 17
3. Marine Discharge (§301(h)) Variances 20
4. Ocean Disposal (§403(c)) Criteria Evaluations 20
D. CLEAN WATER ACT PROGRAMS 21
1. Cross-Program Management Initiatives 21
a. National Municipal Policy 21
b. Sewage Sludge Management 22
2. Water Quality Standards, Planning and Assessment 24
a. Water Quality Standards and Criteria 25
b. Monitoring and Wasteload Allocations 26
c. Water Quality Management Planning/Priority 27
Waterbodies
d. Nonpoint Source Management 28
3. Permits and Enforcement 28
a. Permits 29
b. Enforcement 30
c. Pretreatment 31
d. State Program Approval, Review and Oversight 33
e. RCRA Activities for NPDES Facilities 34
-------
4. Construction Grant Program 35
a. Transition to State and Local Self-Sufficiency 36
b. Effective State/Regional Management 37
c. Effective Construction/Program Integrity 37
d. Completed Projects 39
e. Program Management 40
f. Performance of Facilities 40
LIST OF SUPPLEMENTAL GUIDANCES TO BE ISSUED 41
-------
FY 1987 OFFICE OF WATER AGENCY OPERATING GUIDANCE
I. GUIDANCE OVERVIEW
The Office of Water portion of the FY 1987 Operating Guidance
provides national direction to EPA Regions, States and the
regulated community in carrying out programs mandated under
Federal water protection statutes. These statutes include:
the Safe Drinking Water Act (SDWA), the Clean Water Act (CWA)
and the Marine Protection, Research and Sanctuaries Act
(MPRSA). The Office of Water and the States also implement
programs to protect groundwater quality through authorization
under several different statutes described in the Groundwater
Protection Strategy.
This portion of the guidance is arranged in three sections.
The first outlines the new program thrusts and priorities for
FY 1987 and the water program policy for Regional negotiation
of the FY 1987 program assistance to the States. The second
section contains the specific program guidance and priority
activities for each major water program. The third section
is the "water" portion of the appendix, which identifies the
strategic planning and management system (SPMS) measures to
be used in evaluating performance on priority activities in
each of the critical program areas.
In addition to the SPMS measures, the Office of Water will
again be publishing a program evaluation guide for FY 1987.
The guide will include definitions, procedures and evaluation
measures for reviewing Regional Office and State agency perform-
ance on water program activities during FY 1987.
The text and priority activities that follow do not assume
passage of any new legislation pending at the time of
publication. Supplemental guidance will be issued for FY 1987
to implement the legislation once enacted.
A. New Program Thrusts and Priorities for FY 1987
In FY 1987 and beyond, management of the water programs will
follow five major directions, consistent with the Administrator's
management plan and Agency goals and priorities. The priority
activities outlined in Part II support and build upon these
five broad, crosscutting program directions.
-------
-2-
Implement Our Basic Programs with a Focus on Environmental
Results
Much of the effort in FY 1987 will be to aggressively implement
standards, regulations, and policies already in place.
Highest priority efforts in this area include support for
State implementation of ground-water protection strategies
developed in FY 1985 - 1986, strong and consistent implementation
of the National Municipal Policy, a shift to pretreatment compliance
and enforcement, a move to compliance and enforcement in the
UIC program, and the first steps in the transition to State
and local responsibility for construction of publicly-owned
wastewater treatment works. The Agency will also initiate
new VOC monitoring requirements for public water systems,
based on promulgation of new drinking water standards, and
implementation of drinking water health advisories where
regulations are not warranted.
To improve our focus on environmental results, the water
program in FY 1987 will reorient monitoring across
water programs to better determine accomplishments, improve
compliance information, identify unregulated contaminants,
and anticipate future problems. The water program will also
pursue performance improvement in the field through support for
geographic initiatives, use of priority waterbody lists,
implementation of the ground-water monitoring strategy,
drinking water health advisories, and technical assistance
for permit and compliance decisions.
Expand Emphasis on Toxics Controls Across All Programs
Several major new thrusts will take place in FY 1987 related
to toxics controls in ground-water and surface water.
Priority efforts include new water quality and permit toxics
criteria development, implementation of the TSCA ground water
strategy, new focus on applying drinking water standards for
water quality-based toxics controls, and the beginning of an
incineration-at-sea program for disposal of hazardous wastes.
Strengthen Protection of all Waters from Difficult or
Uncontrolled Sources
Major new efforts will move forward in FY'1987 to investigate
and develop programs for abating toxic and conventional
pollution from uncontrolled sources. These efforts will
include implementation of a base nonpoint source program to
implement the National NonPoint Strategy, development of a
-------
— 3 —
sediment strategy to identify toxic contamination in sediments,
an increased and stronger emphasis on basin-wide estuarine
management, implementation of the pesticides in ground-water
strategy, the development of Technical Information Publications
(TIPs) for sources of ground-water contamination of significant
concern, continuation of the pesticides in ground-water
survey, and initial studies on unregulated industry categories
with toxic dischargers.
Focus on Cross Media Impacts
Increased awareness is needed by water program managers of
the intermedia impact of the Agency programs, both the impact
our programs have on other media (e.g., air) and the impact
other programs have on our activities. In FY 1987, several
major efforts are planned that will move toward intermedia
decision-making: implementation of the sludge management
program; implementation of the ground-water classification
guidelines; promulgation of the organics (plastics and
pesticides) industry effluent guidelines; implementation of
new RCRA requirements at POTWs, industrial NPDES facilities,
and at Class I UIC wells; and water program participation in
other program working groups.
Broaden Public Awareness/Outreach
The water program plans to pursue several external outreach
initiatives in FY 1987 to better communicate water program
policies to our constituencies. These initiatives will focus
on increased communication with Congress, State agencies and
associations, public interest groups, trade associations, and
industries. In addition, the program will aggressively pursue
ways to ensure that other Federal agencies continue addressing
environmental issues of common interest (e.g., nonpoint
source, oceans). The program will use the Communications
Strategy Plan process (coordinated by the Office of External
Affairs) to inform the public and affected groups of the
regulatory decisions and actions we take.
B. Water Program Performance-Based Assistance Policy
On May 31, 1985, the Administrator issued the Policy on
Performance-Based Assistance, which explicitly links EPA
assistance to effective State performance. This section
supplements the Agency policy for program grants administered
by the water programs. The policy has three components:
negotiation of work programs, oversight of program performance,
and actions to reward accomplishments and correct problems.
-------
-4-
Performance-based assistance programs are built on commitments
jointly negotiated prior to grant award. Work programs must
provide for early warning of missed commitments and a mechanism
to respond to them. The overall approach is to use the
assistance process to jointly agree on how and to what extent
Agency and State priorities will be met.
The water program performance-based assistance policy applies
to all State and local assistance programs under the Clean
Water Act, Safe Drinking Water Act, and related appropriations.
Funding priorities should be based on the Agency priority
list, the individual program priority activities (see part
II), and achievement of State SPMS commitments. All water
program assistance agreements in FY 1987 are to be consistent
with the policy outlined in this section.
Negotiation of Work Programs
Regions and States are to tailor their work programs to the
priority activities listed in Part II of this guidance,
recognizing the individual Region/State circumstances and
priorities and the level of program assistance. Regional
Offices may issue written guidance tailored for each State to
incorporate national, Regional, and State priority activities
into the work program negotiation process. Work programs
must contain realistic commitments for every national SPMS
measure. It is critical that the work program clearly identify
both the performance expectations and the plan for EPA's
evaluation of State performance. The States should be
encouraged to provide a comprehensive work program that
includes activities outside those paid for under the assistance
agreement.
Oversight of Program Performance
Oversight will be designed to give an early indication of
State progress and problems in meeting the work program
commitments. Regional Offices must monitor and evaluate
program performance both informally and formally, maintaining
continuous dialogue with the States to give early warning of
emerging issues. Regions must conduct a minimum of one on-
site raid-year evaluation, culminating in a report of findings
and follow-up activities. Regional reports must include
comments from the State on the report's findings. A copy of
the mid-year evaluation report for each State is to be sent
to Headquarters.
-------
-5-
Actions to Reward Accomplishments and Correct Problems
Follow-up actions to evaluate findings are meant to find the
most effective way to maintain and improve program performance.
Regional Offices should encourage good performance by
publicizing accomplishments and reducing the extent, level,
and scope of oversight. Where appropriate, financial incentives
should be provided. Likewise, where performance problems
exist, the Regional Office is to initiate a series of escalating
actions to resolve the problem in a quick and fair manner.
Where performance problems persist, actions should include the
use of the grant mechanism as outlined in 40 CFR Part 30 and
Subpart A of Part 35. Corrective measures are to be based on
the severity and persistance of the performance problem, in line
with the performance expectations laid out in the original
work program.
-------
-6-
PART II
FY 1987 WATER PROGRAM GUIDANCE
NOTE ON GUIDANCE FORMAT
Part II of this guidance contains specific program direction
and priority activities for FY 1987. The priority activities
are of two types, activities that support one or more Agency
priorities or those that support one or more Office of Water
(OW) program priorities. Activities that support Agency
priorities are denoted on the left-hand margin by an asterisk
(*) while activities that support OW activities are denoted by
a bullet (°).
Although many of these activities appeared word-for-word in the
FY 1986 - 1987 guidance others have been modified or added to
reflect changes in the program direction and/or responsibilities.
Modified priority activities are denoted by a dash (-) in the
right hand margin while new priority activities are denoted by
a plus sign (+). This simple coding of priority activities
should considerably improve the reader's ability to identify
changes in program activity for FY 1987.
An additional note, the subsection identifiers (a, b & c . . .)
relate only to the structure of this guidance document and not
to the structure of the OW Evaluation Guide soon to be published.
-------
-7-
II. WATER PROGRAM GUIDANCE
A. SAFE DRINKING WATER ACT PROGRAMS
Two of the priorities listed in the Agency's priority list for
FY 1987 are directly implemented through the drinking water
programs. The first priority is to control drinking water
contaminants which encompasses implementing the Volatile Organic
Contaminant (VOC) Regulations, monitoring for unregulated
contaminants, promulgating additional standards as needed, and
ensuring compliance with the existing drinking water standards.
In addition, it includes expanding the health advisory program
in support of RCRA waste banning decisions, Superfund cleanup
activities, and control actions for agricultural chemicals.
The second Agency priority is the control of underground
injection. This encompasses monitoring underground injection
permit issuance and enforcement efforts on existing facilities
that present the greatest threat to underground sources of
drinking water, and to review the current practices of under-
ground injection of hazardous wastes and initiate appropriate
control actions.
1. Public Water System Supervision (PWSS) Program - Priority
Activities
* The principal objectives of the State and Regional programs
should continue to be the elimination of all violations of
the National Interim Primary Drinking Water Regulations
(NIPDWRs). Of particular concern to EPA will be community
water systems which are in significant noncompliance (SNC).
(The new definitions of SNC, to apply to FY 1987, will be
contained in the Office of Water Accountability System (OWAS)
guide. They will be subject to change dependent upon the
outcome of the three PWSS Data Policy Seminars to be held in
April.) EPA's goal is that every SNC will either be returned
to compliance, be operating under and adhering to an enforce-
eable compliance schedule, or have a formal enforcement
action taken against it to elicit compliance. (Ongoing)
* Regions and States are to negotiate annual targets for the
maximum allowable number, and percent, of community water
systems which are significant noncompliers. For FY 1987,
we ask that one combined target (rather than separate
targets as has been the practice in the past) be set for
systems which are significant noncompliers of any of three
contaminants — microbiology, turbidity, and total trihalo-
methane (TTHM). (Regions may negotiate separate targets in
addition to the combined target if they desire). Further,
-------
-8-
we are not setting a national target for significant non-
compliers as has been done in past years. Rather, Regions
are to negotiate each State's target based upon that State's
current compliance and capabilities. We are, however,
asking that each State's target reflect, at least, a 10%
improvement over its previous year's results. Regions
should negotiate for more than 10% improvement where they
believe States can achieve greater improvement. (Ongoing)
States and Regions are to place greater emphasis on systems ( + )
which violate a chemical (organics other than TTHM and
inorganics) or radiological requirement. We will develop
a definition of what constitutes a significant noncomplier
of a chemical or radiological requirement during FY 1986,
and will track these systems and ask States to report en-
forcement activity to us during FY 1987. We anticipate
requiring States to negotiate targets for these noncomplying
systems beginning in FY 1988. (Ongoing)
States and Regions are to place high priority on the quality (-)
of the compliance, inventory, and enforcement data submitted
to the Federal Reporting Data System (FRDS), as this data is
the foundation of much of EPA's oversight program. As one
element of the quality assurance effort, Regions are to
continue to conduct data verifications of State violation (
reports. Regions are to follow up on those States for which
previous audits revealed reporting inconsistencies to ensure
that the recommendations made are being implemented and
that there has been an improvement in the quality of the
reporting. (Ongoing)
States and Regions will implement the VOC Regulations and the (+)
requirement for monitoring the unregulated contaminants. HQ
will develop guidance on implementation of these regulations
and on Agency support for enforcement of failures to monitor
for the unregulated contaminants. (First Quarter)
States and Regions should place special emphasis on tracking ( + )
results, and improving compliance, of the Oceanic Islands
and other groups of systems which have an inordinately high
degree of noncompliance. (Ongoing)
States are to begin, if they are not already doing so, to ( + )
enter into FRDS the analytical results where chemical and
radiological Maximum Contaminant Levels (MCL) violations
occur so that determinations can be made about degrees of
noncompliance. (Ongoing)
HQ and Regions will increase their efforts to achieve better (+)
coordination with the Offices of Solid Waste and Emergency
Response and Pesticides and Toxic Substances. (Ongoing)
-------
-9-
Regions are to ensure that States have developed formal
compliance strategies and that they are being implemented.
(Ongoing)
States and Regions are to ensure enforcement actions are
timely and appropriate. (HQ will revise, as necessary, the
existing national timely and appropriate "timelines" to be
consistent with the new definition of SNC.) (Ongoing)
HQ and Regions will continue to review State enforcement
actions and will consider Federal enforcement actions on
noncompliers against which the States have not taken an
appropriate action and show no signs of immediate return to
compliance. Regions will, in the conduct of their compliance
and enforcement programs, identify and refer to OIC for
investigation of suspected criminal conduct, "tips' or other
information relevant to criminal enforcement. (Ongoing)
States are to continue to provide quarterly inventory and
violation reports to Regions. Regions are to discuss with
the States the goal of shortening the data submission and
review periods. Regions are to place greater emphasis on
their own reviews of state compliance data, both in terms
of quality and turnaround time. When the quality of the
data reporting is maximized, we will focus on turnaround
time with the goal being the extraction of the compliance
data from the PROS within one quarter. (Ongoing)
Regions will conduct intensive reviews of selected primacy
State programs. (Ongoing)
States and Regions are to collect and assess data on com-
pliance rates of "high priority" noncommunity water systems
(schools, day care centers, factories, hospitals, campgrounds,
etc.), and begin an effort to improve the compliance of these
systems. (Ongoing)
Regions are to fully implement the PWSS program on Indian (+)
lands to improve compliance with drinking water regulations
and should ensure that their program is consistent with the
Agency's Indian Policy. (Ongoing)
States and Regions are to ensure that compliance at Federal ( + )
facilities is part of their compliance and enforcement pro-
grams. To enable EPA to identify Federal facility compliance
automatically, States and Regions should ensure that Federal
facilities are correctly coded in FRDS.
-------
-10-
2. Drinking Water Standard Setting and Health Advisories -
Prioirity Activities
The Agency will continue to revise the National Primary Drinking
Regulations in phases and to develop health advisories.
In addition to satisfying the Safe Drinking Water Act require-
ments, the MCLs and advisories will assist Superfund cleanup
activities, response to contamination incidents, and other
purposes.
* HQ will promulgate the first phase of revised National Primary
Drinking Water Regulations for volatile organic chemicals
(VOCs) and monitoring rule for unregulated VOCs. (First
Quarter)
* HQ will promulgate recommended maximum contaminant levels
(RMCLs) and propose MCLs for synthetic organic chemicals,
inorganic chemicals, and microbiological contaminants.
Requirements will be proposed for filtration and disinfection
of surface water supplies and disinfection of ground-water
supplies. (Second Quarter)
* HQ will promulgate RMCLs for radionuclides and propose MCLs.
(Third Quarter)
* HQ will continue with the review of Interim regulations and
research results concerning disinfection by-products.(Ongoing)
* Regions will assist States in drinking water contamination
cases involving regulated and unregulated contaminants and
provide follow-up to water supply monitoring in coordination
with other programs such as RCRA and Superfund. (Ongoing)
* HQ will develop additional health advisories and disseminate
to the Regions and States. EPA Headquarters will direct a
Performance Improvement Project to assist in use of the
health advisories. (Ongoing)
0 HQ will continue to conduct the National Pesticides Survey.
(Ongoing)
0 HQ will finalize implementation of a third party certification
program for drinking water additives, and will continue to
review petitions for use of additives in drinking water
during the transition to the third party program. (Ongoing)
-------
-11-
3. Underground Injection Control Program - Priority Activities
The major goal of the Underground Injection Control (UIC)
program in FY 1987 will be to assure the effective implementation
of high quality direct implementation and primacy programs.
Objectives for FY 1987 are to assure that: (1) programs conform
to applicable regulations and program descriptions; (2) reporting
is accurate and used for management purposes; and (3) EPA and
primacy States take timely and appropriate action to resolve
instances of significant noncompliance. A major Headquarters
activity will be to develop appropriate restrictions on the
injection of hazardous waste.
* HQ and Regions will monitor and review mechanical integrity
of injection wells authorized by Rule to determine compliance
with the UIC regulations and determine whether the current
regulations are adequate to protect Underground Source
of Drinking Water (USDWs). (Ongoing)
* States and Regions will complete the assessment of Class V
wells required by regulations to determine the potential
for contamination of ground-water through improper underground
injection activities and/or practices. (Ongoing)
* States and Regions will vigorously control land disposal of (+)
hazardous waste using injection wells and HQ will complete
the necessary studies to determine which hazardous wastes
should be banned from land disposal by well injection.
(Ongoing)
* States and Regions will establish a strong field presence by
conducting field inspections and surveillance, initiating
compliance evaluations and commencing appropriate enforcement
actions. (Ongoing)
* States and Regions will review and make permit determinations
for new and existing injection wells based on the following
priority order: (Ongoing)
1. new Class II oil and gas wells.
2. existing Class I wells, if any.
3. existing Class III wells, if any.
4. new Class I and III wells.
5. existing Class II salt water disposal wells.
-------
-12-
Regions and HO will continue support for enforcement
cases begun in FY 1986 under the UIC enforcement
initiative. (Ongoing)
States and Regions will annually inspect all Class I (+)
and IV wells and Class II and III wells with significant
violations to verify compliance with permit and regulatory
requirements. (Ongoing)
States and Regions will respond promptly to all instances (+)
of noncompliance by Class I and IV wells and significant
Class II, III, and V violations. (Ongoing)
Regions will oversee delegated State programs, conduct
intensive reviews in selected States, negotiate (-)
enforcement agreements, and take enforcement action where
the State has not or cannot respond to significant violations
in a timely and appropriate manner. (Ongoing)
States and Regions will ensure compliance with all formal (-)
enforcement actions through tracking and prompt follow-up
when deadlines are missed. (Ongoing)
HQ and Regions will process sole source aquifer petitions. (+)
Regions will review Federal projects in designated sole
source aquifer areas to assure that drinking water sources
will not be contaminated. (Ongoing)
Regions will review existing Class II enhanced recovery ( + )
permit files in lieu of repermitting. (Ongoing)
HQ will manage the necessary research studies to evaluate
the practice of storage or disposal of hazardous waste in
salt domes, bedded salt, and caves. Regions will work
together with HQ to evaluate the research results and propose
changes to the UIC program regulations as necessary to protect
public health and the environment. (Ongoing)
Regions will perform hydrogeological evaluations on ground- ( + )
water contamination incidents that may have the potential
to contaminate drinking water sources. (Ongoing)
Regions and HQ will review alternative methods for demonstrat-
ing mechanical integrity of wells for which no current method
is yet acceptable (i.e., dual completion wells). (Ongoing)
Regions will continue existing well construction reviews to
complete their commitment to review all wells within five
years. (Ongoing)
-------
-13-
B. GROUND-WATER PROTECTION PROGRAM
The major objectives of EPA's Ground-Water Protection Strategy
include: 1) supporting State ground-water protection activities;
2) addressing sources of ground-water contamination; 3) adopting
guidelines for ground-water protection; and 4) providing greater
EPA ground-water focus and coordination.
This program addresses the first Agency goal of reducing risks
of exposure to existing pesticides and toxic chemicals.
Specifically, most aspects of this program focus on the third
priority under the first Agency goal to support development of
State strategies and programs as well as methods to address
sources of contamination of national concern. This program will
address high priority concerns expressed in the Regions' Environ-
mental Management Reports.
1. State Ground-Water Protection Activities - Priority Activities
States have responsibility for the protection of the ground-water
resource and EPA has responsibility for the control of certain
contamination sources. EPA will provide grant support for State
strategy development and technical and management assistance, with
the Regions serving as the principal contact with the States.
* HQ and Regions will continue to refine section 106 State
ground-water grant guidelines with final grant guidance avail-
able in February. (First/Second Quarters)
0 Regions will assist States in developing coordinated FY 1988
ground-water work plans and strategies which will assess their
ground-water protection problems and develop appropriate
protection efforts. (Third and Fourth Quarters)
* HQ and Regions will jointly conduct three State workshops
focusing on elements of successful State ground-water
programs. (Ongoing)
* HQ and Regions will jointly conduct three workshops to foster
the capacity to manage the classification guidelines and to
implement the findings of the Technical Information Publica-
tions (TIPs) such as that developed on septic tanks. (Ongoing)
0 HQ will issue technical reports on ground-water management in
areas such as monitoring, classification, well field protec-
tion, and State/local coordination. Topics will be determined
with the Regions. (Ongoing)
-------
-14-
* HQ and Regions will carry out activities initiated in 1986 (+)
related to aquifer mapping and classification. Technical
assistance will be provided to States, in conjunction with
the U. S. Geological Survey (USGS) on aquifer mapping as it
relates to ground-water quality management and classification.
2. Sources of Ground-Water Contamination - Priority Activities
The Strategy calls for efforts to determine the extent of problems
caused by ground-water contamination sources not covered by
Federal statutes and to provide assistance to States on appropri-
ate responses.
* HQ will convene two technical panels to develop expert
consensus and to produce Technical Information Publications
(TIPs) describing successful practices for dealing with
selected unregulated activities affecting ground-water quality,
(e.g., unregulated mining, run-off from road salting). Regions
will assist in developing the TIPs and in working with the
States. (Ongoing)
* HQ and Regions will work with the Office of Pesticides (+)
Programs and the States to implement selected provisions of the
Agricultural Chemicals in Ground-Water Strategy. (Ongoing)
* HQ and Regions will implement the ground-water monitoring
strategy and hold meetings with States to address major prov-
isions. (First Quarter/Ongoing)
* HQ will develop a ground-water data program capable of storing ( + )
and analyzing ground-water quality data collected by EPA,
States, and private industry which will be linked to other
ground-water related systems (e.g., USGS). (Ongoing)
3. Guidelines for Ground-Water Protection - Priority Activities
EPA will issue guidelines based on a three-tiered classifica-
tion system taking into account the value and relative vulner-
ability of the resource. Guidelines will apply to new and,
over time, existing ground-water programs.
0 Regions will assist States in implementing guidelines through
technical assistance, workshops and other vehicles, as needed.
(Ongoing)
0 HQ and Regions, working with RCRA and Superfund, will assess
EPA ground-water regulations, guidelines, and policy state-
ments and propose revisions to improve the consistency of
ground-water programs. (Ongoing)
-------
-15-
0 HQ will work to apply the ground-water classification, ( + )
monitoring, and other concepts of the strategy for nonpoint
sources. (Ongoing)
* HQ and Regions will work with States that have ground-water (+)
classification systems to help achieve the equivalence of the
State systems to EPA's so that the State system can be applied
to EPA programs in lieu of EPA's approach. (Ongoing)
4. EPA Ground-Water Focus and Coordination - Priority Activities
EPA established ground-water offices in Headquarters and the
Regions. Using the strategy and other mechanisms EPA will
assure coordination among ground-water programs.
0 HQ and Regions will manage internal coordination committees to
address major policy questions and to fully integrate Regional
ground-water operations. External coordinating committees will
be managed to involve key constituency groups such as State/
local governments and other Federal agencies. (Ongoing)
0 HQ and Regions will manage MOU's with the U.S. Geological
Survey and the Bureau of Reclamation to enhance collaboration
in achieving ground-water protection goals. (Ongoing)
0 Headquarters will represent EPA with the National Ground-Water
Commission to be established under the RCRA reauthorization.
(Ongoing)
0 HQ will continue a public information program to inform the ( + )
public on ground-water issues and EPA protection initiatives.
(First Quarter/Ongoing)
0 ORD will continue to provide both technical information and (+)
improved methods for predicting contaminant movement, trans-
formation, monitoring and aquifer reclamation including deve-
loping laser-induced fluorescence for monitoring ground-water
by fiber optics.
0 ORD will conduct studies to determine the effects of seasonal (+)
variation and sampling frequency on the accuracy and confidence
of ground-water monitoring.
0 ORD will continue to focus on methods development and studies (+)
of subsurface transport and fate processes such as sorption,
biological transformation, redox and hydrolysis.
0 ORD will conduct research to determine the cost-effectiveness (+)
of in situ aquifer restoration techniques, leading to cleanup
where previously the cost was prohibitive.
-------
-16-
C. MARINE AND ESTUARINE PROTECTION AND GREAT LAKES PROGRAMS
Title I of the Marine Protection, Research, and Sanctuaries Act
(MPRSA) regulates the transportation and ultimate disposal of
materials in ocean waters. Its purpose is to prevent or limit
disposal of harmful materials and to establish a permit program
for disposal of dredged and other materials. Clean Water Act
(CWA) provides for protection of marine, estuarine, and Great
Lakes water quality, including permitting secondary treatment
variances which comply with criteria, evaluating compliance of
ocean discharges with established criteria, and conducting
targeted programs to deal with major environmental problems.
These activities are responsive to the Agency's environmental
goal to maintain and improve water quality and also the goal to
protect near coastal waters. The programs are supported by
Office of Research and Development, including development of
assessment procedures for ocean disposal of waste, procedures for
wasteload allocations to improve estuary source control decisions
and study of transport, fate, and effects of toxics in Great
Lakes. Some activities result from problems cited in 1985
Environmental Management Reports, including national data
management system for estuaries, monitoring for 106 Mile Ocean
Disposal Site, and improved site designation for ocean disposal.
1. Ocean Disposal Program
MPRSA required that the Agency establish criteria for ocean
disposal, which are in Agency regulations that establish a two
stage process for site designation and permit issuance.
MPRSA provides authority to designate sites and times for ocean
disposal of acceptable materials and any critical areas where
disposal may be prohibited. Upon delegation of authority, the
Regions will assume site designation authority (except for incin-
eration-at-sea) and responsibility for attendant site designation
rule making and final decision packages. The Agency has begun
evaluating sites for incineration-at-sea, and HQs will continue
to be responsible for designating incineration-at-sea sites.
MPRSA §102 requires EPA to establish and apply criteria in review
and evaluation of incineration-at-sea and other non-dredged
materials permit applications. EPA reviews dredged material
permits prepared by Corps of Engineers based on EPA criteria.
a. Site Designation - Priority Activities
0 Regions, with EPA HQs assistance, will continue to conduct
field surveys to analyze impacts of waste disposal at
existing waste disposal sites. (Ongoing)
0 EPA HQs, having delegated disposal site designation
authority to Regions (except for incineration-at-sea), will
continue to provide guidance for preparing environmental
assessments and making designation decisions. (Ongoing)
-------
-17-
0 EPA HQs and Regions should complete activities in Memoranda
of Agreement with Corps of Engineers on resources to
designate dredged material sites. (Ongoing)
0 EPA HQs will continue providing technical support to Regions
for developing environmental assessments or impact statements
and for continuing site management. (Ongoing)
* EPA HQs will conduct incineration-at-sea site monitoring to
establish baseline data and to ensure adequate site
management. (Ongoing)
0 Regions will prepare environmental assessments or impact
statements and site designation rule-making packages, issue
permits, and conduct monitoring reviews for site management.
(Ongoing)
b. Permit Issuance - Priority Activities
* EPA HQs will develop revisions to ocean dumping regulations (-)
in response to two law suits and statutory amendments, and
will develop technical guidance for the revised regulations.
(Ongoing)
0 EPA HQs will implement a research strategy for incineration-
at-sea permits in cooperation with Office of Research and
Development and permit applicants. (Ongoing)
* EPA HQs will develop and implement incineration-at-sea
regulations and, as appropriate, will develop and issue
incineration-at-sea permits. (Ongoing)
0 EPA HQs will support monitoring activities necessary for
evaluation of permit compliance in cooperation with U.S.
Coast Guard, and take necessary enforcement action. (Ongoing)
0 Regions will review Corps of Engineers public notices for
ocean disposal permits for dredged materials for compliance
with EPA ocean disposal criteria. (Ongoing)
0 Regions will review ocean disposal permit applications,
require field and laboratory tests to evaluate wastes on
case-by-case basis, conduct needed hearings, require monitor-
ing to evaluate permit compliance, and take necessary
enforcement action. (Ongoing)
0 Regions will review and make determinations on research and (+)
emergency ocean disposal permit applications. (Ongoing)
2. Programs for Chesapeake Bay, Estuaries and Great Lakes
In FY 1987, EPA will continue ongoing basin-wide programs in the
Chesapeake Bay, Great Lakes, and support for study and planning
initiatives for selected State and local estuary programs.
-------
-18-
National estuary program funds will again be distributed under
cooperative and interagency agreements with individual estuary
program participants. In FY 1987, emphasis will be on completion
of characterization of environmental status and trends and on
development of master environmental plans.
a. Chesapeake Bay - Priority Activities
* Chesapeake Bay States, with Implementation Committee and
Liaison Office, will continue to implement 1985 Chesapeake
Bay Restoration and Protection Plan. (Ongoing)
0 EPA HQs and Region will continue to coordinate EPA and other
Federal programs for surface water toxics, loss of environ-
mentally sensitive areas, and ground-water contamination
affecting Chesapeake Bay. (Ongoing)
EPA HQs and Region will provide Bay States with technical and
funding assistance for controlling nonpoint pollution sources
and maintaining data base. (Ongoing)
EPA HQs and Region will support State monitoring programs for
Bay's mainstem and key tributaries to assess water quality
problems and evaluate abatement programs, and target inspect-
ions and enforcement actions on sources in Bay area. (Ongoing)
Region, with Bay States, will develop Phase II Implemen- ( + )
tation Program to be completed in three years. (Ongoing)
National Estuary Program - Priority Activities
EPA HQs will develop criteria for selection of additional
estuaries. (First quarter)
EPA HQs will provide technology transfer to assist programs (-)
with guidance and state-of-the-art science and methodologies.
(Ongoing)
Regions, with EPA HQs, will assist estuary program partici- ( + )
pants in implementing national guidance. (Ongoing)
Regions and EPA HQs will develop data evaluation systems to
complete characterization of status and trends, to define
pollution and resource problems, and to identify management
initiatives. (Ongoing)
States and program participants, with EPA HQs and Regions ( + )
assistance, will carry-out estuary projects funded under
FY 1986 workplans. (Ongoing)
-------
-19-
* States and program participants will conduct characterization (+)
of status and trends, assessment of living resources, and
preparation of information and presentation materials on each
estuary program. (Second and third quarters)
0 Regions, with EPA HQs assistance, will develop funding agree- ( + )
ments with program participants from approved FY 1987 annual
workplans to address and carry-out workplan elements.
(Second quarter)
0 EPA HQs and Regions will continue to coordinate with NOAA and
other federal agencies on research and monitoring activities
in estuaries. (Ongoing)
c. Great Lakes (GL) - Priority Activities
0 Regions and GL States will participate in activities of Inter-
national Joint Commission (IJC) and IJC Water Quality Board
and track U.S. progress in meeting terms of GL Water Quality
Agreements. (Ongoing)
0 GL States will continue to implement phosphorus load reduc- (+)
tion plans for Lake Erie, Lake Ontario, and Saginaw Bay, and
participate in 1988 bi-national review of progress in
reaching the target loads. (Ongoing)
0 Regions and GL States will continue to investigate and report
remaining effluent toxicity from point sources in GL Basin,
including toxicity testing for major municipal treatment
plants, major iron and steel sources, petroleum refineries,
chemical manufacturers, and pulp and paper mills. (Ongoing)
0 Regions and GL States will continue to investigate and report ( + )
effluent concentrations and quantities of top priority
compounds identified by IJC, consisting of the eleven primary
track compounds identified to date, and will complete for
appropriate industrial categories as part of permit
reissuance process. (Ongoing)
0 Regions and GL States, supported by GL National Program (+)
Office, will continue to emphasize implementation of
action plans and related U.S.-Canadian initiatives for
toxics monitoring and control programs for Niagara
River. (Ongoing)
0 GL States will complete and implement remedial action plans (+)
for areas of concern, updating plans as needed, and including
development of plans and measures for addressing in-place
pollutants and combined sewer overflows. (Ongoing)
-------
-20-
0 Regions and GL States will implement GL Monitoring Strategy (+)
Strategy, including the redesigned GL Atmospheric Deposition
network. (Ongoing)
0 Regions, with GL State support, will continue to undertake,
in support of toxic chemical mass balance, studies to deter-
mine the contribution of toxicants from poorly quantified
sources, such as groundwater, landfills, and pesticides from
agriculture, and undertake mass balance modeling efforts for
Green Bay and/or Saginaw Bay. (Ongoing)
0 EPA HQs, Regions, and Great Lakes States will support IJC Water
Quality Board in developing U.S.-Canada priority ranking of
toxicants in GLS having adverse effects on human health and
ecosystem. (Ongoing)
3- Marine Discharge (§301(h)) Variances - Priority Activities
CWA §301(h) authorizes EPA to allow publicly owned treatment
works (POTW) to discharge into marine waters with less than
secondary treatment, iE certain criteria are met.
0 Regions will review 301(h) applications, issue decisions and
permits expeditiously, and assure that POTWs implement
approved monitoring programs, including appropriate quality
assurance planning. (Ongoing)
0 EPA HQs will provide overview, guidance, contractor assist-
ance, and national task force support to maintain national
consistency for 301(h) decision process and monitoring
programs. (Ongoing)
0 EPA HQs will assist Regions in managing and analyzing an
increased volume of monitoring data. (Ongoing)
4• Ocean Disposal (§403(c)) Criteria Evals. - Priority Activities
CWA §403(c) requires that EPA evaluate ocean discharge permits on
the basis of Agency criteria developed for activities requiring
such permits, including marine point source discharges of munici-
palities and industries and oil and gas operations on the outer
continental shelf.
0 Regions, with EPA HQs guidance and policy and technical (+)
assistance, will prepare Ocean Disposal Criteria Evaluations
for oil and gas operations on the outer continental shelf.
(Ongoing)
-------
-21-
D. CLEAN WATER ACT PROGRAMS
The Clean Water Act (CWA) provides a comprehensive structure for
water pollution control. The Act provides for establishing
technology-based and where necessary, water quality-based controls
for point sources of pollution, establishment of water quality
standards, monitoring to assess water conditions and trends, and
water quality management (WQM) planning to analyze problems and
design needed control measures. EPA and State agencies implement
a permit and enforcement program for municipal and industrial
dischargers. In addition, the Clean Water program provides grants
to municipalities for construction of wastewater treatment
facilities and State program assistance.
1. Cross-Program Management Initiatives
During FY 1987 the Agency will pursue two cross-program manage-
ment initiatives to more systematically address key environmental
concerns: implementation of the National Municipal Policy (NMP)
and sewage sludge management.
a. National Municipal Policy; An Overview of Roles and
Responsibilities
A top Agency CWA priority during FY 1987 is for EPA and the States
to move aggessively to achieve as much compliance as possible
by July 1, 1988, under the National Municipal Policy. FY 1987 is
a year that presents some interesting challenges to the Federal/
State partnership in water programs. First, FY 1987 is the time
when administering agencies will be following through to complete
filed cases and when municipalities may begin to miss the milestones
in their enforceable schedules. As this happens, administering
agencies may face relatively large enforcement workloads. This
calls for the EPA Regions and States to work side-by-side to
handle the workload cooperatively and efficiently, and to look for
better ways to approach jobs such as responding in a timely and
appropriate manners to compliance schedule violations.
Second, FY 1987 is the year in which administering agencies
accelerate their efforts to get minor POTWs on enforceable schedules,
with special attention on municipalities that receive Federal
grants and on unfunded POTWs that are contributing significantly
to water quality impairment. In dealing with unfunded municipali-
ties, administering agencies need to exhibit great sensitivity to
their special problems and needs. In working with these communi-
ties, for example, every effort should be made to provide them with
available technical information on financial capability assessment
and on alternative, less costly wastewater treatment technologies.
It is also important to develop reasonable, expeditious schedules,
even if that means court-approved orders to go beyond July 1, 1988.
-------
-22-
Meeting the Agency's FY 1987 NMP goals also calls for close
cooperation across key organizational units at Headquarters and
in the Regions, especially construction grants, permits and enforce-
ment. The NPDES compliance and enforcement program has overall
responsibility for managing the NMP effort, including: assuring
that permits contain appropiate final effluent limits; issuing or
obtaining enforcement orders to require compliance; monitoring
whether POTWs meet the milestones in these orders; and escalating
enforcement actions as necessary. EPA Headquarters is responsible
for contractor assistance and guidance for compliance support
activities, including financial capability analyses and other
technical and legal support for selected NMP cases (see page 30
for the specific activities).
The construction grants program has major responsibilities in
several areas. It will continue to provide assistance to help
States and local governments pursue sound alternative funding
mechanisms. The program will also work directly with affected
municipalities. For POTWs that receive (or are expected to
receive) Federal funding, these activities include: precertifying
potential grantees in advance of actual grant awards to speed up
the process; ensuring that construction and compliance schedules
are reasonable, expeditious, and consistent; monitoring schedules
and taking program action where necessary; and reporting major
slippage beyond July 1, 1988, to the enforcement program. Where
fully constructed POTWs are not operating in compliance with their (
final effluent limits, the program will provide onsite compliance
assistance to selected small POTWs and will review grantee
project performance certifications, assisting as appropriate in
development of corrective action programs.
For unfunded municipalities, the construction grant program
responsibilities include: making technical information on financial
capability assessment and treatment technology available; and
reviewing Municipal Compliance Plans (MCPs) and making determinations
on the accuracy and reasonableness of the proposed solutions,
schedules, and financing mechanisms. (see page 36 for specific
activities)
b. Sewage Sludge Management
Section 405(d) of the Clean Water Act requires the Administrator
to publish regulations providing guidelines for the disposal of
sewage sludge and the utilization of sewage sludge for various
purposes. Based on the statute, recommendations of the Sludge
Task Force which studied sludge management issues from 1982 to
1984, and the "Policy on Municipal Sludge Management" (49 FR
24358; June 12, 1984), EPA is developing additional technical
criteria governing sludge management activities, and requiring
States to develop programs, or improve existing ones, to assure
that wastewater treatment works, and others that generate or use
sewage sludge, follow the technical criteria.
-------
-23-
The Office of Municipal Pollution Conrol (OMPC) is developing the
State Sludge Management Program Regulations (40 CFR Part 501) and
the Office of Water Regulations and Standards (OWRS) is developing
the technical criteria governing sludge management practices (40
CFR Part 503). These regulatory development activities are being
coordinated with related program activities in the Office of Marine
and Estuarine Protection (OMEP), the Office of Water Enforcement
and Permits (OWEP), and the Office of Air and Radiation. (OAR)
Activities of the Office of Solid Waste and Emergency Response
related to the implementation of the Hazardous and Solid Wastes
Act of 1984 may affect sludge management practices. The revision
of the extraction procedure (EP) test, the "land disposal ban
rule", and application of the "permit by rule" and "corrective
action provisions" to wastewater treatment works are the most
significant activities. The Office of Water is working closely
with the Office of Solid Waste and Emergency Response on these
and other issues. The goal is to have sewage sludge regulated
under the CWA except for those cases in which sewage sludge is
co-disposed with solid wastes in landfills where regulations
under the Resource Conservation and Recovery Act would govern.
For the purpose of this discussion, sewage sludge means the
residuals from wastewater treatment works treating primarily
domestic sewage. Not included are residuals from privately-owned
wastewater treatment works operated in conjunction with industrial
manufacturing and processing facilities. Current estimates are
that about 7 million dry tons of sewage sludge are generated each
year by domestic sewage treatment works. This figure is expected
to double by the year 2000 as more sewage treatment facilities are
upgraded and go into operation.
Sludge-Management - Priority Activities
0 EPA Headquarters (OMPC) intends to publish the final State
Sludge Management Program Regulations (40 CFR Part 501)
in FY 1987. (Second Quarter)
0 EPA Headquarters (OWRS) plans to publish the final sludge
technical regulations (40 CFR Part 503) in FY 1987. (Fourth
Quarter)
0 EPA (OWRS/OMPC/ORD) will conduct seminars to assist the
Regions and States in the implementation of both the Part
501 and Part 503 regulations. (Ongoing)
0 EPA Headquarters (OWRS/ORD) will begin evaluation of
additional pollutants of concern which will be subjected to
the risk assessment methodology and potential for regulation
in FY 1988. (Ongoing)
-------
-24-
0 States should be developing an inventory of sludge use and
disposal facilities. The inventory should provide an
estimate of the quantity/quality of sludge being handled at
each facility, summarize the quantity/quality of sludge being
handled by each of the major sludge use/disposal practices,
and identify projects not in compliance with applicable
regulations and what actions are being taken to bring them
into compliance. States should develop the inventory whether
or not the final State Sludge Management Program Regulations
have been published. (Ongoing)
0 States should be assessing their current sludge management
programs and determining what, if any, improvements are
necessary to comply with the State Sludge Management Program
Regulations. Regions should be prepared to assist the States
in this effort. (Ongoing)
0 States and Regions should cooperate in developing a schedule
for the orderly submission and approval of State programs to
avoid overloads and delays. It may be possible for some
States to submit their programs to the Region within six
months after the final State Sludge Management Program
Regulations are published. (3rd Quarter)
0 Regions and States should ensure that existing and new
construction grants projects are consistent with sound
sludge management practices and applicable regulations (e.g.
40 CFR part 257). (Ongoing)
0 Headquarters will, in cooperation with Regions and the
States, develop appropriate compliance and enforcement
guidance to support the sludge management program.
(4th Quarter)
0 Regions and States should assess sludge management activities
in conjunction with National Pollution Discharge Elimination
System (NPDES) pretreatment inspections to determine POTW
compliance with applicable sludge disposal criteria. (Ongoing)
2. Water Quality Standards, Planning and Assessment
Clean Water Act programs directly implement the Agency goal to
maintain and improve water quality by addressing point and non-
point sources (NPS) of pollution. In the point source area, OWRS
will continue to support the application of technology-based
effluent guidelines and the development and incorporation of
toxic criteria into water quality standards. In cases where
these technology based limitations are not adequate to achieve
water quality standards, we will continue to push implementation
of post BAT controls using chemical-specific and biomonitoring
methods to develop water quality based permit limitations.
-------
-25-
Nonpoint source controls are needed to meet water quality goals
in many areas and comprise, along with point source controls, an
essential element of control strategies. Water programs will
place greater emphasis on improving State NFS assessments, stren-
gthening State and local NFS management programs and accelerating
State and local implementation of site-specific NFS controls.
Although the NFS problem is documented, resources are limited
(106, 205{j), and the estuary program). Therefore, EPA and the
States need to work with other programs and other agencies to
encourage their participation in the NFS effort.
In support of the Agency priority to focus on critical water
quality problems, water quality management (WQM) planning will
play an increasingly important role. Priority waterbody lists
should be used by the Regions and States as a management tool to
direct resources to those areas with the highest water quality
improvement returns, to highlight coordination between programs
and to assure that necessary activities are properly sequenced.
a. Water Quality Standards & Criteria - Priority Activities
Water quality standards (WQS) set the goals to be attained and
maintained based on designated uses of a waterbody. If tech-
nology based controls are inadequate to protect designated uses
from the impacts of toxic and other pollutants, the standards are
the basis for determining: (l)the need for more stringent treat-
ment to control point sources; and/or (2) best management prac-
tices (BMPs) needed to control nonpoint sources.
In FY 1987, EPA will provide technical assistance to the States
and tribal governments on determining attainable WQS through
guidance documents and seminars, reviews of WQS, and assistance
in developing criteria for pollutants where toxicity data is
limited. In 1987 EPA will accelerate development and issuance of
water quality criteria and advisories for aquatic life and human
health to help Regions and States determine appropriate pro-
tection levels for toxic and other pollutants.
* Regions will assist States to incorporate water quality cri-
teria and/or narrative standards for toxic pollutants into
State WQS, including free-from implementation procedures.
(Ongoing)
0 EPA Headquarters, with support from the Regions, will promul-
gate water quality standards in States that don't comply with
EPA regulations. (Ongoing)
0 Regions will provide technical assistance to States for
identifying waters where toxic and other pollutants may be
adversely affecting water quality, or precluding the attain-
ment of a designated use. (Ongoing)
-------
-26-
0 EPA Headquarters will develop freshwater aquatic toxicity and
human health criteria and advisories; develop marine and
estuarine criteria and advisories. (Ongoing)
* Regions will work with the States to ensure that antidegra-
dation methods are implemented according to EPA policies. (+
(Ongoing)
b. Monitoring & Wastelpad Allocations (WLA) - Priority Activities
Data generated from monitoring efforts are used to support water
pollution control and program planning decisions at several
levels, including issuance of the third round of NPDES permits.
In FY 1987 activities will continue to focus on the identification
of waters where uses are not fully attained and where controls
for toxics are needed using either pollutant-specific or bio-
monitoring techniques. Emphasis will be on controlling toxic
pollutants.
In FY 1987 States will continue to implement the water monitoring
strategy, the Guidance for State Monitoring and WLA Programs,
and use environmental indicators and procedures to measure water
quality trends. EPA will assess the extent and severity of per-
sistent bioaccumulative pollutants and sediment contamination.
Where appropriate, States should develop Data Quality Objectives
(DQO) for their monitoring activities and include these in work/
project quality assurance plans.
ORD will continue to support monitoring and WLA activities by
evaluating aquatic ecoregions as one approach for estimating the
ecological potentials of attainable uses. For site specific
controls, ORD will assess ways to couple the single chemical
approach with the toxicity reduction approach based on bio-
monitoring techniques. ORD will also conduct research to deter-
mine the effects of pollution on infectious diseases transmitted
through shellfish to humans.
0 States will conduct activities necessary for water quality
assessments to support preparation and submittal of FY 1988
305(b) reports. (Ongoing)
* States will identify all waters needing water quality based
controls for toxics and non-toxics and report this information ( + )
to EPA in 305(b) reports, FY 1987 WQM work programs, or FY 87
205(j) assessment updates. (Ongoing)
-------
-27-
* States will develop needed water quality based controls (i.e.,
TMDLs/WLAs/LAs) for toxics and non-toxics and submit them to (-)
EPA for review and approval. Target is 20% or more of waters
known to need controls as of beginning of FY 1987.
* Regions will ensure that States have approved technical pro-
cedures for conducting and approving TMDLs/WLAs, and will (+)
track the number of waters with approved WLAs/TMDLs for toxics.
(Ongoing)
0 Regions will review State work programs (including monitoring
checklists) to ensure conformance with EPA guidance and will ( + )
conduct audits to assess States accomplishments. (Ongoing)
0 EPA Headquarters will provide guidance, technical assistance,
and workshops on monitoring and WLA program activities and
will continue to provide data system support. (Ongoing)
* Regions will ensure that States have developed agreed upon
environmental indicators and procedures to measure water ( + )
quality trends. (Ongoing)
0 Regions will complete field sampling for the bioaccumulative
study and initiate pilot scale sampling for the sediment (-)
study. (Second Quarter)
c. Water Quality Management (WQM) Planning/Priority Waterbodies-
Priority Activities
State WQM plans provide the basis for setting priorities, analy-
zing problems, considering alternatives, and making WQM de-
cisions. Using data from 305(b) reports, WQM plans and moni-
toring activities, States will assure that their priority water-
body lists reflect their most critical and solvable water quality
problems or preservation areas and will use the lists as a basis
for determining priorities for WQM grant funds.
States should update WQM plans to reflect changing water quality
conditions, to incorporate signficant new water quality efforts
or products and to fulfill NPDES permit and construction grant
consistency review requirements.
* States will update their priority waterbody lists as necessary
and will use them as part of their management approach to
achieve environmental results. (Second Quarter)
0 States will update and use WQM plans to establish priorities,
direct activities to achieve water quality goals, conduct
consistency reviews, and make pollution control decisions.
(Ongoing)
-------
-28-
d. Nonpoint Source (NFS) Management - Priority Activities
EPA will continue to implement the EPA NFS Strategy (Feb.'85) by
providing national leadership among Federal agencies and over-
sight and guidance to State/local NPS programs; by ensuring that
other Federal agencies support both their national strategies and
State and local NPS objectives through their technical expertise,
existing delivery systems, financial resources and land manage-
ment authorities; by collaborating with other EPA program offices
(e.g. estuaries, ground-water, and pesticides) on such items as
guidance/requirements for agricultural chemicals management
practices); and by providing technical assistance and support to
State and local NPS managers and, where appropriate, to Indian
leaders. Estuary programs will continue to provide the major
source of BMP demonstrations and institutional approaches to NPS.
* Regions will support and assist States and local agencies in
identifying and establishing priority for NPS problems, in
developing comprehensive NPS management programs and in imple-
menting NPS controls within specific priority waterbodies.
(Ongoing)
0 EPA Headquarters will provide national leadership/oversight
for FY 1987 Regional, State and local NPS activities; stren-
gthen the support of other Federal agencies (e.g. Departments
of Agriculture and Interior) for State and local NPS objec- (
tives; collaborate with other EPA offices (particularly the (+)
estuary and ground-water programs) on NPS issues of mutual
concern; provide technical assistance and technology trans-
fer to EPA Regions, States and local agencies in such areas as
data evaluation and analysis, targetting of priority water-
bodies, and design/start-up/evaluation of specific control
systems; and inititate development of a national clearing-
house/reference center for information about state-of-the-art
NPS assessment, control and management techniques and
approaches. (Ongoing)
3. Water Permits and Enforcement
A top FY 1987 CWA priority is for Regions and NPDES States
("administering agencies") to continue aggressive NPDES
municipal enforcement to achieve as much compliance as possible
by the July 1, 1988, deadline consistent with the tenets of the
National Muncipal Policy. In addition, EPA will focus on (-)
toxics control through full implementation and enforcement of
pretreatraent requirements and reissuance of NPDES major and
significant minor permits, with emphasis on establishing and en-
forcing water quality-based permit requirements for toxics, as
well as best available technology (BAT) requirements.
-------
-29-
a. Permits - Priority Activities
The Agency's goal in the third round of NPDES permitting is to
eliminate toxicity in receiving waters that results from point
source discharges. Both industrial and POTW dischargers will be
required to routinely screen all effluents suspected of being
toxic, using chemical or biological testing techniques to determine
the extent and cause of any toxicity that may have adverse effects (-)
on the receiving water quality. In accordance with the results
of such analyses/ administering agencies will establish permit
limits consistent with the Policy for Development of Water Quality-
based Permit Limitations for Toxic Pollutants, national BAT/BCT
effluent guidelines, and best professional judgment, where appro-
priate. In appropriate cases, current permits will also be
reopened to include limits for toxics.
In addition, each Region and State with a backlog of expired
minor permits will follow its strategy (developed in FY 1986 in
accordance with the National Minor Permit Issuance Strategy) for (-)
reducing/eliminating that backlog. EPA headquarters and Regions
will continue to implement the Permit Quality Review program to
assure the basic integrity of the NPDES permit program. (See
State Overview section)
Consistent with the national goal of eliminating toxicity from
point source discharges, the NPDES permit program will aggressively
implement new State water quality standards and wasteload alloca-
tions for toxic pollutants, will assure proper protection of
surface water quality in any CERCLA action involving a discharge (+)
to surface waters or POTWs, and will impose best management
practices (BMP) requirements in permits for toxics dischargers
as necessary and appropriate. In addition, the national
anti-degradation policy will be implemented in all States.
* EPA (OWEP) will prepare a National Third Round Permit Policy
to address water-quality based permits for toxics. ( + )
(First Quarter)
* Regions/States will issue major permits to incorporate toxics
controls, acting promptly in the last 6 months of an expiring (-)
permit term to avoid a recurrent backlog. (Ongoing)
* Regions/States will complete reopeners scheduled for FY 1987,
and will modify other major permits as needed to impose neces-
sary and appropriate toxic controls. (Ongoing)
0 EPA will provide technical assistance to implement effluent
guidelines and develop water quality-based permit limits/moni-
toring requirements (including whole effluent biomonitoring).
(Ongoing)
-------
-30-
* Regions/States will reissue/modify municipal permits to address
any effluent toxicity and incorporate: approved/modified
pretreatment programs and related requirements for reporting; (-)
removal credits, where appropriate; monitoring for toxics;
determinations under the secondary treatment regulation; and
final §301(h) decisions. (Ongoing)
* Regions/States will issue general/individual permits to minor
dischargers consistent with State strategies developed in FY (-)
1986. (Ongoing)
0 Regions/States will resolve outstanding variance and eviden-
tiary hearing requests to assure enforceability of NPDES
requirements. (Ongoing)
0 Regions/States will identify CWA requirements associated with ( + )
Superfund site cleanup. (Ongoing)
b. Enforcement - Priority Activities
The FY 1987 goals under the NMP are to complete filed enforcement
cases against major POTWs, to track and respond to POTW noncom-
pliance with milestones in enforceable schedules, and to accel-
erate issuance of enforceable schedules to affected minor POTWs.
Administering agencies will take enforcement actions against
major POTWs based on the Enforcement Management System (EMS) and (-){
the FY 1987 National Guidance for Oversight of NPDES Programs.
Where noncompliance with existing administrative orders
(AOs) involves major slippage beyond July I, 1988, the presumption
is that judicial orders will be required; if there is a
significant workload, administering agencies should rank
potential cases based on past violations, water quality and
public health impact, and grant funding.
To support the Agency's CWA priorities on toxics control, adminis-
tering agencies will direct industrial enforcement efforts to
tracking schedules and enforcing BAT requirements for toxics and (-)
water quality-based permit requirements. Regions and NPDES
States will use compliance monitoring and assessment activities
to support this emphasis on toxics control, and will conduct
toxics inspections.
To improve protection of waters and aquatic resources from chemical
and physical destruction, Regions and States will increase enforce-
ment against unpermitted discharges of solid waste to waters, (+)
including wetlands.
-------
-31-
In FY 1987, all Regions will use PCS directly as the national
data base for the NPDES program, and all NPDES States should
either use PCS directly or effectively maintain existing inter-
faces; States seeking NPDES authority should become direct users
of PCS at the time of program approval. Finally, Regions and
NPDES States will fully implement the EMS, the Oversight guidance,
the Compliance Inspection Strategy, and the PCS Policy Statement.
* EPA/States will complete filed cases, monitor POTW compliance
with NMP milestones in AOs/consent decrees/permits, and will
initiate/escalate enforcement actions as necessary based on the (-)
priorities in the NMP and consistent with procedures in EMS/
Exceptions List/Oversight Guidance. (Ongoing)
* Regions/States will place priority on industrial compliance/
enforcement activities related to BAT/water quality-based ( + )
requirements for toxics. (Ongoing)
0 Regions will ensure that EPA municipal/industrial referrals/
consent decrees contain appropriate components/civil penalties
consistent with the CWA penalty policy. Where dischargers (-)
violate consent decrees, Regions will respond with stipulated
penalties, contempt proceedings, decree modifications, and/or
additional compliance monitoring requirements. (Ongoing)
0 EPA (OWEP/OECM/Regions) will identify program priority areas
for criminal cases (false reporting/fraud/significant unper- (-)
mitted discharges/willful injury to public health and environ-
ment) , and will provide technical support for such criminal
investigations and prosecutions. (Ongoing)
0 Regions/States will implement the new Federal Facility Compli- (-)
ance Strategy. (Ongoing)
0 Regions/States will use PCS as the national data base for all (-)
major NPDES permittees, and will maintain a greater than 95%
accuracy rate. (Ongoing)
Pretreatment - Priority Activities
The goal of the pretreatment program is to assure removal of
toxicity from POTW effluents and to protect against interference
with POTW operations. In FY 1987, the program will focus on
assuring that treatment is in place in accordance with currently
enforceable industrial user (IU) requirements and that additional (-)
local limits are developed to address toxic pollutants (§307(a)
and others) that are not adequately regulated under existing
Federal, State and local law. Regions and approved States will
-------
-32-
oversee control authorities (States or municipalities) through
audits, inspections, and review of annual reports. The Regions and
States will negotiate the appropriate mix of activities based on
resource levels and the stage of implementation in FY 1987,
giving highest priority to activities associated with the Agency's
priority list.
Administering agencies will complete enforcement cases against
any POTWs with unapproved local programs. Enforcement actions
will be initiated against POTWs that fail to implement approved
programs. Assistance and advice will be provided to POTWs exper-
iencing difficulty in the early stages of local pretreatment
program implementation. Control authorities will have primary (+)
responsibility for enforcement against noncomplying lUs. Adminis-
tering agencies will initiate IU enforcement actions where neces-
sary, generally in conjunction with enforcement against the
responsible POTW that is failing to enforce or as part of an
overall strategy to bolster a local program.
* Regions/States will assure that required IU treatment is in
place by overseeing implementation of local programs through
review of annual reports, audits/inspections, ensuring public (-)
notice of violations, and where appropriate enforcing against
lUs. EPA, in cooperation with the States, will audit all
approved programs over a 5-year period. (Ongoing)
* Regions/States will establish POTW effluent limits and related
requirements needed for control authorities to develop local (+)
limits for toxic pollutants of concern, and will assure that
local limits to prevent pass through and interference are
established where needed. (Ongoing)
0 EPA (OWEP) will promulgate revised General Pretreatment Regula-
tions, and, in accordance with Pretreatment Implementation
Review Task Force (PIRT) recommendations, will issue
additional guidance on interference (with ORD), local (-)
limits development, and responsibilities of POTWs not required
to have local programs and of Regions/States acting as control
authorities. (Ongoing)
0 EPA (OWEP) will provide technical/contractor assistance to
control authorities for program implementation focused on (-)
development of local limits/control mechanisms. (Ongoing)
* Regions/States will assure compliance with schedules in permits
and enforcement actions; new enforcement actions will focus on ( + )
POTWs that fail to implement approved local programs/IU viola-
tions, as appropriate. (Ongoing)
-------
-33-
* Regions/States that act as control authorities will implement/
enforce the pretreatment program consistent with national ( + )
guidance. (Ongoing)
0 Regions/States will establish an inventory of IDs where there
is no local program, will establish control mechanisms, and ( + )
will enforce where necessary. (Ongoing)
d. State Program Approval, Review and Oversight-Priority Activities
Effective implementation of the CWA is predicated on a strong
Federal/State partnership in carrying out NPDES and pretreatment
program activities. In FY 1987, the goal is to further strengthen
program integrity by ensuring that all NPDES States meet their (-)
statutory obligation to administer the pretreatment and Federal
facility programs. Regions will also continue to work with other
States to promote full NPDES program approval, and will help
NPDES States obtain general permit authority.
Regions, with Headquarters assistance, will continue to review
State programs to determine whether current State laws and regu-
lations provide adequate authority to administer and enforce the (-)
current national NPDES/pretreatment programs. Regions will work
with the States to make any necessary changes.
Regions will negotiate FY 1987 NPDES agreements with their States,
and will continue to oversee State program operations consistent
with the Oversight Guidance and applicable NPDES regulations.
Regions will assure that States implement the national anti-degra-
dation policy, meet national program output objectives, and
provide adequate resources and staffing to implement the national (-)
program. Regions will encourage State agencies to involve the
State Attorneys General (SAGs) in the process, where appropriate,
and to establish effective lines of communication to ensure the
SAG's general support for EPA's national enforcement priorities.
As a separate but related activity, EPA may support one FY 1987
model project involving an Indian tribe working towards future {-)
assumption of NPDES permit and enforcement responsibilities. In
the meantime, the Regions will continue to issue the NPDES permits
for facilities on Indian lands, as appropriate.
* Regions will approve remaining State pretreatment/Federal
facility programs, will condition FY 1987 grants as necessary, (-)
and may begin program withdrawal if States fail to seek full
program authority. (Ongoing)
0 Regions will work with non-NPDES States to take full program
authority and with NPDES States seeking general permit author-
ity, and will provide assistance as appropriate. (Ongoing)
-------
-34-
0 Based on State self-evaluations, Regions will review State
NPDES programs consistent with national guidance, and will (-)
assist States in making necessary changes such as revisions to
State laws, regulations, program descriptions, or MOAs.
(Ongoing)
0 Regions will negotiate grants/oversee State NPDES/pretreatment
programs based on FY 1987 National Guidance for Oversight of
NPDES Programs and applicable NPDES regulations, with special (-)
attention to overseeing the six State-run local pretreatment
programs. (Ongoing)
0 Regions will conduct State PQRs of industrial/municipal permits,
including pretreatment requirements, will provide constructive
feedback on permit program quality and will work to ensure (-)
that any needed corrective action is initiated. (Ongoing)
* EPA will work with States to ensure State water quality standards
for toxics are in place for the third round of NPDES permits. (+)
(Ongoing)
e. RCRA Activities for NPDES Facilities-Priority Activities
In FY 1987, Regional and State water programs will assist in
implementing RCRA requirements that apply to the NPDES program. (+) |
The three primary activities are:
Implementing RCRA corrective action requirements at POTWs
receiving hazardous waste by truck, rail, or dedicated pipe ( + )
(for all releases of hazardous waste or constituents from
any of the POTW1s solid waste management units);
Acting on industry requests for exemption from double liner
requirements for new or expanded landfills/surface impound- ( + )
ments; and
- Implementing recommendations arising from the domestic
sewage exemption study by assuring that local limits to
control both CWA priority toxic pollutants and hazardous ( + )
waste are established and implemented under the pretreatment
program (See "Pretreatment").
The extent to which Regional and State water programs will assist (+)
in the first two of these activities will depend on FY 1987 RCRA
resources and assignments of responsibility.
In carrying out the RCRA corrective action requirements, the
Regions and States may be involved in one or more of the following
activities: issuing RCRA §3007 letters (the RCRA counterpart to
-------
-35-
CWA §308 information requests); determining whether affected POTWs (+)
are "in compliance" with NPDES permits for purposes of meeting the
RCRA permit-by-rule; determining compliance with other RCRA
permit-by-rule requirements; conducting site inspections; and
establishing corrective action requirements. Regional NPDES/RCRA
programs will work with the States to coordinate implementation
of the corrective action requirements with NPDES permit issuance
wherever possible.
With respect to requests for exemptions from the RCRA require-
ments for double liners, the Regions (with State assistance) (+)
may be engaged in one or more of the following activities:
reviewing applications requesting exemptions from the RCRA require-
ment for double liner; determining whether a facility uses aggres-
sive biological treatment; and making recommendations for approval (+)
and denial based on RCRA §3005(j)(3) criteria.
0 EPA (OWEP) will promulgate necessary regulatory changes, and
will issue guidance to help implement RCRA corrective action ( + )
requirements. (Second Quarter).
0 EPA (OWEP) will promulgate needed amendments to the General
Pretreatment Regulations to cover results of the domestic {+)
sewage exemption study, and will develop implementing guidance.
(Fourth Quarter)
0 EPA will issue guidance on NPDES/RCRA inspections and on (+)
issuing RCRA §3008 orders for POTWs not in compliance with
NPDES-related RCRA responsibilities. (Unknown)
0 Regions (with States) will gather information needed to identi-
fy POTWs subject to the RCRA permit-by-rule, will review (+)
notifications from POTWs, and will establish corrective action
requirements for the highest priority POTWs. (Ongoing)
0 Regions (with States) will review applications for exemptions (+)
from RCRA double liner requirements, and will recommend
approval/denial. (Ongoing)
0 Regions/NPDES States will inspect POTWs covered by RCRA and
will issue RCRA §3008 orders (or State equivalent actions) or (+)
bring court action for POTW noncompliance. (Ongoing)
4. Construction Grants Program
The construction grants program provides grants to municipal
agencies to assist in financing the construction of cost effective
and environmentally sound municipal wastewater treatment facil-
ities to meet the water quality and public health goals of the
Clean Water Act. States also receive funds under section 205(g)
to assist in carrying out program implementation responsibilities.
-------
-36-
Since Title II of the Clean Water Act is scheduled for reauthor-
ization in FY 1986, a key objective in FY 1987 of Headquarters and
Regional Offices is to ensure timely implementation of any amend-
ments. Reauthorization will require significant revisions to
the guidance for this program. Additionally, if reauthorization
provides for direct program activity with Indian Tribal Governments,
Headquarters will then develop timely procedures for implementing this
program.
Regions will work closely with States to amend delegation agree-
ments, promote the understanding of and assure the capability to
carry out any new activities, and address future issues.
In FY 1987, the construction grants program will focus on six key
objectives:
a) manage the transition to State and local self-sufficiency
to ensure compliance with the CWA;
b) ensure effective State/Regional management;
c) ensure effective construction and program integrity;
d) expeditiously complete and closeout projects;
e) improve program management; and
f) improve the performance of treatment facilities.
a. Transition to State and Local Self-Sufficiency -
Priority Activities
The construction grants program will continue to provide
assistance to help States and local governments pursue sound
alternative funding mechanisms for construction of wastewater
treatment facilities, including State-financed revolving funds.
To promote self-sustaining operation and maintenance, and to
protect the substantial Federal investment in municipal waste-
water treatment, Regions and States will continue to ensure
that current and prior grant recipients have advanced the
resources within their financial capability to meet the
required local share and to provide for long-term operation,
maintenance, and replacement of the POTW following initial
construction.
The Construction Grants program will continue its implementa-
tion of the NMP in cooperation with the permit and enforcement
program. Emphasis will be placed on the improved management of (-)
project schedules with particular focus on bringing projects
affected by the policy expeditiously through to completion of
construction.
-------
-37-
0 HQ and the Regions will develop regulations/guidance to imple- (+)
ment the 1986 Clean Water Act reauthorization, if enacted.
(Ongoing)
0 Regions and States will review grant applications to determine
whether proposed facilities are consistent with the Financial
Management Capability Policy. (Ongoing)
* Regions and States will ensure effective coordination between
construction schedules and compliance schedules, and will im-
plement effective strategies for developing and managing pro- (+)
ject schedules for all municipal treatment works to ensure
consistency and coordination with the National Municipal Policy.
* Regions and States will coordinate with the enforcement pro-
gram in working with municipalities that are required to
develop Municipal Compliance Plans (MCP's) under the National
Municipal Policy. (Ongoing)
b. Effective State/Regional Management - Priority Activities
EPA will continue to work with States to ensure full and effective
delegation of construction grants management, and to refine over-
sight systems and approaches consistent with the Policy on
Performance-Based Assistance.
0 Regions and States will implement the Agency policy on delegation
and overview, and the applicable regulations of 40 CFR Part 35,
Subparts A and J, including the negotiation of an annual work
program, overview plan, annual on-site performance evaluation,
and a performance-based program grant. (Ongoing)
0 Headquarters will evaluate Regional management of delegation to
ensure consistency with National Policy. (Ongoing) ( + )
0 Regions will oversee the Corps of Engineers Interagency Agree-
ment to see that workplans address priority needs and that
workplan commitments are achieved. The Corps will emphasize
training of selected States to maintain delegation of con-
struction management. (Ongoing)
c. Effective Construction/Program Integrity - Priority Activities
In FY 1987, a high national priority will be the timely comple-
tion of quality construction projects that are within budget.
Continued emphasis will be placed on the improved management of
project schedules to bring projects expeditiously through (-)
construction, the initiation of operations, and project perform-
ance certificattion. EPA will continue to place emphasis on
assisting States in refining priority funding systems and lists
-------
-38-
consistent with water quality, public health, and NMP objectives.
Improved priority funding systems will result in a better targeting
of grant resources. EPA will also continue to improve its capabil-
ity to document and predict water quality improvements resulting
from the Construction Grants Program. Headquarters will provide
computerized tools and systems for Regional/State use in document-
ing water quality improvements associated with construction grant
funding.
In FY 1987, EPA will continue to work with States and munici-
palities to help develop and implement self-financing techniques.
In addition, EPA will continue technology transfer to improve
technical and financial management of treatment projects. (+
Substantial attention is being directed by the Construction
Grants and ORD programs to provide information to the States
and the grantee community to assure that municipalities benefit
from the experience gained in dealing with various technologies
and project management systems.
0 Regions and States will conduct and evaluate Construction Man-
agement Evaluations (CME's) and Project Management Conferences
(PMCs) to assure that grantees have adequate management capabi- (-]
lity to construct and operate projects, and improve pre-award,
preconstruction and on-site construction management. (Ongoing)
0 Regions and States should place particular emphasis on ensuring
that previously phased/segmented projects proposed for 75 per- (-)
cent funding are carefully scrutinzed to assure that the
"grandfathering" provisions of Title II and 40 CFR Part 35 are
properly carried out. (Ongoing)
0 Regions and States will manage the preconstruction phase to ensure
that construction initiation dates are met. (Ongoing) (-)
0 Headquarters and Regions will implement improved management
procedures based on the findings of FY 1986 Internal Control
Reviews. (Ongoing)
0 Regions and States will manage the I/A Technology, Rural Grants,
and the Value Engineering (VE) programs. (Ongoing)
0 Headquarters and Regions will continue to implement positive
management initiatives to prevent waste, fraud and mismanagement (+)
including a cooperative effort with the OIG on the assessment
of grant project bid-rigging. (Ongoing)
* Regions will work with States to implement needed revisions to
State priority systems and lists, to maintain water quality and (+)
public health emphasis, and to maximize municipal compliance.
(Ongoing)
-------
-39-
0 Headquarters will evaluate the use of the Reserve Capacity
Guidance to ensure that the present capacity limitations in (+)
the CWA are implemented. (Ongoing)
0 Headquarters will develop and disseminate information on inno-
vative, alternative, and conventional wastewater treatment
technologies which have been determined to be cost effective
as well as those which have had operational difficulties.
Regions and States will ensure the dissemination of this
information to municipalities that need to construct wastewater
treatment facilities in compliance with the CWA. (Ongoing)
0 HQ and Regions will work with States to help establish and im-
plement methods for evaluating environmental results of the (+)
Construction Grants Program. (Ongoing)
0 EPA Headquarters will evaluate AT projects with incremental
cost over $3 million to ensure significant water quality improve-
ment, and will oversee Regional and State AT project reviews
conducted under the AT Review Policy to determine (a) which
Regions qualify for AT Review responsibility involving projects (-)
with incremental AT costs greater than $3.0 million, and (b)
whether the Regions which are already assuming such responsi-
bility, comply with the Policy. (Ongoing)
* EPA Headquarters will complete a municipal lagoon study to de-
termine the impact of existing lagoons on ground water quality,
leading to a report to Congress in November 1987,
d. Completed Projects - Priority Activities
Continued emphasis will be placed on the elimination of current
backlogs and the prevention of new backlogs. Regions and States
will continue to place a high priority on resolving issues which
are causing delays on projects.
0 Regions and States will manage grants efficiently to ensure
that preconstruction lags or completion backlogs do not occur,
that projects are completed and closed-out in a timely manner,
and that the level of unnecessary unliquidated balances contin-
ues to be reduced. (Quarterly)
0 Regions and States should continue to implement the Claims
Management Guidance. (Ongoing)
* Regions and States will ensure that projects awarded before
12-29-81 are administratively complete within 12 months of
physical completion, and that grants awarded after 12-29-81
are administratively completed within 18 months of initiation ( + )
of operations. In addition, all Step 1 and Step 2 grants
should be administratively complete by the end of FY 1987.
(Ongoing)
-------
-40-
0 Regions/States will continue to work with the Agency1s
Office of Inspector General to ensure timely, high quality audit
resolution. (Ongoing)
0 EPA Headquarters will maintain the clearinghouse for grant
dispute decisions to facilitate timely and consistent
decisions. (Ongoing)
0 Regions will implement procedures to achieve the time-based
goals for resolving disputes.
e. Program Management - Priority Activities
EPA HQ will continue to work with Regions and States to improve
program management, accelerate municipal compliance to meet NMP
goals, and document environmental results. In addition, improved (+)
use of the State Project Priority lists, the Needs Survey file,
the Grants Information and Control System (GIGS), and office auto-
mation to satisfy program management needs will continue to be a
high priority.
0 Regions and States will manage outlays and obligations within
prescribed variances to meet national budget commitments. (-)
(Monthly for outlays; quarterly for obligations)
0 Regions will continue working with States to improve the use
of GIGS for program management. EPA Headquarters will continue (+)
the implementation of the GICS modernization initiative and
continue to improve the Database System linkages between the
GICS, PCS, and needs files. (Ongoing)
0 Regions will work with Headquarters on development of revised
and new program regulations, policies, and guidance. (Ongoing) (+)
f. Performance of Facilities - Priority Activities
The Construction Grants program will coordinate with the enforce-
ment program in implementation of the NMP. In support of the
Policy, the Construction Grants program will emphasize Region and
State on-site compliance assistance to small POTW1s, project per-
formance certifification and remedial compliance programs for
grant-funded facilities; work with municipalities that are re-
quired to develop Municipal Compliance Plans (MCP's), and ensure
coordination between the Region and State O&M, operator train-
ing, construction grants and permit/compliance programs.
0 Regions and States will ensure effective implementation of the
project performance certification requirements, including time-
ly preparation of a Corrective Action Report (CAR) where a
positive certification is not possible. (Ongoing)
-------
-41-
* Regions will continue the Operations Management Evaluation
(OME) Program at minor POTWs to assist selected communities and
operators in maintaining effective operations and maintenance
management programs in compliance with permits. (Ongoing)
0 Headquarters and Regions will continue implementation of the
O&M Excellence Awards program at Regional and national levels
recognizing municipal wastewater treatment accomplishments.
(Ongoing)
0 Regions and States will continue to encourage the training of
municipal treatment plant operators. (Ongoing)
E. LIST OF SUPPLEMENTAL GUIDANCE TO BE ISSUED
DURING FY 1986-87 FOR OPERATING YEAR FY 1987
- Guidance for PWS Compliance Reporting
The guidance will describe how chemical and
radiological MCLs will fit into the definition
of significant non-compliance and provide the forms
for reporting in FY 1987. (June, 1986)
- Guidance for UIC Compliance Reporting
The guidance will explain how Regions and States
will report UIC Compliance using the new definition
of significant non-compliance. (May, 1986)
- Guidance for FY 1987 State Ground-water Program
Grants
The guidance will provide direction to the Regions
and States in the development and administration
of consolidated ground-water work programs for
FY 1987. (March, 1986)
- Guidance for State 305(b) Reports
The guidance will assist States in developing
their FY 1988 305(b) reports by providing guidelines
on methodologies, format and scope. (May, 1987)
- Guidance for Oversight of the NPDES Program
The guidance will expand on the FY 1987 Agency
Operating Guidance relating to oversight of the
NPDES program. Detailed direction relating to
Permits, Enforcement and Pretreatment programs
will provided in the guidance. (April, 1986)
-------
Office of
Solid Waste
and Emergency Response
-------
OSWER TABLE OF CONTENTS
Page
I. Introduction 1
II. Superfund Operating Guidance
0 Program priorities 4
0 Guidance 6
0 Goal I - Achieve environmental results 6
A) Stabilize actual or potential threats 6
1. Response to threats by releases and spills
2. Address reportable quantities, release notification
3. Address oil discharges
B) Reduce or eliminate risks from uncontrolled
hazardous waste sites 9
1. Ensure that all phases of the "pipeline" are being
initiated and are moving towards completion
2. Continue to operate a strong pre-remedial program
3. Obtain RP cleanup through settlements
0 Goal II - Ensure a strong enforcement presence.... 10
1. Section 106 referrals
2. Administrative Orders
3. Incentives for settlements
4. Section 107 referrals
5. Federal/state enforcement actions
6. Oversight of PRP, federal facilities and state
actions
0 Goal III - Continue to decentralize and delegate
authority 14
1. Deletion
2. Remedial Delegations
3. Enforcement Delegations
0 Goal IV - Improve scientific expertise 15
1. Expand capabilities of the ERT
2. Implement better systems for technology transfer
3. Analytical support
0 Goal V - Improve technical communications with
the public 17
1. Chemical Emergency Preparedness Program
2. Improve effectiveness of community relations efforts
0 Appendix/Supplemental Guidance 20
-------
III. RCRA Operating Guidance Page
0 Program priorities 21
• Operating themes 23
0 Guidance 25
0 Goal I - Address previously neglected problems
and restore environmental quality to
acceptable levels 25
A) Strengthen the permitting and enforce-
ment process to improve the timeliness
and quality of actions 25
1. Integrate permitting, enforcement and
corrective actions at hazardous waste
management facilities
2. Coordinate RCRA/CERCLA permitting and
enforcement
3. Continue to foster an effective working
relationship with States while maintaining
necessary oversight of national priorities
B) Implement RCRA authorities at hazardous
waste management facilities to protect human
health and the environment 28
1. Implement the corrective action program through
the use of permitting and enforcement authority
2. Require proper closure of facilities to ensure
protection of human health and the environment
3. Ensure compliance with interim status and final
permit groundwater monitoring requirements
4. Resolve technical, scientific and regulatory
issues associated with "how clean is clean"
5. Expedite review and decision-making for Part B
permit applications
6. Improve compliance at Federal Facilities
7. Provide technical support to the criminal
enforcement program
8. Promote innovative compliance monitoring and
enforcement of the small quantity generator
regulation
-------
0 Goal II - Control the use of existing commercial
chemicals and pesticides that pose an
unreasonable risk to health and the
environment 32
1. Shared basic research
2. Pesticide disposal
3. Listing decisions
4. Land disposal ban
0 Goal III - Anticipate and prevent future environ-
mental problems and maintain high levels
of environmental quality 33
1. Fix existing regulatory framework where appropriate
2."New initiatives
3. Increase public education/outreach efforts
0 Appendix/Supplemental Guidance 39
Summary of the FY 1987 RCRA Implementation
Plan (RIP) 40
IV. UST Operating Guidance
0 Program priorities 41
0 Guidance 42
0 Appendix/Supplemental Guidance 44
-------
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
INTRODUCTION
The Office of Solid Waste and Emergency Response Operating
Year Guidance for FY 1987 presents the national strategies,
goals and objectives for implementation of the hazardous waste
programs. This guidance reflects requirements of the Resource
Conservation and Recovery Act (RCRA), as amended by the
Hazardous and Solid Waste Amendments of 1984, and the Compre-
hensive Environmental Response, Compensation, and Liability
Act (CERCLA) of 1980. It is anticipated that CERCLA will be
reauthorized sometime during FY 1986. It is likely that
CERCLA strategies and goals will need to be refined once
CERCLA is reauthorized.
As in FY 1986, one of the Agency's major goals for FY 1987
is to reduce risks from disposal of hazardous waste and
stabilize imminent threats from uncontrolled hazardous
waste sites. There are three principal themes of our
FY 1987 Operating Guidance: 1) reduction of risks to human
health and the environment from improper past disposal of
hazardous waste, 2) ensure protection in the future; and
3) strive to use our resources and expertise most effectively
by institutionalizing sound management systems and procedures
and delegating programs to Regions and States where appropriate.
From FY 1986-FY 1987, the emphasis of the OSWER programs will
change from initiations to completions. Priorities center
around making our processes more effective while also striving
to attain high quality environmental results. Additionally,
OSWER will work towards a multi-media, risk assessment approach
to the management of hazardous waste.
In addition, OSWER acknowledges the existence of various
cross-cutting activities and issues which are currently
being addressed by various Headquarters and Regional groups.
These activities include:
Streamlining processes - OSWER intends to evaluate
and improve upon several programmatic functions such
as regulatory development and information management
as well as overall management planning of projects
and facilities.
"How clean is clean" - Several workgroups are addressing
this complex issue as it applies to the implementation
of activities such as corrective action, closures and
remedial cleanup.
-------
-2-
Groundwater protection - Since groundwater protection
is an Agency and OSWER priority, we intend to maintain
an interdisciplinary approach to determine the most
effective techniques for addressing current ground-
water problems as well as ensuring groundwater
protection in the future.
Overlapping RCRA/CERCLA/UST issues - OSWER recognizes
that there are several activities which may require
involvement by RCRA, CERCLA and UST staffs during
various stages. Appropriate policies and procedures
are currently being discussed. Such overlapping
issues include: RCRA sites on the National Priorities
List, RCRA/CERCLA Off-site Policy, corrective action
of leaking tanks and Loss of Interim Status facilities'
potential impacts on the CERCLA program.
OSWER interface with other programs and agencies - In
an effort to improve multi-media cooperation and
consistent decision making, OSWER intends to solidify
an effective working relationship with EPA programs
such as Air and Radiation (Air Toxics Strategy/Chemical
Emergency Preparedness Program, and air emissions at
RCRA facilities), Water (corrective action at POTW's)
and Pesticides and Toxic Substances (PCB disposal).
Additionally, OSWER will work with other Federal
agencies to ensure that Federal Facilities comply
with RCRA and CERCLA requirements. Where resources
permit, we encourage our Regions to work with Tribal
Governments to undertake activities associated with
hazardous and solid waste on their reservations.
Enhance scientific expertise/pursue alternative
technologies - OSWER is committed towards improving
technical expertise (i.e. SITES project with ORD) as
well as in encouraging innovative technologies where
feasible (i.e. incineration). Additionally, high
quality analytical support and effective sample
management will be stressed.
Strengthen the enforcement program to ensure corrective
actions - OSWER intends to take an aggressive stance
towards violators in order to ensure timely and
appropriate corrective actions. We will utilize our
enforcement authorities to increase PRP activity in
cleanup processes, as well as to address those
facilities that are in significant non-compliance.
Enhance human resources - It is an OSWER priority to
enhance its workforce through various approaches such
as individual development plans, training and rotations
Additionally, the OSWER training needs survey and the
Superfund Workforce planning project completed in FY86
will be utilized to increase the capabilities of the
on-scene coordinators (OSC's) and remedial project
-------
-3-
managers (RPM's). Other training efforts will
focus on groundwater, Chemical Emergency Preparedness,
State support and RCRA/CERCLA relationship courses.
Such efforts are geared towards the professional
development of our staff as well as in improving our
overall effectiveness.
This year's guidance is divided into three program areas:
Superfund, RCRA and Underground Storage Tanks. This structure
allows for more specificity in articulating the goals and
priorities of the individual program areas within OSWER.
-------
-4-
FY 1987 SUPERFUND OPERATING GUIDANCE
I. INTRODUCTION
The basic authority under which the Agency addresses threats
from uncontrolled hazardous waste sites is the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA). This guidance reflects current program goals under
the 1980 statute. It will be revised following the CERCLA
reauthorization.
A) PROGRAM PRIORITIES
Speed Up the Remedial Process
In FY 1987, the emphasis in the Superfund program continues to
be to implement a balanced program to ensure that environmental
threats pos«d by sites are addressed as quickly and effectively
as possible. During FY 1987, Regions will begin implementing
programmatic changes identified in the FY 1986 pilot projects
that improve both the management and technical performance of
the remedial program. The pilot projects are planned to examine
issues concerning contractor continuity and strategy, methods
for expediting the response process and the approach for
identifying remedial alternatives. The Agency will closely
monitor performance at sites where work is underway and
will place continued emphasis on site-specific planning and
management in the Regions. Emphasis will shift from initiations
to completions.
Accelerate the Pace of Site Cleanup through a Strong
Enforcement Program
The overall goal of the CERCLA enforcement program is to
accelerate the pace of cleanup by responsible parties at
inactive hazardous waste sites. The most effective approach
for accomplishing this goal is a balanced program involving:
0 Fund-financed cleanup, coupled with cost recovery
action under §107;
0 Enforcement action under §106, including litigation
and administractive orders;
0 Negotiated private party cleanups; and
0 State enforcement actions under State authority.
The Agency seeks to integrate criminal enforcement with the
routine operation of the CERCLA program. Accordingly, Regions
will, in the conduct of their compliance and enforcement
programs, identify and refer to the Office of Criminal Investi-
gations for investigation suspected criminal conduct, "tips"
or other information relevant to criminal enforcement.
-------
-5-
Implement Improved Management Systems
The increased number of sites with ongoing removal and remedial
activity requires greater emphasis on site-specific management
and the necessity for improving tools for managing the Super-
fund program. During FY 1986, the Regions will be working
with Headquarters to improve Superfund management and
information systems. This project will focus on methods for
assisting with site-specific management planning as well as
the transfer of project inventory, tracking, and planning
information to a common system for Headquarters and Regional
program management. During FY 1987, the Regions will be
implementing the site-specific management planning using the
tools developed in FY 1986. Also, increased emphasis will
be placed on data completeness and quality.
Increase Use of Alternative Treatment Technology
During FY 1987, the Agency will aggressively implement the
results of several efforts directed towards increasing the
use of alternative treatment technologies in removal and
remedial activities. Demonstrations of alternative
technologies at Superfund sites will be a priority activity.
FY 1986 will see the increased availability of alternative
treatment technology studies and reports, treatment capacity
studies, and other technology transfer studies. In addition,
early evidence of private sector interest in the SITE (Super-
fund Innovative Technology) program as well as removal program
initiatives with alternative technologies will be available.
As scientific and engineering evidence supports the efficient
and effective use of these innovative and alternative treatment
technologies, the Agency will encourage their utilization at
sites ready for remedy selection.
Implement the Chemical Emergency Preparedness Program
In FY 1986, interim guidance was issued on the Agency's
Chemical Emergency Preparedness Program. The interim guidance
describes the Agency's program to assist States and local
communities in identifying and developing contingency plans
to deal with potentially acutely toxic chemicals. In FY
1987, Regions will coordinate with States, local communities
and Regional Response Teams (RRT) to ensure that community
needs for emergency preparedness/prevention and contingency
planning are being met. The Agency will develop training
programs and make them available to States and communities
to complement the preparedness program.
-------
-6-
II. GUIDANCE
GOAL I Achieve Environmental Results
A) Stabilize Actual or Potential Threats from Releases of
Hazardous Substances
1. Response, through removal actions at NPL and non-NPL
sites, to threats to public health and the environment
posed by releases from uncontrolled hazardous waste
sites and spills of hazardous substances and oil
Although the removal program historically has been generally
reactive to hazardous substance releases, the broadened
authorities of the revised NCP allow the removal program
to assume a more proactive role by addressing threats of
releases and thereby preventing releases of hazardous
substances. We will continue to respond to threats posed
by releases or threats of releases at unlisted waste sites
and from other unanticipated events.
0 Broader language contained in the revised NCP gives
the removal program more latitude to abate threats
in general rather than limiting responses to imminent
and substantial threats. The Agency will undertake
removal actions using these broader authorities at
NPL sites. The Agency expects the current level of
NPL site removals to remain relatively constant.
0 We will continue to explore the feasibility of using
Multi-Site Cooperative Agreements (MSCAs) for removal
actions at NPL sites to enable states to stabilize NPL
sites prior to initiating remedial activities. A
workgroup dealing with multi-site cooperative agree-
ments for removals has been convened to consider
options for State involvement in removals and to
develop procedures where appropriate.
0 The removal program will make greater use of alter-
natives to land disposal through adherence to the RCRA
Off-site Disposal Policy, which directs the program to
comply with the 1984 RCRA amendments and the intent of
Congress to "foster the use of more permanent solutions.
The transition to alternative treatment and disposal
technologies will parallel the framework of the RCRA
amendments which call for an evaluation of alter-
natives to land disposal. The major factors to be
considered by the Regions in this evaluation are
1) the determination of minimum waste quantities and
any possibility that excessive quantities may tie up
facilities or exceed facility capacity; 2) waste
characteristics, which include mobility, hazardous
constituents and concentrations, volatility, toxicity,
and persistence; 3) capacity of alternative facilities
and 4) cost.
-------
-7-
0 In order to accomplish its removal program goals, a
contracting network of Emergency Response Cleanup
Services (ERCS) contractors was established to resoond
to releases or threats of releases of hazardous
substances. ERCS consists of four zone contracts
covering all ten Regions, plus a projected total of
sixteen to thirty smaller, supplemental Regional
contracts. During FY 1987, all four zone contracts
will terminate. 'Currently, these four contracts
together provide almost $60 million in capacity for
cleanup each year. To be able to continue to ensure
quick response to removal actions anywhere in the
country without a break in coverage, EPA will initiate
procurement activity for recompetition of ERCS about
nine months prior to termination of each contract.
The contract initiative is intended to ensure that
sufficient contract capacity is available in order
to carry out removal actions consistent with CERCLA
and the NCP.
0 Removals for the purpose of site stabilization or
for response to emergencies may be Fund-financed or
conducted by responsible parties. The Regions should
contact Potentially Responsible Parties (PRPs) and
consider whether private-party response is appropriate,
in lieu of Fund-financed response.
0 The Agency will issue Administrative Orders in appro-
priate circumstances before initiating Fund action, as
long as the site does not pose an unreasonable risk of
harm to the public health, welfare or the environment.
The Regions should consider issuing Administrative
Orders in situations where there is at least one week
between the time that the OSC determines that a removal
action is warranted and the time that actual on-site
response must begin. In the event of non-compliance
with an administrative order, the Region should be
prepared to quickly initiate a Fund-financed response
and seek fines or treble damages from the responsible
parties. Further detail is provided in the policy
entitled, "Issuance of Administrative Orders for
Immediate Removal Actions", February 21, 1984.
Additional guidance is being developed on the impact
of the revisions to the NCP which broaden the use of
removal actions.
2. Address the promulgation of regulations pertaining to
reportable quantities and release notification
0 In FY 1986 and FY 1987, OSWER will develop for Head-
quarters and Regions a national release notification
system for collection of data on releases of oil and
hazardous substances. The objective is to design
and implement comprehensive national notification
and response data on accidental releases of oil
and hazardous substances. The proposed system
-------
-8-
will improve data quality and quantity and promote
a consistent format for review.
0 Additionally, OSWER will promulgate final RQs for
potential carcinogens, and propose new listings
promulgated by the media programs directly affecting
the CERCLA section 101(14) hazardous substance list.
In addition, OERR will propose RQ's for the approx-
imately 250 new air toxics listings which are not
currently on the CERCLA section 101(14) hazardous
substance list, but which very likely will be
statutorily required as a result of Superfund re-
authorization.
0 It is expected that CERCLA reauthorization will
include civil and administrative penalties, as well
as the criminal penalty for failure to notify.
Releases equal to or exceeding an RQ which are not
properly and promptly reported will now be subject
to civil and administrative penalty provisions.
These provisions will greatly enhance compliance
with the RQ reporting rule. However, the civil
and administrative penalty provisions cannot be
effectively implemented unless a notification system
is in place to capture all release notifications
received by the Federal government. Therefore, the
timing of RQ implementation and enforcement will be
largely contingent on the development of the release
notification system mentioned above.
3. Address the Agency's continuing commitment to respond to
major discharges of oil
0 Regions should maintain their present level of on-
scene response to major oil spills as defined in the
NCP. Further, the Regions should continue to provide
on-scene oversight of private party cleanups of major
oil spills. Where States or local governments are
known to have the capability and commitment to respond
to spills, including major discharges, they should be
encouraged to the maximum extent possible to provide
response. Technical assistance should be provided to
the Coast Guard in coastal oil spills when the Coast
Guard specifically requests it or when the RRT is
activated.
0 The Spill Prevention Countermeasure and Control
Program continues as an important priority in the
oil program. Available resources following response
activity should be directed to SPCC activities. In
some situations, it may be possible to perform SPCC
functions in conjunction with spill response activities.
Each Region should review and update its strategy for
SPCC inspections and plan reviews for the coming year.
-------
-9-
B) Reduce or Eliminate Risks from Uncontrolled Hazardous
Waste Sites
1. Ensure that all phases of the site clean-up "pipeline"
are being initiated and all projects currently in the
"pipeline" are moving efficiently toward completion
0 A major initiative to be conducted by the Agency
in FY 1986-1987 will be the.implementation of the
remedial improvement pilot program. The Office of
Emergency and Remedial Response, acting as the lead
office, is currently working with several Regions in
testing several new approaches which will impact
project schedules.
0 Regions will continue to develop comprehensive Site
Management Plans (SMP). The SMP provides a vehicle
for "the Regions and States to reach agreement on a
schedule for initiating action at each site. Initially,
the multi-year plan will be used to develop and adjust
SPMS commitments and allocate resources. The SMP
process will be improved as a component of the remedial
pilot program to provide a basis for effective project
planning, monitoring and control over the entire
"life-cycle" of a site. The new process will provide
the Regions with the tools and the support needed to
develop and maintain effective project plans, monitor
progress towards achieving planned milestones, and
highlight the need for corrective action.
0 Regions will place an emphasis on selecting alternative
technologies as part of on-site remedies. The revised
NCP encourages the use of reliable technologies that
have long-term effectiveness. Records of Decision
should evaluate at least one alternative to land
disposal. The alternative technology need not be
applied to all the waste at the site.
0 Regions will focus on site completions and the ability
to delete sites, through remedial action, or removals
confirming that deletion is appropriate.
0 Regions will place emphasis on program reviews of
States that have lead responsibility under single or
Multi-Site Cooperative Agreements. Use of the Manage-
ment Assistance Program (piloted during FY 1985-1986)
is encouraged.
0 Regions will ensure that States are meeting their
responsibilities for operations and maintenance at
sites where remedial action has been completed.
0 Pursuant to Headquarters guidance, Regions will
implement the natural resources claims regulation and
response claims regulations.
-------
-10-
2. Continue to operate a strong pre-remedial program
0 OERR will develop and promulgate in FY 1986 and FY
1987 HRS changes which recognize improvements and
enhance the Agency's ability to correctly classify
sites for the NPL.
0 Submission of NPL candidates and related rulemaking
documentation to"support remedial program and Congres-
sional mandates;
0 The Regions and States will continue to aggressively
conduct site evaluations which involve a sequence
of investigations to determine the extent of contamin-
ation at a site and to provide a data base sufficient
to identify the most appropriate response.
»»
0 Area specific discovery of new sites for the CERCLA
inventory to support NPL process and the adequate
identification and characterization of uncontrolled
hazardous waste site problems.
0 Program reviews by the Regions of all State cooper-
ative agreements and State contracts, assuring that
conditions are met with quality products.
3. Obtain responsible party cleanup through settlements
This is the highest priority of the CERCLA enforcement program.
Achieving the proper balance between §106 and § 107 actions
is essential to the overall cleanup effort under CERCLA. A
visible enforcement presence is needed to encourage settlements
for private party cleanups. Reliance on §107 actions is not
sufficient to establish this enforcement presence, particularly
where the Agency defers enforcement action until the remedial
action is completed.
GOAL II Ensure a Strong Enforcement Presence
1. §106 actions at sites which will not be the subject of
further Fund-financed cleanup are the highest priority
for referrals for injunctive relief
Referrals for injunctive relief may also be appropriate in
cases where it is still possible that Fund-financed cleanup
will be undertaken. Such referrals may be needed where there
are potential statute of limitations concerns, or where the
site has been identified as enforcement lead, and prospects
for successful litigation are good.
-------
-11-
2. Administrative Orders will continue to be an important
method for assuring private party cleanup
Orders should be issued in situations where compliance with
their terms is feasible. The Regions are not required to make
a pre-issuance determination that Respondents will comply with
an order, but rather that compliance is practicable. The
following factors are relevent to this determination:
0 The needed response action and liability are straight-
forward .
0 Respondents have adequate financial capability.
0 There are relatively few PRPs.
0 The response action is reasonably specific.
0 The Agency should be ready to litigate the merits of
the Order.
0 There is no need for long-term court oversight.
Failure to comply with an Administrative Order will lead in
appropriate cases to the institution of further enforcement
action including civil contempt proceedings. Where the Admin-
istrative Order has been incorporated into or entered as a
court order or decree, disobedience may also be punished as
criminal contempt under 18 U.S.C. §401(3).
Procedures for issuance of orders will be undergoing modif-
ication in response to CERCLA reauthorization.
3. Create a climate that is receptive to private party
cleanup proposals
Responsible parties will continue to have an opportunity to
perform or be involved in the studies used to determine the
appropriate extent of remedy. Specific details are set forth
in the policy entitled "Participation of Potentially Responsible
Parties in the Development of Remedial Investigations and Feas-
ibility Studies under CERCLA" (Lee M. Thomas and Courtney M.
Price, March 22, 1984). The Agency anticipates that both the
Fund and private resources may be used at the same site in some
circumstances. When the Agency settles for less than 100% of
cleanup costs, it can use the Fund to assure site cleanup will
proceed expeditiously, and then sue to recover these costs from
the non-settling responsible parties. When the federal govern-
ment accepts less than 100% of cleanup costs and non-financially
viable responsible parties remain, Superfund monies may be
used to make up the difference. The Agency's "Interim CERCLA
Settlement Policy", December 5, 1984, outlines the general
principles for private party settlements under CERCLA. The
Agency will develop more specific procedures to clarify the
process for mixed funding. CERCLA reauthorization may also
necessitate changes to the Agency's Settlement Policy.
-------
-12-
4. Cost recovery referrals
The following types of cases are the highest priorities for
referrals in the area of cost recovery: §107 actions in which
all costs have been incurred; and §107 actions in which a
significant phase has been completed, additional injunctive
relief is needed and identified and the Fund will not be used.
0 The Agency recently finalized its policy of filing of
cost recovery actions. (Price and Porter, "Timing of
CERCLA Cost Recovery Actions", October 1, 1985). The
current legal interpretation is that the Statute of
Limitations expires six years after the completion of
the response action. Priorities for referrals are
completed removals, completed remedial actions, and
response actions where there is a significant gap of
time between removal and remedial actions, or between
phases of the remedial action.
0 To assure timely cost recovery actions and avoid the
loss of evidence and witnesses, cost recovery actions
should be initiated within one year of completion of a
removal action at non-NPL sites. Cost recovery action
should be initiated within one year of the completion
of the removal action at NPL sites, if there will be a
significant gap (18 months or more) between removal
completion and the signing of the Record of Decision
(ROD). Cost recovery action for remedial action should
be initiated as soon as practicable after the signing
of the ROD, usually within 18 months of that time.
0 Anticipated amendments to the law under CERCLA reauth-
orization will authorize the Agency to develop stream-
lined procedures for collection in small cost recovery
cases where the amount of resources to be recovered does
not merit a full-fledged referral.
0 On October 2, 1984, the Agency and ASTSWMO issued a
joint policy on "State/EPA Relationship in Enforcement
Actions for Sites on the National Priorities List."
This policy discusses actions to be taken that will
improve the State/EPA relationship and increase the
effectiveness of enforcement actions for NPL sites.
5. Federal/State enforcement actions
The most important initiatives for improving the Federal/
State enforcement relationship include:
-------
-13-
0 EPA issued guidance on January 17,1986, for providing
funds to States for RI and FS at State-lead enforce-
ment sites, and funding for oversight of responsible
party conduct of RI, FS and RD. EPA will also develop
guidance to allow, where appropriate, funding for
other State enforcement-related activities including
oversight of PRP RA negotiations and litigation to
compel or encourage private party cleanups.
0 Sites will ultimately be classified as State-lead if
States prepare RI/FS, negotiate within established
time limits, provide for public comment, implement a
remedy at least as stringent as would be required
under the MCP, and keep EPA informed of its actions.
0 State/EPA Enforcement Site Agreements will be estab-
lished where appropriate to identify the nature and
level of detail of involvement in each other's act-
ivities.
0 States and EPA will establish effective arrangements
for information exchange to keep each other informed
concerning progress at each other's sites.
6. Oversight of PRP's, federal facilities and State actions
0 The accelerated pace of enforcement activity, the
private party initiatives, the number of cleanup
actions being conducted under settlements and state-
lead enforcement actions, and federal facility
cleanups increase the need for intensive oversight
of private party, state and federal facility cleanup
activity.
0 During FY 1987, EPA anticipates an increased number
of private party cleanup actions performed under
administrative orders, consent decrees or court
orders. This increase in responsible party actions
will reauire a greatly enhanced capability for
ensuring responsible party compliance with formal
consent decrees or administrative orders. PRPs may
be involved in all phases of response.
0 The Agency anticipates that CERCLA reauthorization
will provide additional authorities for oversight of
responsible party actions. Guidance is being developed
on Federal and State oversight of PRP activities and
the definition of roles when more than one entity has
site responsibilities (e.g., EPA, State, and PRP).
-------
-14-
0 OSWER and OECM will jointly develop necessary pro-
cedures , systems and measures for tracking the
status and appropriateness of responsible party
actions in all phases of site response.
0 The Agency will increase the level of effort devoted
to oversight of Federal facility cleanup action under
CERCLA. Oversight should be substantilly equivalent
to oversight of PRPs, and a specific target for over-
sight of federal facility RI/FS has been included in
the SCAP.
We anticipate that the process for federal facility cleanup
under CERCLA should be clarified by changes to the statute.
GOAL III Cqntinue to Decentralize and Delegate Authority
1. Deletion
As the program matures, the deletion of sites from the NPL
becomes an important priority. Guidance regarding the
deletion process will be issued in FY 1986. The guidance
will discuss the criteria for determining when a. remedial
action is considered complete and how a site deletion should
proceed, including requirements for analytical support.
2. Remedial Delegations
The Regions will be given additional authority and expanded
criteria in making final site remedy selection. These actions
will help the program maintain a balance between its planning
and remedial action activities.
0 Each Region is responsible for reviewing the cleanup
status of its sites and initiating deletion review
activities for those sites that are ready to be
considered for deletion.
0 In FY 1987, the Assistant Administrator for Solid Waste
and Emergency Response will address the delegation of
deletion decisions to the Regions.
3. Enforcement Delegations
0 With the anticipated changes in the statute, OSWER and
OECM will address enforcement delegations to the Regions
such as settlements and direct referral of small cost
recovery cases.
-------
-15-
GOAL IV Improve Scientific Expertise
1. Expand the Capabilities of the Environmental Response
Team
During PY 1987, several significant programs will be in
their first or second years of implementation, including
the Chemical Emergency Preparedness Program, the Underground
Storage Tank Program, and the Ground Water Evaluation/Protection
Program. Because of its experience in all of these technical
areas, the ERT will be looked upon to provide program continuity
both in terms of Region to Region as well as from Federal to
State to local government organizations.
0 The ERT will rely on its established and nationally
recognized training program, its in-house staff of
technical experts, and its contractor support staff.
However, due to the continuing policy of delegating
responsibility to the Regions and States, we will
attempt to increase ERT contractor support. This
will enable the ERT to expand the training program,
technical support, and information services.
0 Regions should develop support groups through more
formal use of the RRT's.
0 Establish a new function within the ERT to provide
technical information exchange through a wide variety
of media. Included will be the responsibility to use
state-of-the-art techniques and equipment to enhance
communication with emergency response personnel and
remedial project managers. Implementation of this
program will allow more efficient use of ERT staff
time, provide quicker exchange of field experiences
among Regions, and increase program continuity and
oversight.
2. Implement Better Systems and Procedures for Technology
Transfer
All participants in the CERCLA process need ready access to
current technical information. A system must be established
to facilitate the transfer of research and other technical
information reflecting current knowledge and findings so as
to make measurable improvements in the performance of Super-
fund cleanup activities. Initial emphasis should be placed
on the transfer of information on alternative technologies
to land disposal and on-site treatment options. Several
Headquarters/Regional workgroups are currently examining
alternative technologies criteria relating to treatment
performance standards, cost-effectiveness and other issues.
0 Maintain a focal point in Headquarters for technology
transfer activities and information.
-------
-16-
Ensure that all important technical reports, guidance
and policy documents are kept at a central location,
are routinely updated, and are readily accessible to
rsA^^p^^i^l iie>&v»0
------- j
potential users
0 Implement a system to inform users of available
information and to actively communicate technical
facts and data concerning ongoing research and on-
site activities.-
0 Establish an interactive, two-way communication process
to match users needs with the offices that provide
technical information.
0 Plan and participate in technology transfer activities
with the Regions and Headquarters.
0 Provide a forum for discussion among government,
industry and the public of technology transfer plans,
activities, problems, overlaps and new opportunities.
0 Actively support and help implement the OSWER/ORD
hazardous waste Technology Transfer Task Force strategy,
and the ORD/OSWER SITEs Program.
3. Analytical Support
In FY 1987, analytical support for Superfund will be affected
by two factors: 1) need for flexibility to be able to respond
to changing program requirements and 2) provision of additional
support systems to the Regions. There will be continuing
emphasis on maintaining adequate capacity to meet program
needs, minimizing turnaround times, and improving data quality.
The Agency will consider an emphasis on field analytic
capability, including mobile laboratories and short-term field
labs handled through the on-site contractor.
The groundwork for this expansion will be laid in FY 1986.
The Contract Laboratory Program will establish new types and
levels of analytical support to mesh with requirements
developed through Data Quality Objectives. The CLP will
continue the process of decentralization, while maintaining
program oversight and national consistency, by furnishing an
Environmental Services Assistance Team (ESAT) to each Region
under a national contract. In addition, Regional Sample
Control Coordinators (RSCC) with Deputy Project Officers
(DPO) will be more closely integrated into Sample Management
Office information and tracking systems.
0 Continued modification and expansion of the menu of CLP
services to meet new and different requirements.
0 Development and implementation of procedures by
which field contractors of the HSCD and ERD can
obtain information and support from the CLP, while
concurrently providing documentation on non-CLP
-------
-17-
analytical activities.
a During FY 1986, a decision will be made on imple-
mentation and development of an integrated Analytical
Support Communication Network linking the Regions and
the contract laboratory community with Headquarters.
This system will streamline and speed up the scheduling
and tracking of samples and sample data.
0 Expanded and decentralized support to the Regions,
via ESAT contracts and access to SMO information
systems, to meet the growing and changing requirements
of both RCRA and CERCLA. As the Regional RSCC and DPO
functions are required to provide more and more support,
the existing support will be expanded and modified based
on the new requirements.
0 Continued and expanded Quality Assurance Support and
oversight will be necessary to insure that increasing
and diversified analytical support activities meet Agency
requirements. The existing QA structure will be extended
to all analytical activities of the Office of Solid Waste
and Emergency Response as quickly as the availability of
resources permits.
0 Continued emphasis on maintaining capacity, timeliness
and quality of the CLP.
0 Development of procedures to track all Superfund
samples and to provide a common base of information
on the routing of these samples.
GOAL V Improve Technical Communication with the Public
1. Chemical Emergency Preparedness Program
FY 1987 will be the second year of the Chemical Emergency
Preparedness Program, which was announced in June 1985 as part
of the Agency's Air Toxics Strategy. In FY 1986 the program
objectives were: to develop the List of Acutely Toxic
Chemicals and accompanying guidance to assist communities in
use of the List and development of preparedness programs,
build program infrastructure at the Federal, State, and
local levels, and begin program implementation. In FY 1987,
the objective will be to continue and extend program imple-
mentation through expanded training and technical assistance
to States and, through States, to local personnel. New
initiatives may also be mandated bv CERCLA reauthorization.
The overall program goals are to promote community awareness
of chemical hazards and assist in the development of State
and local preparedness programs and response capabilities.
-------
-18-
0 The role of EPA Headquarters is to provide overall
coordination of program development and implementation
and provide additional guidance, program oversight
and assessment, and support to Regional Offices.
In particular, Headquarters will coordinate Federal
training and technical assistance resources to Regions.
Federal interagency coordination at the national level
will take place largely through the National Response
Team.
0 EPA Regions will be responsible for program imple-
mentation within their Region. In this role, Regional
staff will work with States to ensure dissemination of
program materials and provide training and technical
assistance to States and through States to local
personnel, and assess program implementation. The
Regional Response Team should provide a forum for
coordination activities in the Regions, particularly
in the area of training and technical assistance.
0 The program depends upon the participation of local
and State governments. The local government role is
to take the lead in carrying out the contingency
planning, preparedness, and response functions
described in the program guidance material. The State
role is to distribute program materials to local
communities, be the principal point of contact and
liaison with these communities, and provide training
and technical assistance to these communities.
0 Emphasis will be on simulations and exercises to
evaluate contingency plans, preparedness, and response
operat ions.
0 Emphasis will be on increased enforcement and
information gathering regarding reportable quantity
releases.
2. Improve Effectiveness of Community Relations Efforts
The Superfund community relations program has been in place for
three years. During that time, the program has expanded. New
community relations initiatives, such as a dispute resolution
pilot project, have been undertaken.
0 Experience to date has reinforced the importance of
two-way communications based on informal, personal
contact with Regional project officers and site
residents. In FY 1987, the Regions will continue to
expand their community relations activities, in terms
of "risk" discussions, as well as conducting more
community relations activities in the early and late
phases of the remedial process. Guidance will be
developed on making presentations to the public on
site cleanup alternatives.
-------
-19-
The Regions will continue to implement the basic
community relations program, consistently providing
a minimum three week public comment period for
remedies at remedial sites. In addition, Headquarters
will continue production of generic fact sheets (on
subjects such as risk assessment), while Regions will
focus on site-specific fact sheets. Responsiveness
summaries will continue to play a major role in feed-
back to the public on their reactions to site remedies.
In FY 1985, the Agency finalized procedures governing
community relations for enforcement actions. The
provisions for public review of RI/FS in enforcement
actions are comparable to those required for Fund-
financed cleanup, and responsiveness summaries are
required for enforcement actions as well as Fund-
financed actions.
Headquarters community relations efforts will focus
on evaluating the effectiveness of Superfund community
relations efforts and recommending changes, assuring
the integration of the community relations program
currently in place, increasing public educational
materials, and developing program and financial
tracking systems.
-------
-20-
III. APPENDIX
SUPPLEMENTAL GUIDANCE *
1. Superfund Comprehensive Accomplishments Plan (SCAP) Guidance
2. Several guidances, as yet undetermined, related to the
Superfund reauthorization legislation.
3. Several guidances, as yet undetermined, related to the
results of the Remedial Program Improvement Pilot Project.
Potential guidances are:
0 Contractor continuity
0 Expediting the removal/remedial process
0 Revised contracting strategy
0 Revised RI/FS guidance
0 Project and site management
4. Evaluation Guidance - OERR will develop a document to draw
together the various criteria used to evaluate performance.
The document will include both Quantitative measures (SPMS,
SCAP) and qualitative factors (recurring items of the
annual Regional reviews).
5. Potential Enforcement Guidance Documents
o
Mixed Funding Guidance
0 Procedures for Small Cost Recovery Cases
0 Guidance on Oversight of PRP Activity
0 Guidance on Funding State enforcement related activities
NOTE: The anticipated availability dates are unknown at
this time due to their relationship to the pending CERCLA
reauthorization.
-------
-21-
FY 1987 RCRA OPERATING GUIDANCE
I. INTRODUCTION
The basic authority for the national hazardous waste management
program is the Resource Conservation and Recovery Act (RCRA).
It was amended and strengthened in 1984 by the Hazardous and
Solid Waste Amendments (HSWA). RCRA established a "cradle to
grave" approach to the management of hazardous waste. The
major goal of this system is the protection of human health
and the environment. HSWA significantly expands both the
scope of coverage and the detailed requirements of RCRA.
A) PROGRAM PRIORITIES
A number of priorities will drive the effective development,
implementation and enforcement of the national hazardous
waste management program in FY 1987. The FY 1987 RCRA
Implementation Plan (RIP) will provide detailed imple-
mentation guidance and direction to the Regions and States
on how to implement these priorities. It identifies specific
goals, priority activities and implementation policies that
must be reflected in State and Regional planning documents.
Groundwater Protection
Groundwater protection is the goal of numerous provisions
of HSWA. Ensuring installation of adequate groundwater
monitoring systems at land disposal facilities is the base-
line for tracking the impacts of these facilities. It also
provides the basis for requiring corrective action to clean
up releases to groundwater. HSWA requires the Agency to
restrict land disposal of certain hazardous wastes. In
addition, HSWA requires the use of minimum technology
standards for those wastes that have to be land disposed,
e.g., liner and leachate collection systems, and strengthens
the standards for groundwater monitoring. It also requires
regulations prescribing location standards for hazardous waste
facilities and correction of environmental problems from past
mismanagement of waste at RCRA facilities.
The hazardous waste program will examine the linkages among
these provisions and the Agency's approaches to implement
them to determine the most effective and consistent means
for groundwater protection. In the past, the Agency has
treated these items independently. We must determine the
incremental benefits of these items when used in combination
and then integrate them into the Agency's groundwater strategy
and classification system guidance.
Permitting and Closures
OSWER will work towards meeting the HSWA-mandated permitting
deadlines for land disposal units (11/88), incinerators (11/89),
and treatment/storage units (11/92). In addition to very strong
-------
-22-
effort towards meeting the permitting deadlines, we will also
approach closures on a priority basis, based on environmental
significance.
Identification of Releases and Corrective Action
Implementation of permitting and enforcement authorities for
corrective action under sections 3004(u) and 3008{h) is
essential to protect human health and the environment from
releases of hazardous waste and constituents from TSD
facilities. Corrective action encompasses several key
phases of activity: evaluation of facilities, identification
of releases; prioritization; compelling interim measures as
needed to abate immediate threats and contain potential
threats before they become significant problems; compelling
a remedial investigation, and design and implementation of
corrective measures. Long term corrective action should to
the extent practicable be conducted on a facility wide basis
and address all releases associated with the facility.
Enforcement Program
A strong and highly visible enforcement program demonstrates
the Agency's resolve to implement the hazardous waste manage-
ment program effectively. The Regions and States will inspect
handlers and bring civil, administrative and criminal enforce-
ment actions to achieve compliance, particularly at land
disposal facilities.
Federal Hazardous Waste Management Law (Loopholes)
The hazardous waste program will continue to implement the
provisions of the 1984 Amendments to close the loopholes that
existed in the previous law with regard to management of
wastes from small guantity generators, underground storage
tanks, municipal, nonhazardous (Subtitle D) landfills, listing
additional hazardous wastes, regulation of used oil, and the
burning of hazardous waste fuel mixtures. For example, final
regulations on the technical and transportation standards for
burners and blenders of hazardous waste fuel mixtures will be
promulgated in FY 1987. Final regulations concerning the
listing of used oil and related management standards will be
issued by November, 1986. Following promulgation, these
regulations will be implemented and enforced.
Statutory Deadlines and Hammer Provisions
OSWER intends to meet the statutory deadlines for most of the
regulations, studies and listings. However, we have missed
some deadlines and will likely miss others. The delays were
largely the result of Agency's need to resolve complex legal,
technical and policy issues before promulgating regulations.
Treatment Capacity
Ensuring adequate and safe alternative treatment capacity and
-------
-23-
defining the role of the Agency in siting of hazardous waste
management facilities is known to be a regional priority.
OSWER will address these requests on several fronts. Stream-
lining the permitting process may be the most productive area
to assure adequate capacity. Development of alternative treat-
ment technologies is critical for the program. The development
will be assisted by expedited research, demonstration and dev-
elopment permits as well, as permitting mobile treatment units.
In addition, the Headquarters program will develop information
materials on various types of treatment technologies and work
with the Regions in siting.
Improve Information Management
EPA and States must continue to improve information management
systems as a tool to improve management of the RCRA program in
FY 1987. OSWER is focusing on a new hazardous waste data/infor-
mation system called RCRIS. OSW and OWPE respectively will be
developing integrated information management systems. The
hazardous waste program must determine what data we need to
answer questions regarding environmental results and protection
of public health. Information systems will be refined and
maintained to provide adequate information on the timeliness
and appropriateness of actions at facilities and to provide a
clear picture of the regulatory and compliance status of each
facility.
B) OPERATING THEMES
Cross Media/Cross Program Cooperation
In FY 1987, the program will accelerate its efforts to work
with other Agency programs and offices to develop the most
effective and efficient regulatory approaches Cor controlling
toxic chemicals and hazardous waste. For example, OSWER will
utilize information being developed on the chemicals by the
Office of Pesticides and Toxic Substances (OPTS) in RCRA
listing decisions. In addition, the program will cooperate
with OPTS on disposal methods for pesticides, sharing data
collection systems on new and existing chemicals, assessing
risks, and transferring responsibility for PCS disposal from
OPTS to OSWER. OSWER will utilize the information gathering
provisions of the Toxic Substances Control Act (TSCA) to
require manufacturers of chemicals to provide health and
environmental fate data on chemicals/wastes covered by RCRA.
Agency policy and approaches to hazardous waste management
must be coordinated between the Office of Water and the
hazardous waste program. There are a number of overlapping
-------
-24-
issues, some of which include: municipal sludge management,
corrective actions at wastewater treatment facilities, ground-
water classification, location guidance and standards, re-
strictions on land disposal and underground injection of
hazardou* waste, as well as the linkages among land disposal
restrictions, corrective action and the drinking water
standards established under the Safe Drinking Water Act.
In addition, the exemption for domestic sewage from RCRA
regulation and issues associated with section 404 (wetlands
protection) of the Clean-Water Act must be addressed by both
offices. Final regulations on the domestic sewage exemption
will be promulgated by August, 1987.
OSWER will cooperate with the Office of Air and Radiation to
resolve issues associated with the burning of hazardous waste
fuel mixtures, use of municipal waste combustors, standards
for facilities other than incinerators, and the disposal of
naturally occurring radioactive materials and other low-level
radioactive wastes. OSWER will also look to the Office of
Research and Development for assistance in developing quality
assurance programs, monitoring programs and alternative
treatment technologies.
Risk-based Analysis
In FY 1987, OSWER will move toward greater reliance upon risk-
based decision-making to resolve some of the major issues
facing the national hazardous waste program. Such issues
include a policy on "how clean is clean," a comprehensive
listing and delisting strategy, and the development of risk-
based site-specific decisions regarding land disposal
petitions from hazardous waste treatment, storage, and
disposal facilities.
Site-Specific Decision-Making
Headquarters will work closely with the Regions to transfer
site-specific decisions in FY 1988 and FY 1989. In addition,
Headquarters will provide SWAT teams and examples of model
decisions to facilitate rapid and consistent decision-making.
Permit and Enforcement Integration
Within the Office of Solid Waste and Emergency Response
(OSWER), OSW and OWPE will cooperate with the Comprehensive
Environmental Response, Compensation, and Liability (CERCLA)
program to develop a consistent, effective approach to
corrective action, to implement the Agency policy for
disposing of CERCLA hazardous waste off-site, and for
-------
-25-
listing RCRA sites on the NPL. OSW and OWPE will work to
implement a facility management approach that integrates
permitting, enforcement, and corrective actions. Related
issues that will have to be resolved in a coordinated manner
include treatment of new v. old hazardous waste, need for
consistent cleanup standards and risk assessment approaches,
capacity shortfalls, and control of source v. control of
exposure. Finally, cooperation between OSW and the Office
of Underground Storage Tanks (OUST) will be essential to
ensure that good regulatory rationales exist for technical
standards for product and waste storage tanks.
Streamline and Simplify Program Guidance
OSW will accelerate its efforts to develop and distribute
clear and useful guidance. Headquarters will include the
Region and ,.the States in developing this guidance.
OSW will concentrate on clarifying guidance documents to
better explain, to the regulated community, the thinking
process that guided Agency decisions in development of our
regulations. Two examples of OSW's attempt to simplify and
clarify guidance documents are:
o Land Disposal Ban Petition Process; and
o Alternate Concentration Limits.
II. GUIDANCE
GOAL I Address previously neglected problems and restore
environmental quality to acceptable levels
A)
Strengthen the oermitting and enforcement process to
improve the timeliness and quality of actions
1. Integrate permitting, enforcement and corrective actions
at hazardous waste management facilities
EPA and the States will integrate the use of permitting and
enforcement authorities to obtain timely compliance with
interim status permitting, and corrective action requirements.
Complimentary use of permitting and enforcement authorities
will ensure timely progress in achieving compliance and will
serve as an incentive to owners/operators of facilities for
improved compliance in the future.
o Implementation of the facility management plan (FMP)
approach initiated in FY 1985 will be a particular
priority. A strategy to bring each facility into
-------
-26-
compliance with all applicable requirements will be
developed through early planning and coordination
between permitting and enforcement staffs.
o FMPs should also reflect known and anticipated
corrective action needs at the facility, including
initial investigations, interim measures, remedial
investigations and corrective measures. The FMP
should also identify the mix of authorities which
will be used to"address environmental releases or
potential releases associated with the facility.
These authorities include CERCLA §106 and
appropriate State authorities.
o Regions and States must develop a team management
approach for each facility composed of a team leader
who acts as a facility expediter and is responsible
for overseeing the development and implementation of
a facility management plan/compliance strategy for
each facility.
o At each facility, early and ongoing formal meetings
with permit applicants and States, where appropriate,
must be held as part of the facility management
approach. These discussions will not be a substitute
for enforcement, and planned enforcement activities
will not be discussed.
2. Coordination between RCRA permitting and enforcement and
CERCLA enforcement
In FY 1987, OSWER will improve coordination of RCRA and CERCLA
enforcement authorities at facilities. This will allow EPA to
ensure that all human health and environmental threats are
addressed.
3. Expedite permitting and enhance enforcement efforts
OSWER will continue to foster an effective working relation-
ship with the states while maintaining necessary oversight
of national priorities. EPA and the States must continue
to work together to improve the quality and timeliness of
permitting, inspection and enforcement actions as States take
over more program responsibilities.
o Improved joint permitting procedures and greater State
assumption of HSWA requirements will be a focus of the
program during FY 1987 and 1988.
-------
-27-
o EPA will encourage active participation by State and
Regional technical, scientific and legal staffs in
regulatory development and implementation work groups.
OSW will develop Implementation Plans during the
proposed rule period and finalize them when the reg-
ulation is promulgated.
o EPA regions must coordinate with and maintain over-
sight of State actions on closure to ensure protection
of human health and the environment.
o Enhancement of State programs will be fostered through
a combination of resource-sharing, peer matches, and
technology transfer.
o Headquarters and Regions will provide technical and
legal assistance and training.
o Enforcement staff must work to engage State Attorneys
General staff with State program staff in program
planning and management decisions and in developing
EPA/State enforcement agreements in such program
areas as corrective action, closures and groundwater
monitoring. The State Attorney General's role should
be reflected in State grant agreements. In particular,
EPA will conduct training based on the Groundwater
Monitoring Technical Enforcement Guidance Document
and Compliance Order Guidance.
o As in the last two fiscal years, the Regions and States
are subject to the RCRA program Interim Quality Criteria
and the Enforcement Response Policy. The criteria will
be revised as needed to reflect additional program
experience and program goals.
o Regions should carefully monitor progress in enforce-
ment action against significant non-compliers (land
disposal facilities with violations of the groundwater,
closure/post-closure, and financial responsibility
requirements) and take action where the States cannot
or will not take timely and appropriate action.
o Regions should maintain oversight of State permitting
and enforcement actions to ensure that States follow
their commitments in the State grant agreements, the
State enforcement agreements, and the interim quality
criteria.
-------
-28-
B) Implement RCRA Authorities at Hazardous Waste Management
Facilities to Protect Human Health and the Environment
1. Implement the corrective action program through the use of
permitting and enforcement authority, as appropriate
EPA and States (when authorized) will require preliminary and
detailed studies to determine the extent of contamination in
surface and groundwater,- soil, and air and require owners/
operators to initiate interim and final corrective action
measures.
o Initial investigations should be conducted at operating
and closing facilities to determine whether there are
releases from hazardous waste management units (HWMUs)
and/or solid waste management units (SWMUs). Whenever
possible, the initial investigation should be conducted
on a facility-wide basis. When completed, the Region
should determine whether the owner/ operator should
undertake additional data collection, interim measures
and/or remedial investigation (RI).
o Priorities for corrective action include operating and
closing land disposal and incineration facilities, and
facilities providing alternative treatment capacity,
as well as storage facilities with known significant
releases and target populations likely to be exposed.
o Use of section 3008(h) orders to address releases at
closing facilities is a priority to ensure that they
do not pose current or future threats to public health
and the environment.
o Use of section 3008(h) to compel interim measures as
appropriate, especially at closing facilities, is a
priority. Compelling interim measures is the most
effective mechanism to abate significant threats and
to prevent potential releases from becoming actual
releases.
o Regions and States will ensure that RCRA RI activities
at facilities are consistent with Superfund RI to
facilitate transition to CERCLA when the facility
cannot fund remediation activities under RCRA.
o EPA Headquarters will coordinate among program offices
to develop an approach to corrective action for POTWs
and underground injection wells, which are subject to
RCRA Subtitle C permit-by-rule and individually
permitted under CWA and SDWA.
-------
-29-
2. Require proper closure of facilities to ensure protection
of human health and the environment
o Closing facilities must have adequate groundwater
monitoring systems in compliance with 40 CFR Parts 265
and operate them properly.
o
Initial investigations and further corrective action
requirements, on a facility-wide basis to the extent
practicable, are priorities.
o Facilities may not close surface impoundments by
removal of wastes until they have demonstrated that
there is no groundwater contamination and that
satisfactory investigations demonstrate the absence
of residual contamination.
»»
o EPA and States must ensure that closure and post-
closure plans are sufficient to protect human health
and the environment, that they are carried out as
approved, and that facilities implement applicable
requirements for the life of the plan or post-closure
permit.
3. Ensure compliance with interim status and final permit
groundwater monitoring requirements
By FY 1987, all operating and closed land disposal facilities
must at a mininum have groundwater monitoring systems that
meet 40 CFR Part 265 requirements, using the RCRA Groundwater
Monitoring Technical Enforcement Guidance Document to make
determinations on the adequacy of systems. Facilities that
are not in compliance must be subject to a formal enforcement
action in FY 1986. In addition, land disposal facilities
seeking an operating permit must satisfy the groundwater
monitoring requirements of 40 CFR Part 270 or be the subject
of a formal enforcement action in FY 1986.
o Both operating and closed land disposal facilities
will continue to be inspected once a year to evaluate
compliance status.
o EPA Regions and States will conduct quality compre-
hensive groundwater monitoring evaluation (CUE)
investigations at facilities where this has not
been done or where a CME completed in the past was
inadequate.
-------
-30-
o OWPE will evaluate inspection guidance to refine
and improve inspection methodologies through more
detailed guidance, handbooks and training. OWPE
will also develop innovative approaches to conducting
inspections, such as the use of private inspectors.
o Special attention is to be given to evaluate whether
facilities in detection monitoring have releases and,
therefore, should undertake assessment monitoring to
determine the extent of contamination.
o Enforcement actions against facilities with inadequate
groundwater monitoring systems must be brought to a
final order as expeditiously as possible.
o EPA and States must monitor compliance with ground-
water monitoring requirements specified in permits and
orders and bring prompt enforcement action for non-
compliance.
o Continue to implement the off-site policy to provide
acceptable disposal facilities for CERCLA waste.
4. Resolve the technical, scientific, and regulatory issues
associated with "how clean is clean"
In the interim, decisions on cleanup levels will be made on a
case-by-case basis with appropriate program guidance. These
decisions will be applied to permitting, corrective action, and
closures, as appropriate.
5. Expedite review and decision-making for Part B permit
applications
All land disposal facilities must have submitted a Part B permit
application by November, 1985 in order to continue to operate.
Processing of these permit applications must be completed by
November, 1988. During FY 1987 and 1988, the Agency and the
States will evaluate permit applications so that permit
determinations can be completed by November, 1988. Review of
Part B permit applications is a lengthy, iterative process,
involving negotiations with the facility's owner/operator, public
meetings, and enforcement activities. Approximately 500 land
disposal facilities had already applied for an operating permit
by the end of FY 1985.
o As indicated previously in this guidance, FMP's are
the mechanism to develop a strategy to move facilities
through the permitting process in a timely fashion.
Regions and States will use a team approach to co-
ordinate permitting and enforcement action at the
facility. Agency/permittee meetings, documented as
part of the regulatory record, will be used to facil-
itate the permitting process.
-------
-31-
o EPA and States will continue to streamline the
permitting process.
o Priorities for permitting are land disposal, incin-
eration, and alternative treatment facilities. Lower
priority permits, such as non-environmentally sig-
nificant storage facilities will be processed on a
slower schedule.
o EPA and States will work to expand public involvement
during the permitting process.
6. Improve compliance at Federal facilities
OSW continues to issue permits to Federal facilities. Head-
quarters is working closely with the Regional federal facil-
ities coordinators who are responsible for program coordin-
ation with Federal agencies. It is a priority to make
compliance at Federal facilities a model for all RCRA
Subtitle C facilities. OSW has developed a policy document
which emphasizes the Agency's commitment to enforce RCRA
permitting requirements at Federal facilities.
o EPA must conduct all inspections at Federal facil-
ities, as well as all facilities owned by State and
local governments. State inspectors may accompany
EPA inspectors. Whenever possible, inspections
should be facility-wide to identify corrective
action needs.
o EPA encourages States to take prompt and appropriate
enforcement action when violations are identified,
including formal enforcement actions for Class I
violations. When States cannot or will not take
action, EPA will take enforcement action.
o Regions should use 3008(h) to compel corrective
action, as appropriate, at Federal facilities.
o EPA and states should continue monitoring to ensure
compliance with orders.
7. Provide technical support to the criminal enforcement
program
During FY 1987, the Agency will continue to take criminal action
in cases in which a person knowingly violates interim status or
permit requirements, causes hazardous waste to be transported to
unauthorized facilities, or exports hazardous waste without
meeting certain conditions.
-------
-32-
o Particular attention will be given to persons who
knowingly and illegally dispose of hazardous waste.
o EPA and States must develop an effective communications
strategy to publicize successful criminal action as a
deterrent to the rest of the regulated community.
8. Promote innovative compliance monitoring and enforcement
of the small quantity generator regulations.
EPA and States must develop new and innovative approaches
relying on intensive public education efforts and targeted
enforcement approaches.
GOAL II Control the use of existing commercial chemicals
and pesticides that pose an unreasonable risk to
health and the environment
OSWER is comitted to creating a link regarding, information on
commercial chemicals and hazardous waste from those chemicals.
1. Shared basic research
OSWER will work with the OPTS to coordinate and share basic
research on a variety of chemicals and toxic substances. The
program can draw upon both the methodology and the substantive
conclusions reached through the risk assessment and management
activities of OPTS.
2. Pesticide disposal
Joint efforts will also be undertaken to develop effective
approaches to disposal of pesticides as this activity overlaps
the mandates of the hazardous waste and pesticide programs.
3. Listing decisions
While OSWER faces increased requirements and pressures to list
large numbers of toxic materials as hazardous waste, it will
cooperate with OPTS in making its listing decisions. It can draw
upon data developed by OPTS in its new chemical/new pesticide
reviews and registration standards reviews to assist in this
effort.
-------
-33-
4. Land disposal bans
OSWER will work with OPTS and use TSCA information gathering
authorities to obtain needed data.
GOAL III Anticipate and prevent future environmental problems
and maintain high levels of environmental quality
OSWER will work to prevent risks from hazardous waste treatment
and disposal activities in the future through development of new
regulations and programs and revisions of existing regulations.
1. Fix existing regulatory framework where appropriate
o Appendix VIII
In FY 1987, the program will make final changes in its
groundwater monitoring requirements, especially the
requirements for monitoring the hazardous constituents
listed in 40 CFR Part 261, Appendix VIII. Owners/
operators of facilities and the EPA Regions, have
requested Headquarters assistance in implementing
groundwater regulations. Short-term fixes will
occur in FY 1987. For example, in consultation with
outside experts in December 1985, OSWER will produce
short-term guidance on how to apply the constituents
listed in Appendix VIII to the permitting program.
o Clean closures
The requirements for closure of interim status surface
impoundments now allow closure of a facility with no
post-closure care requirements, if an owner/operator
can demonstrate that the remaining hazardous wastes
have been removed. The closure standards for char-
acteristic wastes at interim status facilities are
not consistent with those of finally permitted facil-
ities. In FY 1987, the program will amend these reg-
ulations to resolve the inconsistencies. Further,
OSWER will also ensure that closure standards are
made consistent with those specified in our reg-
ulations on land disposal restrictions.
o Definition of solid waste
The regulations on the "definition of solid waste"
set out which secondary materials are excluded from
hazardous waste regulation because they are recycled in
-------
-34-
certain ways or otherwise integral in an industrial
process. These regulations are complex and relate to
•any segments of the hazardous waste regulations. The
Agency will continue to simplify wherever appropriate.
o Delisting program
OSWER will develop a comprehensive delisting strategy
that involves Regional and State determinations on
site-specific delisting petitions.
o Major/minor permit modifications
Current and proposed RCRA regulations require a re-
source-intensive administrative process for approving
most modifications to RCRA permits once they have been
issued. Although some minor modifications can be made
without public notice and opportunity for comment,
most permit modifications ("major modifications")
require adherence to 40 CFR Part 124 public partic-
ipation requirements, including public notice and the
opportunity to comment.
During FY 1986, the program intends to revise current
permit regulations to allow greater flexibility in
making changes to facilities' equipment operations.
The use of regulatory negotiation for this issue is
being explored. The environmental community has raised
the sharpest criticism with regard to changing the
regulations. The Agencvr States and owners/operators
agree, however, that some modifications should be made
outside the cumbersome, full-blown process.
o Mobile treatment
The Agency will develon mechanisms to improve the
currently complex procedures for permitting mobile
treatment units in cases of site-specific cleanups
where the treatment facilities may not be needed
permanently. It has proved inefficient and counter-
productive to require a Federal permit and a permit
within each State where treatment is needed.
o Financial assurance criteria
OSWER must promulgate regulations specifying financial
responsibility requirements for facility owners/
operators for corrective actions (HSWA sections 206
and 208).
-------
-35-
o Subparts X and Y
Regulations will be developed for the treatment,
storage and disposal facilities using management
practices not currently addressed by our regulations,
(i.e., non-incineration thermal treatment, open deton-
ation). In addition, regulations will be developed
for experimental facilities for treatment of wastes
in salt domes, salt beds, mines and caves.
2. New initiatives
o Burning and Blending
OSW is phasing in regulations to control burning and
blending of waste fuels. These rules will provide
controls for storage and transportation of all fuels
that contain or are derived from hazardous waste and
used oil, and permit standards for burning such fuels
in industrial and utility boilers and - industrial
furnances. The Agency would prohibit burning of
waste fuels in non-industrial boilers. In FY 1987,
OSW must focus in developing the proposed technical
standards. Some of the issues OSW must address during
FY 1987 are:
- whether to use a site-specific risk assessment v.
general performance standards;
- whether to tailor permit standards for facilities
burning hazardous waste fuels by developing design
and operating requirements and a waste specification
for permitting boilers and industrial furnaces rather
than the expensive and comolicated trial burns required
for incinerators to demonstrate effective combustion
of toxic organics; and
- whether to permit facilities under permit-by-rule
standards which would not require interaction between
facility owners and operators and Agency officials.
o Small Quantity Generators
OSWER will promulgate the small quantity generators
rule in the spring of 1986. We estimate that these
new requirements will affect approximately 175,000
establishments that produce small quantities of hazardous
-------
-36-
waste. OSW must inform small quantity generators about
the new requirements and assist them to determine their
regulation status and fulfill their new responsibility.
OSW has developed and will implement a 3-phase outreach
program. Phase 1 of the outreach program is underway.
In FY 86-87, OSW will focus on implementing phase 2
which includes:
working with trade and professional associations,
trade press, and other national groups to alert
the small business community about these new
requirements;
developing and disseminating print and audio/visual
materials to explain new requirements; and
assisting State and local agencies to develop
State-specific education/outreach programs and
target affected business.
Subtitle D
In FY 1987 and FY 1988, the program will proceed with a
major new initiative in the area of non-hazardous waste
(Subtitle D) landfills. By November 1987, the Agency
must report to Congress on the adequacy of the existing
landfill criteria to protect human health and the
environment from ground water contamination. It will
recommend additional enforcement authorities, if they
are needed. In FY 1988, the Agency must revise the
criteria for facilities receiving hazardous household
or snail quantity generator wastes. At a minimum, the
Agency will require groundwater monitoring, establish
location criteria, and provide for corrective action,
•where appropriate.
Since there are approximately 275,000 Subtitle D facil-
ities and limited Federal, State and local resources
to tackle this issue, careful attention will have to be
focused on those facilities and wastes most likely to
cause adverse health and environmental problems. The
program has already begun a massive outreach effort
involving State and local officials as well as many
representatives of the private sector. The activities
will be expanded during FY 1987.
-------
-37-
0 Waste minimization
Securing implementation of appropriate waste reduction/
minimization methods on the part of generators will be
an important part of the hazardous waste program for
FY 1987. The Agency will be issuing a Report to
Congress on Waste Minimization at the beginning of FY
1987. This area holds promise for helping to abate
capacity shortfalls and for assuring the public that
effective efforts are being made to manage waste
responsibly.
o Land disposal restrictions
An integrated regulatory approach to land disposal
restrictions that protects human health and the
environment will continue to be developed and imple-
mentation initiated during FY 1987. This approach
will take into account various components that, to
a large degree, are now considered separately:
standards for corrective action; minimum techno-
logical requirements (e.h., liners, leachate
collection systems); facility location criteria;
land disposal restrictions; standards for determining
how clean is clean; standards governing facility
closure; and determination of what constitutes a
release of a hazardous substance or waste.
During FY 1987, the land disposal restriction program
will be extremely active. Final regulations establishing
a framework for determining which wastes will be banned
from land disposal will be promulgated in FY 1987. In
addition, final rules on land disposal restrictions
pertaining to dioxins, solvents and the "California
list" of hazardous wastes must be issued by July, 1987.
The final rule regarding land disposal restrictions on
the first one-third of those wastes listed by EPA as
hazardous must be promulgated by August, 1988.
o Comprehensive approach to listings
During FY 1987, the program will examine alternatives
for a comprehensive listing strategy. Regulations for
EPA toxicity testing are due by March, 1987.
Environmental and public health protection will be
increased through key new listing decisions regarding
the waste generated by industries associated with
-------
-38-
petroleum refining and wood preserving, as well as
the listing of used oil and additional solvents.
Other benefits may accrue from decisions based upon
the section 8002 large volume studies which will
review waste treatment and disposal in the mining,
utilities, and .oil and gas industries as well as
wastes treated in cement kilns.
3. Increase public education/outreach efforts.
o Headquarters is considering several candidates for
negotiated rulemaking, including major/minor permit
modifications, financial assurance for corrective
actions, PCB regulation, and groundwater monitoring
requirements (Appendix VIII). Further, we will have
major outreach efforts in the areas of small quantity
generators and Subtitle D.
-------
-39-
* III. APPENDIX
SUPPLEMENTAL GUIDANCE
Estimated
Document Availability
Location Standards Guidance, Phase II (Final) 5/86
Land Treatment Standards (Final Draft) 12/86
Guidance on Retrofitting Surface Impoundments
(Final Draft) 6/86
Guidance an Bulk Liquid Hazardous Waste (Final) 8/86
Guidance on Corrective Action (Final) 10/86
Preliminary Assessment/Site Investigation
Guidance (Final) 6/86
Closure Policy (Draft to Regions) 8/86
Interim Exposure Assessments Guidance
(Draft to Regions) 1/86
Alternative Concentration Limits Guidance (Final) 8/86
FY 1987 RCRA Implementation Plan 4/86
-------
-40-
Tentative Outline of the FY 1987 RCRA Implementation Plan (RIP)
(1) Goals and Priorities
(2) Facility Management
(3) Compliance Monitoring and Enforcement
o Inspections
o Enforcement
(4) Permitting
o Joint Permitting
o Permit Processing Priorities
o Exposure Information
o Surface" Impoundment Retrofitting Waivers
o Public Involvement
(5) Corrective Action
(6) Closures
(7) State Authorization
(8) Federal Handlers
o Annual EPA Inspections
o Biennial Inventory
o EPA Enforcement for Federal Handlers
(9) Oversight
o Requirements for State Grant Work Programs
o Evaluating Performance
(10) Grants Administration
o Grant Allotments
o Use of Grant Funds
o Training
(11) RCRA Reporting
(12) Strategic Planning and Management Systems (SPMS)
-------
-41-
FY 1987 UNDERGROUND STORAGE TANKS OPERATING GUIDANCE
I. INTRODUCTION
The Office of Underground Storage Tanks (OUST) is a new
Office established at EPA to respond to the requirements of
Subtitle I of HSWA. The Underground Storage Tanks (UST)
program is new in the sense that the HSWA amendments ask
EPA to address this program area. We recognize, however,
that some local and State governments have been dealing with
environmental and health problems caused by leaking under-
ground storage tanks for many years.
What may be new is the national recognition that leaking
underground storage tanks are a much more frequent occurrence
than any of us realized. Congress has indicated, in Subtitle
I, that the Underground Storage Tank program may be run by
approved States "in lieu" of a Federal program. We will
emphasize that approach by focusing on providing tools for
development of approvable State programs. We Will also develop
means to address the needs of individuals on the firing line.
This may be a local fireman, or inspector, a tank installer,
a facility owner or operator, or a State or local agency
regulator.
A) PROGRAM PRIORITIES
We are committed to developing impleraentable regulations
that protect human health and the environment. We are also
committed to giving States every incentive to apply for UST
program approval. There are many uncertainties and unknowns
in this field, many questions left to be answered. Therefore,
we will seek to promote the development and exchange of useful
and practical information and minimize requiring or directing
specific approaches to be adopted.
Our goal is to have organizations, trained people and effective
methods available, over time, to deal with the problem of
underground storage tanks and to prevent leaks in the future.
EPA's (Headquarters and Regions) role is to help bring this
about through support and assistance to State program devel-
opment while developing a Federal program standard to protect
human health and the environment.
To assist States in developing their UST programs, we will
evaluate a variety of alternative funding mechanisms the
States may use to supplement Federal program grants. Dif-
ferent approaches are already being used in several States;
we will assess these mechanisms and work with the States to
identify those that are successful.
-------
-42-
To summarize, the UST program is designed to halt the
installation of tanks that are most likely to leak from
corrosion, help States identify the universe of tanks to
be regulated, establish standards for tank design and leak
detection and clean up damage where leaks have occurred.
II. GUIDANCE
Regulations
The highest priority task for FY 1987 is completion of proposed
regulations for tank technical standards, corrective action
and State program approval . OUST will develop these reg-
ulations through the workgroup process with extensive
participation from the Regions and States. In particular,
OUST will cooperate with CERCLA and RCRA staffs to address
the disposal of used and removed tanks. Research findings
from EPA projects and others will support these workgroup
efforts.
Notification
Early in FY 1986, the Office of Underground Storage Tanks
(OUST) promulgated the rule on notification including the
Federal notification form. This primary goal was accomplished
with considerable input from the Regions and the States. We
issued a Notification Handbook to explain the process to
States and recently developed a software program tailored
for use in the State notification programs. This software
program and relevant training were provided to over two-
thirds of the States. OUST, with Regional support, will
continue assisting the States with notification. The data
from notification will be used to report to Congress on the
program size and problem and may be used to determine grant
allocations in FY 1988.
In FY 1987, OUST will work with States to identify classes
of non-notifiers. We will work with the States to analyze
notification data so they can characterize reliably the
regulated universe and to take follow-up action as
necessary. User groups will be formed to take advantage of
analyses, reports and State uses of the notification data.
State Programs
State grant guidance for FY 1987 will be developed by mid-1986
with an eye towards incentives for States to seek UST program
approval . Although the grant allocation formula remains the same
for FY 1987, the State match will increase from 5% to 15%.
During FY 1987, OUST will implement and support the FY 1987
State Grant Program with assistance from the Regions and grant
and contract support. These groups will also develop the State
grant guidance for FY 1988. The State match will probably
increase again in FY 1988 to 25%.
-------
-43-
The OUST program will be working in close cooperation with
the Regions and the States to ensure program implementability.
We will seek to use a team approach in managing grants and
contracts with the Region acting as task managers wherever
possible.
Headguarters and Regions will begin reviewing State enabling
legislation when it exists and encourage development of
appropriate legislation where needed. OUST has developed
and distributed for comment a DRAFT Model Enabling Legislation
for use by States. We will finalize it in mid-1986.
Outreach
We will continue to have an active Outreach program. Com-
mentary and slide shows describing the requirements of Subtitle
I, the UST program and the UST problem have been provided to
the Regions. Several hundred thousand UST information pamphlets
and notification forms are being distributed to the States and
Regions. Extensive outreach efforts are also being coordinated
with the various trade associations, industry groups, States and
environmental groups. A newsletter is distributed quarterly to
a mailing list of over 1,000 persons.
Interim Prohibition/Enforcement
As a priority, OSWER, in working with the Regions, will
develop grants and cooperative agreements with States to
enforce the notification and interim prohibition requirements.
OSWER will develop a compliance inspection and enforcement
strategy and will also develop guidances for enforcement of
notification and interim prohibition.
-------
-44-
III. APPENDIX
SUPPLEMENTAL GUIDANCE
Document
Estimated
Availability
Enforcement Guidance
Interim Prohibition
Notification
State Program Approval Plan
»,
State Grant Guidance (FY 1987)
September 1986
September 1986
September 1986
June 1986
-------
Office of
Pesticides
and Toxic Substances
-------
OFFICE OF PESTICIDES AND TOXIC SUBSTANCES
PROGRAM GUIDANCE FOR 1987
I. INTRODUCTION AND STRATEGY
The 1987 guidance for the pesticides and toxic substances
program is the product of a very deliberate development process.
The strategy and guidance are in accordance with the direction
of EPA management, as expressed in the Agency priority list
and the Administrator's Management Plan. The current position
of the pesticides and toxic substances programs was carefully
considered as were the major thrusts of the 1987 budget. The
lead region for pesticides and toxic substances was a full partner
at all stages of the guidance development process.
Strategy
The basic authorities for the pesticides and toxic substances
programs are the Federal Insecticide, Fungicide and Rodenticide
Act and The Toxic Substances Control Act. These acts are similar
in important respects. Both acts recognize the inherent risks
to human health and the environment from pesticides and toxic
chemicals and, at the same time, their numerous benefits. Both
acts also recognize the need to balance the benefits and risks
of pesticides and toxic chemicals -- both new products and those
already in the market place.
Historically, in the pesticide and toxic chemical programs the
establishment of programs to evaluate the risks and benefits of
new products took precedence over the establishment of programs
to evaluate existing products. The result was that new products
were subject to more stringent standards than chemicals and
pesticides that had been in use for many years.
In the past several years a great deal of progress has been made
in developing and testing mechanisms to review existing products:
the 60,000 toxic chemicals in commerce when TSCA was passed and
the 40,000 pesticide products comprised of 600 active ingredients
In the pesticides program, generic chemical review, with its
components of registration standards/ data call-in, and focused
-------
-2-
Special Reviews, has been proven to work. At the end of 1985
registration standards for 117 pesticide active ingredients had
been developed and essential chronic testing data for all food
use chemicals had been called in. In addition, over 65 pesticides
have been subjected to Special Review; numerous products have
been suspended from use or have had certain uses restricted.
In the toxic substances program a phased program to identify,
evaluate and control the risks of existing chemicals has been
established. The program has screened over 3,000 chemicals.
There are approximately 85 chemicals undergoing detailed inform-
ation gathering and analysis at all times and risk management
actions have been completed on 12. These actions include: Section
6 rules on PCBs, asbestos, dioxins, and chloroflurocarbons; Section
9 referrals to the Occupational Safety and Health Administration
on 1,3-butadiene and 4,4-MDA for potential workplace safety
measures; a significant new use rule on hexachloronorbornadine,
and chemical advisories alerting the public to potential problems
related to used motor oil, burning used oil, nitrosamines in
cutting fluids, leaking underground storage tanks, MBOCA, butyl
benzaldehyde, butyl benzoic acid, and butyl toluene. Risk manage-
ment actions under Section 6 and/or Section 9 are being developed
for asbestos, methylene chloride, glycol ethers, metalworking
fluids, and formaldehyde. In addition, rulemakings to define
significant new uses for several other existing chemicals such as
urethane are in progress.
1987 Priorities
The single overriding priority of the 1987 pesticides and toxic
substances programs will be the emphasis given to existing
chemical programs. The importance of this emphasis is reflected
by the Agency's having established reduction of risk from
existing pesticides and toxic substances as its first priority
in 1987.
In the pesticides program in 1987, the emphasis on existing
chemicals will take several forms. Missing data for non-food
use pesticides will be called in, the call-in of chronic data
for food use chemicals having been completed. Final Registration
Standards and Tolerance Reassessments will be developed for some
-------
-3-
priority chemicals with completed data bases. Registration
Standards will be developed for some pesticides used as inert
ingredients. The sampling phase of the pesticides-in-groundwater
survey will continue and several special groundwater
studies will be initiated. Finally we will begin to review and
revise state restricted use applicator certification and training
plans to update them to agree with current requirements.
In the toxic substances programs, we will also address
existing chemical problems using a multi-statute approach
in which TSCA may be used to gather information, for action
under another agency statute, or to control the problem. We
will also expand the category approach to all aspects of the
program. We will place greater emphasis on using human exposure
as a basis for initiating existing chemical evaluations. The
unique features of TSCA will be used in special efforts aimed at
groundwater contamination and acute hazards.
We will also continue to emphasize toxic substances enforce-
ment case development work in the regions and compliance assistance
to the regulated communities in order to improve the efficacy of
TSCA regulations.
In both the pesticide and toxic substances programs, we
will continue to emphasize the need for integrity of laboratory
test data. The laboratory inspection program was strengthened
in 1986 by centralizing more functions in the National Enforcement
Investigation Center.
We will continue to ensure that the business of the Agency's
toxics and pesticides programs is openly, accurately and fairly
conducted. EPA will use the Communications Strategy Plan process,
coordinated by the Office of External Affairs, to inform the
public and effected groups of the regulatory decisions and actions
we take.
Changes from 1986
In both the pesticide and toxic substances programs the 1987
guidance is essentially the same as the 1986 guidance. Changes
reflect, principally, 1986 tasks that will have been completed
by 1987, and the natural movement toward "next steps."
-------
-4-
In the pesticides program, the principal changes include the
movement of the non-food use data call-in program in 1987 from
pilot to an operational program, initiation of a limited program
(in 1986 and 1987) to develop Final Regiatration Standards and
Tolerance Reassessments for pesticide chemicals with complete
data bases, evaluation of product chemistry data called-in in
1986, and the development of registration standards for at least
one pesticide used as an inert ingredient. We also have planned
a pesticides-in-groundwater survey since the 1986 guidance was
written and will complete a substantial proportion of the sampling
phase in 1987. Finally, we plan to review and revise State
restricted use pesticide applicator certification and training
plans in 1987 in order to update them with current requirements.
In the toxic substances program, the principal changes are
the greater use of TSCA to support cross media environmental
problems such as groundwater contamination and acute hazards,
expansion of the category approach and increased attention to
those chemicals for which there is evidence of high human exposure
-------
-5-
II. PESTICIDES 1987 GUIDANCE
In 1987, the-Pesticides Program will continue to emphasize the
review, through the Generic Chemical Review program, of existing
pesticides. Existing product registrations are largely supported
by incomplete data, or data which is inadequate by today's standards
By first obtaining needed high quality data and then evaluating
it and making necessary risk control decisions, public trust in
EPA pesticide oversight will be strengthened.
A. Program Goal; Protect Health and the Environment from Any
Unreasonable Adverse Effects from Pesticides Currently in Use.
The principal programs in this area are Data Call-in, Registration
Standards, and Special Reviews. The Data Call-in program, by
which existing pesticides data bases are updated to meet today's
standards, will shift in 1987 from calling in exposure data to
calling in data for non-food use pesticides and evaluating product
chemistry data called in in 1986. The 1987 program includes
continued development of Registration Standards, review of studies
submitted in response to data call-in and earlier registration
standards, and completion of at least one Final Regulatory Stand-
ard and Tolerance Reassessment (FRSTR). The 1987 program also
includes Special Reviews of the risks and benefits of pesticides
suspected of causing unreasonable adverse effects on human
health and the environment. The need for Special Reviews may be
identified during the establishment of a registration standard,
during review of data supporting applications for the registration
of new chemicals, during the revision of existing registrations,
or by referrals from other sources.
1. Program Objective; Continue the review of previously registered
chemicals currently being used.
a . Key Program Activities;
(1) By the end of 1986, the pesticides program will have completed
142 Registration Standards. In 1987, 25 additional Standards
will be established. (Fewer standards may be established if,
due to high exposure or indications of potentially unreason-
able risk, it is found necessary to increase the number of
Final Regulatory Standards and Tolerance Reassessments -
FRSTRs).
-------
-6-
Registration Standard reviews will continue to be conducted
on clusters of similar-use pesticides (e.g., insecticides,
herbicides, fungicides on given crops) in priority order of
their exposure and potential hazard. By the end of 1987,
registration standards will have been established for es-
sentially all chemicals in 9 of the top 10 clusters. (HQ)
(2) We will continue the program begun in 1986 to improve the
rate of compliance with registration standard data and
label requirements. (HQ)
(3) A Final Regulatory Standard and Tolerance Reassessment (FRSTR)
will be developed on at least one high priority chemical,
beginning in 1986 on a pilot basis and continuing in 1987.
FRSTRs are conducted on chemicals where the data base has
been completed, in response to Data Call-in and Registration
Standard requirements, and involve the comprehensive review
and updating of the regulatory position of the standard
and, in the case of food use pesticides, reassessment of
tolerances. (HQ)
(4) In 1986 we will evaluate a 1985 pilot project which required
registrants to identify and fill data gaps for non-food use
chemicals. Based on the evaluation, we plan to implement
the non-food use DCI program in 1987. (HQ)
(5) In in 1987, the product chemistry data called in during 1986
will be evaluated to develop an up-to-date data base
essential for determining inerts, impurities, and contami-
nants (e.g., dioxin and DDT) of toxicological concern in
pesticides. (HQ)
(6) Studies generated by Data Call-in and required by Registration
Standards will continue to be reviewed as received in 1987 if
they meet the criteria for early review:
— product chemistry and acute toxicity data necessary to
approve label changes
tiered test data
data flagged in accordance with flagging criteria im-
posed by EPA or submitted in accordance with the adverse
effects provision of FIFRA § 6(a)(2) which requires
registrants to report information indicating potential
adverse effects.
-------
-7-
— studies identified during the establishment of a standard
as critical to resolving a health or safety problem.
The Agency will rigorously enforce the 6{a)(2) provision. (HQ)
(7) The survey to sample pesticides in groundwater, designed in
1985 and begun in 1986, will continue in 1987. This statisti-
cally based, stratified survey for about four dozen pesticides
is being supported by both the Office of Pesticide Programs
and the Office of Drinking Water. (HQ)
(8) Work will continue in accordance with the National Pesti-
cide Monitoring Plan (NPMP) to further develop a national
information clearinghouse on peticide monitoring activities
and to provide guidance to the monitoring community on
priority pesticide monitoring needs.
The regions will conduct training programs for State
personnel as they develop the capability to address the
problems of groundwater contamination, especially recog-
nition and enforcement of use restrictions. Assistance
will also be provided to State lead agencies to educate
users on the proper handling of pesticides with ground-
water restrictions. The regions will also be involved in
studies of groundwater problems that are unique to a parti-
cular geographic area. (RGNS)
2. Program Objective; Restrict or ban the use of pesticides
posing unreasonable adverse effects to human health and
the environment.
In approximately 25% of the Registration Standards estab-
lished to date, health problems have been identified
requiring the comprehensive evaluation of pesticide
risks and benefits through the Special Review process.
Candidates for Special Review are also identified in the
course of reviewing data supporting applications for the
registration of new chemicals or for the revision of
existing registrations, or by referrals from other
sources.
-------
-8-
a . Key Program Activities
(1) Special Reviews initiated in 1987 will continue to employ
revised risk criteria that more realistically reflect
actual exposure and hazard. Opportunity will be available
for public participation in the evaluation process.
Formal hearings are expected to be required on proposed
Agency cancellation/suspension actions on suspect chemicals
The regions and state programs will give extra attention
to enforcing stop sale orders on cancellation/suspension
actions. (HQ)
(2) Where feasible, alternatives to cancellation for mitigating
unreasonable risk will be pursued, such as modifications
to the terms and conditions of use, and improved pesticide
labeling (e.g., requirements for protective clothing and
equipment, reentry intervals, warnings, directions for
emergency treatment, etc.) to reduce risk. The Agency
will also promote use of closed-system containers, child-
proof packaging, and safe container disposal practices,
and will continue to refine disposal instructions for
pesticides, pesticide containers and rinsates, working
closely with the hazardous waste program. (HQ)
(3) Tolerances for cancelled pesticides will be revoked and
replaced with appropriate action levels where necessary.
This is a continuation of a process which started in
1985. (HQ)
(4) The Special Review process will continue to focus on
review of clusters of similar use pesticides such as wood
preservatives, termiticides, and grain fumigants, when
appropriate. We will also begin to examine the problem of
stimulating industry innovation in high-risk classes such
as fungicides. (HQ)
(5) The program will cooperate closely with the Toxic
Substances program on high priority chemicals where TSCA
data may be available or TSCA data gathering authorities
-------
-9-
raay be useful. We will also continue a pilot program,
begun in 1986, to broaden registration standards for
active ingredients, which are also used as inerts, to
consider exposure due to inert uses. (HQ)
3. Program Objective; Reduce the incidence of pesticide misuse
a. Key Program Activities:
(1) Encourage the States, which are the primary operating
arm of the national pesticides compliance monitoring
effort, to increase the level of State pesticide use
inspections conducted under Federal/State cooperative
enforcement agreements, particularly with regard to
groundwater contamination, chemigation, aerial drift,
the proper use of restricted use pesticides such as
wood preservatives and 1080 collars, enforcement
against the use of cancelled or suspended products,
and misuse of registered products. Annual guidance will
be developed which will indicate priorities for the
cooperative agreement program. Commitments to be in-
cluded in the cooperative agreements will be negotiated
by the Regions and States with the States using the
formal priority-setting mechanism to establish priorities
within their own programs. EPA will also request in-
formation from the States on their State enforcement
response policies (HQ/RGNS)
(2) State applicator certification and training programs
will be strengthened through the review and revision
of State applicator certification and training plans
to update them to agree with current (or new) require-
ments and to make them consistent from state to state.
We will also continue to develop and implement new or
revised training materials and programs, especially in
specific areas where such training materials do not
exist or are inadequate, such as wood preservatives,
fumigants and groundwater. (HQ/RGNS)
-------
-IO-
CS) Federal oversight will be maintained in all cases to
assure nationwide consistency in the pesticides compliance
monitoring program and that timely and appropriate en-
forcement action is taken. (RGNS)
(4) The Agency will operate Federal compliance monitoring
and enforcement or certification and training programs
in instances where States are unwilling or unable to
conduct their own programs. (RGNS)
(5) Federal case development support will be maintained for
referrals of State enforcement actions and in EPA-
operated maintenance programs. (RGNS)
(6) The Agency seeks to integrate criminal enforcement into
the overall compliance monitoring/enforcement programs.
Accordingly, regions should identify and refer to the
Office of Criminal Investigation (OCI), cases or
incidents that concern knowing/willful violations
resulting in human death or major environmental harm,
that involve egregious repeat offenders, or that
involve data fraud or pesticide misuse. These cases
are further limited to those which occur in States
for which EPA has primary enforcement responsibility,
or which are referrals from States. Activities to
integrate the programs should include cross-referrals
within the Regions between OCI and the program
office. The regions will also provide technical
and program support to criminal investigations and
prosecutions, as necessary. (RGNS)
(7) Revisions to the FIFRA and TSCA Enforcement System
(FATES) which contains all enforcement data, will be
continued, withinput from the Regions, to increase
its efficiency and usefulness. (HQ/RGNS)
-------
-11-
(8) Small business outreach efforts will be developed in
the area of compliance with FIFRA. (HQ)
(9) We will begin to examine administrative and statutory
alternatives to strengthen the compliance program.
(HQ/RGNS)
(10) We will develop cooperative enforcement and certification
and training programs with Indian Tribes to address
problems of pesticide use and misuse. (HQ/RGNS)
(11) EPA will maintain compliance monitoring programs at
Federal facilities. (HQ/RGNS)
4. Program Objective; Conduct research and develop methodologies
to support existing pesticide risk reduction efforts.
a . Key Program Activities:
(1) The research program will emphasize the development
of methodologies and techniques needed to evaluate
health and environmental risks associated with
existing pesticides. These important tools are
critical to both the testing and regulation of
existing pesticides. (HQ)
(2) Models for evaluating environmental concentrations
of pesticides and for determining health risks will
continue to be developed and validated. Hazard
assessment methodologies which are critical in risk
analysis of chemicals will also be developed. (HQ)
B. Program Goal; Prevent Unreasonable Risks Prom New Pesticide
Active Ingredients And Products And Encourage Use Of Safer
Products (New Or Old).
The Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA) and the Federal Food, Drug, and Cosmetic Act (FFDCA)
provide for Agency control of the terms and conditions
-------
-12-
under which new pesticides may be legally used in the
United States, through pre-market reviews of their potential
human and environmental effects. Registrations permit
pesticide use under specific limitations, and Tolerances
specify maximuim pesticide residues permitted on food and
feed products. Exceptions may be made to registration
requirements under the Special Registration program which
provides for unregistered uses for experimental purposes or
in emergency situations, and for registrations by the
States for special local needs.
1. Program Objective; Provide careful review to assure that new
pesticides do not add unreasonably to total risk.
a. Key Program Activities;
(1) The program will continue to be alert for applications
for new chemical or new use registrations which indicate
a possible need for intensive risk/benefit analysis.
Agency forums such as the Scientific Advisory Panel will
be used to review difficult science issues. (HQ)
(2) Current monitoring efforts will be redirected to focus
more effectively on special problems such as groundwater
contamination, and guidance for monitoring, predicting,
and preventing pesticide contamination of groundwater will
be provided to registrants. (HQ)
(3) Methodologies for assessing risks posed by new products
of biotechnology will continue to be refined in 1987. (HQ)
(4) Problems of pesticide application such as aerial spray
drift and chemigation will be assessed and appropriate
regulatory action taken. (HQ)
(5) The safety of farm workers and families will continue to
be promoted. Revised Worker Protection Standards to
encourage safe pesticide use practices will be the subject
of regulatory negotiation and will be proposed in 1986;
a final rule will be published in 1987. (HQ)
-------
-13-
(6) In support of the Agency's goal of pesticide safety, the
program will undertake to expedite the availability of
fundamentally new products to displace riskier, older
products. (HQ)
(7) Integrated Pest Management (IPM) technology will be en-
couraged, and where appropriate, IPM alternatives will be
considered in risk/benefit decisionmaking. (HQ)
(8) Improvements in information management and automation
support will continue in 1987, with the goal of supporting
pesticide program decisionmaking with rapid and compre-
hensive access to relevant information, and more efficient
processes for creating, storing, using and updating
important regulatory decisions and supporting technical
assessments. Changes to data base systems and content will
address regional as well as headquarters needs. These
improvements will also provide the public with more
meaningful information on the properties and effects of
pesticides. (HQ)
(9) Internationally consistent pesticide tolerances, and
greater efficiency in the use of resources expended in
tolerance-setting will be sought through the Codex
Alimentarius program of the U.N. World Health Organi-
zation. (HQ)
(10) New approaches to the protection of endangered species
and other wildlife from pesticide hazards will be de-
veloped. One approach under consideration would rely
on generic labeling and the use of bulletins distributed
by field operations of USDA and Interior Department
agencies. The bulletins would provide detailed in-
struction on the conditions under which pesticides are
prohibited as a result of concern for endangered
species. The pesticide program will also continue to
work to develop requirements for ecological monitoring
by registrants. (HQ)
-------
-14-
(11) Experimental use permits, emergency exemptions and special
local need registrations issued under Sections 5, 18 and
24(c) of FIFRA respectively, will be monitored to prevent
unwarranted circumvention of Section 3 registration
requirements. (HQ/RGNS)
2. Program Objective: Insure the integrity of data submitted to
EPA .
a. Key Program Activities;
(1) The Agency will perform both full-scale audits of a sample
of completed test studies that have been submitted to EPA
and in-process audits of studies being conducted. (HQ)
(2) Ensuring compliance with Good Laboratory Practice (GLP)
requirements is a high priority for the Agency. In
cooperation with FDA, Regions II, III and V will perform
GLP inspections at at testing facilities. Headquarters
(NEIC) will perform GLP inspections in other regions.
(HQ/RGNS)
(3) We will implement the mandatory Agency-wide Quality
Assurance (QA) program which ensures that all envrion-
mental measurements are of known and documented quality
and meet the requirements established by the responsi-
ble office or laboratory. Each program office, region,
and EPA laboratory must maintain QA programs consisting
of a QA program plan and appropriate updates, Data
Quality Objectives (DQO's) for specific environmental
data-generative activities, and QA Project Plans for
all monitoring projects; and must provide for periodic
audits to assess compliance with approved QA plans.
-------
-15-
III. TOXIC SUBSTANCES 1987 GUIDANCE
The 1987 Toxic Substances program will continue the
emphasis on assessment and control of existing chemical problems.
While progress is being made in reducing risks from existing
chemicals, it is still clear we must continue to seek new ways
to improve the effectiveness of the existing chemicals program.
The emphasis we are placing on existing chemicals does not
minimize the importance of TSCA's new chemical programs. We
will continue to meet the demands placed on us by industry's
introduction of new chemical products and to deal with the
emerging new chemical programs such as biotechnology.
A. PROGRAM GOAL; Reduce Significant Risks from Existing
Chemicals.
(NOTE: Because of the complexity and public interest in
the asbestos problem, we have established a. program goal
for asbestos, separate from the existing chemical program
goa Is . )
The 1987 program continues the emphasis on the category
approach to existing chemical evaluation and management. We
will also place greater emphasis on using broad-based exposure
for determining program priorities. The Agency will address
existing chemical problems using a multi-statute approach for
which TSCA may be the key information gathering and analysis
tool. Under this approach, we anticipate that TSCA information
gathering features will be called upon increasingly, especially
for special efforts such as groundwater and air toxics.
1. Program Objective: Identify and evaluate the potential
risks of suspect existing chemicals.
(1) In 1987 we will continue our efforts to evaluate
chemical categories and begin to develop category
chemical testing and chemical control rules. When
taking action on a new chemical, we will also consider
the need to take some action on existing chemicals in
the same structural category. (HQ)
-------
-16-
(2) The National Human Monitoring Program (NHMP) will be
continued with emphasis on the identification of
chemicals which are found in human tissue and fluids
and thus are direct evidence of broad human exposure.
NHMP data will be used to identify candidates for
Section 4 test rules, to develop baseline/trend data
necessary to support regional and State evaluation of
local concerns, to set priorities for existing chemicals
which warrent regulation under Section 6 of TSCA or
other statutes, and to monitor environmental results.
We will continue efforts to make this data available
to other EPA headquarters and regional offices. (HQ/RG)
(3) Section 8(a) and Section 21 will continue to be used
as important chemical screening tools that allow
public input to our risk identification process;
Section 8(a), 8(c), and 8(d) will continue to be used
to obtain current production, use and hazard data on
chemicals that are under review. We will continue
efforts to finalize the Section 8(a) Comprehensive
Assessment Information Rule that will facilitate
information gathering for all Agency programs. (HQ).
Program Objective: Initiate and promulgate regulatory
actions under TSCA to reduce risks to human health and the
environment'from existing chemicals.
Key Program Activities;
(1) The Agency will address existing chemical problems
using a multi-statute approach. We will continue
to use Section 6 and 9 authorities to deal with
existing chemical problems when they are the most
effective authority to deal with the problem.
Section 9 of TSCA will be used to refer chemical
problems to other regulatory authorities. Section
6 will be used where other agency statutes and
other EPA statutes do not provide appropriate
risk management options. (HQ)
-------
-17-
(2) The significant new use provisions of Section 5
will be used to track the future commercial develop-
ment of suspect existing chemicals that, based on
current production and use information, do not
present an unreasonable risk to society. (HQ)
3. Program Objective; Utilize TSCA's unique features to
approach cross-media problems in an integrated manner.
(1) In 1987, we will continue to place a strong emphasis
on working jointly with other program offices and
other agencies to develop and implement coordinated
regulatory and enforcement strategies on priority
cross-media chemical problems. (HQ/RGNS)
(2) We will continue to educate other EPA offices as to
the features of TSCA that permit cross-media integrated
approaches to problems. (HQ)
(3) Work will continue at the headquarters, regional, and
state level to exchange TSCA information on risk
assessment and regulatory activities. (HQ/RGNS)
(4) We will continue to refine and update the acutely toxic
chemical list and chemical profiles. Changes to
criteria for including chemicals on the list will be
considered and studies may be undertaken of means to
improve plant safety. (HQ)
The Regions will serve as contact points for questions
from the public, States and communities about the
chemical list and profiles. (RGNS)
(5) We will support the groundwater initiatives through
the use of available screening tools (e.g., DRASTIC
Index, exposure assessment models) to predict areas
which are vulnerable to groundwater contamination. We
will also use these tools to establish data collection
priorities for areas most likely to be contaminated.
The information collection provisions of TSCA may be
used to obtain data on groundwater contamination by
volatile organic chemicals (VOC's), fertilizers, and
waste discharged from septic tanks. (HQ)
-------
-18-
4. Program Objective; Conduct research and develop methodologies
to support existing chemicals risk reduction efforts.
Key Program Activities;
(1) The research program will emphasize the development
of methodologies and techniques needed to evaluate
health and environmental risks associated with existing
chemicals. These important tools are critical to
both the testing and regulation of existing chemicals.
(HQ)
(2) Short-term testing will be conducted to fill critical
data gaps for regulatory decision-making on important
chemical classes. (HQ)
(3) We will continue to develop assessment methodologies
based upon structural characteristics and physical-
chemical properties. These will be used to screen
classes or categories of both new and existing chemicals
for potential risks and to prioritize chemicals within
a category. (HQ)
(4) Models for evaluating environmental concentrations of
chemicals and for determining health risks are being
developed and validated. We will continue to develop
models to define exposure pathways for toxic chemicals
along with methods to extrapolate data from animals
to humans; and models and methodologies for predicting
quantitatively the toxic activity of chemicals. (HQ)
(5) Finally, data and models will be developed to predict
the release of and exposure to new and existing chemicals
via research in environmental engineering and technology.
(HQ)
-------
-19-
Program obj ective: Continue to strengthen State capacity
to deal with existing chemical programs.
a . Key Program Activities:
(1) The revised 1986 resource and activity level for the
State cooperative agreement program will be continued
in 1987. (HQ/RGNS)
(2) Confidential business information concerns preclude
the States from participating in the enforcement of
certain sections of TSCA. Thusr the States will
continue to limit their responsibility to conducting
compliance monitoring programs for TSCA Sections 6
only. (RGNS)
(3) The Office of Enforcement and Compliance Monitoring
will support OPTS efforts to strengthen State part-
icipation in existing chemical programs by reviewing
current State toxic substances laws and developing
model State legislation. (HQ)
Program Obj ec tive; Improve compliance with all toxic
substances regulations.
a. Key Program Activities;
(1) Because of confidential business information concerns
the Agency will continue to have the responsibility
to conduct Federal compliance monitoring programs
for TSCA sections 5, 8, 12, and 13. (RGNS)
(2) Hazard assessment and information collection in-
spections under TSCA section 5 and 8 will be
conducted by regions II, III, V, and headquarters
(NEIC) for other regions. (HQ/RGNS)
-------
-20-
(3) EPA will continue to provide Federal case development
support for all enforcement actions, including those
resulting from State inspection activity (until the
enactment of state laws). Enforcement and litigation
priorities will include laboratory data cases, PMN
cases, and PCB disposal. In cases involving settlement
with conditions, the regions will insure the conditions
are met. (RGNS)
(4) The Agency seeks to integrate criminal enforcement into
the overall compliance monitoring/enforcement programs.
Accordingly, Regions should identify and refer to the
Office of Criminal Investigation (OCI) cases or incidents
that concern knowing/willful violations resulting in
human death or major environmental harm, that involve
egregious repeat offenders, or that involve data fraud.
Activities to integrate the programs should include
cross-referrals within the Regions between OCI and the
program office. The Regions will also provide technical
and program support to criminal investigations and
prosecutions, as necessary. (HQ/RGNS)
(5) Compliance assistance will receive continued attention
in 1987., Compliance assistance involves alerting the
regulated community of EPA regulatory actions, and
providing advice and direct assistance to industry
in its efforts to comply with TSCA rules. These
tasks are particularly important between the time
EPA issues a proposed or final rule and the time
a final rule becomes effective and enforceable.
Outreach and interaction before EPA begins
compliance monitoring for a new rule will increase
the capacity of industry to comply and result in
more effective use of EPA compliance monitoring
resources. (RGNS)
(6) The regions will continue to be involved in the multi-
media effort to implement the national air toxic
strategy. They will continue educating the public as
to the purpose and contents of the list of acutely
toxic chemicals and the potential problems and remedies
They will also work with state and local governments
as they develop contingency plans and the ability to
address potential problems. (RGNS)
-------
-21-
(7) The Agency, with input from the Regions, wil continue
to revise the FIFRA and TSCA Enforcement System (FATES)
to increase its efficiency and usefulness. (HQ)
(8) EPA will continue to send draft compliance strategies
to the Regional Offices and, as necessary, to the
States, for comment before publication. (HQ/RGNS)
(9) We will continue to emphasize small business
compliance issues in developing TSCA compliance
monitoring strategies. (HQ)
(10) EPA will conduct compliance monitoring programs at
Federal facilities. (HQ/RGNS)
B. PROGRAM GOAL: Address Hazards from Asbestos
1. Program Obj ective; Strengthen the asbestos-in-schooIs
and public and commercial buildings program.
a. Key Program Activities:
(1) Technical assistance activities will be continued.
Activities include (1) operation of the toll-free
number, (2) guidance to school officials and public
and commercial building owners and managers, and (3)
dissemination of information materials. The role of
the regional asbestos coordinators will continue as
an integral element of the technical assistance program
as they provide assistance on both abatement and
compliance issues. (HQ/RGNS)
(2) Three regional pilot information centers were established
in 1985 to provide information concerning the identifi-
cation and abatement of asbestos hazards and to educate
-------
-22-
and train people in proper asbestos identification
and abatement techniques. Three additional centers
may be opened in 1986 or 1987. (HQ/RGNS)
(3) The state contractor and consultant and certification
program will be expanded from 28 states expected at
the end of 1986 to 36 in 1987. These programs help
ensure adequate training and certification of contrac-
tors involved in abatement projects. (HQ/RGNS)
(4) Compliance with the worker protection rule for public
employees not covered by the current OSHA rule will
be a major priority in 1987 for both the regions and
the contractor. We also anticipate that inspection
activities will be directed toward compliance with
the contractor certification requirements imposed by
Congress through the ASHAA program, asbestos abatement
worker training rules to be proposed by OSHA and EPA,
and a possible rule requiring the reinspection of
schools for asbestos. Wherever TSCA enforcement coop-
erative agreements are in place the States will conduct
compliance monitoring inspections in support of the
asbestos worker protection rule. (RGNS)
(5) The Agency will move toward promulgation of the Section
6 rule to ban certain asbestos products and to phase
out the use of asbestos in all other products. (HQ)
(6) We will continue to refine guidelines to assist the
public in identifying those situations in which asbestos
containing materials present a serious risk. (HQ)
(7) Field studies to examine the efficacy of various
asbestos abatement technologies, and the feasibility
of air monitoring before, during, and after abatement
will continue in 1987. Because of the insidious
environmental characteristics of asbestos, control
technologies must be thoroughly investigated prior to
public recommendation or endorsement by EPA. (HQ)
-------
-23-
(8) In 1986, we intend to develop a case study of an
exemplary private asbestos abatement effort; the study
will be disseminated in 1987. We will also conduct a
survey of the manner in which public building owners,
in general, are addressing asbestos problems. This
will help us tailor our technical assistance programs.
(HQ)
C. PROGRAM GOAL; Prevent Risks From New Chemical Substances
And Significant New Uses Of Existing Chemical Substances
In 1987, our emphasis in the new chemicals program will be
on continuing to operate a careful but efficient premanufacture
review program that is responsive to the workload demands
generated by industry's submission of notices. There will
be increased attention to close coordination of reviews and
actions with other programs to ensure that decisions are
consistent across the Agency and that future environmental
problems (e.g., air, water, or disposal) are effectively pre-
vented. Close coordination with the existing chemical program
will be an integral part of all new chemical decisions.
Program Objective; Subject all new chemicals to a meaningful
review, taking action on those that pose an unreasonable
r isk .
a . Key Program Activities;
(1) EPA will conduct reviews on all new chemical notices
within the respective statutory deadline, including
any notices for biotechnology products that fall
under TSCA's purview. The emphasis in these reviews
is on early identification of data gaps and concerns
so that resources can be directed toward the review
of the most hazardous new chemicals. (HQ)
(2) We will take action on new chemicals which present
unreasonable risks. The provisions of Section 5(e)
will be used to induce data development and, when
-------
-24-
necessary, to control exposure. Section 5(f) will be
used when it is necessary to control those chemicals
that pose an unreasonable risk. (HQ)
(3) Close coordination with other EPA programs will be a
priority, particularly to prevent groundwater problems
and to identify new chemicals that meet the Agency's
acute hazards criteria.
(4) A scientific study to determine the effectiveness of
structure activity relationship (SAR) as a hazard
indicator will be continued. The SAR technique is
used in the majority of PMN reviews. The study will
select a sample of past new chemical decisions using
SAR; test those chemicals; and determine if the decision
would be the same if actual data had been used instead
of the SAR technique. (HQ)
2. Program Objective; Protect society against risks which may
develop as new chemicals are commercialized.
a . Key Program Activities:
(1) EPA will continue to issue chemical-specific significant
new use rules, when warranted, to require notification
of EPA if the chemical is to be used in a different
manner than described in the PMN. (HQ)
(2) We will pursue development of more efficient regulatory
approaches, including category rules, to the follow-up
of new chemicals. (HQ)
Program Objective: Insure integrity of data submitted to
FPA.
a. Key Program Activities;
(1) We will perform full-scale audits of completed test
studies that have been submitted to the Agency and
in-process audits that are being conducted. (HQ)
-------
-25-
(2) Ensuring compliance with Good Laboratory Practices
(GLP) requirements is a high priority for the Agency.
In coordination with FDA, Regions II, III, and V will
perform (GLP) inspections at testing facilities.
Headquarters (NEIC) will perform inspections in other
regions. (HQ/RGNS)
(3) We will implement the mandatory Agency-Wide Quality
Assurance (QA) program which ensures that all environ-
mental measurements are of known and documented quality
and meet the requirements established by the responsible
office or laboratory. Each program office, region,
and EPA laboratory must mtainin QA programs consisting
of a QA program plan and appropriate updates, Data
Quality Objectives (DQO's) for specific environmental
data-generative activities, and QA Project Plans for
all monitoring projects; and must provide for periodic
audits to assess compliance with approved QA plans.
(HQ/RGNS)
-------
Office of
External Affairs
Q)
-------
OFFICE OF EXTFPNAL AFFAIRS
T. INTRODUCTION
The Office of External Affairs (OEA) was established with the
very clear mandate to provide the Agency with the expertise
necessary to inform the American public, the Congress, the media
and the regulated community on the issues we address and the
decisions we make. Only by ensuring that the business of the
Agency is openly, accurately and fairly conducted, can the trust
and integrity of EPA be established in the minds of the public.
OEA communicates with external groups using a comprehensive and
coordinated process. The key element of this process is an
Agency document which outlines EPA's communications strategy - a
Communications Strategy Plan. OEA, affected programs, regional
components, and the Administrator's staff establish the frame-
work for announcement of a given agency action through the
Communications Strategy Plan.
Regions will continue to inform the public through active
participation in the Communications Strategy Process and through
their own outreach efforts.
Within the Office of External Affairs (OEA), the Office of
Federal Activities (OFA) is responsible for establishing effective
liaison and coordination between EPA and other Federal agencies
on environmental issues and for working with those agencies to
assure that they carry out their activities in an environmentally
sound manner; for assuring that EPA's programs comply with the
goals and requirements of the National Environmental Policy Act
(NEPA) and related environmental legislation; for administering
EPA's program under section 404 of the Clean Water Act; and
coordinating the implementation of EPA's Indian Policy of
November 8, 1984.
This guidance presents national goals and objectives for
the Federal Activities Programs for FY 1987-88. The guidance
also identifies the actions that EPA and, where appropriate,
States must take to implement these goals and objectives. The
guidance consists of three parts. The first part (I) provides
an overview of Federal Activities Programs, summarizes the five
major goals which shape the five major programs, and highlights
major changes in emphasis or direction. The second part (II)
describes program objectives for each goal/program and lists the
specific actions that must be taken to carry out the national
strategy. This part also identifies general priorities/
directions for FY 1988 which will be used in the formulation of
national program strategies and budget requests. The third part
(Appendix) details the specific performance measures that will be
used in tracking our success in addressing FY 87 objectives.
-------
-2-
A. Overview
In addition to Agency responsibility for communications activities,
OEA administers five national programs which contribute toward
accomplishment of the fundamental EPA mission and its major
goals:
1. Federal Facilities Compliance Program. Goal: Ensure
the Federal Government shows leadership in environmental
control practices through Federal facility compliance with
air, water, toxic, and hazardous waste requirements.
2. Environmental Review Program. Goal: Prevent future
environmental problems from major Federal projects and
activities by providing effective EPA input through par-
ticipation and review in accordance with the provisions of
section 309 of the Clean Air Act and of the National
Environmental Policy Act (NEPA).
3. Dredge and Fill Program. Goal: Reduce the loss or
degradation of wetlands through vigorous implementation of
EPA authorities under section 404 of the Clean Water Act.
4. NEPA Compliance Program. Goal: Protect and enhance
environmental quality through ensuring EPA compliance with the
goals and/or requirements of the National Environmental
Policy Act (NEPA) and related laws and directives.
5. Indian Program. Goal: Ensure environmental protection
on American Indian reservations through implementation of
EPA's authorities and programs.
Each of the OFA programs managed by OFA, supports more than one
of the points in the Administrator's Management Plan. Because
of their multimedia and crosscutting nature, these programs are
implemented in close coordination with the media programs at
both Headquarters and Regional levels, and help address many of
the subjects on the FY 1987 Agency Priority List.
Collectively, these programs cut across all environmental media
and consider a broad range of impacts on environmental values
and natural resources, as well as public health. In this regard,
OFA's program goals and objectives serve both as independent
goals for focusing Federal Activities resources and as key
elements in supporting the goals of the major media programs.
For example, the Federal Facilities Compliance and Indian
Programs both address such Agency priorities as compliance with
air quality standards, groundwater protection, and hazardous
waste site clean-up, where these are significant issues with
respect to Federal Facilities or Indian lands. For these two
programs, most of the resources and implementation responsibilities
are in the media programs, with Federal Activities personnel
playing a key coordinating and catalytic role.
-------
-3-
Federal Activities functions also serve as EPA's primary focal
point for working with other Federal agencies to ensure that they
carry out their project-related activities in an environmentally
sound manner. The Environmental Review Program provides EPA with
a unique opportunity to anticipate and prevent future environmental
problems associated with Federal actions, by affording the opportunity
to influence decisions, often where it is too early in the planning
cycle for direct application of EPA regulatory authorities.
EPA's NEPA Compliance Program plays a similar role internally by
encouraging consideration of the full range of environmental
impacts in EPA's project and regulatory planning. By focusing on
the full range of potential environmental impacts in evaluating
Agency actions, such as the award of sewage treatment construction
grants and issuance of new source NPDFS permits, EPA can assure
that environmental effects can be identified and minimized.
The Federal Activities programs serve a key role in reducing
damage to sensitive environmental areas. This is achieved not
only through direct program responsibilities for wetlands protection
under section 404 of the Clean Water Act, but also in helping to
protect other sensitive areas like near coastal waters through
other programmatic responsibilities, particularly the Environmental
Review and NEPA Compliance programs.
B. Changes in Program Direction
With the exception of NEPA Compliance, which has been modified to
reflect the current status of Clean Water Act reauthorization and
the Construction Grants Program, the FY 19P7 Guidance represents
no major change in direction from the current Guidance. Rather,
the new Guidance reflects incremental changes in emphasis or
approach which track the continuing evolution of these programs.
With regard to the measures and commitments, changes have been
made to clarify and simplify the process, reflecting two years
experience with reporting measures and one cycle of commitment
negotiation.
C. Supplemental Guidance
OFA plans to issue no comprehensive supplemental guidance in FY
K7. Program-specific supplemental guidance, where planned, is
listed in the appendix. All significant supplemental program
guidance is issued as part of the OFA Policy and Procedures Manual.
II. GUIDANCE
1. MAJOR PROGRAM GOAL: FNSURF THE FEDERAL GOVERNMENT
DEMONSTRATES LEADERSHIP IN ENVIRONMENTAL CONTROL
PRACTICES THROUGH FEDERAL FACILITY COMPLIANCE WITH
AIR, WATER, TOXIC AND HAZARDOUS WASTE REQUIREMENTS.
-------
-4-
FY 1Q87 Guidance
a. The Federal Facilities Compliance Program is designed to
bring Federal facilities into compliance with environmental
laws and regulations in the most cost-effective and
timely manner possible. During FY 1986 the framework for
a strengthened program to return Federal facilities to
compliance and prevent future non-compliance was further
developed and implemented. This was done, in part, in
response to the Administrator's call to make Federal
facilities "a model for compliance". Key actions include:
efforts to obtain accurate data on the compliance status
of Federal facilities to aid in targeting corrective
programs; improved Federal and State procedures for
resolution of compliance problems; strengthened State
participation in review of agency pollution control
plans under OMB Circular A-106; strengthened communication
and technical assistance to Federal agencies; and assistance
in development of Federal agency environmental auditing
programs.
Of particular significance is development of two impor-
tant guidance documents relating to Federal facilities
compliance. The first is revision of the Federal Facilities
Compliance Strategy ("the Yellow Rook") in conjunction
with OECM, the media programs and EPA Regions. The
second is the Joint OFA/OSWER Strategy for Federal
CERCLA Problems which will clarify interactions between
FPA and other Federal agencies and accelerate attention
to this issue. £/ Many of these efforts will continue in
FY 1987. In addition, reauthorization of RCRA has
established numerous new requirements which call for an
expanded Federal Facilities Compliance effort. OFA will
continue to work with OECM and the Media Enforcement
Offices to improve the existing Compliance Agreement
Process.
During FY 1986, OFA is working with the OECM Steering
Committee on the State-Federal Enforcement Relationship
to clarify guidance on the State role in assuring Federal
compliance; this will be reflected in the revised Federal
Facilities Compliance Strategy.
In managing the Federal Facilities Compliance Program, OFA
and the Regional Federal Facilities Coordinators will work
closely with the media program offices. A major OFA program
objective is to assure that the program priorities and
objectives established by the various media programs are
met by Federal facilities.
2_/ Note: Although this document has been completed, its imple-
mentation/modification must await clarification of changes in
Federal facilities requirements in the pending Superfund
reauthori zation.
-------
-5-
During FY 86 and FY 87, OFA will be working with certain
Headquarters compliance program offices on selected special
initiatives to help improve the overall quality of the
Federal facilities compliance program and increase
compliance rates among Federal facilities. Resource
limitations may preclude some Regions from fully addres-
sing all the key program activities in this guidance.
Where that is the case and it becomes necessary to
establish priorities for regional effort, Regions should
be guided by two principles. First, it is critical to
the integrity of the FFC Program that all of the key
program activities, be addressed even if less than
fully. Second, Regions should determine relative prior-
ities for emphasis within these key program activities
based upon: (1) the FY 1987 Agency Priority List; and (2)
the relative contributions of the regional media program
units to the objectives of the Federal Facilities Compliance
Program.
b. Key Program Activities
(1) Increase technical assistance to Federal facilities.
Executive Order 12088 requires EPA to provide "technical
assistance and advice" to other Federal agencies "in
order to ensure their cost-effective and timely compli-
ance" with environmental laws. Because of inherent
delays in the Federal program and budgeting system,
installation managers must quickly plan for new environ-
mental controls, or they will be unable to budget,
design and contract facilities rapidly enough to get
into compliance. Because of CERCLA policies and the
many new requirements established by the RCRA
reauthorization, requests for assistance will increase
greatly. Special seminars and workshops should be
planned for Federal Facility Environmental personnel in
FY 87 to transmit such information. At least one multimedia
workshop should be held for Federal facility environmental
personnel in each Region. In addition, Federal Facility
Coordinators should hold periodic (monthly/bi-monthly)
meetings with Federal Agency Regional Environmental
personnel to disseminate information on new developments
and regulatory requirements. In FY 87 EPA personnel
must become more familiar with the significant Federal
facilities in their Region in order to provide advice
and guidance. Federal Facility Coordinators accompanied
by appropriate media program personnel should make
periodic coordination visits to significant Federal
facilities to provide program assistance. OFA will
develop a consolidated multimedia training manual for
dissemination to Federal facilities in each Region.
(2) Increase the quantity and quality of inspections
at Federal facilities. Federal Facility Coordinators
-------
-6-
are responsible for coordinating a comprehensive Regional
Federal Facility Inspection Program. Compliance inspections
at Federal facilities are the responsibility of the
media program offices and are conducted by regional
media and State personnel. Federal Facility Coordinators
must meet with the media program offices at the beginning
of each fiscal year to review Region and State inspection
plans to ensure Federal facilities are being inspected
according to required program frequencies. Effective
compliance monitoring systems are an essential first
element in improving Federal facilities compliance.
Compliance status will be verified regularly by on-site
inspections and/or reviews of self-monitoring reports.
Results of inspections conducted by EPA or State agencies
must be provided to the Regional Federal Facility Coordinator
in a timely manner through negotiation with each State in
the enforcement agreements.
In FY 87, emphasis will be placed on obtaining valid
compliance data nationally at a statistically signifi-
cant number of facilities belonging to each Federal
agency. With better information on patterns of compli-
ance, future inspection programs at Federal facilities
can be better focused and more productive. More specific
guidance on this subject will be furnished at a later date.
Federal Facility Coordinators should work with program
offices to ensure that all major Federal facilities are
receiving the required EPA or State annual inspection.
Inspections will be performed at major sources of pollu-
tants at least once a year. Significant minor sources*
should be monitored through inspections, at least once
every two years. (The 1984 RCRA Amendments require
Annual inspections for all Federal Treatment, Storage
Disposal (TSD) f aci 1 i t i e~sT. Other sources will be
monitored through the review of self-monitoring
reports and through inspections when a violation is
suspected. In FY 87, Regional Federal Facility Coor-
dinators in cooperation with each pogram office, will
review media program lists of majors and minors to
ensure that all Federal facilities are properly
classified. (PCB compliance monitoring inspections
will be conducted as necessary to monitor compliance
schedules described in Federal facility compliance
agreements and to otherwise address PCB compliance
within the Federal sector). Sufficient inspections of
minor facilities will be conducted to provide the com-
pliance picture at individual Federal agencies described
above. Whenever possible, inspections will be multimedia
* Significant minor Federal facilities do not meet criteria as major,
but are designated by their Regional Federal facilities coordinator
(working cooperatively with media program representatives) because
the facility has unique characteristics and/or it produces parti-
cularly hazardous pollutants, and/or it has chronic compliance
problems. Limited to no more than 10% of minor facilities.
-------
-7-
in nature since these can be both more effective and
more efficient uses of EPA resources. In FY 87
Federal Facility Coordinators will develop a named
list of up to 10 Federal facilities per Region (based
upon size, complexity or unique environmental problems)
as candidates to receive multi-media inspections. In
delegated States, Federal Facility Coordinators will
work with program offices to ensure they receive
the same percentage of oversight inspections for
Federal facilities as is done for other sources.
To the extent possible Federal Facility Coordinators
are encouraged to accompany program office inspectors
on oversight inspections.
(3) Improve State/Federal relationships as they impact
on Federal facility compliance. Executive Order 12088
requires, with the exception of National Interest waivers,
that Federal facilities comply with all Federal, State
and local pollution control laws. EPA is responsible
for acting as liaison between Federal agencies and State
and local governments to ensure that Federal facilities
act in good faith to resolve compliance issues promptly.
In FY 87, EPA will take a number of specific actions to
improve the role of the States in the Federal facility
compliance process.
States should be encouraged to designate counterparts
to the Federal Facilities Coordinator as part of a joint
effort to improve compliance. In FY 1987 an effort
should be made in State/EPA Enforcement agreements to
request States to identify these counterparts where
mutually agreeable between the Regions and the States.
In addition, FPA must initiate actions through the
State/EPA agreement to ensure that States: (1) inspect
Federal facilities in accordance with this guidance,
and (2) report the results of their inspection and
enforcement actions to EPA in an accurate and timely
manner as agreed to in the enforcement agreements between
Regions and each of their respective States. In addition,
at least one meeting will be held annually with the
States in each Region to identify and discuss compliance
problems at Federal facilities and action to be taken to
address them.
Even in States which have been fully delegated for media
programs, EPA has a responsibility for tracking compli-
ance actions and compliance status of Federal facilities.
(A) Increase emphasis on returning Federal facilities
to compliance in a timely manner. EPA responses to
-------
-8-
Federal facility violations will follow the "timely and
appropriate" guidance established by the individual
media programs. Media-specific guidance will govern
the type of initial response as well as the timeframes
for the response. Notices of Violation (NOVs) or
their program equivalent generally will be issued as
E P A ' s initial written response for significant violations.
In all cases, EPA (normally the Federal Facility
Coordinator) should make every attempt to informally
notify the Federal facility (i.e., telephone call) as
soon as possible after the inspection is completed and
a violation has been identified and before the written
notification is issued. This will provide the Federal
facility with some additional time to remedy the
identified violation prior to receiving formal
notification from EPA.
When the violation will take longer to correct than
the specified target date, EPA generally will use the
Federal Facility Compliance Agreement as the primary
enforcement tool to formalize mutual agreements on
what the Federal facility will do to attain compliance
for specific violations. Regional Federal Facilities
Coordinators are responsible for coordinating the
negotiation of these agreements with Federal agencies,
in cooperation with media program representatives.
In FY 87, emphasis will be placed on rapid negotiation
of compliance agreements in line with each of the media
programs "timely and appropriate" guidelines. When
agreements cannot be negotiated within these time-
frames, formal administrative action may be taken. If
additional delays occur, Regional Federal Facilities
Coordinators will bring this to the attention of the
next higher management level of the Agency concerned,
as well as to OFA, using the escalation process estab-
lished by Executive Order 12088.
(5) Improve Qualitative Level of Fiscal Plan Review
under OMB Circular A-106. EPA must evaluate the updates
of Agency pollution control plans for technical, cost,
and timing adequacy and submit an annual report to OMB
hy September. Regions should utilize this review as an
-------
-9-
integral part of their compliance effort. Regional
Federal Facilities Coordinators are responsible for
coordinating the review, in cooperation with the media
programs. In FY 87 EPA Regions will initiate actions
to improve the role of States in the A-106 Review
process. This should include communications or meetings
as appropriate with States to compare A-106 submissions
to any State determinations of non-compliance or enforce-
ment actions against Federal facilities.
Review of projects in the A-106 plan is an on-going
process throughout the year and should include visits
to priority projects to provide technical assistance
and to review progress. When appropriate, EPA represen-
tatives should participate in a pre-design meeting for
input in the beginning of project development.
In FY 87 Federal agencies will be encouraged to use the
A-106 process to report non-point source (NPS) pollution
abatement projects and other selected program priority
areas.
(6) Stimulate Federal Agency progress in identifying,
assessing, and cleaning-up abandoned hazardous waste
sites (CERCLA). Federal Agency implementation of EPA's
CERCLA strategy will greatly increase EPA involvement
with Federal agency CERCLA sites.
During FY 87 EPA will continue to assure that
potentially hazardous waste sites are identified
and properly evaluated and, when appropriate, placed
upon the National Priorities List. Utilizing the E.O.
12088 and the A-106 process, EPA will review and approve
Federal agency plans for site cleanup, including an
assessment of the appropriateness of their remedial
actions. In addition, EPA will continue to support HoD
in its Installation Restoration Program. The new Federal
Facilities Program Manual for Implementing CERCLA
Responsibilities of Federal Agencies provides
detailed guidance in this area.
(7) Increase assistance to Federal Facilities to pre-
vent them from falling into non-compliance with RCRA.
RCRA reauthorization has added a large number of
additional responsibilities to those of EPA and other
-------
-10-
agencies. These include regulating underground storage
tanks, establishing minimum technical standards, greatly
expanding the list of generators who must comply,
mandating annual inspections at Federal facilities,
and biennial updating of an inventory of hazardous
wastes by each Federal agency.
(8) Emphasize development and implementation of
environmental auditing programs by Federal agencies.
During FY 1987, EPA developed a policy to encourage
environmental auditing programs by the regulated
community including Federal agencies. During FY 87,
OFA will implement a strategy to develop environmental
auditing programs at as many Federal agencies and
installations as possible. The program for self-
auditing of PCR's at DoD installations will continue
to be tracked, and expanded as appropriate, to other
non-DoD agencies. Headquarters will continue to pro-
vide substantive support for regional environmental
auditing workshops.
FY 1988 Guidance
In FY 88 the Federal Facilities Compliance Program will
continue to emphasize prevention through specific
technical and program advice and assistance. While
emphasis on proper design and construction of control
facilities will continue, greater emphasis must be placed
on correcting operation and maintenance problems at
facilities.
In FY 88, Federal agencies will have largely completed
the identification phase of their CERCLA programs. EPA
emphasis will shift to reviewing Federal agency progress
in assessing those sites previously identified and
closely reviewing their proposed remedial actions. The
number of sites on the NPL should be reaching its peak
with a maximum effort in support of Federal agency
cleanup programs.
Federal agency RCRA programs will also he in midstream.
Hazardous waste conforming storage sites will be under
construction. Many facilities will be permitted, but
many will remain in interim status. Closure of sources
of pollution including surface impoundments will require
close EPA attention. Detailed guidance will be needed
to assist Regional permit writers in permitting DoD
open burning/open detonation sites. The impact of the
Leaking Underground Storage Tank (LUST) program and the
number of Federal generators being brought under RCRA
will be at its maximum.
-------
-11-
2. MAJOR PROGRAM GOAL: PREVENT FUTURE ENVIRONMENTAL PROBLEMS
FROM MAJOR FEDERAL PROJECTS AND ACTIVITIES BY PROVIDING
EFFECTIVE EPA INPUT THROUGH PARTICIPATION AND REVIEW IN
ACCORDANCE WITH THE PROVISIONS OF SECTION 309 OF THE CLEAN
AIR ACT AND OF THE NATIONAL ENVIRONMENTAL POLICY ACT (NEPA).
FY 1987 Guidance
i. This is the fourth year of a four-year concerted
effort to streamline and improve the effectiveness of
EPA's Environmental Review Program (ERP). At the comple-
tion of this fourth year a system of policy directives,
technical and procedural guidance documents, and reporting
and administrative oversight procedures will be in place.
In addition, by the end of FY 87, all Regions will
have made significant progress in re-establishing effec-
tive ongoing participation in the NEPA processes of
other Federal agencies. In FY 88 and beyond, the
program emphasis will shift from development and imple-
mentation of management systems to more intensive inter-
agency activity to increase the effectiveness of that
participation and the resolution of potential environmen-
tal problems.
In FY 85-86 emphasis was placed on implementation and
refinement of the newly revised ERP procedures. FY 85
activity emphasized administrative changes to ensure:
concentration of review resources on those issues with
potentially significant impacts; increased early partic-
ipation in project planning; and intensified follow-up
with agencies to resolve potentially significant impacts.
In FY 86 emphasis was placed on development of technical
guidance to increase the effectiveness of the review process
and on Headquarters and Regional liaison with other Federal
agencies to maximize the agencies' conformance with EPA's
environmental protection strategies and to improve the overall
environmental protection aspects of their planning processes.
The FY 87 Guidance given below emphasizes the more direct
and long-term environmentally protective actions related to
increased interagency involvement and de-emphasizes the
program-building activity of guidance development. In FY 87
the emphases will be placed on interagency coordination
through general liaison to improve relationships and under-
standing, early involvement on specific projects to reduce
environmental problems and conflict at later stages, and
follow-up on those projects where problems persist to ensure
-------
-12-
an environmentally satisfactory resolution. For the first
time, commitments will be placed on parly involvement and
follow-up activities.
b. Key Program Activities
(1) ERP staff at Headquarters and Regional levels will
continue to conduct specific liaison activities with Federal
agencies to ensure that they are aware of EPA regulatory
or programmatic policies and initiatives dealing with
national level environmental problems. Federal agencies,
especially at the field level, will be encouraged to
become constructively involved in promoting regulatory
compliance with and participation in EPA initiatives
for the resolution of these environmental problems.
Special emphasis will be placed on Headquarters and
Regional coordination of such EPA initiatives as wetland
protection, air pollution reduction in non-attainment
areas, non-point source pollution, and groundwater protec-
tion. This activity, in conjunction with the project
specific liaison described below, is intended to ensure
that the environmentally protective intent of EPA's
programmatic goals is not compromised through the actions
and projects of other Federal agencies.
(2) ERP reviewers at both the Headquarters and Regional
levels will focus their pre-Environmental Impact Statement/
Environmental Assessment (EIS/EA) activities on early
involvement with those classes of Federal projects that
have the potential for the greatest environmental impacts.
For these high priority projects, FPA will seek to provide
input to agencies' project development processes to
ensure consideration of the full range of alternatives
and appropriate use of assessment methodologies. Early
participation or consultation in Federal agency planning
processes should surface, and lead to correction of,
potential problems at the earlier stages of project
pianni ng.
(3) In setting Region specific review priorities and
goals for FY 87, reviewers should give special consider-
ation to projects with potential problems that fall
within the Administrator's five priority areas. For
example, reviewers should:
a. Emphasize reviews of Federal land management agencies'
vegetation and pest management programs and other
agencies' use of registered pesticides in sensitive
environmental areas to reduce risks from exposure
to existing pesticides and toxic chemicals.
b. Carefully review all NEPA analyses related to
siting, relocating, and clean-up of hazardous waste
sites to insure full consideration of long-term,
cross-media impacts.
-------
-13-
c. Carefully review Federal transportation and energy
projects (including outer continental shelf oil and
gas activities) to ensure minimum conflict with air
standards attainment or maintenance programs.
d. Work with the Federal agencies to maintain and improve
water quality with particular efforts to minimize or
eliminate non-point source pollution from proposed
activities.
e. Fmphasize reviews of Federal construction projects
impacting wetlands and other sensitive areas to ensure
that, first, these impacts are avoided and second,
that unavoidable impacts are mitigated in accordance
with Federal policy.
(4) ERP reviewers at the headquarters and regional levels
will conduct follow-up liaison on all project reviews where
EPA has identified significant environmental problems.
The purpose of follow-up is to explain EPA's concerns
and to obtain positive agency responses to EPA's specific
recommendations. Where necessary to resolve environmental
problems, the reviewers will elevate controversial projects
to higher EPA management levels.
FY 1988 Guidance
Tn FY 88, Headquarters and Regional staff will continue
emphasizing general interagency liaison, early involvement
on specific major projects and follow-up on issues of
continuing concern. OFA, in cooperation with Regional
reviewers, will assess the overall review effectiveness,
in terms of environmental results, and institute modifica-
tions to the review process to increase its effectiveness.
3. MAJOR PROGRAM GOAL: REDUCE THF LOSS OR DEGRADATION
OF WETLANDS THROUGH VIGOROUS IMPLEMENTATION OF EPA
AUTHORITIES UNDER SECTION 404 OF THE CLEAN WATER ACT.
FY 1987 Guidance
a. Reflecting the high Agency priority placed on protecting
wetlands, major efforts have been underway to focus and
strengthen the program. In view of the number of signif-
icant 404 initiatives currently in progress, guidance to
supplement the Operating Year Guidance is to be issued in
1986 in a document entitled "Strategy for Wetlands
Protection under Section 404."
Key program objectives are to: (1) establish consistent
and effective national policies as a basis for application
-------
-14-
of section 404 authorities; (2) assure wetlands protection
through participation in permit review and enforcement,
while moving towards a more focused anticipatory program;
(3) assist the States in strengthening their wetlands
protection programs, and help increase public understanding
of and involvement in wetlands issues; (4) improve wetlands
protection through cooperation with other Federal and EPA
programs; and (5) strengthen the scientific and technical
basis for wetlands decisions.
During FY 1985-86, OFA has been working to improve the
interagency framework to help meet these objectives.
Major steps towards clarifying relationships with the
Army Corps of Engineers were achieved through the signing
of Memoranda of Agreement with the Corps on resolving
disagreements on proposed discharges under Section 404(q)
and on the regulation of solid waste discharges into
waters of the U.S. Resolution should also be achieved on
other major issues of importance, such as the Corps'
proposed revisions to their National Environmental
Policy Act regulations and on procedural and technical
issues relating to jurisdictional determinations of
wet!ands.
Three major internal initiatives have been undertaken in
FY 1985-86. The first is to develop the capability to
become pro-active in the exercise of EPA authorities to
protect the most valuable and threatened wetlands.
While permit review, our most resource intensive
responsibility, is always exercised in reaction to a
proposed discharge, EPA's other authorities are under
study to determine how they can be used in advance of
permit actions to address wetland loss problems in
specific geographic areas. These authorities are
advanced identification of site 404(c) restrictions
or prohibitions, wetland boundary determinations,
compliance/enforcement initiatives, and public information
efforts. In FY 8Fi Regional offices developed wetland
priority lists as the first step toward a pro-active
approach. In FY 86 the lists will be refined and
implementation strategies will be prepared to identify
the mix of FPA authorities that will improve levels
of protection for the most pressing wetland loss
problems in each Region.
The second initiative underway in FY 1985-86 has been
to strengthen our policy framework to make EPA's program
more effective, consistent and streamlined. This has in-
cluded development of draft guidance on mitigation, advanced
identification, use of section 404(c) authority, wetland
jurisdictional determinations, and bottomland hardwood
wetlands. EPA regulations for 404 State programs and
for section 404(c) are also being revised.
-------
-15-
Improving EPA's capability to enforce against unpermit-
ted dischargers is the third major internal initiative.
This has involved a comprehensive effort to improve the
efficiency of EPA actions through procedural guidance and
training, and to improve our effectiveness in obtaining
the most environmental gain with the actions we pursue.
In FY 87 we will incorporate into the program the
results of the Agency's Strategic Planning Initiative on
Wetlands, refine elements of the regulatory and
policy framework, and increase our attention to pri-
ority wetlands.
b. Key Program Activities
(1) Headquarters will continue to build consistent and
effective EPA policy for exercising our 404 Program
authorities. Final 404(c) regulations will be promulgated.
Policy guidance will be developed on interpretation of
the 404(b)(l) Guidelines and on permit exemptions.
(?) Headquarters will work with the Department of Army
to effectively implement the revised 404(q) agreement
and the 1986 Solid Waste agreement, and to address
remaining issues such as joint mitigation policy, the Corps
permitting regulations, and the agreement on enforcement.
(3) Regions will continue permit review activities and
will work with Corps' Districts and Divisions to effectively
implement the revised Section 404(q) MQA.
(4) Regions will maintain and update their wetland
priority lists, and will develop implementation strategies
to increase the level of protection for selected priority
areas. Regions will also consider these areas as can-
didates for inclusion in their Environmental Management
Report action plans for addressing geographic problem
areas. The implementation strategies will be based on
the use of FPA authorities in a pro-active manner,
including, as appropriate, advanced identification of
areas as suitable or unsuitable for discharge under
the 404(b)(l) Guidelines; restriction or prohibition
of areas for discharge under Section 404(c); jurisdictional
authority; and enforcement. The mix of authorities to
be exercised in each selected priority wetland area
will be designed to yield the greatest environmental
results. Following policy review in FY 86, the program
to reduce losses of bottomland hardwood wetlands will
be implemented.
(5) Headquarters will support technical studies by the
Regions on priority wetlands and major permit cases.
-------
-16-
(6) As EPA begins to develop and issue strategies
for priority wetlands, Regions will increase efforts
to relate these to other EPA programs such as groundwater
protection, non-point source control, municipal wastewater
facilities and RCRA and Superfund activities in the
geographic areas of concern. Headquarters will conduct
five additional Regional program evaluations, at which
inter-program coordination will he assessed.
(7) Regions will focus their enforcement efforts on
unauthorized discharges in priority wetlands (including
bottomland hardwood wetlands) and will ensure that sign-
ificant violators are returned to compliance expeditiously
or have a formal enforcement action taken against them.
Regions will work with the Corps to enforce against
violations of permitted discharges only after
making a determination that such efforts will yield more
environmental results than additional enforcement against
unauthorized discharges. Regions will apply the definition
of "significant violator" to the backlog of cases from
FY 86 and to the universe of violators in FY 87.
(8) Headquarters will provide training to the Regions
on the use of model Administrative Orders and the 404
Enforcement Manual .
(9) Consistent with available resources, headquarters
will implement a more active program to inform the
public of the values of wetlands and EPA's role in
protecting them, with approaches specifically tailored
toward developers, farmers, local governments, environmental
groups, citizens, educational institutions, and fishing
and hunting interests.
HO) Regions will develop public information/outreach
programs, with special emphasis on priority wetlands.
(11) Regions will continue working with the States to
improve their effectiveness in protecting wetlands,
and will accelerate assisting the States to the extent
that resources permit. Headquarters will develop guidance
on EPA's enforcement role in States with approved 404
programs. We will strengthen communications and technical
assistance to State wetlands programs through a more
active EPA role as a clearinghouse for information on
State initiatives.
(12) Headquarters will continue to participate in inter-
agency efforts to update and refine wetland plant and
soil lists and to revise the Adamus Methodology for
evaluating wetlands. Regional testing and use of the
the Adamus methodology are also expected to increase.
(13) Headquarters will monitor uses of the EPA/Corps
methodology for establishing wetland boundaries,
-------
-17-
expected to be Issued in FY 86, and will identify needed
refinements or improvements.
(14) Regions will install the Section 404 Management
Information System developed in FY 86 and will make it
fully operational. Regions will also develop mechanisms
to obtain data from the Corps to track permitting and
enforcement actions referred by EPA.
(15) OFA will continue the wetlands technical training
program for EPA 404 personnel, maintaining our cooperative
agreement with the Corps' Waterways Experiment Station
to conduct courses tailored to EPA's technical development
needs.
(16) The Office of Research and Development (ORD) will
strengthen the research program in accordance with the
seven year Wetlands Research Plan, addressing the following
questions in FY 87: (a) What effects do wetlands have on
water quality? (b) Can we predict or determine the cumulative
impacts of wetlands loss and relate individual permit
decisions to that loss, and (c) Are techniques to create
and restore wetlands working, and how can we best ensure
success in the environment?
FY 1988 Guidance
In FY 88 Headquarters will revise the "Strategy For Wetlands
Protection Under 404" based on practical experience
gathered during the preceding two years, ORD research
efforts, and the findings of the Agency's Strategic
Planning Initiative on Wetlands. The 404 program will
continue to reflect a heavier emphasis on the anticipatory
approach to wetlands protection. Depending upon the
results of analyses performed in FY 86-87, program pol-
icies may be revised to tailor EPA's 404 regulatory
response to categories of wetlands based upon functions
and values, environmental context of impact areas,
and institutional recognition of ecological values.
4. MAJOR PROGRAM GOAL: PROTECT AND ENHANCE ENVIRONMENTAL
OUALITY THROUGH ENSURING EPA COMPLIANCE WITH THE GOALS
AND/OR REQUIREMENTS OF THE NATIONAL ENVIRONMENTAL POLICY
ACT (NEPA) AND RELATED LAWS AND DIRECTIVES.
FY 1987 Guidance
a. The objectives of the NEPA Compliance Program are to:
(1) help improve EPA decision-making in order to avoid
unanticipated environmental impacts, with an emphasis
on identification of alternatives, of the full range
of potential impacts, including impacts on natural
resources and possible intermedia transfer of pollutants,
and of mitigating measures to avoid or minimize adverse
-------
-18-
impacts; and (2) ensure that EPA complies with the
requirements and procedures of other relevant environ-
mental laws and directives.
The interdisciplinary experience developed in the course
of NEPA compliance (primarily for water media programs)
is increasingly being made available to assist in other
EPA program areas. In FY 87, the NEPA Compliance
Program will continue to be directed to ensure that
EPA's regulatory and other programmatic actions comply
with the goals and/or requirements of NEPA and other
related laws. The program will be used to promote
improved decison-making for complex and controversial
projects through comprehensive environmental impact
analyses, impact mitigation and public involvement.
Emphasis will be placed on those activities with the
greatest potential for adverse public health or natural
resource impacts and intermedia pollution transfers.
It is expected that a major new area of activity will
he required to support NEPA requirements for off-shore
oil and gas permitting. In addition to those programs
for which formal NFPA analysis is required, the NEPA
compliance program will also continue to assist agency
programs, especially those with potential intermedia or
natural resource impacts, in carrying out review processes
that are functionally equivalent to NEPA.
Assistance will also be provided in the compliance of
EPA with the requirements and directives of other Federal
statutes and Executive Orders affecting such environmental
values as wetlands, floodplains, coastal zones, historic
preservation, and endangered species. Finally, the
regions will develop region-specific strategies to focus
and describe their activities in this area.
b. Key Program Activities
These activities will be carried out within each region
in accordance with region-specific NEPA Compliance
strategies developed in FY 86.
(1) Continue to see that projects proposed for funding
under the construction grants program have complied with
the requirements of NEPA. Where segments of a project
have not been previously reviewed under NEPA, where the
review occurred five or more years ago, or where the
proposed project or environmental conditions have
changed, an environmental review will need to be per-
formed. Where major elements of this review are per-
formed by delegated states, technical assistance and
support should be provided. Review the performance
of delegated states. (The scope of this activity in
FY 87 will be dependent upon the provisions of the
-------
-19-
pending Clean Water Act reauthorization.) (Regions)
(2) Continue to provide new source determinations,
FNSI/EAs, and EISs, as necessary, for all new source
industry permits where States have not assumed National
Pollutant Discharge Elimination System (NPDES)
permitting authority. Provide new reviews required
for off-shore (Outer Continental Shelf) oil and gas
NPDES permitting. Assure that NEPA compliance
documentation is complete, useful for decision-making,
and timely. (Regions)
(3) As resources allow, evaluate the effectiveness
of NEPA compliance activities on selected projects
for which FNSI/EAs were issued, with an emphasis on
accuracy of impact prediction, actual installation of
proposed mitigation measures and effectiveness of
implemented mitigation measures. (OFA, Regions)
(4) Ensure that special or generic studies required to
support EPA's NEPA compliance program are performed and
made available to decisionmakers in a timely manner.
(OFA, Regions)
(5) Increase the Agency's effectiveness in meeting the
goals of NEPA in the development of policies, regulations,
and other initiatives. Participate in selected working
groups on key issues with potentially wide public health,
intermedia, or natural resource impacts. (OFA)
(fi) Assist in site-specific evaluations, e.g., working
with CERCLA staff in the development of feasibility
studies for remedial actions and RCRA staff on permitting
activities, emphasizing the analysis of alternatives,
cross-media impacts, mitigation, and public involvement.
(Regions )
(8) Improve communication with other Federal agencies
responsible for implementation of environmental laws
and Executive Orders with which EPA programs must comply,
in order to evaluate problem areas and facilitate Agency
compliance. (OFA)
(9) Reflecting the results of the FY P6 reviews and
communication with other Federal Agencies, continue to
provide oversight and assistance to Agency programs in
complying with the requirements of other Federal environ-
mental laws and relevant Executive Orders affecting
wetlands, floodplains, agricultural lands, coastal
zones, wild and scenic rivers, fish and wildlife,
endangered species, historic and archeological sites,
etc. (OFA, Regions)
-------
-20-
FY 198P Guidance
Emphasis will continue to be placed on working to
improve EPA decisionmaking within on-going Agency
procedures in order to avoid unanticipated adverse
public health and natural resource impacts or inter-
media transfers of pollutants. Interdisciplinary
approaches to decisionmaking will be encouraged, and
both guidance and training, as appropriate, will be
developed to assist program and Regional Offices.
Implementation of region-specific strategies is
expected to strengthen the effectiveness of this
program in identifying and focusing on priority
needs and issues.
5. MAJOR PROGRAM GOAL: ENSURE ENVIRONMENTAL PROTECTION ON
AMERICAN INDIAN RESERVATIONS THROUGH IMPLEMENTATION OF
EPA'S AUTHORITIES AND PROGRAMS.
FY 1987 Guidance
a. The objectives of EPA's Indian program are to: (1) directly
apply EPA's authorities and programs on Indian reservations;
(?.} develop and enhance tribal institutional capabilities
to assist in the implementation of EPA's authorities
and programs on reservation lands; and (3) eliminate
legislative and regulatory barriers to program implemen-
tation (ranging from partial participation of the tribe
to full delegation of programs to tribal governments).
This program reflects the fact that EPA retains program
authority on Indian reservations even where that reserva-
tion is geographically located in a "delegated" State;
our responsibilities are as they are in "non-delegated"
States.
In FY 87, the results of the environmental survey of
reservation lands and the pilot projects will be evaluated
and made available for use by EPA program and Regional
offices, other Federal agencies, Congress, and tribal
governments. Technical assistance will continue to be
provided by OFA contract to assist in problem identification
and infrastructure development. Coordination with other
Federal agencies will continue to increase, focusing on
program implementation through cooperatively funded
activities. Regions and programs are expected to continue
demonstrating significant and credible steps toward
implementation of the Policy within the constraints of
available resources. Additional opportunities to ex-
tend program applicability and provide technical and
administrative assistance to Indian lands will arise as the
remaining statutes and regulations are amended. OFA will
continue in its role of program coordinator, providing
guidance, direction, and oversight, as appropriate.
-------
-21-
Key Program Activities
These activities will be carried out within each Region
in accordance with region-specific strategies developed
in FY 86 consistent with the December 1985 Interim
Strategy for Implementation of the EPA Indian Policy.
(1) Increase the level of direct programmatic involve-
ment on Indian reservations to address the most critical
air, water, and hazardous/radioactive waste problems
consistent with the overall goals and objectives of the
media programs. (Regions)
(2) Develop on a selective basis several Tribal/EPA
agreements analogous to State/EPA agreements identifying
priority environmental problems and measures to address
them. (Regions)
(3) Continue to provide direct technical assistance to
Tribal governments including assistance on problem
identification and infrastructure development. (Regions)
(4) Continue to strengthen external liaison with Indian
Tribal organizations and relevant Federal agencies.
(OFA/Media Programs/Regions)
(5) Strengthen outreach and liaison with Tribal govern-
ments, providing information and opportunity to participate
in EPA programs, as appropriate. (Regions)
(6) Continue, as necessary, to seek revision of EPA's
statutes and to revise EPA's regulations to include
consideration of Tribal governments. (OFA/Media Programs/OGC)
(7) Continue to factor Indian program needs into media
program fiscal and program planning processes. (OFA/Media
Programs)
(8) Work with the media programs to develop specific
measures relating to implementation of the Indian pro-
gram for their programs. (OFA, Media Programs, OMSE)
(9) Maintain and, as appropriate, update the data base
developed during the FY 86 Survey of Environmental
Conditions on Reservation Lands. (Regions)
-------
-22-
FY 1988 Guidance
In FY 88, EPA will continue to develop its programs
along the lines outlined in the Strategy for Implemen-
tation of the EPA Indian Policy/within the constraints
of available resources. Direct program activity by
the Agency on reservation lands will increase and,
as the statutes are amended, regulatory programs may
begin to be delegated to Tribal governments. Regions
will maintain good communication with major Tribes, and
will continue to provide technical assistance to Tribal
governments as they assess their environmental problems
and needs, and as they continue to build up the institu-
tional capability to deal with environmental problems.
It is to be expected that, as this process continues,
additional Tribes will be identified as reaching an
institutional level capable of dealing with environmental
problems. Innovative and alternative institutional
options will receive a high priority where they provide
an effective means to address environmental problems in
terms of cost and environmental results. The
information base on environmental problems on reser-
vation lands will be updated and expanded to additional
reservations and will assist in focusing Agency
priorities on the most significant issues. By FY 88
it is expected that the Agency will have wholly
incorporated consideration of Tribal governments into
all of its management and budgetary processes, and that
the Regions and media programs will have developed
strategies to incorporate Tribal needs and programs into
on-going Agency activities, both for the current fiscal
year and as additional statutes and regulations are
enacted or revised.
-------
-23-
FY 1987 Supplemental Guidance to be Issued
by OFA
(Publication dates unknown)
Federal Facilities Compliance Program
1. "Criteria for Identifying Potentially Environmentally Significant Federal
Facility Minor Sources."
2. "Guidance on the Identification of Environmentally Significant Federal
Facilities."
3. "Guidance on the Development of Federal Facility Compliance Management
Plans."
Dredge and Fill Program
"Guidance on Advance Identification (Section 230.80)"
-------
Appendix
-------
2
Ed Ed
Z
O
a
<
05
Q
z
£
Ed
H
CO
X
co
EH
Z
Ed
£
Ed
U
<
Z
<
Q
Z
CO
Ed
05
D
CO
<
Ed
«
H
Ed CO •
> Oi
Cd Q rH
Q Ed I
Q CO <
2 CO O
< M
Ed
5 Ed O
Cd CQ <
M ft
> J
Ed J 2
05 M O
S
O5 Ed
Ed CO >J
Q Ed 3
2 05 Q
D D Ed
CO K
X < CJ
J Ed CO
H £
2 Ed
Ed J E
05 < EH
05 Z
D M X
M O
< 2
Ed
EL,
O
Ed
CJ
M
Cm
Cn
O
2
Z
U
M
O
Ed
00
O\
Eb
CO Ed
Z O
O O Q
Ed M
« K O
O U
En Ed U
E <
CO H
Ed 2
« Q M
D 2
co < «>
< 00
Cd CO H 2
En CD Ed
*
-------
<
*—I
a
a:
a
UJ
o
o
z
UJ
cr
UJ
""
UJ
Q
O
0
CO
2.
QL
CO
LU
-^
oo
•r- (O .p tO
0 >» C CU •—
•r- r— -P CU J= O
4- 4- C E -P '-
CU CU CU C -P
-O T- E -r- >> C
t- C (C jQ O
£- jQ ••- .p (J
CU 3
J= O 0 J= O O
P co .p 5 i_ co
•r- CU C Q.
3 0 — >, >>
J? >, «-
CO CO -P (C
> • O 4—
1C P 4- -O CU > O
CU 3 OVi— CU C
{_ r— C -P -P O 4-1—
(Oi — T- C U N O-iX4- O T-
CU >> O CU O T- O>
E -Q -P -P CU
C 1 • CO CO
(C C CU Q. O CD
^.^ (^ N^ H^ C frr? • ^ P*
^ ^ ^_> (^ (/"^ ^5 t) tO £~ 4^
n3 3 +J T- O 0) CU
Cr— CU+J -r-O i— >>
O r— O>J= U -O -r- O.-Q
COC-PCU C4- E
o *r- t »p» (£• «r— ^3
CU CU +J t- O CU
-cicjauo c c-o
4J CU U Or- O -r-
c to e_ as >
4->OC<_O_ 4->C -PO
t- ooi-« £-0 t-i_
OtO'r-OUO O-I- OO-
0.0. -p o. 01 a.
CU >— i O O t, CU QL) CU to
o£oo
jc +j to p to o c:
4Jp (CtOU Ct-T-
(C J= (U (O UJ Q.-P
a. cu c o. to cu
•-1COE3.* t-0)
OO *r" CCUfCO vCDE •
E <-> *C to -C co
r— CU'O.P cu+Jtot^ S
(^ ^^ -+J ^ *r"* T^3 ^J M"^ 3C 'O
o o c u c u o
•i— a}*o*o t/i O) i — t/>
CX • >< (/) (I) 4--' CU Q ^J OJ
d. t/> d) ^y ii C 4J n3 "^3 -C
'O [r^* *^ ^J £^ fQ 4— '
c -a ^
•i- 3
to o
CU co
•o -p
C C_J
iC iO O
o ^>
-C -r-
•P 4- <
•i— *r—
$ C CO
31 tO
(O T- (C
CU 10 r—
t- 0
iC O
O 4-
•— > o
r—
rC 4- t- 00
0 O CU UJ
1 -Q O
a. t- E •— '
I-H CU 3 • U-
00 J2 C —* U-
E E O
t- 3 r- CU
O C (C -P _J
-P to «C
-P CU O >, Z
c jc +j oo O
CU -P >— i
E CU iC CD
C -P -C -P UJ
•i—* L- ^J fO p^
'O ^5 j^j
-P Q. 0
4J CU -P O)
(C U O
C T3 C
O •* d) (O
c E «- -r-
Q. (0 i—
CU Q. Q. Q.
C E E
O LO O O
N r— U O
O •
O '-O CU
-C «- J=
U A O -P
TJ -P
CU >
-o
cu
Q.
o
f^ "O
cu c
> 1C
cu
"O **"**
^Ik
CU . t_
O tO fO •
C 1C TD CO
(C CU C •!-
•o t_ o to
•r- (C U (0
3 cu ja
Oil — tO
1— p
o -• >>r-
03 OO t- i—
3 1C O
to t- E ex
t- 0 -r- 1
3 t_ >,
0-^ Q-jQ
C • — 1
to cu -P
C E -PC
o c c ic
•i- -i- CU -P
to io E 3
tO 4-> C r-
•I— +^ *r~ r—
E cu o c
C CO
VD O
CO N CU to
01 O _C CU
r— -P -r-
1— .p
t— r- o: c
, CU i— '
c£. -Q a: co
-------
o
co
•
1 1
UN
Q*
Q
z
o
HH
1—
<
1— 1
O
^£
Qi
a
"^
^^
?*v*
t_l
^£
U-
0
UJ
o
HH
u.
u.
0
oc.
LL.
UJ
O
0
co
a.
co
UJ
a:
—^
CO
^^
UJ
z:
r—
cr
00
cr
to
a.
i— <
co
re
0)
re
-P
c
cu
E
c
• r~
re
•p
-p
re
c
o
c
t
a>
c~
-P
0
-a
C
re
to
n
t— i
co
•P
c
cu
«r—
O
•^
<4_
•o co c
• r-
-C <*- CU
-t-* O f*\
.)—.
2 -P
c c
c» Q) O
re E **""
CU Q.-P
t~ o o
re P— re
cu
C_ > CU ^
0 CO JZ t—
u- -o -P - —
•
re
i
i.
o> o
c u
•1- -p
CU 0 0.
jQ CU VH
t. co
to c-
e o t-
O 0 O
•r—
-P O -P
O -P C
re cu
T3 E
CU C C
j=: re -i-
.p re
•p -p
CU C 4->
^^ QJ fO
*(~™ E
C- C J=
0 -i- U
to re T—
CU -P JZ
-a -P 3
re
" >»
CU O JD
^ P
O C CU
^o re
cu
•r— O) to
-pea.
C -r- l-l
3 t- CO
O J3
0 -P
0 C
r— -P CU
r~ •»-
re c u
O) -r-
l~ J* 4-
o re cu
u. P -a
•
•^
cu
1 *
u
cu
*"•)
x
cu
to
• r—
C
o
• r-
} *
O
cu
(_
c
O}
•r-
OO
CU
-o
re
JC
+j
•r-
^
re
cu
c_
re
r-.
r—
re
o
i
Q.
t— 1
co
t_
o
4^
c
cu
E
c
•r-
re
-P
-p
re
c
o
c
cu
c
0
N
O
_e
(j
re
a>
<_
o
u.
• •
a:
^f
o
o
•p
t_
o
a.
cu
c_
A
gz
*^
Q.
UD
r^
•
O
A
CU
3
re
>
co
cr i
«C CU
< -p
z re i—
•P re
cu in c
c o
o cu ••-
N JZ -P
o 4J re
"^
cu o>
JT C CU
-P -r- J=
t- -p
14- 3
O TJ C
•P-
* CU
* -p -a
t/> *r- CU
•o
CU
+J
cu
• p—
£_
0
1
1
c
o
(r-
-p
re
^_
3
a.
o
a.
t
i
to
cu
u
c
re
-a
cu
cu
o
X
UJ
cu to •<-
U
+j s_ re i-* -p
o o cu to
CU 1 to C- CU
a. c o j=
X O CU it- 01
CO -r- C -r-
•P O '-^ 3=
it- re N ^ i
O r- O C 1
3 re to
t- Q.T3 OO CD
CU o CU O
.0 Q.-P re c
e re +j re
3 cu c re -o
c j= aio cu
•P T- CU
cu t/) c- o
JC -P 0) •!- X
H- re T3 ,
cu c -r- re
J= 0-— • E
4-> O 1 1
c
o c to oo
o re CT*
* N CU r—
* o to
to c_
CU 4J CU O
O tO C <4-
c a) o
03 JZ U s~*
-a en o _*:
CU -r- C
cu jz -a re
o cu oa
X CU P
cu JT re re
•P C -P
TJ o) re
CU J= -r- Q
-p P in
o •!- a> &-
CU 3t TJ T-
Q. 1 <
x cu cu
CU -P -P i —
•r- re re
If- I/) -P C
o to o
CO -i-
C- S O) +->
cu Z •
3 CU O^ CU • — .
c JZ c jz re
•P *r— -P -^^
a» t_
JZ -P 3 C O
i— re -o T- .p
cu
p"
^j
•
en re
•r- re
c -o
•r-
£ C
CU -r-
-P to
CU (/>
-O -r-
E
O t-
i»- O
c
O -P
•r- C
•P 3
re o
r— O
3 O
CT> re
cu
i- -p
re
jQ -P
•o to
cu cu
c u
•i- C
it- re
cu -a
•a cu
cu
U 0
•r- X
-P CU
m
•r- If—
•P O
re
-P t_
to cu
jQ
CU E
JZ 3
1— c
•X
*
UJ
o
•-3
oa
o
-------
LA,
Q
a
«c
u.
o
LU
O
o
111
UJ
cr
UJ
0£
UJ
o
o
o
to
Q.
to
UJ
Of.
ID
to
UJ
z:
UJ
>
H-
o
UJ
•-3
CQ
O
^
ft
CM
cr
^
A
CM
cr
^
•i
CM
cr
^
ft
CM
o-
CO
c
O
•r- -0
•P C
fB O
t- O
+J CU
c in
eu
O -P
c: 10
O cu
O JC
CTl
t_ •!-
3 JC
o
JC CU
1 JC
0
CO T-
E M- tO
O Z!
p IO Z
(B
E Z
.,—
C- CU
3 JC
-o -P
E E
O T-
•^
•P ~O
IB CU
-P ^
C- CO
(B C
E O
O T-
•i- -P
•P IB
IB i—
P 3
l/> 31
Q.
i — i
(U 00
JC
P "O
CTl
P O E
-B t_ -i-
P 0. f
in Q. o
> o
IB -Q 4-
OJ
13 CU
t- CU JC
0 4- P
IB
1 «
o
+J
(Q
*f™
o
p
3
o
VM*
^-~*
t/1
CD
f-
o
CO
cu
E
.^
r_
cu
T3
•r-
3
CD
CU
3
cr
•r—
E
f
O
cu
CO
•— cu
O -I-
C_ (-
P O
cu
^-^ E
' — • CO O
(A CU N
cu ••- o
•i— C_
t- o ^o
O CTl 30
CTl CU CTl
CU -P ^~
+J (B
(B O >-
O U.
CU
CU > CU
E -i- JC
•r- M- +J
E
M- E
<4- O •«-
O
r— T3
i— (B CU
fB P •!-
4-> O 4-
0 -P T-
P -P
tB E
IB CU
<4- -0
i*- O T-
O
P CO
P 3 IB
3 O
O ~-* co
— ' cu
CO *r~
10 CD t-
CD 1— 0
<*- CO C CTI| — O CT)
> l_
Q£ O CU
< u -o
O E
•^~*» 3
o - — "O
OJ
4-* t/1 f—
4- O) -r-
O -r- 3
Q. t- CT
CU O CU
a; CTI s_
o cu
CJ P
K-. 0
Q.LO
3 i —
o
C- <+-
CD 0
o
O > O
CT> t/)
CU
p t-
IB CU
t- JC
-P -P
in O
o
"O E
cu cu
p ^
CO IB
•r- Jp
CT) O
in E T-
CU T- JC
•r- >, CU f.
t- jc ja
o z >,
CTI in ja
cu cu c
•P jQ O '-^
IB T- •!- t/1
U t- -P - —
o o cu
cu in IB .p
JC CU IB
P T3 CU -O
jC
t_ •> ^ cu
o -a jc
(4- CU • 4-i"-*
t- -o t-
t/) CO CU "O — '
E > •>> E
O O IB IB
•r- 0 •— .
•P CU r — ^O
IB -P "O IB CO
i — O > -p
3 E E O O
CTl CU C- CU
co P cu a. a.
t- 3 J3 Q. X
JO IB CO
O CO -^
O " IB E c/1
> T3 JC O •!-
CU •!-
CU t- r— en r—
C T- IB I/) IB
CO 3 > T- >
JC 0- O E O
S CU t- jQ t_
t- Q. 3 Q.
in a. in Q.
IB CU IB IB
cu t. --^ eu ^
t- IB E .p E
IB O •!— O
Q. in
IB ^ ••- X -i-
< E CU E
t- ja ja
0 E 3 0 3
u. •!- m
cu c
f~ .^
P IB
-P
E P
•r- IB
-o o
CO 4J
^
•r~ ^3
3 CO
CU CO
t- CO
E
f.
O CU
C* f)
in i —
•i— ^_
•r-
z: ?
HH L.
O
CU
L. a.
CU i— i
jc to
f
CO
(B E
CU O
C- (si
IB O
JC t-
0 0
IB -^
cu -a
E
(H f&
O
M- CU
-a
o: -r-
<£ X
o o
E
0 0
P E
-P c:
t- O
O -d
a. t-
CU IB
a: u
CO CU
-P t-
iB 3
p CO
10 C
CO
E
•r- 0
IB P
1 ^
E m
T~ ^
IB IB
E c_
T3 O
E C.
iB f^>
JC n'-
t/I IB
•r- U
r— O
(•> r^
IB
P "O
in E
UJ IB
. ,
CO
to
cr
<£
Z
E
0
•r—
IO
in
.^
p!
CO
p
CO
CO
(/}
0)
,—
o
•1—
C"
(U
>
^J
'O
C"
-p
•a
cu
c
co -a
§„ *^*»
1— 4 t-H
CU CO
t» £_
O) CO
JC JC
3E Z
CO t/1
IB IB
CU CU
Lm £_
^o *o
CU CO
JC JC
•p p
0 0
^
•r—
CO
JC
.p
-p
o
JC
CTl
3
O
(^
JC •
•P CO
i*-
m -i-
-a r—
s_
IB ^**
T3 3
E <*-
IB CO
P in
t/) 3
„
-o
CU
p
-p
•r-
E
3
in
P
O
E
P
3
f*\
ft
CU
3
-o
I/I
•r-
E
(B ••
C_ CO
O •!-
c_ c_
a. o
in
z: cu
i— i
A
CO TJ
JC CU
P -P
E
CU CO
!_ f=
CO CU
JC r—
3 QL
E
CO •!-
IB
CU L.
t- 0
"O
r— CU
. — :>
(B O
t
t- a
0 0.
U_ IB
•p
cu
a>
t_
10
(O
c
o
a>
cu
ea
Irt
CU
cr
cu
cu
3
CO
-------
«£
i—i
O
Q
C£.
u.
O
o
III
LU
cy
LU
u.
LU
0
O
s:
to
LU
ry
-^
to
LU
z:
LU
I-H
W_
O
LU
r-^
co
0
^
o-
cr
^
•o
7> C
c o
OJ P
^ ^3
p
co c:
1=
g
cy
a.
g
^.
o
1— —
(T3
5^.
o
L-
a.
a.
re
« OS
c <
0 O
CO
CO
•p-
rt
•^
CO
c
a>
3
^.
^
ai -o
P cu
rO P
T3 0
cu a.
-C X
P CU
o
-C
•r— 4_>
i $
o c
dJ 'P~
c_
s- -a
o cu
O -1-
4-
CU -P-
P C
cu
C "O
O -P-
+-> CO
t- E
o cu
Q.P-
t- O
L_
CO Q.
3
P p—
fQ fO
P C
CO O
rO -P
03
OJ C
4-^
3 CU
•p- 4-2
t
-P C
CO O •
•p- CO
-o c -P
"^3 ^^ T^
C re 3
re -P re
CU CO UO
<~ c co
re O CT>
GL-p- r—
O) P
t- 0 >-
QL. fO U_
c_
re ^>
C 4—
O •!-
•r- 4J
-P c E
fO Q,}
p- 0
ra O t-
•p- ^_) Q.
c
CEO
CU CU -P
JD CO CO
>, cu
CU CO r-
-C O
•p -p ^a
cu -a co
00 3 -Q
O «C O
to
LU
o
H-H
u_
u.
o
_J
^^
0
I-H
C3
LU
Q:
•
CO
CO
OJ
Q)
^
•1—
^_>
u
cj!
4-
tu
•
^> ^*> 'Xv*
-P 4- C»
•r- *H* O^
t- P r—
O CU C
•P- -E CU >-
«- -P T3 U_
Q. I-H
C C
0 -r- -P-
IP- •
4- CU CO 0)
•r- O 4-> P
O 'P~ ^ re
CU '4- O P
a. 4- a. co
CO O CU
1 t» c*
CU •— U
•P re P re
rO C -r- CU
p o -a
CO -p- 3 >,
O> re -Q
4- CU
o a: vo TO
00 CU
P cu m P
CO .C p- O
•p- P CU
•— >- £-
re Jb o
CU 0
i*v ~^j r"
st CU -P CU
O -r- J2
4- 4-
O -P- O O
P -P P
C >>
T3 O> 5- CO
c -o * cu
cu -P- e -p-
co E O
co 3 cr
T3 CU CO 0)
C -r- -p-
rO O -p-
CU CU -i— 4-
s_ -p- P a)
re o 3 -a
Q.-I- O
cu <•— cu cu - — »
t_ cu x -= i—
Q. -0 P CT> t-
3 CO p- CU
P 3 a.
re e >-
P LL. t-
co CD ro
u a> ai
CU T- C >,
J= 4- -p- 1
•P 4- t- O
O 3 S
C T3 -P
O p-
rO CO CU
cat c cu -d
< o ••- P
O -p- O
Ol C £-
O CU O) CU
•P ^^ O^ > ^"^
re O •
-P J= C
t- O p- CO O
O re re -P T—
Q. CU O T- P
CU O TJ CU
C£. <— 3 5_
re U
CL> "O CO
• -P CU Ol •!-
CO O -P -C T3
-P Z U -P
•p- — ' 0) CO
T3 P- -O -
3 CU re CU
re • co CU U
CO t_ -p-
r~ P -o 0.4-
00 -P- C CO '4-
-~.-O ro O
^O 3 >s
00 *O <1) - -P CO 3 -r-
U- CU -Q CT>
•— P- CU
CU CL r— •> rvr
P S ro 1 —
CU O OO CU
p— U -P CT> -C
Q. -P- P- p
§CU T3
-C 3 >- +•>
OproU.rO
• •!
I co
o) cu
p P
re ro
P P
to to
P >»
0 JC?
cu
t- -a
£- 0)
O P
O 0
cu
O t-
-P C.
o
to u
•P
i- CU
0 -Q
4- .
4- O r—
CU P p-
1
4- co ee.
O OJ ~^
•p- <
to o
3 C t-
P CU CU
rO -p- -O
P O C
CO -r- 3
4-
CU CU T3
-C "O CU
-P •!-
C p -p-
0 -P- P
L. C=
a: o cu
=C T- -a
o «- -p-
OL
O O)
-P O £-
•p- ro
-P 4-
t_ -p- CU
O O CO
a. cu cu
CU Q--C
a: co P
P
CU
O)
c
o
cu
OS
10
-------
V
U-
O
<
I—4
a
OC.
o
o
UJ
cr
UJ
on
UJ
a
o
o
oo
f.
a.
oo
LU
as
oo
UJ
y
UJ
^fc
I— 1
t—
CJ
UJ
-3
CO
0
A
oo
cr
^
ro
cvj
A
I—
cr
o
CO
r—
C
•^
^*
-P
•r-
s
a:
i^
o
o
•P
-P
£_
O
a.
- to
U_ -r-
r— P
« -r-
C -O
•r- 3
<4- *
CU (O
oo -o
to
c
t- o
0 -i-
»t- p
0
to ra
c_
Q) , — .
-P CVJ
^ *•— *
a: s-
cu
O -P
-P £-
(0
-a 3
cu cr
T3
t. <~
(O U
3t (O
i_ CU
O
<4- CU
3
* -a
to
c >>
O r—
•I— jt
P CU
0 C
**^
Q- i —
i — i • — ••
oo
cu
0)
O 0)
u_ t_
a.
1-1 O
oo -P
to cn
to c
0) -i-
o -o
O t-
s- o
a. o
o
o
o cu
o t-
>.
p—
cu
•p
*o
(_
*o
a.
O)
to
cn
c
•f»
^
O
,__
o
l+-
>
0 r-^
•r- t-
> CU
CU 4->
t ^
a. *
-P O
0 -r-
C i —
0
cu ~*
^
(O l-
JC O
•I-J
-P n3
c—
-P M-
O
c cu
o to
•r- 3
to ro
•r- O
> CU
CU -Q
(_
£_
o cu
i— i 40
oo t-
(O
M- 3
o cr
t- cu
cu JC
o 4-J*
E
3 CJ1
c c
•r"
cu s_
_C"! 3
h- TD
•
rd
•
x^^.
T3
I™
O
C"
C
O
to
c
o
.,_
-p
o
fQ
•*
•
OJ
•
•r*
**~'
C
O
•1—
+->
*XJ
o>
«r~
•P
r—
5*^
L.
O
O^
cu
•p •
fO t_
o cu
4->
c: c_
'r^ fO
3
cn cr
c
•r- CU
i— JC
•— P
<*- cn
c~
•p -I-
O L.
C 3
•a
to
c -o
o cu
•i- JC
to to
•r- -r—
> r-
0) J3
t- 3
a.
IX
t-H C
oo cu
cu
t>« jQ
O
-p
t- o
a> c
f*}
£ QJ
Z3 >
C ^
JC
r.^
c
•f«
£_
3
-a
cu
JC
to
•r-
r^
JD
3
a.
to
c
o
•r™
t/)
•r4
>
OJ
a.
HH
OO
4-
O
^
CU
J2
E
3
C
r-M
(O •
P «-
o cu
-p +->
CU (O
J= 3
I— cr
•
o
A
to
Q-
K*<
OO
4->
C
cu
•r—
O
•i*"
^—
cu
o
+J
to
c
o
•p
0
a>
c.
c_
o
0
T3
cu
-p
'r~
c
^
3
to
1
CU
•p
-p
to
>>
1—
c
o
to
r^
.-0 (0
i— C
3 O
cn-i-
0) cn
c- cu
cc.
•o
CU TD
•P C
•P r.
E «
ja to
3 T3
to t.
CU "O
-P C
(O (O
-p -p
to to
to
cu c
o o
Q •!-
CO
to
• •!—
to E
•P CU
c
§A
«
C7
r_ •
•P
-------
U.
<
I-H
Q
O
LU
O
o
LU
o-
LU
OC.
LU
LU
O
0
O
00
Q.
00
LU
rf
~~^
oo
^^
LU
z:
LU
t— *
h-
O
LU
co
0
^.
oo
CM
•»
^—
0-
^.
co
CM
•t
^—
Or
, en
c
•t—
to i—
3 ro
(0 C
O O
•i—
CU 0>
C_ cu
rO rv
•P -O
tJ C.
jf^ n$
-i->
1 — c_
_O rO
O 3
t- CT
CLT3 OO
rO LU
CO CO O
p" ZC *— ••
-P U.
CO LU
C£. <4- JE O
>
-0 rO
,— .
r— CO
fO -Q
t_
CU O) •
C C CO
CO T- I—
O) to CU
CO >
ro CU CU
U i—
•r- Q. 0
0 0. C
t_ i— i M_
Q- OO O
>.
,__ *
•P >»
c C
CO O
L. C
3 CO
O >
E
CO •!-
c
o cu
••- JC
t/) 4-5
•r™
> c
CO •!-
c.
to
Q- C
i— i O
OO •!-
to
14- -r-
o •>
CO
to £—
3
4-> r—
tO r—
4-> > en
o «- c
O -r-
0 4-> 5
^ C 0
CO i—
>> > <—
r—^ <= 0
-E -I- >4-
-P
C O- CO
O i— • -E
•P CO -P
C- .E t-
0 -P 0
0. 0-
cu c cu
at. •<- t.
O)
c
• ^
to
CO
CO
0
o
a.
c
o
CO
o
E
*o
•o
•r™
3
CD
C
•^
-a
CO
c
• r™
14-
co
-o
to
ro
*,^r
c_
o
(O
E
14-
0
t_
O)
o
E
3
C
CO
.E
h-
«
ro
E
O
•r—
-P
U
-o
CO
to
0
a.
0
t_
a.
o
c
^
0
•r-*
f^
•g.
e.
o
14-
to
c
0
•^*
t/)
•^
>
CO
c.
Q.
i— i
oo
^— ^
to
E
O
•r-
CO
•f—
>
CU
o:
a.
i— i
OO
cu
•P
rO
O)
f—
4->
t
14-
to
f~
-P
c
o
E
CU
*,—
14-
co
c_
CO
-p •
t_ CO
rO -P
3 ro
CT-P
-a to
o
_a co
u,
to
ro 14-
^= O
•73
CO
to
o
a.
o
t_
a.
o
c
e~
U
c~
^
t^,
O
00
c
o
•r™
(/)
•r"
>
CO
t_
Q-
KH
00
14-
o
t_
CO
f^
E
c
^~
fl3
4->
o
-p
CO
.e
i—
a
-Q
CO
f—
I ^
c_
«i
to
i %
E
O
E
CO
•r™
^.^
CO
L.
CU
-p
t_
rO •
3 CO
CT-P
"T3 rtJ
(O -M
a> tn
T*
CO
O -E
-p -p
•P E
c o
CO t-
tO >4—
E -p
CO Q.
CO -i-
.0 CO
o
to co
ra C-
f—
14-
E O
o
•r- CO
•p -p
U rO
<0 -0
C C
0
0
•r- CO
-E > •
2 >r~ r^
14— rO
t- to
O to O
14- s- a.
CO O
CO 4-> t-
E t- Q.
O rO
•r- 3 14-
co cr o
•r— "O
> (O E
CU CU O
t_ a: -i-
-P
a. o ro
•— « -P O
oo -i-
+^ —
i- E JD
O CU 3
-5 to a.
rO
E E
5 >p""
<4-
u.
O CO •
14— &~ ^~
O) ro
tO 4-> CO
E t_ O
O ro Q.
•^30
to O^ t-
-.- -O Q.
> ra
0) CU 14-
t- 3T 0
Q. O E
>-" -4-> O
00 T-
P P
4- E (O
O CU 0
CO •!-
t- i—
CU E XJ
J3 CO 3
E CO Q.
3 _n
E «C
tO Q-
i — ro LU
rO f~
-P 4-
O E O
•P O
•r- CO
CO .p 4->
.C O ro
1— rO -O
«
•a
o
•4-*
*4—
•o o
CO 4-
-O 0 E
t- O
(O CO T-
? -^ tJ
*» (O ^o
O T3 0
(4- .,-
CU -—
CU -E JD
t- 4-> 3
cu a.
to
•P t- -
si a.
-P tO LU
to
CO CU 14-
E i— O
O
•r- t- (U
to o -P
•c- ro
> CO "O
CU -E
C- -4-> £_
E O
Q- O
i— ( E CO
oo -P
CO 4J
O T- tO
""^ 4-~
ra CO
E E -E
<4-
O to E
£- O
t- d) t_
CO -P 4-
f*» u.
E <0 -P
3 3 Q.
-O CO
CO ro O
-E CO CO
1— I t-
v
a>
•
r™
ro
to
O
a.
0
c_
a.
VD
I
-------
U.
Q
a
oc.
O
LU
O
o
rfE>
LU
o-
LU
eg
""
LU
0
O
O
CO
CL
CO
LU
OS
(^
^£
LU
£
LU
i— i
|__
0
LU
>™5
QQ
O
^.
OO
3s -P
fc. re
o -o
<4-
O)
(U JC
(U
S g
•P L.
re *-
r:
P to
to
(U
C t—
o
•I- t_
to O
•r-
> to
O) -C
t- -p
c
CL O
(•H P£
co
O)
<*- >
O -r-
tt—
t_
0) C
"i""
3 (0
C t.
i— a:
•
<*-
t|^
O
C
o
•I—
•P CO
re s:
U CL
•i- CO
r—
-O O)
3 JC
Q. P
to 0)
t-
< 0
Q. <*-
LU 01
-0
«f-
o -o
O>
D 13
4J *r~
re o
T3 O>
•o
t_
O 0)
n
ca. to to
U O O) O)
a» t. t_ s_
«- 3. 33
ret fO
ni d)
^ E
OL.
*— i
CO
CT
4-> C
o; -r-
(V -M
B ^_>
(/) *r~
a. t/> £
1-1 0) -Q
C +J
O tO L.
•r- O
P -P <4-
o re
< J= to
p a>
r^ p»
re a) 3
••- t_ -a
O 3 (U
0) to jC
a. co
co LU to
01 C
.e o
4-> d)
a; -P
t_ o re
o c o
••4- re o
•a c —
C -r- -1- r—
o 3 re
•i- en -o
en dj ~o
a> o> i- c
oi ~o o; re
•i- >
SI. > O •
O O O to
re (- to
DO- • O t-
it«
o
^
u
o
a.
a.
3
to
L.
0
tv-
c
0
•r—
O>
O)
to +J CLCtf
p<
^^
o
•a
a>
to
.^
>
•i- C
+j
r—
•r- C
to p n
c re £
O en QJ
•i- i — C-
tO 3 T—
•r- S 3
> o a-
a> <_ a>
t- n. t-
to P
•o c to ai
c re n jc
3 +J O .p
<4- 3 t_
^- 30)
+J <— OP
co to re
re a. •<-
t ^D P
en t_ c -i-
•r- re c
LO re *^
O to
i— I i — • +J O
re to c -P
coat re
o o c -P to
•r- ^ O 3 C
•P ---. P r— O
O O> 10 i— -r-
ai P a) o en
to re i — a. ai
•P •!- OS
r~ to E j^
oo to >>
cr> tj_ TQ -1-4-
r- O C L. •<-
re i P
>- +-> JC O
u. c to en c
0) O) -i-
re o -r- P oo
o c t_ o ^H
1— C •!- I—
r— C l_ O) >•
«C O) Ok CO U.
to
3
O
•a
, — t_
4-> re re
t- U M
o o re
a. r— s:
OL
3 -O tO
to c to
re at
c. ^
O 0) T3 •
— -p -a to
-a re re -P
C p C
re to o re
p P
-CO) 3
tO > l/> r—
•r— *r— £ r—
r- -P re o
J3 O S_ d.
re at en
•P 4- 0 i-
10 <4- L. -r-
LU at a. re
JC
u co
re 1 1 i
O) O
t— i
0 Ll_
P LU
O
to
-o _i
c <
3 Z
t^» • CO
tO I— 1
p 0) CD
C T- LU
re 4-> o£
t_ T-
cn >
•^•> p
C3 0
i-i re
C r—
o re
•r- O
P 0
O r—
O>
(/> T3
C
OO
O^ OJ
I-I -p
re
>- -P
U- to
c_ •
re o
c
**— 0)
o en
re
•p
C r-
ai re
ftj
o
O r—
c
re oi
^: ^
c re
O) -i-
t_
t- a.
0 O
a.
to a.
•a re
c
3 -a
t)- C
re
P
c ai
re P
c_ re
O^ 4-*
to
LO
o j=
•— o
re
c a>
o
•i- 0
-p p
o
0) to
to at
•r—
r^ +j
00 •!-
Cft r—
r» •r-
r\
>- re
U- Q.
re
a> u
^->
•TJ tO
0 0
O •!-
r— X
r— 0
< -P
-------
D
<
r-H
Q
OS
a
U.
o
>_
0
LU
ZZD
cr
LU
Lu
LU
Q
O
O
oo
2:
QL.
oo
CVJ
cr
«*
cr
«t
r— •
cr
"^
oo
CVJ
•»
i —
Cr
1 .C
0) .p
£_ C_
CT> C O
re o
Q.
-P CO O
C CO r—
re
s_ s_ >
^^ ^^ ^
o -o
O) U
P Q. 0
re .p
•P CO
LU
oi
:->
^£
LU
LU
t^
J—
0
LU
•-3
CO
o
CO .C O>
•P P
r— re
re <«- -P
3 O 01
•o
•r- C _C
> O O
-0 -P O)
c a.
•r— «r— >v
C- -Q
O> O
<— (/) g~
•P O CO
"O ^
<*- re
o re -P
>>'~^ CO
«- r— T3
re — c
E 3
e
3 0) E
^1 "^3 ^
3 u.
re •— 01
O 0
OS C S-
< T- .1
O
-P t-
O rO (O
•4-J .c^ d)
4-5 >s
-M 1
.p- r/) T—
E -P -P
.0 C r-
3 O) 3
oo E E
•o
c
re
v/
t -P
o a> c
5 co re
a> t_
t- .C O)
O 1—
>> o
<_ . r—
re co
E re c
E a> o
•=> f- •>-
co re -P
0
re o a>
i— 1 CO
••-^ i
CVJ CO T3
», * Q)
C -P
"O T— re
C £
re co -r-
-* -P
E •- CO
re (-
L. ai
O1 "O "O
0 C 3
t_ re r—
Q. 0
CO C
00 C T~
o o
•r- ••- "O
X CO r-
O CO 3
-P -i- O
E f~
Up d) CO
•r—
re co co
CO P
t_ 0) t-
•i- CO O
a> co a.
-C H3 O>
•p <~
a
,
0 <-
c: co re
re c E
c— re E
£= r— 3
O) O. CO
1
•r—
^ ^~
•r- LU
O C
re '^~
r- -O
fO (U
u ^->
•r— Q)
-P r—
•r- 2L
(_ E
U O
o
c_
o a>
i»- jQ
CO O
D -p
-P
re co
"O d)
c
c o
0 -P
•i- co
P OJ
u •—
r-— *r"
a. e
a>
u c.
o
•P E
c
re (~
> o
a>
r- O)
0) C
t- o
-a o>
c c
re -r-
T3
CO 3
C O
3 C
**— T-
a> « •
+J co r^.
re a) oo
•P -r- CT>
CO -P r—
c_
o
c
o
•r""
+J
rO
C7*
0)
'a!
en
c
•r-
4-*
2.
a>
u
o
re
CO
a>
re
-P
CO
*t—
o
u,
0)
E co
3 00
c a.
oo
0) Z
-C
-p -a
c
a: re
^£
O CO
Qu
0 ^>
o; c
CO
X3 0)
C -r-
re -p
•r—
C r—
O -r-
•r" f*l
-P T-
re co
•p c
c o
a>
i— t-
ex
e -p
•r- C
1^. ^
CO C_
C 0
C- C
1—
'D
L
0)
o
{_
3
O
CO
i
O)
c
i.
0
*»—
•
CO
O)
(J
c
(U
a>
>-P
^3 (& (O **~^
C -O «- •
-p o re d>
c en -P
O 00 (.
u c re o
•i- OL
§£: T3 O)
-p d> L.
C_ T- CO
"4- 3: co a>
a> .a
re ai u.
-P O Q. O
re -r- x -P
-O
2: air-
M- O O) -C
O -r- O O
en t- co
a> a> a>
^> o£ ^ re
re ^^ *p
•p d) re
C J= -0
a> -P •
o t- oo
t- o a> s
3 co
-C 4J O- 3
4-> u. 0
O O) 3
as Q.-C c
-P T-
o t. ^
<4- C
O CO O O
-Pi- U
a> ~o
4-> N C O)
< >^ CO f~
Or— P
a. re ai
a> c jc v»-
os re +J o
•a o
c
re oo M-
c. o
>> o o
i — .(j T- 4J
d) -P c~
E cy re aj
•r- 00 C E
4-^ re T— c
Eip—
re
a> re tu -P
4.) 4.) -(_> 4_>
at re CD re
•— T3 -a
O- T3
§00 >, C
y1 ^« frj
o =c ai
Z E to
re T- -a
0) -P C
O) -P O)
-o re D t-
•r- t_ r— +J
> 3 J2
o o re i-
t- O C -r-
^ re co re
c
•r~
-C
•p
t- •!-
3 2
O
.£Z 0)
1 U
^^ *r"
CVJ 4-
E 0
O
t_ r—
<*- re
c
re o
-P T-
-O O)
as
OO
s: m
Z -P
M- O
O +J
O) "O
O> O)
re -p
-P t-
C 0
ai a.
0 OJ
c. c_
O)
o. oo
c_
re -r- 4->
^: re
-o -p t-
CU T- 01
oo 3 a)
CO 4->
o> -o c
£_ O) T-
CL-P
X t- t_
O) O 3
Q. 0
at cu -C
O) C- 1
re *s-
+j re cvj
C P
d) re r—
o -o re
i- -P
O) OO O
a. S -P
**-^ ^c
Z O
-p
« -o
t_ O) t-
a> 4-> ai
•p re +->
!_(_£_
re 01 re
3 a> 3
o"^-> or
c
O> -r- O)
^: ^:
-p t- -P
3
a>
O)
D -C >T- >,
re -p re
TO re -o
0 0
o> re en
^— ^
•
-o
a>
-p
0
o.
0)
c_
O)
o
-o
a>
3
-o
0)
u
CO
re
4->
re
•o
OO
s:
-------
U.
<
1-^
a
<
u.
o
o
Ul
cr
Ul
u.
Ul
o
o
o
oo
o.
OO
Ul
~^
(/)
^£
Ul
z:
Ul
1—
o
CO
0
„.
oo
CM
,
0"
^j.
cr
CM <*
r— CO
cr
o
03
3 ««
O 01
U f—
t-
C
TO *>>
-i->
C -r—
o i—
•i- 03
Ol 3
•r~ O"
0
O) TO
t- -p
Q. (O
T3
p.— ^)
cu o
E =
•i- O)
4-> O>
<
O Cn
c
O> •<-
Ol-P
(O O)
•P 01
c e
0)
o -— »
t- -p
O) C
Q. (C
-p
0) 3
.C r—
-P r—
o
C£. 0.
O >>
JD
O ^_-
4J
to
•P -P
C. C.
o o
Q. Q.
O> 0)
Qi f-
i— Ol
J")
• E
I— 3
C
t_
O) i—
-Q TO
E •P
O) O
> -P
O
C"
>. ^_j
r*»
O
•D -P
O)
3 0
O1 -r—
O) 4->
•r- 03
i,
O)
<•> n3
O 01
4-^ TO
O) T3
U O)
C Ol
,•0 O1 ' — -
TJ O) •
•r- t_ T3
3 O. U
u> x s-
O) -r-
O 3
•P o> cr
en D
C 4->
•r- C O1
-a a> 4->
t- 0 C_
o t. o
u ai a.
O CL. O)
TO ~— ' L.
^_
01 C-
t~ 0
0) 4->
N (9
^i *
i— O
c n3
TO r—
O1 >»-
3 O
O
3 01
c a>
•r- 0
-P 0)
C •!-
O Q.
o
ai
JC C
-P O
N
01 -a
•r—
>> x
S o
c
o^ C3
< E
0
C
o o
•P .a
4«> fl3
C 0
o
a. t-
o> o
a: t-
o?
TO
s^^
t_
TO
C^
^^
r—
TO
O
01
•r-
t4_
O)
r*
4-»
s71
C
•r-
t_
3
-a
•o
O)
o
r»
Q.
1)
t_
-^">
f.^
r»
TO
3
4->
0
C
0)
f*X
•^
3
O)
-C
4J
C-
Ol
TD
C
3
O1
4->
•a
3
TO
0)
C
•r-
^
O
^)
•r—
C
O
E
4->
C
u
a>
t_
-p
o
O)
f.
-p
c
•r-
-o
o>
4-
• ! —
J *
C
a>
s—**
h-
•
•P
t/>
>k
t^
-*->
•f—
•a
3
<£
C_
•r-
*C
,_
TO
C
O
• T—
4->
C^ T3 'O
O)
•r™
Z.
^
00
r_
>fc
JD *
(—
c
O U
*^* ^
4-> J2
^O E
t_ Ol
ai >
a. o
o -z.
•^ >>
<~ 3
o
5 *o
4-> O)
O) 3
c to
I/)
O-r-
f— «|
s: oi
a. ^2
O) O
C" 4-*
4->
ai
<4- O
o c
TO
Ol TD
3 •!-
•P 3
-P
Ol O
•P
0)
_c^ 01
4-» C
•r-
a: -a
0 0
o
0 0
•P TO
4-> •
(- 0)
O 4->
t^ TO
O) -P
a: to
c
t_
O
4->
C
g
o
r- f
Q.
Ul Ol
t— (_
^3 O
TO S
•P 4J
LO 0)
Ul C
C
•r-
r_
Q.
E
Ul
<*-
0
D
a.
^^
•P
A
Ol
0)
4->
•r™
Ol
4-
Q
t-
cu
E
3
C
a>
j=
•p
0)
-a
3
i—
O
•r—
!—
r^
•I—
3-
4->
^
O
Q.
O)
£_
0)
f^
1—
" —
01
r— t_
TO O
•r~ 4-^
4-> '^*
TO C
to e
"O 4—
c o
TO
C-
>> O)
o *^
c E
at 3
3 C
a-
a> o>
C- -C
4- 4->
en o)
C T3
•i- 3
^_ ^—
a. o
E c
TO •!-
01
O
A Ol
10 r-
O> TO
4->
TO r—
T3 i—
• r—
C ^
o
•i- 4J
4J «-
TO O
t- a.
0) 0>
o. t-
o
Ol
A C^
4J H-
ai
e •
Q. O)
•r* ^-"
3 TO
CT U
O) 01
^
01
.0
E
3
C
a>
-C
4J
Ol
TO
P—
r—
O)
5
Ol
TO
A
C
o
•r—
•4-*
TO
t.
O>
OL
0
C
• r*
T3
C
ft)
[-»•.
oo
Ol
p—
>-
u.
c
•I—
"8
t/)
rd
j^
U
U
3
Q.
>^^
j—
v_^»
x— X
•
fO
T3
a>
c
•p-
4->
£_
0
a.
0)
^
01
c_
0
4^
•r-
C
o
E
01
c
•r"
4->
TO
^
Ol
a.
o
4-
°
ai
(O
01
01
cr
(U
(_
3
O1
-------
•
U.
<
I—1
o
on
u.
o
UJ
o
o
LU
— ^
Or
111
LU
Oi
u.
LU
O
O
o
oo
Q.
oo
LU
Of.
•=3
oo
i^
LU
LU
i— <
1—
O
LU
*~5
oo
O
oo
O'
,3.
cr
1— 1
cr
oo
cr
o
t_
3
o
to
i *
c
•r—
0
0.
E
o
-p *
to •
^i C3
00 Of.
O
(0
•P 0
(0 -P
Q
C_
Of. CO)
< o >
O •<- -r-
CO ( —
CO Ol
•i- "O
E
1 1 1 -0
c
r- 19
(O
c •>
0
fc
oo
oo
•P '^
(0 r-
Z T3
r*"
JD
^_
Q. (O
§^J
(O
O "O
to a.
ai a.
tO Q. O
C C-
O t- +J
•I- O -r-
•P <»- C
(0
>_x< (1) .
o -o t-
•P O X OJ
(0 -P O >,
TJ T-
x^^ 'Q CM
•o to a)
O) 3 C_ Q.
t- P 3
•r- (O it- 01
3 -P •— C
O" CO 3 O
o> to +j
t_ c
O 4- O
P -r- O O
•r- P r-l
E TJ CO
J3 S C C
3 C O
•^ 0) -P
* E *o
P OJ t— 0)
O -P to 3 C7»
t. >,P
t- 00 0 to
O fO O
O ^J C5
1 ^ ^m ^^
M (O -P
-* 0 -^ t-
O SO
<1J C
.c o to •
o T- oi to
CO O CD
-P to c_ -o
•1- •!- 3 -r-
-0 E O X
LU LU t/) O
i *
•r-
f—
(O
3
cr
o
4^
CO
O)
CO
c
o
Q.
to
QJ
c_
O)
+3
(0
^_>
CO
(4»
O
IX.
o
o
^_>
1— *
re •
•P CO
•P E
•r- 0)
-Q
C O
ITJ C_
t- a.
J^A
0}
>
3 J?
cr
(U
OJ 0
x: c
P *XJ
•o
c: -r-
•i- 3
.c. en
•i- C
^ *r~
'O "O
P a>
ra T3
T3 -r-
C O
O C-
•r- Q.
-P
at cu
r- -Q
a.
o ^~
0 ••-
T3
0) OJ
•r- 3
3 tO
a* fc
r—
3
C
0)
_c~
«!->
o
i-H
-------
m
U.
Qi
a
O
<
>—I
a
U.
O
Ul
o
o
z
Ul
GT
UI
OC.
LL.
LU
a
o
o
00
a.
00
Ul
ae
00
Ul
2:
Ul
1— 1
1—
o
Ul
•-3
CO
o
CM OO
cr or
**
A
CM CO
cr cr
CM •*
« A
r- CO
cr
t«
•r-
>, (O
•r- 00
i— as
>
JZ CO
O) CO
-P • •!- >>
01 E r— .p
,_ o> ja •!-
Q..P » to 3
o co ui cr
V,
• 1—
r— .
(O CO
3 t_
cr 01
£ « .
(O 3 CO
cr 01
oo -o o
a; > =
•— i to nj
c
o
•r*
* to
• (/)
t/) *f~*
(U £
•<-> flj
•r—
to u
*p"
en x
C 0
•!"• -^
'o. i-
E T-
00
r- C
ft} •r*
C i—
O -r> (/>
•r- Q. Ul
P E O
"O O U.
T3 U.
-l
Ol 3 C3
E T3 Ul
C Ol Q£
OO O
•r- O
r— L.
J3 Q.
03
P U
co O
Ol
Ol
J2 T—
r_ •
co 01 co
2: -o 01
< -I- •^•
(- 3 «-
cn o
T3 4->
C Ol C
IO 3 Ol
Q. CO >
X 00 C
Ul I-H •!-
C >> t-
0 r— -^-
O "f~ r*™ *O
•P -P (0
(T) *r~ r« O
TD O -P -P o o o
Ol -r- -P • O-r— 4->
O» -P O CO Q.
C C 3.-P 3 T3 CO
0> C CO C CO
to -O 4- «3 00 C
t™ 00 *O *r™ *^ E *a
"O Ol OO r— -P tJ -P
Ci— (OO jDOt-3
fO Ol '^ *T5 Ol Cn r~* •
O.O-OX 4J4-Oi—
XOCO 004-UO
UJ (O r>3 P UIOIQ.Q.
•— Ol
(O O
•pec
$_ O (O
(O *r~ XJ
Q.+J •!-
(O 3
> CTJD
r- r— 0) 0
r— ^ ^ ^-)
rtj Ol « O
•P 0
§t_ JkJ
(O C a;
t- 3 (O «f
4- CTCQ O
(O to (O >,
•P ~ -P ^
(O Ol (O
-O -P Q XI
Ol 4- C-
p cf> co o en
C C 3 O
O) -i- P £-
•r- «_ t_ J= 0.
Q fO O O^
E a. <«-•!- >>
(DO) 00 4_
t_ T3 t- O
OO. C 01 -P
r-l « > (O
s: = o r-
a. -i- O) 3
co i— en
XI ^1 ^ C t—
•r- 00 O
> 3
tJ
c
•r—
XJ
L_
o
o
CO
*
-------
a
<
I—(
o
Qi
o
LU
cr
LU
LU-
LU
o
o
o
a.
oo
LU
a:
"^
oo
^^
LU
s:
LU
^»
I-H
f~
O
LU
co
o
_
cr
ro ro
CM CM
^ ^
Or cr
^.
oo
CM
^
cr
cn
c
•r—
t_
CU
a.
E
id
i »
i
•r—
-P
C
id
»+_
o
c
o
p
id
-p oo
C LU
CU O
E —•
CU U_
r— U.
a: O. O
< E
0 -r- _l
*c
c z
o o
HH
>> UJ
U • LU
•r^ CO C£
i— E
o id
a. i_
cn
>> O
0 S-
C 0.
a)
en cn
< c
i— -E
id o
c P
•r— T—
<«- 3
CO
d) 1
3 i —
CO P
-P 3
C co -P O
-r~ i v "§>
E t- E 3
en o
"O O (/> t.
C t_ 0) -C •
Id Q.I— -P CU
O M-
.C r— -I- CO -r-
co id .c "O i—
•r- U CU C-
r- o > id i—
.Or— -O 3
id p C M-
to "c 5 P co
LU (d P CO 3
CO
C 0 I ">>
O +J CO
J3 -i- C 1
«- cu E f- -P < O.
o cn id -P
•JldfUO C5-CUr—
OJCUt-t- O O r— O
ct--i-a. CCX.J3S-
3 0) -i- -P
•OPcrcn cut_coc
c o cu c -a co
(O ^— ^» *l~* *^ * ^3 ^J
c j= x r^. a.
O>(dr-O OOOCOC
C O •— 4-> CCT>CUO
•r- 'i — »r- O *— t_ -r-
-P -P S X E » cu co
•r- -C O) 1 C JO .C M-
X -P 3 r^ O -P E
dJ ^~ CU -Q P CU
CO (d 3 C- C tt-
cj— id > c^» id CU O dJ
O O) ^-^ O E O
t- c cn c co i_
C- Id Cn C "O •*"• 3 3
d) -i— T- C .TJ +J O
_Q +J CO t- .13 -P Id CO
E c o> N O ^" J^
J= (O O 1 O id -P O
P P S= -r- CU E
-p 2 p $ t- cn
ex: id c cu -i- <4-
*C c "o id c -p co o
O O c o id
C id C "O C o CU
o id c c a.
-p cu r~- id id >> >>
C 00 4- . o i— -P
•>, o crv o +J en t_
r— N r- C CPCUO)
4-O CO) -r-ld+J-C
fl^ >v O E ~P ^ r P
4~> ~O *^ *i — C CO -P Id
t_ C P -i- •!- 3 C
rt3 13 -4^ 'O *T3 ^ (O CD* CD
3 C -P P CU id
crcucuc-p cuidc
"O E Q) *d ^~ ^. O
P -r- C E •— Id C -r-
^ x *i^ cu ^ id o co
O O Id r— O -P -I—
f"» C P r^ fd i— C iv O
a) o P e a> ocu<:cu
CCEid-r-t- LUEOT3
•
c
o
«^
+J
fO
f>
c
(J^
E
O)
f.^
Q.
E
L.
O
C
o
•r-
I i
Id
t
CU
•a
CO
c
o
c_
cu
•a
3
co
^o
t_
cn
f—
id
o
o
-o
c
id
0) --^
P I—
•d — '
i *
CO •
CO
2 E
cu id
c t_
cn
>4- O
o t_
a.
L.
O> cn
<^ ^
E ••-
3 J=
C O
P
to
CO
QJ
cr
a>
£_
-------
o
I—I
<£
»•—*
O
z
o;
u.
o
Ul
>_
0
z
Ul
cr
Ul
CSL
UL.
Ul
Q
O
O
o.
oo
Ul
oc
to
Ul
z:
Ul
t— «
1—
o
Ul
OQ
O
^.
*
CO
•k
t-t CM
Cr cr
ro
•»
OJ
A
•— « *
cr
OO
cr
o>
• c
E -P -r-
3 (-
O "3 O)
t- a.
CL oo O
oo o E P
3 'r— fO »r—
0 > t. -O
•r- O) O> 3
C- C- O «3
O) Q. C_
00 Q-P~
O> 00
T3 .C 00 --^
C +J 3 '•£>
(O O CO
O> *r- O>
r- C t- r-1
(O -I- 0)
US- 00 >-
••-3 U.
P -o -o
•i— C Ol
(_ "O
o v- o c
-p -r- •!-
•PC 4-> £_
00 O) -i-3
•r- -O t- T3
r— ••- U
-o
($ (/) Cf. ^)
E 0 •^-
^ O) t-
•p r~ P "^
•i— -Q 00 P
SO •.- C
t_ r- r—
> t- ro -Q
O OJ T3 O
C_ Q. Q- t-
a. o o Q.
•i- 0
^'•P E
rf «f— (O
t_ (_
t- 0 0)
•i- O «
^C ^^ ^- d
Hi °-e
c c ^.S
O (U I-H O
•^ -0 t-
4J -r- 00 OL
(O 3
Z O O C
.p -^ 0
«U I- "-
.c E a> -P
p c-
OJ OO "O 0)
00 >, C Q.
r> to ^
-o
0)
Q)
u
^— X
O h-
p - —
oo
c •
O 00
•r- E
P (U
u .—
(O J3
O
14— L-
O Q.
00 O>
3 C
P -r-
fO P
P 03
00 t_
O)
0) Q.
J= O
P
P «J
t_ C.
O C7>
0. O
a; c_
a: Q.
oo
^g*
a.
to
• • P—
00 fO
E c
10 ••-
(_ 4-
o>
o a;
c_ c_
Q. O
^.
£ 3) *-H
c c u.
•r- -r- U.
X E O
o C
r- 01 -1
r— -p ^
O O> ~Z.
't- "O O
1— 1
(DO) CO
JC JD Ul
•P ^™* fv*
r— •
t- i— -a
o T- ai
<*- X 3
OO
OO OO 00
P O) •!-
•I- p
•a (O o>
3 -P I-
fQ VI (O
at <*- 01
P O Ol
Ol £-
r— P 3
a. w>
f'r" (Q
1 Q)
0~E
00
c.
3
.. 00
oo (Q
E 0)
TJ E
L_
C7^ t/)
O 2
£• Qw
0.00
2; ^-
"^^ 'O
HH C
•r-
0)4-
c
•r- Ol
2 (-
0 0
1— 4-»
r- Ol
o .a
14-
-a
ai oi
J= C
-P T-
t_ c.
O Ol
^1 1 ^
Ol
oo "a
-p
•r- 01
"O -Q
3
fO r—
r"
Q.T-
3 2
t
5 oo
O Ol
•— p
r—
-------
U.
O
<
I—I
a
LU
CJ
^.
o
z
LU
»^
cr
LU
oc
u.
LU
0
o
oo
a.
00
LU
ce.
oo
LU
s:
UJ
1— 1
t
o
LU
QQ
O
A
CO
A
CM
A
A •»
CO CO
•* •»
CM CM
M «
I— 1
0. Q-
g i— •
O OO
o
o>
c to
•i- CO - —
S •• re co
o co i — oi
(/> I— •!- O •!-
LU r— CO 4->
o o re -r-
i— i 4- _a to i —
U_ 0) •!-
U. Ol >> 0 O
O -C i— t- (O
•P t- 3 <*-
—I O> O
<: 4J 4-> CO i—
z e t_ re
o o re »- t-
i— i a. 3 o a)
f j*i QJ cr *i~"> "o
LU i- re 01
o£, re E *+••
^~
i — > c: <+- •>
•r- O O CO
2 a.
a£ co CO
<4- •
O CO LU Ol CO
o o o oo
r- •— Z C OL.
re -P <: re oo
C (/> H-. v- Z
O ••- —1 i—
•r- -P O. Q. «
o> re s E ci-
ot -P O O •— *
a: co o o oo
CO t
•— Ol
01 S~
Ol 3 .
Ol U
^~ c_ ^^
-&•_ »— *i4^
O)
•t- 0) t-
-C J= -r-
c
re -p re
•P -r- Ol
c s •—
•r- O
re ai
E 0 01
C ^
"O 'O +->
<0 r^ ^*-
0. O
•r- O CO
fO O 4->
4-> C
•(-> *t— <1)
< 0 E
-a
Ol
4_>
o
C Ol
•r- 0. 4.
« co ai
-o to c -P
o> oo -i- t-
-P a. re
0 00 Ol 3
01 z «- cr
a. 01
co « S Oi
CO. C
•r- >— 1 >, O
00 <—
c r— re
oi r-H re
Ol ff. 3 O)
-O -P >
co o re
at u> re sz
> re
re •— -P r-
r* t_j ro i —
• ^-C •!—
-0 4-> 3t
i — CO
3 t--— 01
O Ol CO (_
-C -P O) 3
CO t- •!- CO
re -P re
4-» 3 -i- Q)
re err— S oo
JC -f- v_x Z
•P t- O O
3 re >— <
O 4- • H—
Ol (4- Ol O
O r— 4-> CC
•»- - t_ +j re re
1— 3 C t- -P LU
— ' O Ol Ol CO >
CO O "O •— i
oo oi 01 re i—
z: it- t- <*- '-^ H-
H- -p co co re oo
<_> c o a. , re a
•-< CL. +j z ja -a i
c c
o o
„.,_ aj .^
'-v+j JE: -P co
to o -p re c:
'•»' re r^ o
ro >, oi -r-
— 1 Ol JD QC -P
r-H -P O
•*— ^ re "O i * re
+J Ol C ^
«< CO 3 Ol Ol •
Q- CO = 4-> O>
LU •> co oi re re
E T- 0 4-> r—
>> 3 1- OO
/~i E oi o ^-" re
•r- O re o -p
CO -p +J -i- t_
c re c oo -P re
o - — r- -^, -r- 3
•r- ^- C CT
+j co JT re -r-
O Ol -P (_ *4— Ol
re 4-> <- oi oi c
re o T3 "O o
Ol -P >*- Ot
> co LL. t- re
•r- -P O
•P "O O) C *+— *""
re c co o -P
t- re x •!-
-P re oi -r- s
CO x-^ -r- O) T3
•r- O t_ +J C T3
c oo oi -p oi oi
•i- •— 1 -P •!- CL 4->
E •<- e Q. «-
XJ •> «- E re o
re r-~ o o a.
IO O Ol Ol
(4— rH 4-) Ol ^
o oi a>oo
« m C O>
^_ ,~^ g£ T— r^
a) -a i- «
.a • — -P oi a.r—
E oo co oi -r- i —
3 rH 3 4-> J= -r-
Z r-H E OO CO 3
t/)
+•>
0)
c_
(O
-------
m
U.
<
t—*
o
>_
o
z
LU
o-
LU
oe
u_
LU
O
o
1
UJ
CD
00
LU
*:
LlJ
>
HH
t—
o
LU
T
QQ
O
•t
co
•«
CM
•i
i-H •?»•
•t
co
A
CM
A
1-H
^
«*•
0
^
>fc
o -a
C Ol
QJ r™"
OVr-
Ol CO
P Ol
03 to
P *0
CO U
§»4-
o
t-
*4— CM
Ol
CO -O
*O 3
C- C
c
CO T3
14- C
Ol <0
c_
r«
r" • (0
•i- 4.
> 0)
•i- C
U Ol
13
O)
P ^1
03 Ol
-P C
to t.
O
OO <4- -P
_l O -P
^c *^
oc t-
oc 01 01
LU -Q -P
LU £03
LU 3 P
ec. z to
^^
0) 0.
JC LU
(- E 3
3 O
•> C (.
O JC
CO 0» P
1— £
< 1— "0
Ol
p
P to O
«_ 0) Q.
3 P Ol
O (0 t.
O .p
co Ol
Ol -Q
P *
(O O r—
P ^4— r~
tO •!••
CO 2
C O>
•r- C CO
•r~ r™
r™ f 'O
10 ••- t-
Oi 0)
C i— <4-
Ol » E •—
c LT c
t- O •!-
o s
-p <*_ -r-
p O C.
< 0
«_ ^
Ol 0) r—
P ^a -i-
P 3 'I-
co c u
i
c_
(O
3
cr
01
c
o
03
^
•r-
2
•^
Ol
^>
u.
o
0.
Ol
t_
Ol
n
,—
,«
*^-
^
00
C
O
(p*
1 *
o
ID
Ol
P •
•P Oi
tO 03
r—
10
• p
1— 03
LU -O
O Ol
a p
o>
c
•^
c
t.
3
P
Ol
c.
CO
-o
03
^_>
\s
t_
O
,_
r^
•r-
J
01
QJ
^_>
(^
^>
00
a>
i %
-o
c
CO
Ol
u
*v-
t^.
o
,^
00
c
0
a>
Ol
QC
0
CO
(_
o
03
15
•^
.,_>
C
03
O
«r—
<4-
•r—
C
a>
•r*
CO
C
L.
3
1 *
01
•X
*
01
u
c
(O
•r-
r_
a.
u
o
to
^,
o
ITJ
'o
•r™
>
LU
-P CO
C <
10 CO
O
•r- O
14- H-«
c <:
01 Z
•r- >-
co O
o
CO
C
E
t_
3
CV •
^ -4-^
^j
JC ct
4_>
•i- t-
% "t~-*
i— 0)
c. to
P 3
C- CO
fQ
3 «3
o-
Ol
ITJ (-
tj
C
O co
L_
OH 0
O rtJ
o 'o
j^
c
O P
•r- C
P ITJ
(0
C CO
•r- Ol
O P
,— i—
O ••-
<4- O
Ol <4_
•P i—
TJ
_[._* ^
t- 0)
o -o
Q. Ol
Ol Lu
0* »_«
0)
f^
•o
r- -0
3 C
O (0
^*
to 01
CO
Ol Ol
JZ >
t— -r-
C
3
Ol O
CO -c-
t_ {=
ai i3
> c
c£
3
^ ^3
O +J
P O
(0 P
f—
o P
P «-
C Ol
0 C
••- 3
(^
•r- 0)
C t- ••
ai 01 ^^
"--=>>
to i —
-O Ol
r- CO P
i — P 10
10 t. (_
^* ^3 'O
o> a. a.
> Ol Ol
o «- to
Ol •
r— t-
/^ ^)
03 P
P t-
Q. (0
Ol 3
0 (T
U
(0 O)
t—
C P
10
O 0)
•4-* ^>
r— CO
O -C
•r- -P
•P
+J 10
C
10 Ol
0 r—
•r- 3
"*- "O
•r- CO
C -C
O> O
•r- CO
CO
Ol
14- U
O C
10
<- T-
Ol r—
-Q O.
3 0
Z 0
10
GO
C
•i—
t-
3
•o
CO
£^
0
^J
C
a;
•o
i
>t
r—
1 .
c c_
a>
<4- P
0 t-
10
t. 3
01 a-
^*)
§cu
^
J^ 4J
J3
* *
L.
Ol
P
10
3
or
CJ)
c
t^
^
3
•a
T3
Ol
>•
f-~
0
to
Ol
L.
CO
^
o
p
,—
o
•r—
>
P
c
(0
o
•r-
14-
•r-
C
•?
to
t>«
o
t_
ai
{**
E
3
Z
.
O
C
o
•p"
00
00
•r-
§
r~
TJ
C
•r-
'+—
0>
c
*|M
^
•f"
^
CJ
^0
CO
£_
O
P
IO
r>—
o
•t- •
> to
C
*4— O
O -r-
P
t- 10
Ol P
.0 -r-
E E
3 -i-
Z i—
0
in
-------
U.
a:
Q
<
I—I
a
a:
cc.
U.
o
Ul
o
>.
o
Ul
o-
III
UJ
QC
U.
Ul
a
o
o
00
Q-
oo
LU
Q£
ID
00
^£
Ul
s:
Ul
i— i
i—
C_5
Ul
CQ
O
•t
ro
OJ
^m,-)
cr
^"
Ol
0
C
(0
4|>_
r_
a.
Q
U
Ol
f>
rO
( >
a.
O)
0
o
ro
C
(0
c
o
-o
Ol
o
rO
r—
a.
t/>
t_
o
i *
CO
i—
O
•r™
>
<4- •
O
E f~
3 O
Z 10
0
Ol
u
c •
fO •'••^
•r- O
Q.J3
§-4>
1—
<***
•P ro
C -P
(O ^_
o ai
•r- O
H— o
•r- (O
C
cn c
•r- (O
to
c
<4- O
0
I- O
01 C
_a
E -o
3 C
•
13
j*-^,
I—
LU
00
^£
CQ
O
Ul
X
1— 4
u.
Ol
o
c
c^,
0
+J
^_
o
kr.
>
^>
c
<«
u
•r™
**-
•r~
C
Ol
•^
(X)
^f—
o
to
3
4^
ro
-P
Q)
g*
+J
,_yf
o
re
c_
1—
c
lO
o
•r-
(4—
(/) *r—
01 C
•r™ C7J
+J -r-
•1- 10
r-~
•r- r—
0 i—
ra ra
<4- (-
Ol
r- >
(O O
t-
Ol Ol
-a -c
Ol +J
u.
^ -. i^
o
^
(O -P
Ol O)
»> to
i — 3
ra to
o
I/)
ro
O>r—
C O
•r— *^
C >
C
•r- -P
O) C
0) ra
.a o
O) 4-
_^" »p™
-P C
cn
ro co
Ol
C"
4-*
t.
QJ
T3
C
3
Ol
L.
01
-C
TD
Ol
^J
t_
O
CL
01
O)
o
-o ••
r— '^~^1»
3 >>
O r—
-C Ol
to -p
ra
>. t_
Ol (O
jc a.
1— 01
• ^3
Ol ^^
to ra
c_
0) Ol
> to
•I- <_
C Ol
3 >
•r-
(- cr
O 3
4J
fO ^-—
r- fO
O 4->
••- o
> -p
c
o
• f—
to
(O
•r-
E
Ol
(—
fO
c
•r™
4-
CT)
c
•r™
>
Ol
•r™
-C
o
fO
01
t_
o
,l_>
r«
r—
0
•i—
>
4J
C
*o
a
•r"
t^
•r-
C
cn
•r1" •
CO CO
c
<4- O
O •.-
l_ ra
O) -P
£5 «|—
E E
3 •!-
^^* f—
•
ra
0)
r—
.a
ra
•P
a.
Ol
u
u
(O
i—
O
>r»
>
-»->
C
fO
o
*r—
*4—
•r—
C
a>
•r™
(/)
*4— •
O Ol
t- Is
01 -a
jQ Ol
E ^
3 0
z to
•
.a
•p
c
Ol
o
l_
o
c
Ol
o
4^
4_)
o
Ol
J3
3
to
to
t-
o
+J
ro
r«
O
•r—
^_>
C
ro
O
•r-
4-
•r-
C
a>
•r—
«[
O
(^
01
JO
E
3
•
O
•
r—
rO
c_
s_
OJ
4—
Ol
O)
to
ro
O
t_
O
c_
a>
•a oo
t_ Ul
o • o
s—^ t~H
O) 10 U.
> c u.
•r- O O
-P •!-
rO 4-> _J
J_ -r- <
-PC z
tO •!— O
•r** tt— **H*
C Ol CS
•r- -a ui
E ex
-a t-
ro 0
A
• X
Ol T-
. -a
•r- C
^ Ol
a.
c a.
0 <
+J Ol
o 01
ro oo
v
Ol
•p
•^
c_
Ol
rO
r—
(O
•p
ra
•a
Ol
c
>r_
O)
ai
T3
Ol
o
i—
*
to •
3 tO
O £
3 ra
C C-
-P O
c c.
o a.
o
o>
•P U
c c
Ol r—
r- Q.
a. E
E o
I-H O
-M
OJ
CO
C
o
5)
0)
a;
a>
c_
(U
£_
C/)
O)
3
IO
a;
(/»
(U
-------
Q
<
t—I
Q
a;
i—i
«=c
._
o
LU
Or
LU
oc
u_
LU
a
o
o
co
CO
UJ
C£.
CO
^£
LU
^f
LU
H- 4
1—
0
LU
•-3
00
O
CO
INJ"
r— 1
cr
^»
o
o
jj_>
x- x
>.
i—
GJ
+J
fO
u
fO
a.
(U
CO
**^*
T3
+J
03
•^3
O>
JJ_>
ro
jj_>
trt
•a
c
03
^
a.
LU
en
c
•r-
2:
O
r~_
O
M-
£1)
_c
^_>
4_>
C.
0
a.
at
06
t
p—
0
£_
0
O
^
o
4—
to
c
o
•p-
1 *
(O
r_
3
0>
0)
&H
(U
o
o
c
LU
to
c
o
•r-
) *
«3
"o
•r-
>
a>
•o •—
c o
3 to
CO O 1)
C <*- £-
O to
•r- C CO O
-p 0 C -P
f^J T— O
U 4-> -i- C
•r- O 4-> ^
•l- Q. r- IO
-!__% ^n Q -Ji,^
0 C v-
C *r™ i^ ^^
c
<^> > r— i— i— 3
j— fO fO (T3 -J^J
t» 1 * JL> Jj fl3
<1> O O O -P
•!-> 1— 1— 1— CO
1_
C (Q
0 >
-.- O
to c
CO (U
•r- C.
e
U "O
c
to +J
tO T- •!-
fO r— >
O •!-
o> E ^->
C OJ O
•r- X> W
n^
^f
(^
•X
en
4^ C
a> ••-
0) 4J
E •!->
to E
0) Q
•»-> 3
(O CO
[ *
to t_
o
•P 4-
(O
J= CO
-P
to JT
c u
LU to
•
to
Q.
O
JC
to
\x
c_
o
^
,_—
fO
c
o
•^
a>
OJ
-o
r—
o
T3
C
(O
^
o
c
03
-o
•r-
3
a>
(U
j^j
(TJ
C
•r—
t/)
I/)
*r~
Q
a>
c
•f—
^^
,«
3
(>0
a)
c_
to
c
o
•f—
to
>r-
>
a>
t_
5
ai
c
t+_
o
c
o
.p-
-p
fO
o^
r-~*
3
£_
Q.
co
LU
O
i— i
U.
u.
o
_j
^^
z
o
1— 1
CD
LU
a:
•
CO
-p
c
C t—
0) «
E C
•P O
•r- •!—
E o*
§0)
a:
o
>^
-a c
QJ
to , —
3
4- to
O 0)
(_
to
3 4)
+^ -C
-P 0)
«- T3
O
0.0-
-i
a: co
•
CO
(U
-p
(0
•P
co
a>
j=
-P
^k
j^
-p
ai
E
-P
O
c
0)
t_
(O
+J
^j
(O
c:
Q£
<
O
U
4—
•r-
o
ai
a.
CO
0)
>
(0
o
>
1
[
9
to
•P
tv
£_
ia
•p
P.M
rt3
C
O
a>
E CD *t *O -P ^^
Q.
H^
co
O
^
<+-
rH
s:
a.
*
r-
i-H
I
-------
>-
o
z
LU
— 4
1— ff
u.
• UK.
U-
F»
LU
^ §
O ^
^^
^~.
o
1 — 1
1—
<
Q
<
QC
Q
•^
<
a:
»— i
<
u_
o
LU
O
\ — t
LU
u.
o
ex.
00
LU
Q:
•=>
00
LU
^^
LU
>
i — i
h-
O
&_
0)
LU E "O
0
i—
O Q.
O 03
•r- tO
T3 to C
C O
O3 CO.
•r- tO
-i-> cu c_
TJ 4J
4-> 03 >>
tO Q. U
•i— C
X 0J»
•r- 4-> «-
> t- 03 E
o£ Q- ai
c
o
•^
J^ %
-H*
03
••- -a
-a =
03 03
c_
t/)
O) tO
> D
•i- C
+j -a
O 0) •
c- o
c a. (_
03 a.
c o (U
•i- C tO
03 0) C
4J a> o
c t. Q.
•i- a» w
(rt C! fll
*v C w
2: a> c-
00
I
a
-------
SCHEDULE FOR COMPLETING FY 1987 SPMS MEASURES
ACTION
DATE
0 Present measures and indicators
to Regional Division Directors;
distribute draft measures
March 4, 1986
0 Send Comments on draft measures
to OPMO by COB
March 21, 1986
Hold first work group meeting
March 27, 1986
0 Send revised draft measures to
revi ewers
March 31, 1986
0 Send comments to OPMO by COB
April 9, 1986
Hold second group meeting
April 15, 1986
0 Submit final SPMS measures to
OMSE
April 21, 1986
-------
«
ca
H
<
s
Cb
O
ca
o
M
Cb
Cb
O
s
ca
H
cn
x
H
z
ca
£
ca
0
<
z
<
z:
o
z
<
o
z
H
z
z
<
•4
(X
U
H
o
ca
H
*
cn
ca
a;
D
cn
<;
ca
2
r-
00
CTi
»~H
x
&<
CO
o
z
M tf
OS O
ca
Q ca
M Z
cn o
z
o o
CJ Z
H
cn H
M <
z
cn M
« s
ca ca
33 O
H M
Cb
JM fc
ffl O
ca ca
Q x
< H
CO
J Q
M D
Q Z Z
< - O M
ca « M
3: ca cn ca
> M CQ
ca o
• ^ ca j
iJ O Q i4
< 3: M
Z i4 S
M - <
tu cn
ca
cn
cn
ca
«
D •
cn S
< ca
tf 5 ca
o o H
Cb o
Cb Z
cn o
ca cn
os « ca
D ca «
cn CQ D
< s cn
ca D <
s z ca
CO Cd
2 S3
&<
cn
33
H
ca cn
H x
H
Cb M
O J
M
J CQ
J «C
< H
Z
D
• O
>J CJ
M CJ
r- z Cn
00 M O
O< CJ
r-* D ca
Q «
>H Cd O
Cb os 2
*
P4
ca
H
Q
Z &-
w o
-------
U
U
M
Eb
S
1
b
s
1
00
in
M
CO
s .
•M (0
W >i
O 10
W -H
0 0
ft! Qi
m
O
CM
00
oo
CM
rH
O
VO
00
ID
CO
^
MH CO
03 CO
03?
4-> 0
J8
4J
8
a
Q
03
4J CO
C X
uarte
eissu
4J 03
&
4J
a.
•iH
(0
03
03
JD
0
0
&3
03
0
SH
•H -H
S
03
03 rH
0 33
Ql
03
O SH
g>.m
• * \.
01 n
O
H .
< 00
0 n
•>x: x
>i O PL,
•SB'S
M <4H 0
8
C H -r
CO
&J
rH 03
SfO
MH
•H
-Hr^
0 03
3
03
03
DH
C
•rH
"S
3
§
03
0
N0
03 T3
(0 -H
0) 3
S C3
Q) -rl
4J (0
.?|
lj £J
0
0 0
O 4.)
O
•H -H
MH MH
0
Q
-------
00
>
ro
fM
oo
in
ro
(N
CO
(N
OO
in
ro
M*fe
s g'&'s
JJ -H 4-1
0 ro ^ c
-o 0 0 -H
H .C .Q C
by
de
*-^JJ
" oo US
_ H CO
^0fcg
^5^^
8
0 rH
JJ O
0 S-i
p
o o
CO
to m
to 0 -i
V4 0
I O -H
•H C J3
^•gs
_
-------
vo
oo
in
m
(M
w
rH
O
ro
CN
^
rH
O
n
oT
s
8
00
CTi
6
u
o
0
o
M
c
1 O
•r-l -r-l
i-l JJ ^s
_O JH M rH
to 25 o o
E g U rH
•iH 0 -r-l
>,C TJ 05
rH JJ 0 (0
raber of nonconp
nstruction and
1 facilities ne
ble schedules)
a(u
0
a> HI o M
X! C -H O
^ "O § ^
*• 0 £ 0
C 0
O C J^ HI
D) 03 C £
0 0 -iH
a -H £ rj)
^•^•H|
4^4H 'a c
•H C ••
JJ rH 0 •
C rO O 0
0 a c •
ti -H O -iH
M O C ^
1
o
•H
|
JJ
z
0
JJ
Di
It [ p*
jQ d) S
D C •*
C 03 •
0 0
0 -H .
«--rH 05
03 O 0
uarterly target
or municipal fa
rceable schedul
O1 C O
•H U-j
1^ * •
03 O 0)
(^J rt) fTj r— (
jQ Q) ^3
c" 1 ro 'S
•H a o
CT 0 03
0 X! C
OS JJ O 0
"° <6 D 0
w Vj O
H C O 0
0x:
•rH JJ
Jj -rH
•rH 2
rH .
•rH 0 '—
0 O >i
(0 C rH
4H (0 0
•H JJ
i — I i — I ft
'Q c ®
e "^ 0
jj jj
885
•i—i U)
fO tij
4-1 Q
"S 05 m
^ ^
f-| 0
^ y tj
^ w O
c a
O 0 0
•H rH Sj
« g 0
>i M D
n o p
^!
^•"a
M O JJ
I?
(Q -H
rH
oj a
o 6
•H O 05
JJ 0
$n
) 1 U3
C Q)
0 05 (0
UH -H <
i-J 1 — I
rS ^j ^_j
§ *" &
SrH 2
.C a
JJ -iH 03
0 0
^ *^H r*H
•H II
O V4 O
K O 03 •
Vs-^S
0 0
•> JJ JC JJ
4J Oj JJ (0
ti (0 JJ CJj
0 D>-H 9;
rt m ? 03
O
•iH
rH
O
-------
>H
2
s
g1
b
8
W
rH
0
Lj
JJ
§
g
•H
3
rH
S
rH
•H
O
•H
S
••
(0
0
4!
1
&
|
pr^
g
L_|
i
o
'3-
oo
CM
rH
O
rH
CM
O
J8
jj
0
jj
tO -rl
JJ C
0 -iH
CT
JJ "rH
p?
^1 ^5
Lj CO
S -^
tt
jj
Dl CO
progress
ction Gra
> 0
" g ro
Jsi C
° ti
•8
(0
0
Jj
0
rH
Qj
BIO
JJ
U t)
0
rH O
tO Lj
3 (X
••H JJ
•H O
K^ 1
W 0
^*1
•E j
"0 jj
3 M
10 S
CO DJ
•H 1
0 "8
(Q
^
§°
•H jj
U) U
•rl (D
O CL|
•8 rH
^
•H CO
.C 0
Lj r-H
<8 H
O 0
? to
(0 fO
L^ 0
'Q 6
jJ tO
51
•o •
0 -J
O (li
^.
•H (1) 03
O> ^
Q) -H ^
t;p
to -
£'c m
O -H Ou
<0 J 9)
>H t3 JJ
H <0 Cfl
"*
ro
CM
i-H
O
CM
Q
CO
I
M
JJ
^1
Lj
0
D1
jJ
S
•H
(0
ff
progress
•h
c •
O 10
'B
(j^ jj
^ t)
v^ ^J
h
•g
m
c
Oi
C
fd
i
LJ
S1
o
LI
D4
I
M
•«*
CM
O
m
CM
Q
S1
Lj -H
O 4J
to S
0 LJ
cji o
(u 0
•^ g
rH (0
(0 -H
3 rH
1 1
•rH
S JJ
to
-o
against
returne
progress
or POTW's
v C
11
>^^
""a
*£ C
II
8
c
g
c
o
0
•H
i-H
•rH
0
(0
fcj
1
M
to
(0
g
c •
(0 **^*
•r4 U
i~H &
&S
o c
0
O-H
jj j-i
|l
o£
Jj 0
CO 0
h
tig
(0
0 C
•H -H
SI!
V-i Q^
LJ o.
D O
£
V-i fU
CO
0 4-J
rH rH
*y W
CD d)
(/3 n3
*t
i
°
jj
c
••H
C
•rH
Lj
iH
rH
•H
^
JJ
M
||
W >s
•H -H
under re
Account a
W V-i
0 <5
LJ 2
SB'S
JU
U) "rH
•rH M— 1
*
-------
O
§
•H
4J
O
0
4J
s
•H
^
5
S
(0
i
rH
^j
0
4J
S-i •
<0 CO
*r"f
4-> CO
STJ
-H 0
(0 *O
(0 DI
c
CO -H
CO 4J
0 O
H 0
5? ' — '
H 0
DJ M
•- CO
C 4J
° 'e
la
^^
•^ 92
(C g
^ c
c
CO
• H
CO
•H
0
«
£§
-H §
O 3
CO CO
CO
0 -H
Jj
-H 4J
II
TT
ro
CN
O
r-
cs
^
• •
O
CO
4J
0
Dl
(OH U
-P O O
>i en en
>—t 4-1 4->
S-I C C
J_) C C
S-i w en
<0 C/5 CO
30 0
D1 en en
-P r§ (0
C tH r-l
•H (0 CO
4J •
Dl C C -O
(0 m CU 0
C £ ] l
CO C C (0
CO O O T3 C
0 H !M C DI
H -H -M (0 -H
Ol > > CO
0 C ^ C - 0
s-i 0 co 0 en "O
4J c -H c en
C (0 E C E 4J
O H 0 -H 0 -1-1
•i-H -O 4J 4-1 4J CO
DI "0 (0
0) <4_| 4_l 14-1 JJ 14-1
K O CO O CO O
>, 5-) 4-) !M 4J H
X3 0 O 0 O 0
"o c -H c -3 c
«3
HI 1 1
•H -ft
_, jjl f
(00 -O
4J (0 0
C QjrH C
O V4 T3 O -fH
HOC 4J
•H (0 >-l (0
> CO O C
C 4J CO iW Dl
0 C 4J -i-t
0 C CO CO
0 £H 0 0 0
H CO E Dl"O
a CO 0 (0
0 4J Jii 0
2 CO <0 O 4J
eo 4-> <0 -r-i
CU (0 CO Ctt CO
in
-------
w
H
8
(0
CM
O
ro
fN
^
i-H
O
(N
n
^
cs
^
r-H
O
O
ro
O
4J O)
VO
-p
M
I
>1
O >,
U-t 4J
•H .Q
> (0
2£
CD
cu
4->
(0
U-l
o
a) 8
^ -H
D
0)
o
0)
CO
•H
-------
u
cn
4-1
#
4->
C
I
•a
w
i-i
0
4J
I
4-1
0
8
•H
4-1
4-1
O
03
CO
S-l
i?
&
i
B
E
8
CO
CO
1
£_{
EH
Cd
5
o
4
0
4J
03
§
I
0?
rH
03
03
frt
• t
cd
o
M
] "]
&
u
en
rH
0
0
x:
01
x:
c.
•iH
03
C,
•H
1
00
0
0
•H
1
ro
CM
rH
O
rH
|
§
&
rH 1
03 C
•r-l O
CO 4-1 03
3 C
•O 03 CO
C O W
•H -H Q
1] J f\|
b "c z
•n Dl 4J
g**H JkJ
co o
0
4-1 c 5}
0-H &
4-1 CO
C 0
0 4-> •
o o3 en
S-I 4J 4-)
•ggn
03 PJ 4-1
2 C '-
S-l 1 0 •
0 C 3 >i
,fi O rH i— 1
g C 4-J 0
3 4-1 4-)
C T3 0 03
C S-i
0 03 i-H 03
XI 03 fi
4J CO C 0
u -H en
- Q 4-1
c Pw en
O 2 x: 0
•iH 4-> 4-1
Dl C -iH 03
Q^ CO
en 0
4J n3 Q
- -H -H PL,
O -iH CL 1
03 O g C
S-i 03 O O
H 4-1 O C
CO
Q
2
0
x:
c
•H
8
•r-l
tg
2
CJ Dl
^ti
*.
CN
O
CM
I
Cd
i1
rH 1
(0 C
4J S-I
cn 4-> 0
3 C 4J
"O 03 C
C u -H en
•H -H 0
4-1 X; 4-J
S-I -iH 4-) 03
O C -H 4-)
•n Dl > CO
03 *iH
6 en S-i co
O U
4-1 C "x Q
° 'H c: 2
C 0 C
0 4-> CO O
O 03 0 C
S-I 4-1 rH
0 CrO ^ ""O
Cu po C-
•gS-Su
2 ^ 8
S-I T C PH
3 C 'o tl
C ^ 3 O
C S-i Cu
0 03 4-> 0,
x; en «
4J CO C ~
cl8 .
o 2 x; en
•r-l 4J 4-1
Ol C -ft -iH
0 '^ i^ g '^^
pr^ *iH •
W 0 rH >,
X) - 0
4-1 03 C 4-1
Ji rH 'rH 3 S-I
O -iH CLrH «3
(0 O & 4-1 Qt
r-l 03 O 4-1 0
H 4-1 o 0 en
ti.
CO
CM
s
oo
1
ca
S1
1
rH C
a § "o
•H C
O 4J 03
•H C
c «
O 03 en
M 4-J -M
0 CO -r-l
aco •§
03 PH 4J
2 C **^*
S-l 1 0 «
0 C 3 >i
5 O rH rH
g C 4-1 0
3 4-1 4->
C TD 0 03
C S*^
Q) fO i~) ITJ
x: «j a
j-> en c i 0 o co
X} -H C Cd
4J 03 Q
•• -H -H p^
s^ , — | r—^ gj
O -H n, |
03 U I; C
S-i 03 O O
H 4-1 O C
CO
CM
rH
o
1
§
i
CO
rH 0
a4J
(0
•H 4->
O 4J CO
•H c x;
C 03 4J CO
4-1 p |
lj -iH S4 2
0 C O 1
-J-i_Oi\ C
g en c c
4-1 C 'O
°'H S g
4J CO «H
C 0 3 CO
B^'Sg
S-l 4J X* P i
aco O 2
en
CO 4J
2 4J 0
1 § 2
3 CO •
C T3 C CO
C O 4-)
0 03 O -iH
W 4-> rH
^ Q -M
C CU S 4->
02 c
'D,c8 §
0 -tH C rH --~
PH 03 4-1 «
en -M 4-1 >,
>1 0 rH 0 rH
4J g g 4J
>• -H O -rH 03
J^ rH O S-l S-l
U -H | 0 03
03 O C 4J D4
u m o c 0
H '4-i c -H en
ro
CN
rH
O
in
i
S1
•o
c
03
rH CO
03 ca
SJ 4-1 Q
0 C O4
*O 03 2
0 O
ttj -H 4-»
4-1 r-l
S-i -H Q
oca
•n Dl 0
C 0 -H
S-l 4-1 rH
CO C
03 CM rH
24-1^-
M T 4-1 •
5 c 0 >
"g C rH 0
C T3 C 03
C -H SJ
0 03 4-1 03
XI &
4-) co x: 0
u 4-> en
•. Q -H
c CM s en
02 0
•H 0 4->
Di C O 03
0 -H C 4->
PH 03 CO
en -H
>1 0 rH CO
X3 -rH Q, [d
-•H B PH
vj ,— | y 2*
O -H | |
03 0 C C
S-i 03 0 O
H 4-1 C C
h,
CO
CM
rH
O
VD
I
\
S1
1
c
r-l B -S
U 4-1 0
0 C 4->
T3 03 C CO
0 O '"H 0
frj -H 4J
4-1 XI 03
r-l -r-l 4J 4J
_O C -H CO
frt . ,—1 y^
O Q
4-1 c ^x CM
O-H-gg
^S^g
84-> CO C
(0 0
S-l 4-1 rH T3
aco 3 C
t3 03
CO 0
•o H x: co
c Q o ta
nj CM co Q
2 P-t
5 0-§ »
^ C '4-) 4J
0) fO 4-J CD
4J cn c —
.88
C PM
O 2 x; en
•r-l 4-> 4J
Dl C -H -H
(j) .|— ) 5 K **~N
£H *^ *
en 0 I-H >,
>1 0 U rH
4-> 03 C 4->
- -H -H 0 03
X. r-l rH D S-l
03 O 5*4-1 D<
S-i 03 O 4-1 0
H 4-1 o 0 en
-------
ro
o
00
8
ro
n
4
fe
to
8!
Hi
cm
fe
CO
1
o
&
4-!
0)
a
"SS^
CO
<0
-------
ro
CN!
CO
CO
o
o>
o
w
00
8
M
fe
5-i C
±) -H
CO 0 0
^ ^ &
8
•H
4J
8^
"8 .
-U
y
o -H > s-i _
(C 0 C oj M OJ
U-l 4J -H O O C
ro w
rH TJ 4J <1>
ro ® p 4J SM
••-( C >i
u y
4J 3 JJ
§^ 8B2
•S* ubs
•H (I) fl) vy
> £ C
u ro § 0
1 -C a _,
1 C iH 4J --
i js ro M-I
O 0 S Vj
•H jn C
i-S^^
05
i— I
0)
cn
OiO
•i~H rii
c
Q)
•H -r-l Jj
88
ro
0
-HO
-------
a
m
cs
3
ro
O
(N
3
ro
og
f—t
O
I
CN
ro
i-H
&
1/1
I
s
8
I
u
8
as
4J
fl
en
>,
u-i 4-)
8;
8
o
to O
-H
-------
w
o
M
U
g
1
£
g
8
WJ
O<
U3
g
5
i
>
M
y
2
O
•*
co
CN
O
rH
1
w
G
SE
g
|-2_
03 03
03 rH
rH rH 03
03 03 !t4
J"-J C Jt4
>H -H 0
(D S 4H
4H -H 0
2 b *""
rH 4-4 £1|
•H O E
^
•H LJ XJ
U 0 tJ
p 8
O 3 0
C jk_i
0 0 rH
.Q £ rH
C TD *
03 W
0 ^3 '*•*'
Q)
by Region, the
e Attorneys Gen
n State Courts.
4J "05 '""'
S-i 4-> TJ
p to c&
& XJ 4H
*
0)
03
r*4 l_)
w c
x; w 0
-C Z O
c 0 o — -
•H x! 4j "U
05 xj £ 0
" E "0 C
0 0 u O
-H O & -H
3^23
n
<0 0 E
^sai ' •
0
x;
g
o o
4H Lj
0
rH 0
0 g
•H 03
XJ 0
0 !H
0 4->
4H 0)
U Oi
^r
CO
CM
rH
O
VD
rH
I
w
w
SE
0
^i
j i
03
•iH
C 4J
•H C
C 0
'8 &
03
0 xj
E i O
•iH i3 -H
0 TJ O
« 0 03
>( 03 4J
IV 03 C
•H 0
rH
4-> 05 03
^ S-i >
i^ o S1
*
^J-
co
CM
S
rH
I
U
S
Se
0 rH
4H C S
O 03 U
Cd
VJ rH 2
•Q ^
"c ^
3 c *
CM (D C/}
_£• H
w CL)
•> c
CO M 0)
Q) O 4->
03 4J 03
(tS j--* 4-J
C) »^ CO
4J a> c
B ** "°
(0 rH
0 O -iH
M 4J 4H
0) 4J 03
&S8
03 -H
by Region, for
ivil referrals
of criminal act
EPA referrals).
* o
j J ^ | ij
O Jj Q Q
P,- fO fc Qj
rt w c ^
*
^
co
CN
rH
O
00
rH
1
a
^
SK
•sS
ti 1 1
Q) Vj
*Q Q
*c CX
3 CD
c cB
>^— *
d) •
58
.8
03
4-) 4J
&i
fo t — 1
4J
4J
I'S
titJ
03 S
l»^
•H 0 .
(0 <
D) 4J rH
03 4J 0)
•H 4J
v E 03
O 0 fo
-H Q( DJ
01 0
0 W
^ a cp
>i P Q)
S 03
^ § ^
*
03 Oj
0 O
rH -H
0 t>
h m
v-u
CD
8-^2
C xj O
03 U -H
•H 0 XJ
rH ^ O
0 -H
>4H -H X!
•H rj en
C O
•S "S 1^
M (0 XJ
••H •
S £
0)
CO
0)
3
0 U
ti -iH
3 4-1
CO 4J
-------
g
•H
CO
•H
M
b
fe
t/3
•H
CM
O
en
w
M
in
•^
*
CO
O
= _,
O O Pi
CN
O
-------
I
w
I
O
•r-l
r-l
I
Hi
•r-l
•s
I
•o
O
o
co
CN
t-H
O
^f
§
•g.g
a
S3 ^
•H 0}
as
Di 0
CO ^
•H
d) O
H (P
CO O
(0 -H
fl5 >4-l
s«
f "
-------
ro
h.
CM
ro
ro
^
CM
CN
O
o
O
o
in
CO
5
4J
05
-H
CO
-------
*.
•• CO
ID *
M rg
0 -
•r— IrH
So
T
CO
0
x: •<*
O f->
«.
rH CM
-
O n
w
rH CM
3o
»* ^*
G«
O -
•p~) f^
03
s o
rH
^H
j
CO
0
O T
w
r—) p^
^ O
f
g
•H
0
•O
C
03
0
S
0)
C^
O C 4-1 -H •
•H O O £ Vj
4-> -H C 0
OS 4J 4-1 0 4->
4J 03 C & ^
C fH 0 OS
0 O O >4-l 3
£ -H M O CJ1
S3 ^ 0
. Q. C 0
0)
0
W 05 05
4-> rH rH
O M \1 0 _
S §11 -5! S1
•H ^ rH
O C C 0
M 'f~> 05 w
o
rH T3 OS TD 4J •
CJ C -H 0 03 S-i
M-l 05 rH CO 4J 0
T3 a CO CO 4->
•O C CO £ 0
O CJ
g ta d >i O 4J
•H -H rH 03
Vj IH > i-l 0 M "O
CX^^ 0 O 05 0
4J 4J C DJ Dl
>-i CO C >-i 05 0 Di
O rH 05 05 -H CO 05
IW rH O 3 rH rH
0 -H O & 4J
* f 4-1 S tO 0
V-l -H 0 O -H M
0 ^ C > O rH 05
J3 0 C31-H —•
E -rn-H 4J O 05
3 OS CO 3 4J C 4J
C E O 0 03
0) 0 *O 'H TD
• - C CO 0 4J
Q CO -H C C O
« 0 4J O w (B ••
M 4J >-l O 3 0
(CO 4J 4J 4J
C S CT 0
0 CO C O
•H rH S-l -H U •
C | ^ ^ rH O
>,rH C O 4J 1 rH
X3 Qj 03 -iH C rH
4-( M -H CO
4-> O M 03 S-l J2
C 0 0 0 £1
T3 -r-l M CX 0 -H C
M -O M oT« s nj
03 03
03
CO
O
-------
O
CM
•g
g
5?
I
J-i
0
4-1
OS
S
•g
•H
&
CJ ^
§ ro
O «N
K i — l
fa 6
w
Q CN
8 1
w ^
CO
0
•U 0
o
S-i g 0
O 3 c
<4H C O
CO 0 -O
O> D1
5»l T3 05
05 C rH
-U 05
0
•H CM 03
5-1 EL)
0 OS
[ 1 ^| 4J
OS ^ •§
3 'O
4-> 0
4J O 4->
pr"i ni y
PH ^0 * •*""*
ID CO CO •
CO CO C 0 CQ CO
i
C ft O H
** "*H € 05 fj
C *iH 6 PM
O T3 5-1 -H S
•H rH Q[ £-| ftl
01 0 a y
0 -H >, «
IS O pt|
O ^i 4H 'O MH Z
^H ° ?j i.
U - V4 O 0 »-]
CM o j3 *o i-i s
CO 03 g C CO S
«2 M 3 O 3 O
l-H H C O & &
*
rH
0
0
rH
Bu
•H M
.C D
C 0
•H JC
CO 4->
4J
C C
§ 10
H O
&H '^ C
U C 03
W rO -H
SrH •
0 Q, S
O m S u
•1-1 CJ CT
A O
i"H O CM
•* •*
on ro
CN CN
rH rH
a 6
ro ^*
rH rH
1 1
fi S
rH
rH
i0
M ^1
j? O
2 CO
•• -P CO
0 Ct 03 rH
'O O 'O 05
>H '"H •« i.4
O -U 0 S-l
O -U 0
> g 0
•rH UH ^-^ 5-1 C^
•P O <
03 rH CO
i-t 0 « ^— ro \
CO >i CO CO i— 1 •» U
•H .P 0 0 g
C 4J -U • •• < O
•H>,ccn3 O-O C04J
e J3 4-1 -P 00 "x.
•15 co co co 4-> O -P
CO TD 03 33 C
0 "O >< 13 5-1 0
03CCT C0 OCQ
-P CO 03 co 03 C 4-^
OS CO £ 0 CO
CO CM 5-1 CN C 0
CO CO C^4 ^* CO 0 Xj
5-1 C rH C CO 5-1
-H
t4->0)0 £s4-> OO
3 c -H c 3 c
C 0 rH O C 0 II
•P 03 T3 -P 05
M > CO 0 S-i >
O -H 10 D> 0 -rl
Oj 3 05 Oi QJ p
W 0 O rH fi 0
* *
CO
0
05
CO
o
1
•rH
^"J
&
S-i
(2
5-) ^^
0 •
4J 05
5-1 4->
03 03
B1"0
§!
•a >-i
Ol Pi
DI CD
05 5-1
rH
rH
0 rH
05 ?
05 2£!
•P U
CO W
T3 O
• •
0
4J
12
^-^
I
-
CO CO
0 rH
•H -H
ul
0 0
TJ O
g
CO U-l
fO O
0
CO ••-<
-------
Cd
CO
2
O
(X
CO
Cd
OS
5H
U
2
Cd
O
S3
Cd
P
2
Cd
H
CO
$
P
O
CO
EL,
O
U
Cn
O
S3
Cd
H
CO
>*
co
H
2
P
2
a
2
M
2
2
CJ
M
O
Cd
CO
CO
Cd
OS
D
CO
<
Cd
*
H
Cn
<
g
ao
CTi
M P
5 S Cd
W DC
H CO U
> W CO
W «
05 D W
CO X
tf < H
W W
P S DC
2 H
D J M
< S
>H 2
iJ M U
H Cn CJ
2 2
W <
Pi • P
04 CO PS
D 2 O
CJ O U
M CJ
< (X 2
M
PS Cd
Cd 02 ^O
5 HOO
to a\
O P -H
PS H H i
CO CQ PS
SH Cd
r- H CQ S
oo 2 co
a> Cd P O
rH 33 Cd
ft D Cd
JH O CO O
En J CO «C
Cd M Cu
Cd >
DC Cd Cd 2
H P CQ O
*
-------
JL.
M
i
•o
1
• •
m
1
01
J.J
ffi
u
FREQUEN
1
£Q
CO
1
1
M
fl
§
• w • w
^ o ^ o
ro *H ro *H
" ni " rr>
CN 8 CN 0
"PS "PS
rH i— 1
Q m Q m
rH CN
1 1
ft I ft.
\ \
W
c ~
0 H
g 3
W
0 CO
W C
W O
>i O
ro £L
C CO
•H C
rH M
I 4J
Ju -H
ffi CO
s with completed
Date*
s with completed
00 0
t i i i i t j(
•H -H 0
W SH W 4-1
(t) (0
MH 0 iy P
O >H 0
ll ll r*i
fl) • 0
jQ ^— s rg ^_|
£s s«C £^ ^
3 ffi 3 d)
Z — Z >H
C TJ <0
(0 ®
rH C
•H M CO
4-» 4J 0
ro c 4J
CJ O -H
•HOW
HI M
•H S 0
4J -P
C 4H CO VJ
0 0 ,{0 0
C CO (Q
0036
•P E 0
0 03 TJ >i
rH W W i-H
U CO £E 4J
•s
^ 0
CO -H
i$
ro
1
CO
*
c
o ^
^ 0
(Q C
> 2
Q C
0 4-1
: C
j_) 3
JH PTI
•P rH
W O
<4H
sites with "firs
combined target
Date*
i^ SS
Z >r^
(n rH
vy rn <0
O ro 0
JH 4-1
C) V-i
•Q Q *
^^ tii P-i
3 (D Q^i
Z PS R
0 4J
owe
ij j^j
C C 0
O 0 >
•H 73 Q
4-1 -H O
•H (S
s removal
serious
ire Feder
3 ID o1
£62
.g
^ 0
ro -H
CN ffl
rH
OP^
|
\
W
rH
^
Q
s
rp
H
ro
•H
i
3
[Vj
C
I
w
4J
•g*0
w ,
4H 0 4J
K C "H
•H rH
gi
O1
0
W
W 0
4J
ro
•5! 5
sites stabilized
al action. Year
tfl 1
z S
M
SH U
o c
-Q ^
"& C
3 -iH
Z«H
"^ o
00 -r4
CN CU
" PS
1
U)
•h
S
i-g
w C
4J C
CO -H
0 TJ *
rQ 3 o
fo • 4-1
W 0 -H
ro >H 4-> co
^ iS S
03 0
64 4J O C
\04->
M D> -P
^ S r) (0
ro ro
0 -P 0 CO
VH >n fc
0 T3 \
-C CD M
S C . PS
•H >,
W ^ 4J 14H
0 g -H O
-P 0 rH
•H o -H ni
woe
4-> (0 -H
C -H rH 3
ro ro MH
>y ni >H
0 fl 0 4->
•p w
rH 4-> 0 M
0 r^l DU -H
*C p^ rQ
3 0 C 1
Z PS (0 1
w
8 S
S£w^
£.H£g£
U 4-1 -H 0
CJ) O TD 4-> E
0 m c (0 oj
4J <4H 3 CirH
C U-l t, -H O<
•H 0 O g
C -P 4J 4J '
ro ro o M TJ
.C _Q <3 C CO
4J 4J PU H3 0
0 g 0 P-l 4-» 4J
1 W N o; T-i -H
CD SH -H K n >
'ft B'-'H -n S TJ
H Q< D (0 W <0
0
1
m
)Jv
C7
0
funding ( subsequ
at site.*
^|
3 rH
01*
CO -P
"3 c
c/) 3
|
1
.
^
ro
w
CN
^
rH
0
00
1
w
•o
0
o
0
rH
85
£
0
J8
1
0
w
s
•H
CO
*8
^
fl)
rQ
*fc
3
z
0
4-)
<4H
M-l
0
4!)
Q
ro
4J
*&
M
S
0
•H
S1
PS
a?
4
0
ro
T3
S
ro
^
•
8
u
•a
(0
p
s
w
4J
1
ro
^J
—
C
•H
O
'c
Q
°
o
g
•^
rH •
M
1 81
rJ O4
w
4->
0
01
&
ro
4->
•a
requires region
§
W
ro
w
•H
x:
H
*
-------
O
4-1
>-l
§1
cn
g
jQ
5
2
a
Q
tfj
1
1
•g
M
§
o
^ o
ro -H
CO § TJ
CO r-l
CD Q CD -8
C pq S-i
CD S-i
4J i-l JC fC
(0 O * Q)
D CO
H Q 4-1 •
O * W 4->
^J . 1 ^.4
Q C K (0
O CD 24-1
Oi 3 CO
4-1 CD O C
SCO CD
•Q $
PL, CO .Q >i
1 I 5 03 C
1 1 2 .C O
^ O
CO -iH
CN CD
rH
Q£
O
rH
U
w
Jo
4-1
CD
C 4-1
03 0
1 €
uJ r-l
rH CJl
Qu 0
C £^ r-l
0 C3 -S Cli
4-1 C rH 'O
CJ -iH (0 C
03 -iH 03
'C 'O *
r-l 0) CD * CO
(0 C P CD Qi
•H -H W 4-1 D
<5 * 4-> * T3 03
£0 C • rH 0
04-> O Q rH O rH
-4 -H O D 03 4-1 O
co ca
S 'O i-i U 03 04
4H 0 33 O 0 0 K
C Qi CO • 03
•H 4-) Vl 0 TJ
*D 03 O 4-> 4-> CD T3
C 4H C -iH 4-1 0
3 >i 0 CO CD CJ
4-1 4-> rp 3 rH C
•H CD1 M-i Oj 03
4-1 > -H 0 O £j C
i-l 4-1 S -Q rJ O 4-1
PL, 03 b CO .Q C T3
1 1 P 0 S
1 1 2^ C
•*
ro
CN
rH
o
rH
rH
^J
W
S^
^ y
03
CO C
co -n
0 ^
Q* 4-*
C 5
Q
4J O
tits"
1? *r-t
0*0
£ 0 rH
4-J ^J fl>
(0 'O
0 *O
i-l TJ
CO (0 0
000
4-) >H C
•H 03
CO C
• -iH
4-1 TJ 4-1
O 0 J
4-> &
rJ 03 gj
jQ 4-1
5 'c "fi
2 -|H 03
0
4-1
0
1
0,2
0 4->
u s
0 M
4-1 '1 1
0
rH CO
O, 0
O -1H
C_) CO
CO
4J
0
n>
0}
4-»
O
• H
0)
0
s
•r-4
t
0
9
i
CO
• r-l
si
H
*
-------
s
53
1
1
en
3
1
b3
!>
M
a
^
o
t o
on -ri
(N CD
V*
rH
1
w
en
i
rH — .
x: -H j •
O O K TJ
•H rtj 55 0
jt f| ~j
r-H 4-> rH
4-> TO O CJ
SH
3 (3
CO rH 3 tO
0 0 & JH
g C 0
18 -H CO T3 ^-»
C~5§ rf
CO TJ SH 4-> Z
0 <0 TJ "O CO C
*O SH c5 0 O
O 0 co o
2 ll"5 1
•H C -P CO
4-> 05 05 • tJ
05 H SH 3 CO ft
lH (0 4J 0 Z CO
4J 4J CO ^— 4-> rH
W O -rl CO -H 0 (0
•H 4J C 4-> CO 4-1 L)
C -H C r-j (0 |H
•iH 0g0J TO rH M 0
g XI'DPffi -H (Q (0 4H
•^ 01 0 O 0 05
>i VO S-i C g P U)
| 'u """ '>
£0,^ 4J C • • CJ
CO «3 -rl (0 rH CN
C 0 •
•rt (0 4-)
(0 C
4-> a 0
C !3 S
•H C 0
§ 0 SH
rH 0
"8 ° e
(0 MH 0
o
^ 0) CT
0 rH 3
•H m o
IIS
i
on
CN
O
CN
1
>
4
0
r4 ^
X< K
O> W
3 S O
0 0 CO 4-)
M -H . 4->
X. 4-1 SH C • T3
4J O 0 0 C 85
(0 4-> gO S-J
0 S-t ty >fH SH
C ^i (Q i — ( Oi 0
0 W 3 4-> (D 4H
"O 0 D1 4-> 05 0
0 U CO CO 0
to 0 x; >i4J c
rH C S-l 4-» S-l O
rH O 0 C -H
•H -H 4-1 CO ^ -H 4J
*• 4-> COw OXi O
SO 00 O 4-> (0
« O 4J 0 -H
C 4.) SH SH S r-H
0 co >i r~ m -H
— i >i SH o3 4-1-0 >
4-ito 0 r-nO1 coc5 -H.
(0 FH O ^^ flB O w 0
CO O 0 -H VO 4J
•§ 8 S °s °^ « 1
•H CO 0 0 CO
•OTJ O S-O ^CH MHCO
30 U g0 Bft* O-rl
•<~\ 4-> 3 SH 3 ffi XJ
(Q -O CS-i C_ S-I4J
c P c 0 x; 0
oo 3 0MH 04-> -yf^
CTD G H>H H5 30
•H a SH
•P co rJ • • 0 53
SH •• C/5 03 p f"i p
as H &
0 u •
*
-------
u.
Q
41
1
H
1
co
en
1
i
g
M
^ O
ro -H
CN 0)
ro
t
cn
0
rH
m !> .Q
8-H M •
0 j>, 0 0
0 0 C C (0
^-i lj Q O "O
4-> 0) 'o3 O
O 3 3 Q) V-i
o fTi *o fO
(0 o p
•H O 4-> H SH
> (0 03 05
T3 ^" i-i O •
35 4-> H -.H —
0" 0 M-l 'S 0
xi S o
^O JM ^5 'U
4-J O \ * O 4^
0 -1 0 03 0
g 0 rH g 03
rH O 0 O
4J IW O 4J O
4J 0 ^-'
0 03 M
03 4J 4J 0 4J
O ff 03 4J
0 -H . 0 -O CU 4J
>-l O H (0 ffi 03
4-J O •f"1
8pt 4J
0O •
U « (0 rH
IS O 4J
0 S (C C
-50^0
M C 4J g
0O (D
4-1 0 0 4J S-l
fO J/ 'H 4J T5 144
C O 4J O 0 C
lj (0 (0 C C 0
0 M V-i < O)
4J 4-) 4-> -H -n
C 03 03 0
•H XI -H • 0 rH
t5 c g -o
C -H -H 1C 0
•rH (~j g M 0 4^
0 03 u en
t* 0 'O Oj 03
rH U C -H C
O 3 (0 4J -H
> 03 C C ,C
C (0 03 0 O 4J
-H m 0 g -H ..H
E 0 0 4J S
0 VJ O (0
M Ql O M r4 03
03 C 0 O 0 0
m C C -H 4J
3 M 4-> 0 03 -H
8C C >
0 -l 03
o O 0 03 n> 0
03 4J TJ (0 O 4J
•M 3 C 0 >-l ••-*
•O O 3 g DJ 03
03
4J
G)
ni
(0
4J
rH
S
0
•iH
?
03
0
•H
I
J^
§
03
(0
03
-H
H
*
f
I
-------
w
-* c
• o
CO -H
- DC
• CO
-* c
•> o
CO -H
•> bo
CM 0)
CXM
s
o
s
o
CN
I
C
o
(0
N
•H
i-t
O
42
4-1
3
(0
•o
c
tfl
M
o co
i-<
iH TJ
O C
<4-l (fl
(!) «
4-J O
•H
C 4-1
O tfl
^
4-1 CU
M C
O -r-l
a u
cu c
-a
cu
ca
co
CU
a
14-1
to
CU
CJ
O
(3
43
PM
T3
cu
ca
ca
E
cu
a
cu
TJ
C
cu
cu
o
CU
3
co
ca
c
to
iH
a.
cu
3
co
o
•H
i-l
•H
CO
rH
•H
tfl
M-l
O
01
O
•H
4-1
O
CO
O
cfl
CU
4-1
&
iH
tfl
0
•H
ca
ca
cu
•H
c
g
cu
a
a>
o
a.
to
0
to
rH
a,
cu
CO
o
O
CU
bo
«
c
o
•H
bO
(U
co
cu
•H
3
tr
cu
co
to
cu
E
43
H
CU
CU
ca
o
4-1 C
o
CO i-l
CU 4-1
4J tfl
CO N
4-1 -H
Cfl M
O
42 42
o
4-1
to
4-1
CO
cu
42
CU
a.
P9 CO
O C
(•yf Q
•H
rH 4J •
tfl tfl CO
C C CU
•H -H C
a
01 CU T3
£t 4-1 tfl
tfl CU CU
-------
U.
a
1
1
0
•
*
•
1
4-1
O
W
CO
S
O
PH
co
M
PH
5H
0
a
&
Q
W
5tJ
W
Q
5s
^3
CO
•^j
^
Q
M
0
fa
O
0
H
p&4
O
^3
^»
^
cu
^
o
o
&
-o
c
to
c
o
•H
4J
tO
>
(H
lonse
W
0)
0
sour
B
tO
M
bo
O
H
PH
j>_i
0
sa
S
o-
fa
Q
O
O
CO
^r]
PM
CO
M
PM
t>
W
^J
ptj
u
H
U
Cd
o
• CO (CO
-* e •* c
» O •> O
CO -H fl -H
• bO « bo
CN 0) CN CU
- P- « PSl
^H ,- — [
1 1
U U
Pi pi
oo cy> o
13
Ol
4J
CO
rH
3
bO
Pd
0
MH
01
•H
4J
M
01
C
co o
01 U
3 "bO
CO CH
CO -H
0) M
S o
4-1 C -H
c o c
01 O
§ rH* S
bO ^ M
CQ &) > cr 73
4J C
•H 4J 3
I-H r4 O
•H O M
0 ft O
10 01
• >* o co
^d" *»O O 4J
VO CN ^H ^H
CN • C3
xx e^s *^~ } — i
*H^- t0) ^^ VO
***s \^s CN t j
^™N *Q C3
O *^3 CU ^y> o)
v-x 01 ft s_^ g
rH O rH 01 T3 DO
• rH 01 4J 01 C CO
O 01 > 01 ft CU C
f- > 01 rH O X a
CN 01 T> ft rH Cd S
^ T3 B CU H
B ^ o 01 co 4-1
f tO M T3 fi CO
4-J M bO CO O tO
•H bO O 0) B iH !S
^ O )-] ^H tO | I
(-t ft 3 M o *O
cu ft co bo •< -H
0 bO tO 0 rH
C bO C o) )-i CO
cd c -H e ft cd co
•H *H s*** H rH
rH 1-l^-vO'^e C PH r4
ftOvO4J/->OO O
§4-1 ^— ^ *H r^ *H *H '"N 4J t[-j
•H/'N Cv^ 4-1 4J/-> C
O Co O>~N O OOO 0) P
o N-' Bo to n) ^ B o
•H rH 01-* 01 CUO b04-l
C« Or-l > >V^ CO O
>i OO C> -H 'H-rHCN 0) CUO >
•H 0) ^_x ft c^ t-i M r^> ^. >H
• O4-I g (-1 (H OJ 4J 4J.
4JtOOIt-lOMOO -HO
•H fa OO U O U U«?i rH 01
£ -H M
^ O O O O O O (H
CO O
fa Pi -K fa U
•u
4-1 0
•H M
eft
^T
01 CO
ft
C
bo • tfl •
C >> rH CO
•H 4J ft 4-1
4J -H 0)
tO • rH ^O W
V4 >-, -H CU (H
0) 4-1 O 4-1 CO
ft >H CO 0) 4-1
O i-H HH i-H
•H . ft rH
bO O 01 T3 B tfl
C tfl M -o oi O C
•H MH -H 01 4J O O
^j 4-1 4-1 CU -H
01 0) C tfl rH C bO
01 r4 01 4J ft O 01
CO x-s -H -H B "H Pi
CO 4J M C O 4-1
COO) C O-H OCOCO
01 -H 0) 14H bO OI
•H 4J CO CO -H (H
4J-H 1-J T3 01 CU4-I T-I
•HrH O 0) IH )-iC03
rH-H 14H 4-1 3 3 OICT
•HO 0) CO CO > 01
OCd T3 rH CO tO CM
tO 4H 01 ft CU 0) 1— 1
M-I ^ e B e a)
bO 01 O rH M
oc rH o s e co 3
4J -H Q. -H -H -H CO
CO S M >H (H t3 tO
coo oco 0) cuoicu
OlrH O^-4-l 4J0B
•HO
-------
I—
u.
Q
CJ
M
CU
O
a
13
CO
C
O
CO
M
CU
CO
C
o
CJ
M
3
O
ca
(-1
bO
O
I-l
PL,
[H
CJ
z
g
o-
1
Ed
O
O
CJ
PL,
en
VI
^
p
^
VI
^
14-
_J
J
a
PQ
o
4-1
•H
rH
•H
0
CO
4-1
co co B
C CU 01
H 13 "O CU
>
rH T-H iH -H
Cfl Cfl Cfl 4J
•H iH -H O
U *O 13 CU
CU CU CU I-1
B B B >-i
CU 0) 0) O
fVJ (V, p^ CJ
o o o o
co
•H
C
o
•H
CO
CO
^
CJ
CO
•rl
TJ
*X3
c
CO
Jj
Q)
•H
0)
*-i
S-i
CU
-o
c
3
CO
•H
4J
CO
4-1
CU
^.4
3
CO
CO
cu
^4
cu
4-1
O
3
•o
cu
4-1
4J
•H
B
CU
O. •
4-1
CU C
43 CO
CJ
O lH
4-1 <4H
•H
13 C
CU bO
^~^ *iH
CJ CO
cu
(X >~.
X rH
CU rH
CO 4-1
CU C
•H CU
1 1 g
•H C
rH O
•H M
0 iH
Cfl >
U-l C
cu
<4H
O CU
(-,
1-1 Cfl
cu
rO 4-1
B cfl
3 fi
55 4J
0
-------
w
U.
Q
CJ
2
w
8
S
1
CO
s
I/!
MEASURE
!>
M
1
O
c
o
• H
*
rH
rH
>
K
CO
0
•^H r^^
SB
-H rH
O O
(TJ
4-1 TJ
rH (TJ
(0
CO 4J
-H fO
T3 Vj
$
•SB1
(TJ
CO C • 0
0 T3 4-1
••H rH 0 (0
4J nj 4J J-|
•H 4-> (C (0
rH O rH &
-H 4J 3 0
CtJ 00"
OH £ r4 CO
4-> 0
4-1 0 -H
4-J (0 -.H
0 -H rH
CO O 4-) -H
M 0 (0 O
0 CU.C (TJ
> CO 4J 4-1
-r-l
C
<
5 N
2 CO
4J
4J 0 C
T5 £
0 C 0
(0 '3
•H 0 O1
rH 4-> 0
5*0
O 4J
CO (0
0 O i-l
n (0 y <
Q> N atf
6 2 9 4->
of TSDFs (oth
egulated . ( Do
, generators,
on-regulated s
handlers.)
w w to c -n
]Q 0 "5 rji4-i
3 (TJ jj -H rH
C ^3
fy ^ flj fQ Ij
•^ 1 * V{ O
JJ x-"*, ^D PQ (— )
1— | CO M C
4-1 CO T3 -H 1
•H Q C M-l 0
O Ci 3 -H 4J
0 CQ O 4J (0
Qi-H M O 4-1
CO T3 CT C CO
pa
JQ
4-J
^ CO
0 O
JH *rH
•o'a
c p
(0 O
"(0 O
s (land dispos
orrective acti
nee.
b u m
CO rj)rH
EH C a
4H^S
O -H o
{Q
ll 1) Ml
•Q ®
3 0 co
C CO rH C
•H .2
"(060 4->
4-> H jC U
O 0 CJ 0
EH a co a
CO
c
• M
U -K
^f C
- o
ro -H
CN 0
" 05
rH
CM
1
>
K
0
4^2
(TJ -H
4-)
CO^-tJ
0 4-1 •
•H o oo O
rH <4-4 ™
•H 5H ffi
U !H b 4J
(0<1) (0
4-1 4-> C O
rH (0 CO
(0 a.'O -H
CO D1 CD J3 .
Q 4-> 4->
a.c o
co u 0 c
•H (0 a-H
TD 0 M
C TJ
T3 c -H ©
CO 4J
(TJ -H 0 C
rH 4-> O 3
0 C O
4-1 CD O U
o a 0
0 -H r~- 0
5 _ 00 JJ
3 (0 >H 4J
C b O
•o c
>i 0 C
(4-1 > -H -O
•H -H rH
0003
0 O S Q
a -l 4-> CO
<
rH In r^
(0 0 oo
CO 4-1
aJH
^ (X|
CQ 0
-H 4-1 C px,
"O ^4 -H W
(0 O
T3 3.T!l rn
C O1 0 CD
(0 4-> 4->
ctl as
(0 0 w co
fig"s
V< -H 0
0 4J U C
JS U C -H
4-> CD O
o a TJ
— CO 0
C • 4J
fe c °° o
CO (0 >H O
EH b 0)
TD >-i
4H 0 C
O > -H 0
•H n
' pj It 1) ^
C 0 4-> -O
4-1 £ -H Q
•r-l 4-1 JC
O 4-> CO
0 (0 0
CO 4-> 4-> -r-l
CQ
CO
1
4J
o
-------
g
w
s
1
1
^0
^0
'
BJECTIVE
O
"^ O
ro -H
(N
-------
at
Ml
r:
.•
&
a
U
CO
CO
§
g
HH
1
p
U
p
M
£
fe
U
CJ
M
IJU
o
-p
§
i
Program Area: RCRA
SH
!
1
CO
H
1
aAiioarao
in (0
T3 -P 0O
c M 3 in i -n -H
(0 000 in-H c in TJ
^ -P 0 U T3 *w ^i 0
in 0 j* -H CQ c U (0 .P 0 in 0 -o M-I 0 to in ci "O -"-i O
•H CJnJ-H4J0O -rH W CJ uj "Q > 0 0 4-1 >i
-P r i g -P (0 r-l 0 | * Q) 21 C (O 1 * -*H (0 0 rH-Hj^4J(00
o 0 0 w '— o o ^x 0-H>jj2^£iV40 .H o ^E
i4-irj-P(oCC0W >wC-r-!o 0Q(0 (OXI •Hrnlj •
ol*-|'H-'-'00-P oi*-(0-P'^rHOr-i iwCTin 0-H in
rH\ 4JgrHCC rH-rH M-IC4JCQ M 3ffig^3 -P
(OW0"H'Q(On3o n3-P04-l0C~-'»-Q< rHO30 O1 0
P^.2 ^ 'H T3 '3 "Q, § 8< 'S ^ r-j -Q '(O -C^ M £» _W -P XV M g
§'H COOC(0?^00 rif rt) <~| rQ yj r^ j i
O1 • T3 '"-I 3 C S « -H M O '""I -H rH
TJOO0 -POrJ-P "Q 'rH O H0-I-I-H4J >Ql— I-I-IO C
Cu-H>»(oc O Cfi-Hn33 rH3O •n-HXICir-ins O
(0 4J -H . 4j ^,±1 (0 w 4J O 0 a O1 XI C C -H -H
rH-PCJ00CO-PM rH0OrJO-P60 (03M-I-PO0 D)
•H(OU» COrJ Qj(00 (OUrHU r-l O(0(0> 0
lyg 0-HMm-PO iw -Q-.PO o ox:4-i-H vj
Ow0rH^-OO(0 OOQ)CVjcOL>i iwZWjJ jj
0> -Hr-jcn 4J>30 cwin OCOW4JU w
^Oi-HfUC-PM-lZI-P r-l -H TJr-lOO-P 0CQ30 0
0 -P > O C 'r-l CJ> C 0-P-P0MOC-PC r-I'DrHCOr-l r-l
^OO"0-rH(OCu)0 ^CJOwO — ' (00 00'pO S-i -H
3 M Or— (-H ® 3-r- 1 r-l 0raC30 -£-'-lnJ-P(OO D1
OO<0 g XV-H "3O(0-r-IMO0-d C 0rHV-l«- r-l
£ -n -PCOi— ICDCT XI 4JC3-P1*-! p1 0X1 -H ^^ -U 0
•PXjcj 0 <000 -Pinra r-ic-'-'>10 £|-P0> c y
3 C 0 g r— I -H^ &jC0-P0CX!rH - — • -P O • 0 3
>iin-r-iinaJ(otn-P >ip-rHW(n n, . c c <— i 0 E w
li-l ^| Jta| y -i— ( m *rH C *4*t CO r-l r-l -H 0 *rH 03 C 10 ^H 'rH (0 rH 0) QJ (0
-rH 03 -rH 0 M O 0 rH O *rH EH -rH 0 C 0 in 0 O 0 4-1 "rH (0 M r-l ^^" 0
O Cu 3 > O -H M -rH -rH O 3 > -H r-l -rH -H 4J -H W rH 0 -rH « g
0 P CT-H 14-1 'n *O O -P 0 T5 O'^'|H SO' — l-P-p(C 0^04-^^3X1
QjC/30cc3ro(oo sj4C0c'60rH-Ho-P 8JPS'|J'HP1''J *"
COHr430T-)(0|4-i(0 CO(Or-i3(0'O(OrH(OcO nSn'^S^R '<-
H
CO
u p *
*
c
7
-------
Q
(0
m
1
(0
J8
•o
CO
§
CO
(0
4J M-l (Q
N O fl)
5 (0 c
25 >w O
a
-------
f (?
"'Vfir'\
""V
*--»-» I
z
i
fa
§
u
O3
MEASURE
OBJECTIVE
•<3« C
* 2
CM 0
O ffl
un
I
•D
1-
y-i r-
00
w
0 ><
TD fa
3C
0 -H
C
nificiant Noncompliance - Snapshot (i
verse and all SNCs identified to date
CT---I
•H C
03 3
\
0 ""7
co /— x: > .p i
Q.-PT2 ^J-HTI -r-( 0
C \.C U * Q C (04J C r-l W
•H (Q -P i< 52 W -Q (C IW 0O fO M_| .,-1 14.4 .H
C ^ 03 -P CO O 0 M 0 CO 0 4-> U O 3
co o x: c w en w w CQVJ COM 0c id o1
0 -H .p • C 0 O 00'QQ 0 — • S-i 00ta>0i— IM-IW0
•H^J-HVj-Hg •'-''OCS ^J-l-1 O •H'OC-HCQr—l CM
4-> -H » Q> (DO) 4-> £-1 Q) HJ(0 O 4J>-I04JC'O0O i
•HTJ aJniwjJ -HO w .p .C • -i-iO OO XJ-HC !
rHCCJMC-HC iH\. -HCD£M-I w ro-n »
UO032.0D'E OCJ->0rHMW03C OC4J4-ISJ0 rjl-H 4J |
(0 O1^J00 (OO C-HOC 0 (OO 0OUCOO i
SM-J *H J-) T^ 'H "»H <0 ^
4J (0 »• 4J T3 W > i
iHS O<0;>iD ^-H WfOCJJWw rH-H rH C s
W0OCD0Q0 CflCZ --HrH 3 wCzCE*J(J3-«-l i
QOi-H u 4J S-i QOO30«r-4Jw W C 3.PW.*0
-H JJ (T3 3 O -H 4J -H s: -H O 0) ^ -H 4-) -H (0 -r-i (C (0 S-l s
T3 >Q>iD>-'-l T3-H 4J ^ U rH 'H ^ « t)-H ^-^ 0V4 S
4J0CH^05jJ gC r-jrMC?£ PCW-P-P-PWO
T5O>0CWCJ TlHO^OjrHnj O-P TJWO0MC(OOQO
C0-H O (C CCD-HuefO 0-PQ CCP-H-UDUX: —
(DT-1-P0 ttJ fCfi-P-'-'O-HCQ^3(0^5 (0&4JCOrH4J
r-H.bo.C'go0 rH OJS-HOW in rH oSo O(0^4J-H0O3S-i O<0 >W«4->
IWCQW JJUJ-H IW4-1 OT3J-I-PCTO M-I+J 0"-MCC_)C
O ljj-)CC4J O 0)-P(03'O 0 0 0lJS-i30Z0
100W -rrn^wco jJ>(00 CT-H CO E
wfao O-HCD Mo-ngjj M.P jj WO-H -p a> -P S
0Q CflO-Pw 00-P-HCM -r-114-iC 004J-P& n3<0>-i
,Q030)>-i (QS-i ^ T-) U (0 (D O -P i— I O Q) ^•r-iO'OO0<-H -H
gf-iCcU0.l-iO e^CDCTE 'D-'-1 E s42Q>-C -POW3^
3 -H-o^OO 3JMrt300£OCQ(U 33W-P0(0-H(CD'«
CWlJM -H CW>-liU>4Jn3Cw CCQW >4J> 0JC
0-HQC>iw OW^-H i4-io---i OM-HCO TI^JJ
0X33\a3 O 0CQO0O-P'- -Ha, 0CQO04J ry0 O
^^CTWO-P jCfa 4Jiy(Oj-i0-PO1 £fa -POJi-iC-P >i^
•PO0C 3C -PQD)V-iCViCX!iQ0 4JQn)MMO-rHCOM
MO>lOO 03Co304J04-)rHM 03CJO-P— -TJ-r-lOW
>ca -rH4J -i-l >-,fn-^3 WrH O >iH-^3.W C-H-PO
l4-JCWJ-'--IJii4J M-J MCTrH-HfO-n-r-lC 4-1 MU1-H0(0 (0
•H(CW-H,-|lB0>O -HW-H C0-P0rHCQ
O 0)T2-H0iH O03XIE-H-HCO -i-l O03x:-HWCOo53jJ
0O"pCUi-iO 0X!C71UME334J^J 0J2DIOEU4-) DlC
Cti IZ w O (0 CQ 'H Oj4J0fOO'QC71(03O Q^-P0'0'603O0CU
03 03 O O 4-1 — • > O3Ow0iwn800O<0 O3OVJ
-------
I—
u.
<
oc
O
en
u
en
E
B
M
I
4J
£
£
^^
81
&
Q 1
C \ C .C O
•H (Q 0 -H
S $ H=! >
WO.QO
(D-H I-H
(0
0
JJ
<0
>-4
W
5
-PI
g" g o c c -H
'•O -H ""
W
(0
r-I
(W
0
WO
4J O1 C
Q05-H
>U)
TJ
C
(0
in
a?. 2^
O <0 0 r-j r
-H T1 M ^-^ (O -i
if
C (0 CO -P 5 -n O
iH M (0 0 C
* '6 | "> -H -H O * O
H03
D-U
C
-rHWrH-H >,^J >j
oc-Pr-i ^•(0(0rarn w
(OOnjdracx)IOr-iCq)4JM
4-i-'HX!-Ho^'O(OtnD-H
-P 4J j= x; -s
11 j_) 11 ^ p^,
Z S C (0 oo
_ 0 4J >H 0
10" C O 0 C Pu iw
•H 4J -H C .Q 0
•o-d-
-HC«I -5J0-H
rHO)W>,Oa)^>4J
-H 3(D
W4JT3 ^H
MpC iW
0fl)(0 -HM
cooV4»-i4J
y-H-HO
33C
-------
U.
Q
CJ
cfl
(-1
bO
O
l-i
PH
B
!S
W
D
o-
§
U
Q
O
CJ
CO
S
CM
en
W
2
CJ
en
H
§
w
H
CJ
M
O
oo
*>
CN
i-H
cx
\0
1
w
***^
03
T3
01
cfl
0)
CX
o
^1
o
T3
0)
0
^
rH
rH
tfl
M
01
4-> 13
O 01
42 fa
CO
CX MH
tO O
c
en n
0)
1 43
co 5
01 C
iH
4j 0)
•H 42
rH W
•H
CJ >•>
Cfl MH
PH "H
O
rH 01
Cfl CX
rl CO
01
fv J!
PH ^*
o
•H
bO
(]1
M
«
42
4-1
i*
O
4-> CJ
CJ £5
cfl en
M
4J C
(2 -H
o
CJ CU
i-i
bo cfl
C
•H 4J
•U Cfl
3 42
rH 4J
CJ
C2 s**\
•H CO
\^ 01
•H
CO 4J
01 iH
•H rH
4-1 -H
•H O
rH CO
•H M-I
O
CO rH
MH cfl
rH 01
CO T3
CO 01
0 fa
ft
CO T3
•H 01
tJ 4J
CO
TJ M
C Q)
cfl CX
rH O
C C
o tu
•H
4J 0)
0 4=
CO 4J
01 4J
> co
•H
4J 4->
CJ -rj
Ol B
M M
M 0)
O ft
CJ
M
rJ O
O
}-j
co oi
4J ^
G M
Q) O
0
r4 Cfl
•H
3 MH
0- 0
01
M CO
4J
h c
M Ol
o B
4J 0)
tfl M
1-1 '3
So er
01 01
M t-i
•
|H
01
4J
r4
Cfl
cr
CO
•H
42
4-1
MH
O
-o
CU
4-1 CO
Cfl rH C
r( ffl O
0) S -H
O, rJ 4J
O O cfl
MH rH
M O
O 01 iH
M >
T3 O
OJ B rH
P rH
5 M CO
5 o
bo
rH fi -H
rH O CO
Cfl CO
M CO OJ
0) -H M
TJ T3
01 0) T3
fa M CO
01
(ij f^ ^^
O 4J CO
x_x
M 42 a
oi o o
43 iH -H
i-gtJ
C co
4J
01 CO 4J
42 C C
4J -H Ol
cfl S
>% bO 01
M-I cfl a
•H h
o co o
oi cj MH
a a c
co co oi
pq
1
MH
T-I
(2
bO
•rl
CO
cfl
CO
CO
13
(U
4J
CO
iH
i-H
01
43
O
4-1
r*%
4J
•H
rH
•H
CJ
CO .
MH M
01
01 iH CO
42 rH C
4-1 a o
B -H
T3 O 4J
01 CJ CJ
co c 0
•H 4J
4-1
CO M
M 01
4-1 4-1
CO >-l
•H tfl
C 3
•d cr
fi CO
•a co c
tfl -H O
42 -H
rH 4J 4-J
CO 0
B "O CO
C 01
O 3 0)
MH co >
CO -H
MH -H 4J
0 cj
CO 0)
M C M
Ol O M
43 iH 0
E 4-1 O
3 CJ
C cfl bO
C2
J? a £
rC h T3
JJ , 01 0
MH 0 C
•H M -H
0 0
01 MH 4J
0. C 0
cn 0) C
<«
^
CO
0)
4-1
cfl
4J
en
•a
C
cfl
^3
CM
01
4-1
cfl
f-i
CO
ft
01
CO
CO
•H
42
4J
*o
O iH
1-1 4J
O O
MH oi
C M
O
rH O
CO
B bO
6 c
O -H
01
M-I 01
O CO
M M
0) CU
Q 4J
C M
B cfl
1 &
«
(_i
0)
CO 4J
Ol t-i
CO Cfl
CO 3
cj er
rH CO
tfl iH
C 42 /^
•H 4-1 rH
B cfl
•H >^ C2
M O -H
u n B
0) -H
•a bo M
C CO cj
CO
0) T)
rH 4J C
•H CO tfl
> 4J
•H CO rH
CJ -H
0) >
MH 42 -H
O 4-1 O
M M-I 01
0) O 4-1
43 Cfl
g III t ^
3 <-l cfl
c co a
42 Ol
oi oi en
42 43 N^
4-1
C CO
>. 0 fa
M-I Q
•H T3 CO
CJ Q) H
Q) rH
ft -H O
en MH 4-»
CJ
CU
43
rH
rH
•H
CO
rH
CO
M
CU
MH
Ol
M
rH
tfl
C
•H
•rJ,
^ S
O CJ
w
T3 O
C
cO >*,
rH
•H T3
> 01
•H 4J
O M
O
< ft
CM 01
Ed t-i
,,
Pd
H
O
-------
B
w
rp
I
S
8
s
co
CO
5
1
8
w
^* C ^< C
- O - O
oo -i-< ro v-i
- ni •• rji
CN © CM ©
t-l CN
ft ft
8U
u
in
(Q
© S-l
V4 03 ft
m Q) ft
© (0 U © CD
JM 4-J *O -P
ft CO C C ©
•H 3 r-|
O1 -P 03 © £ *-*
C -H C V4 0 ©
© S (0 (0 O W
& rH -H
© © (0 C V4
JS Qj ^1»^ O ©
M . C 'o3 S
i— 1 © 03 m 03 -H
(tj > (0 n> (0 > C
O © © C © © O
-H TJ ^ -H ^4 i-l -H
@(0 4J (Q 4J
03 C " (0
js c >, o >i s M
U (C -P O -P © 3
rH -M -rH -H P
U-4 ft Vj 14-| V4 > -H
O O O O © 03
C T-l -H U)
^1 O V4 ^4 ^-t ^
© • j-j Cu © Di * •
1 ^ "8 1 "8 ffl -H
S <0 nj cu
-P (0 C -P C O TJ
^ i-4 CT >-i CJiiH 35
arii-rH Q -H © 4J
0 03 ci 03 > en
© V4 © © d) © ©
p^J P-l *Q @£ f^ r^J ±J
rtj CQ
.
^ 0
CO -H
CM ©
CO
ft
8.
U
Q
1
•a
Jj
(T3
•o
i-H
03
03
•m
Q
°
S
'c
•H
(0
'•4-4 CD
0 C
•H
Vj (0
1 ©
C i~H
S-i ©
&^
£^
u
-------
fa*
u*
""•»•»
Q
w
CO
Q
H
m
o
C -H
to
0
0
-»J 0 0 M
o TD 0 a o
u-l O 'O 0
05 _ 'Q '^ -P -H
05 -H 0 0 r-j C 3 -H
4-> E J5 05 (O 0 -P
to o QJ c c to x:
•H0O-POO0UC
•r-i rH fl) -H -H j,j -H -H
05
0
Sj<00
QJ JC 0
0
(0
0
4-> CO
CO 0
O •£
4-1 to > a
0 tr
aHH"5
^ ^i
alS
0
£
93 (0
O 05 -H
•p x: 0 \-i
0 o c a
o ? 0 a 0
o ^ o
35 (D £j
^•^ -a -P -P a c 0
-n
Cfl
0 0
03'O
0 rH O
x; ^ 0
0 03
ITJ O i-
>-l -P -r
-------
r^
iH
I
w
SCHEDULE FOR COMPLETING FY 1987 SPMS MEASURES
ACTION DATE
0 Office Directors submit draft measures
to AA 2/5/86
0 AA includes draft measures in final
draft guidance package and sends to
OMSE, OECM and Regional Administrators
for comment. 2/14/86
0 Comments on draft measures due to OSWER
and OMSE 3/17/86
0 Second draft of measures to OSWER, OMSE
Regions and OECM. 4/8/86
0 Final comments due to OSWER, OMSE and
OECM 4/14/86
0 Outstanding issues and final measures
elevated to OD, DD level for resolution 4/17/86
0 AA submits final measure to OMSE 4/21/86
-------
en
w
u
z
<
H
cn
CO
D
cn
o
o
H
Q
Z
cn
u
Q
M
CJ
cn
w
OH
H
cn
>H
cn
H
z
u
o
<
z
-------
to
0)
•o
-P
to
CU
ft
id
u
W
Q
0
U
CO
ft
CO
S
D
a
W
S
W
H
QJ
W
S
O
A
CN
i-H
0
,_
1
ft
id
^J
id
•o
CU
c
-H
_p
f^
0
s
cn
S
-p
CU
i-H
C
•H
1
rH
H
iO
U
<0
P
id
•o
CU
to
to
H
4J
C
tt>
e
c
0
•H
C
CU
CU
•s
•o
c
id
^f*(
rH
id
CU
-P
u
3
o
M
ft
Sf CN
CO rH
cy
CN
1
ft
rH
10
C
•H
D
C
0
TJ
C
10
• CO
M T3
CU M
•O 10
•H Tl
U C
tf 3
10 CO
CU
ft C
0
tt) -H
to P
3 (0
13 P
o to
O -H
V S1
C* PH
0
c
c*
•H
CO 10
•H -H
X rH
,
id -P
c c
0 CU
10 M
CU 3
>H U
3 to
CU
C -H
id u
•H
g M
o to
M CU
MH ft
j
• ts to
P C -H
C Id Cn
W 5
tO H >i
cu id X)
10 0)
to Sc -o
0>
CU -HO
O T) O
iO E to
cu cu id
rH P 0
Q C -H
£ HE
CU
"O Cn X!
C CO
flj *H
'O 0
V^ r*
id H
T3 O M
C M-i 0
(d MH
-P CU
M "5 4J
^i C
o ci
-P (DO)
Id E rl
rH CU -H
3 rH 3
Cn ft D*
CU E CU
rt H tt
CM
r-T
O1
<•
1
p-l
•s
-cl ft
w
0)
3 -OX! -P
ft CU 4J (d
tt) -t-1 0
O to .C -H
O tt) -P T3
(d 30 C
0^ .M *H
c cu
U1 id ^ Q T3
00 -PC
on <4-i co id
r- O
MH P 3 MH tt)
CU tO T3 tt
X! >i DC
XI 0 E Id H
T3 -P -H Id
DC -p -p -H
SO -P C O
0) -H C id id 0)
CO 10 0) M ft
•H tO • E C -P CO
•H rH tt) -H tO
CO S tt) tt) X! -H
t) 5 XI r) -P CT
^ 3 Id (T -H tt)
Id CO H < > H
•O
C CU
id o o .*
-P id
co £
M-4
o
cu
to
3
0)
4-1
c
id
X)
M
o
-p
u
•H
jj
CO
tt>
tt
sr CN
CO rH
O
tn
I
PH
^
CO
•H
S1
tt
XI
c
•H
tJ
tt)
if) rH
•H Id
> 0
0>
tt to
0)
t-H -H
id t3
•5 s
ft w
CO MH
o
O to
MH $
tt)
T3 -H
tt) >
C 0)
Id
rH
ft
to
0)
0 tt)
•H rH
•P ft
to E
ft 6
0)
cu x!
rH 4J
X)
iO -O
c c
O 10
to
(0 XJ
tt) p
C (0
3 CU
X!
CP
c c
cn E
ft X! •
-p
to Q C
0) 4J tt)
•0 E
•H tO C
0 4J O
•H 0 H
-P tt) vH
CO MH >
tt) MH C
ft tt) CU
0
•H -H
tt) 4J
O Id
CU O
J-l *H
0 4J
0
to C
^
D 10
-P -P
•P U
tt) 4)
rH MH
C tt)
-M
H tO
Id 4)
0 >
Id *§
id ^
V-J "^*
o id
10 VD
•o
M MH
id o
'c -P
Id rH
co to
cu
CH ^-1
•H id
-P
id to
vj id
-------
O
EH
CO
D
CO
U
H
a
u
H
EH
a
to
0)
Tl
•H
O
•H
4->
CO
CO
ft
I
en
g
ft
M
A
A
r \ c^ <± c^ ^ cs »i 2
•H rH CO \
CU -P i-l
(DSC <«
> -H 0> U
•H P -H -H
4J -0 g
O (0 0) D
10 M ,C
c tn u
S -H C
CU -H S
C C 0)
o — C
0 P -H 0
(0 P CO -H
CO MO 4-1 4J
C -P (0
13 M > CO
O O H -H rH
rH H-l CT> 10
IB CO • 0) O O
C U) ,G CO > H -H
-H C -P C -HO E
H-l O O -P -H CO
•H C -H 0 J3 X!
CO 4J 0 -P <0
rH C rJ
ja -H 3
rtJ O
c cu o
O > C •
10 -H CU CO
(0 4J 4J
CO O -O O
M id C 3
C (0 Tf
3 CU 0
TJ CQ M
4J -H 4J ft
COO
CU -H 3 M
CO CO O M-l
M CU M <0
ft ft CM CO
f.
•t A *
rH CO *H CO
ex
t*x
1
cL
•
CO
o
•H
4J
CM
B
0)
X
0)
o
c
co cu
c en
o n
•H CU
4J 6
10 CO
o
•H
rH
fir 1
0. 1
(0
CO
C C
O 0
•H -H
P P
(0 (0
U -H C
03 i~H O
•H a
o> a c
CO 10 O
CO 4J
•o
-------
5H
z
5
a
E
H
8
CO
!
5
R
Pi
1
8
CO
CD
Inspections for Significant Activiti
S
(0
c
•rH
rtJ
JJ
C
•H
T3
C
<0
^
•iH
^
CO
CM
rH
0
rH
'
1
•K
CO
CD
CO
I ra
co®
•H O 4J
TJ m o
CD
II CJ ^
O M rH
fM-l <3
^
R ^ 35
B E'
§ c o
o o
Specify the number of State inspecti'
the following categories identified i
and the number of EPA inspections in
.
8
•iH
rH
y
I4H
0
rH
iH
o agricultural use and follow-up
o nonagricultural use and follow up
o restricted use pesticide dealers
-r
CO
CN
rH
O
CM
1
§
£
!*•
0 D3
??
m o
0
c m
to
p*
CQ C
cj O
C Eti
CQ
0)
•H
•H
•H
Compliance Rates for Significant Act
•rH
fl) Qj
8
o c
ti O
Report number of State enforcement p
the following categories identified <
o agricultural use and follow-up
o nonagricultural use and follow-up
o restricted use pesticide dealers
t
CO
CM
rH
O
CO
1
PL,
C O
-H ^
jj ^-^
(0 CO
* o r-
* -rH rH
*'"** t| |
0)
S
m
0
•H
C
I
s.
Significant Violator - State Primacy
"c E
Ol CJ
•H
CQ O
CO
(0 C
•H
(0 W
C O
For referrals under Section 21 desig
accordance with the procedures set f
cedures governing referrals)
T3
£
CO
rH
2
JL)
0)
M-l
2
•8
2
^
l
3
1
*
(0
J8
rH
rH
•H
fc
** O
"8
•6-3
r*J ^j
|J ll
H fl)
tO -p
Z3 w
&* fC
* All Federal data will be reported i
All state data will be reported gu
of phase.
* See "Definitions."
*
-------
w
ro
CSJ
rH
1
S3
•2 S§,
5 WS
Q) -rl
c >>
* -H «J <
-* 4J DJ
5
m
0
"a
^
I
CO
1
1
^J
m
'o
•5!
ificant
&
•^
C/D
"D CO W
•S <1> C
3 • x: o
rH VD 4J
•H rH O CO
•8£ £„
BC CD CD
•H VJ CO
M -H 4J m
>H (0 C^
144 (B rH CQ
o c o —
•H .,-(
W 14-1 > U
•rt (0 Q-IW
V
fni— 1 -rl O
-»
o oj
CO E
C 4J
•iH
54J
c m
T) O C
Q) CD -H
CQ Qj J3
CO CO Z>
-------
in
S
CO
I
5
to
•H
I
U-l
2
•g
5
r-H
g
U-l
«
i
(C
00
•H C
UH -r-l
.r?3
w m
B rH
£
• -H
O CD -U rH -H
u-i u-i (0 (0 o
2 CD -r-l
SH XI U-l
•rl 0) O U-l
CD CN 4J £1 to
4-> C H
••H "U CD CD
M C to to >
t> OS [3 rH
C rH
U rH
rH
O -H
(0
(tj
d)
to
CD
« UH
O O
4-> U-l
I I
*
- . . rH
t
O
8
4-* O
C M-l
3 g
«
to
g
O
-------
CO
U
a
H
CO
PQ
CO
CJ
HH
X
O
H
Q
a
•
CO M
•H M
-o
>, H
i-H
I-l CO
01 CU
4-1 CO
M cfl
c0 i-G
3 a
cr
to
-a -H
•H iJ
> 01
o >
M O
PH O
rH
CO
•H
4-1
n
CU
4-1 bo
O C
P.1H
4-1
cu co
4-1 iH
CO X
3 01
rH
Cfl 4J
> CJ
cu cu
p.
•O CO
C 3
CO CO
^MH
MH O
•H
4-1 CO
d .***
cu co
T3 -H
^J < i
*
co
i
EH
cu
4-1
C
•H
4=
4-1
•H
|j
CO
4J
CO
•H
rH
U
H
M
^
4-1
CO
rH
•a
(0
4=
4-J
I-..
i— I
cu
42
4J
C
o
d
o
•H
4-1
CJ
CO
rH
CO
•H
4J
•H
d
•H
CU
cfl
H
*
co
rH
Cfl
O
•^j
Q
CU
CJ
•
j^^
CO
cu
"0
o
4J
d
cu
CO
C
o
CJ
*
51
PH
PH
52
*
£— I
Q
M
CO
cu
cu
C
0
*4-(
o
cu
C
•H
rH
TJ
CO
K*t
I-l
O
4-1
3
4J
cfl
4J
CO
^
M
CO
CN
"
O1
^~
i
H
4J
O
a
CO
d
o
•H
CO
•rH
CJ
CU
rH
cfl
e
iH
MH
CO
CU
3
CJ
a
•H
^^
CO
cu
CO
C
o
P.
CO
cu
M
CJ
EH
M
?
4-1
CO
O
P.
CU
4-1
cu
g-
o
•
s~+^
00
a>
r-l
2
4J
CO
cu
4-1
H
CO
C
•H
MH
^•^
-a
cu
CO
o
a
o
a
fs
CO
CO
cu
•"
o
4-1
^
M
01
CM
«
a1
c
0
•H
4-1
Cfl
c|
p
O
MH
C
M
oo
C03
^
U
CO
H
MH
O
^4
cu
ft
e
3
C
cu
4-J
d
o
t*%
l-t
^
cu
4J
CO
3
cr
4J
^1
o
p.
cu
cd
J>^
^0
T3
CU
CU
o
CJ
CO
i-H
cfl
CJ
iH
0
cu
,c
0
14-f
o
cu
0
^3
d
0)
^J
d
o
-o
d
cd
CO
cu
rH
3 •
pei CO
0)
bO i-H
C 3
CU CU
,d co
4J O
cO X
O -M
o-
0!
rH
P,
s
cfl
CO
J^J
1^
0
4J
CU
d
0)
CO
o
P.
•H
T?
cfl
vO
c»
fta-(
CU
42
MH
O
CO
cu
CO
K^
rH
CO
CO
i-H
Cfl
CJ
•H
0
CU
O
cu
cu
rH
8-
0
o
•
^*\
4-1
I-l
o
p.
01
M
CO
3
4J
cd
4J
CO
d
O
iH
CJ
cu
rH
i-H
O
O
^
A
ro
CN
*
O1
CN
1
H
"O
d
cd
*
CO
rH
CO Cfl
C! J*4
O M
•H CU
4-i MH
CJ a)
cfl M
4-1 CTi
d v
01
s -
0) CO
bO d
cfl O
d IH
Cfl 4J
S cj
CO
CO VO
T-l C01
^1
ft
rH CO
CO 0)
CJ -H
•H M
0 0
cu co
rj *,_}
CJ >
•o
Mcd
•H rH
4-1 Cd
co o
•H -H
x e
V 01
I8
co
01 CU
CU 3
rH rH
s-s
0 -H
CO
d
o
•H
4-1
U
cd
3
01 O
4J M
CO MH
bO
i-H CO
0 CO
O «rl
M h
a
01
*X3 ^d!
C ^J
cd
CU
01 CJ
•P 3
cO *^?
tH 01
4-1 I-l
•H
C 0
H 4-1
•
/"N
CO
cu
rH
3
M
CU
CO
3
[J
CU
d
4-1
d
cd
CJ
UH
•H
d
bo
iH
CO
•
CO
rH
cd
o
•H
6
cu
f£*
U
bO
d
•H
4J
CO
•rl
X
cu
CO
3
0
•0
CO
N
a)
43
O
co
CU
CJ
o
CO
I-l
h
0)
MH
0)
H
M
d
CO
01
bO
C
CO
-------
CO
u
H
w
g
CO
0
hH
X
o
H
Q
^
to
O
M
U,
H1
H
CO
w
PM
0
w
u
M
O
CO
cu
CJ
c
CO
w
3
CO
y
•iH
X
o
H,
B^
CO
CU
w
B
cfl
O
PM
z
5
O1
g
§
0
CO
§
CO
M
2
£5
^o.
^
w
5
w
^
M
B
P5
pa
o
<*
m
»
CN
^
u-i
£
T3
c
CO
TJ
CU
•H
CU
CU
J^
CO
cu
y
•H
4-J
o
c
rH
CO
•H
e
&
y
*j
cu
c
U-I
o
fa
cu
£>
e
3
c
cu
1"!
4-1
C
O
4J
O
(X
cu
CO
o
4J
CO
rH
CO
y
•H
B
cu
fi
y
s
cu
c
H
rH
CO
4-1
y
CU
1-)
43
CO
•
M
CU
4-1
IH
CO
3
cr
^G
y
cfl
cu
•o
cu
co
CO
cu
y
o
fa
cm
cu
CO
4-1
T3
C
CO
Jj
CU
•H
>
IV
co
0
.e
4J
rH
O
S-i
4J
C
0
y
o
**
C
o
iH
4-1
y
CO
CO
cu
•o
f— {
y
e
tH
^
CO
C
O
4J
y
co
rH
O
^4
4-1
C
0
y
i-H
CO
y
•H
g
cu
y
|j
cu
c
(4-1
o
(-1
cu
&
B
3
C
cu
f
4-1
C
o
4J
^i
0
o.
cu
Pd
•
^
w
•H
J_t
cu
rH
^o
CO
c
o
CO
CO
(U
^
c
3
a
CO
CU
CO
O
a
/-s
cu
U1
I—J
CO
g
O
MH
M
O
4J
C
CO
e
0
y
A
CO
rH
o
M
4-1
C
o
u
>>
(J
CO
4J
e
3
rH
0
M
00
pj
•H
4J
CO
CU
4-1
^
^4
CO
^J
C
3
rH
O
•
CO
c
M
cu
y
(3
o
y
•^
fit
w
0
4-1
CU
3
rH
CO
|j
CO
M
•O
4-1
•H
{4
0
CO
cu
*o
^
o
x™\
<4H
IO
A
CO
M
01
TJ
^1
0
^
CO"
•>.
CN
1~^
o-
vO
EH
CO
CU
*o
3
rH
y
C
•H
v-x
CO
rH
^3
y
•H
£3
CU
("f
y
S
cu
c
p
o
c
cu
^
CO
4J
CO
c
0
•H
4J
y
*
a
7
3
0
iH
rH
0
•4-1
CU
4-1
CU
rH
P.
Q
U
cu
IH
3
4J
3
I4H
e
0
fH
UH
^
4J
CU
•H
y
o
4J
y
cu
4J
o
M
PH
•
^~\
CO
cu
rH
3
^"\
fl3
\_ /
CO
(«»
fa
0
CO
p^
p^
jgj
to
S
cu
c
CO
CO
4-1
CU
i^j
M
ctj
g
CU
CX.C
o
rH
CU
cu
>>
CO
S
^2
y
iH
s
CO
^
CO
•H
l-l
4-)
e
•rt
O.
O
rH
CU
^
cu
CO
rH
CO
y
*r4
gjj
cu
y
«
cu
y
CO
rH
Q.
-------
ro
co
ro
ro
rJ
O
O
O
O
w
CN
< <
K E-?
S
I
§
CO
8
8
B
±>
o
o
&.
S
B
Pu
S
JC
(0
c
•iH 0)
as O
^J C
C (o
I
14-1
-------
CO
CO
w
(N
CO
O
o
O
M
m
l
*
*
*
i
s
VI
n
r-
oo
I
•H
PL,
6
n six m
ports,
ding (c
the beg
re
sign
have
of
ch
•H 14-1
**
pending
.
to 53
to to c
•rH Q) Q
rH g
Is-
8|J
l!i
M C C
«111
>H tQ tO O
O 05 0) rH
l*H -H -H O
O O O O
ce
co
ca
9
FY
CO
1
I
s
(0
to
«3
4-)
(C
*• 4J
«>
?g§
•H -rH
(C
•K «
*
.C
(0
c
c
•H
c'S
•M 0)
(0 O
^§
•rH -tH
T3 O
C O
V4H
« 0
°ii
(1) rH rH
••H OJ -H
•eis
-------
-------
-8
-------
CO
PS
M
<
b
b
<
J
<
Z
PS
Cd
EH
X
Cd
b
O
Cd
CJ
M
b
b
O
H
CO
»VJ
»"
to
H
Z
s
Cd
0
<
Z
<
s
Q
Z
<
0
z
h~t
z
z
<
(J
eu
CJ
M
O
Cd
C_i
<
PS
EH
CO
*
to
Cd
PS
D
to
<
Cd
2
r-
CO
O*i
l-l
X
b
CO Z
U U
PS S
D CM
CO O
< J
U U
s >
U
Cd Q
CO
O Q
as z
H <
Cd
K
EH
>n
PQ •
ro
Q ,-H
U I
D <
CO Cd
CO O
H
Cd
Cd O
CO <
Z Cd Cd
M OS CO J
b Cd D
PS PS Q
Cd Cd D Cd
PS Q tO DC
< Z < U
D Cd CO
O iJ
H
PS Z
O W
h PS
PS
CO D
Cd CJ
PS
D W
CO {*
< <
Cd
S =
H
CO fc,
S <
^ PS
CO Q
oo co
Cd
iJ DC
•< EH
Z
M 2C
Cb H
CO Cd
2 U
O Z
M <
O Q
Cd (U
PS O
CJ
Cd CJ
DC <
P
Z
<
Q
>H Cd
b. EH
O
Cd Z
nc
EH Cd
00
PS
O.
b < Q
O < b
DC Cd O
HUE
CO M Q
O
s
*
CD Cd
-------
CO
X
LU
LU
O
re
4>
X)
4<
re
c_
01
o
o
LU
O
LU
OL
U.
LU
a
O
CO
^r
Q-
CO
UJ
OL
CO
UJ
LU
^>
i— t
r-
o
LU
•™3
00
o
1— 1
o
*
LU
i— 1
1
^
LU
O
en
4) 10
•p- 4)
4-> t-
•i- >
O •(->
re v- •
O a. o
JZ t-
4-> - X! O
O 4) 3:
E
C 41
O X) JZ
•P- 4) 4-)
4) O XI
OL 41 C
p- IO
JZ 4>
U co «C
IO U_
4) 4) O
JZ
c
E c 4>
IO M- X)
C T-
^J
CL 41 >>
0 X! P-
p- 3 4J
4) •— C
> O -P-
41 C O
Q -P- -i-i
4)
U
IO
i^ 4)
Q. U
E C
O 10 en
O C -P- 41
•p* p— *p~
en 10 Q.4J
41 4-> E i-
•p- C O P-
4-> M- O i-
•p- 10 0
p- E J-
P- {_ 4) 10 41
IO Ol > «- X>
1_ o 4> 4)
4- t- t- JZ U.
x: a. jz 01
41 O *P* 4-^
u- < jz re
CM
0
*
LU
CM
1
LU
0
E
C- 4>
o re
(- 3
o. cr
4>
u re
re
4) JZ •
0) >,
C 3 O
•p- O C
£_ 41
en jz O)
41 4-> to
•^.
4J XI r—
•i- 41 re
p- en t_
•p- en 41
0 41 X!
re t- 41
c a1 o
C- 41
41 re -P-J
JZ O
i * ^) 4«-
4-* QL
4-> *p~
t- 1- l£>
0 0 C
CL-P- t-l
41 (. 1
OL CL<
1 %
C
VC 4) •
O E en
PH 4) en
1 •«-> 41
«t re O
JO O
41 re t_
JZ Q.
4-> C
o o>
JZ -P- C
Ol-P f-
3 3 C
0 p- C
i. p- re
JZ O i—
4-> Q. Q.
^-
cr
•K
LU
CO
1
LU
o
^
0
re jz t—
41 oi re
3 C
C 0 -P-
•p- t- <4-
JZ
en 4-> -
41 en
•p- X! 4)
4J 4) -P-
•p- in o
p- en c •
•p- 41 4) in
O C. Ol C
fl3 ^3 iO ^3
*l- XJ -p-
re p- en
XJ re in
4) C t- f-
•p- 41 41 E
<4_ 4J X! JO
•t- JO 41 3
4-> u. in
C 41
41 > 41 C
x: re jz re
•p- JZ +J i—
a.
>«- JZ C
O 0 M- 4->
•p- C
(- 2 en 4)
4> -ME
jo re o 41
E 4) 4) +J
3 t. -P-J re
c re o jo
c- re
p- >, Q.
4-J *p- ^O O
O t_ O >p-
4-> O PH 4->
f- 1 3
41 <- < i—
jz a. P-
| » Q) Q
E 4-> a.
4-> re re
C- t- 3 \C
o en cro
Q. O 41 i->
4) t- XJ 1
ac Q. re <
i— i
o-
*
UJ
^^
1
^
UJ
0
^
4)
0
3 p- 4) en
re jz o P- 4-> 41
•p- u m re t- o
T> i- 4-> E «-
4) JZ t- C -P- 3
E 3C 0 41 — 1 0
••-5 E «•— en
jz en re c
O 41 E O c-
re u i_ • o
41 (- re >P- E c
3 > re T-
t- O <4- C t. £
O in o 4t 01
M- 0 >>
t. C >) (. 4->
• OOp- O.-P-
C C i- p- t—
o »p- 4J re P" "p*
•p- E -p- -P- re o
o> c 4-> 3 re
41 in i- c xi <»-
a: ai t- 41 ••-
•p- 41 +J > i—
>i+j xi o i- re
JO 'r- Q.X) 4-
p- en c 41
en u E JO 4'
4-> re re c u.
in ej_ {_ o re
•p- O>4-> 4)
p- p- 0 C_ JZ
re (- x> o 4->
41 t- O- 41 <4- •—
E 4i c «*- •
re xj re -p- ^~ o E
c 4i M- E en re
U, XJ t. — '»« t-
p™ 4) 41 4) **"* Ol
re 4> E +-> u «-H o
3 in 4) «- (-
XJ O 41 XJ 3 C OL
•p- jz jz o re
> 40 4j ai in jz re
•p- «_ 4-> -P-
C O 4) C 41 41
•p- 41 jz re c_ E
• E 0 0 O
CL E i- i- E JZ
o re 4-> jz M- o
p- t- o 2 t- o re
a; en c cr c a>
> O +J 01
41 C_ O 3 -P- O C
O Q.X) JO «/> +J i-
>,
4J
•^
r^
•p-
0
(O IS
(+— (Q
L
^~ o^
re o
C- (-
41 CL
4> 41 4->
u. u c
C 41
41 re E
> •!- 41
O P- O>
{_ a. re
tE c
o re
— 0 E
CM
Cr
*
LU
IT)
1
XI C O
4) re •«->
U. 0
•P- XJ
CU 1- 4)
CO -P- +J
O C -P-
jz 01 E
4J -P- t-
m _i
(f_ *•—- •
0 >>
C P- •
o re in
•p- 4J *p-
Oi c in *"^
41 41 re •
ae E jo c
c o
jz o re t-
O (- -P- Ol
re -P- xi 4i
41 > 41 tt
c E
C 41 1 C.
•p- -p- 41
4) +J Q.
4^ t_ f—
m re 3 en
•p- E 4i
p- JZ i-
o re 4J
4* *P* *P"
E JZ c p-
re 2 O v-
C 0
in xi re
re 41 41 <*-
•P- L
f^ 4J Qj f^
O -i- X3 P-«
4) -r- en C
> o c re
41 re o jz
^^ (4. y J^J
^^
o^
-K
LU
^s^
vo
1
•
C <4- X3 41
41 O 4> >
E U- i-
41 E 4->
01 re 4-> o
re t- c 4i
c cn re a.
re o o m
z «- -p- t-
CL**— 4)
4) -p- O.
u re c
c -p- 01 re
re xi *^* *P~
•p- 4' en xi
p- E 4i
a. >> E
E 4i p- l
O 4J P- t-
o re re 4->
>> tl c "3
•p a. 41 E
•p* O E
p- i- c re
•p- a. o
O CL i- E
re re *P* o
u. > t_
JZ C <*-
p~ 4-> 41
re f- c
t- a 41 o
41 4l-i-
X) C t- 01
41 O JZ 41
U. -P- 4J oe
40
Q. re Q.JZ
o c. o o
p- 41 -p re
41 Ct 4)
> O 41
4< O J= C
O U 4-> -P-
41
3
X)
41
JZ
U
en
co
XJ
41
JZ
o
IO
.C
41
l_
3
en
10
4)
10
t_
X!
IO
CU
t-
a.
en
41
IO
O
X5
C
-------
CO
or
a:
LU
x
Lu!
LU
O
Lu.
Lu.
C
CO
QJ
4-3
O
re
t_
QJ
X>
E
re
cn
o
0
^*
UJ
~~^
p
Qi
Lu.
LU
O
o
o
2:
O-
co
LU
o;
— ^
CO
^^
UJ
s.
LU
>*
t— i
r—
O
LU
•-D
CO
O
*
00
*
CM
*
'
CD-
re X3 O XJ
t*^ r*1*. r*^. r**- r^~
ii ill
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
O O O O O
p —
x: re i
O -— t- OJ
•p- = OJ t-
x: cnxi
5 C OJ «•
•p- Lu. CO
1-0- *->
o o «- c
4— O QJ Q)
oo x: E
in = 4-> co
4-> » — • O CO
O QJ
O) c x: in
•r-j O 4-> CO
o -P- -p- re
t- 4-> 3
o. re p—
c t- re
t- -p- O) 4-3
o x; 4-3 c
*t- t_ t_ Oi
o re E
in o 3 c
4-> o cr o
<*- 0) t-
O en- — • in -p-
s_
i- re LU x: c
OJ 4-> 4-3 QJ
XI L.
E 4-3 O XJ U-
3 00 — ' O) O
C C 4-> • •
•p- co re xj x> co
o; re i— i -i- Q> o.' 2
r- cnuj 4-3 3 3 oj
4-3 re i M-
• CO t- -r— > > O)
C CO Q. QJ QJ t-
o O) a' s- t_
•p- !_ QJ oo oo >
QJ O -r- 2 • CO CO -p-
CZ. t- 4-3 00 l— « l— i 4-3
Q. C 00 O) LU LU C
>, re 4-3 T- re
.C J* 4-> t- O 4-3 i— 4->
o oo o c <*- re oo
•> rexii4-oj re c x:
>, t-3>t-cn t_ -p- 3
<4- 1— CO QJ «3; O LU. CO
1 — ^ £ T
X! -i- ••- -i- T-
O)
t- XJ
E OJ oo c
re x: oo "re
t- 4-3 QJ C p—
en o o * re
o
0) Q) QJ X) U O
•p- c T- t- re c.
> O> > 0 4->
Q) > QJ O XT C
oi M- u. o a o
4-> in U
i— U i— >, O
re Q) re p— a. c
4-> <4- 4-> «- O O
c 14- c re c_
QJ QJ QJ QJ O- O.
E E 3 •
c QJ c x: >t- i in
o > o cn o 2 c
L. O t- 3 O O
•p- l_ -p- O 2 p— T-
> O. > t- QJ i — 4-3
c E c x: ••- o o
LU i— i o; 4-3 > t- re
•
00
c
o
>r—
4_>
re
o
•r—
r—
Q.
O.
re
OJ
00
c
O)
o
•f—
^_
^;
C
re
«
in
C
o
•r—
4->
re
pM
3
cn
O)
p^
1
LU
O
C (-
x: re oj
04-34-3
•p— CO C.
x: x; re
3- 3 3
00 D"
u.
O t- in
(4- QJ *p—
-C x:
00 4-3 4-3
4-3 O
O XJ
O) L- OJ
•r-3 O 4-3
o re
t- 00 -p-
Q. C7>4->
C -p-
t- ••- C
0 4-3 T-
> 2
cn o
(- C 00
re QJ oi
4-> cn cn
re c
4-3 re
co Q.X:
C 3 O
•r- 1 X
re s OJ
cn o
re i— c
p- O
CO O •!-
00 >t- 4->
O) re
<- QJ E
cn > j_
O -P- O
t- 4-3 <4-
O- C C
re T-
^ 4-3
O 00 O>
re x >
l- 3 v-
t- 00 4J
,
-
•
^
c
t_
QJ
O
C
o
o
c^
CL.
LU
4-3 C
C CO
O OJ t-
•^— ^o *^~
O^ *r^ ^
QJ C
a: • oi
CO
>> 2 X!
Xi OJ QJ
•i- CO
>> O) re
<«- a: i-
*rf
£ ^
X3 "P~
l — i «.
M-
O
1
4J E
0 •!-
re
O.X:
E cn
•r- 3 •
O C
p— t_ cn
re x: -p-
4-> 4-> CO
C OJ
QJ 00 X!
E 4-3
C O 4-3
O OJ O
t- T-3 QJ
•p- 0-r,
> t- 0
c a. t_
ai a.
t—
Q) re XJ
O (- O)
3 QJ >
x; x; o
OJ OJ t-
tt Lu. Q.
*
XJ
00
1
LU
O
x:
o
•P..
x:
5
c
o
tf_
-o
f"N*
1
(^
LU
0
XJ
c
m
^
f*v.
1
<
LU
o
C
•P—
x;
Q>
•p—
(|_
•p—
4-3
C
QJ
XJ
CO
^
O)
•p—
>
Oi
C£
^
*f
•
TD
QJ
4-3
O
3
XJ
C
o
o
oo
re
^
cn
c
• p—
o.
o
o
CO
QJ
>
•P—
4^
C
re
4^
00
X)
3
00
O
cc
1
LU
O
p—
re
c x:
•p- O
x:
re 2
« L-
« 0
O) <4-
•p— ^*^
» — • XJ
Q)
C- 4-3
QJ QJ
4-> P—
t- 0-
re E
3 O
cr o
CO C
•r- 0.
c— OJ
4-3 X!
XJ 00
QJ re
4-3 x:
CD
i— C
a. o
E -r-
0 4-3
O O
re
00
•3. t_
a' o
•P—
> 4->
ai c
c. oj
g
4-3 E
0 O
O) O
• I—}
o «t
t- Q.
a. LU
tf_
-
•
00
c
t-
OJ
o
c
o
o
r-—
re
4-3
c
QJ
E
c
0
u.
•r-
>
C
QJ
^D
OJ
OO
.p—
re
t_
XJ
re
x:
«^
O-
LU
XJ
00
1
LU
O
f—
ro
C
•r"
4—
CU
JC
^_>
QJ
OJ
x:
5
o
00
1
^^
LU
O
C
•p—
x;
O!
C
•P—
1 ^
C
QJ
XJ
•r-
1SI
3
a>
•i—
>
ai
1 1
o
OJ
"•"3
0
t-
a.
^
—
oo
c
c
QJ
O
C
0
o
eC
O-
LU
[ ^
re
x-
4-3
OO
Q)
re XJ
O OJ
•p- >
x: p—
c o
•p- 00
a>
c c_
o
>r~ ^^
4-3 p—
0 -i-
re t-
o
0 0
re
C CO
E 4-3
E re
O CO
o
QJ
O- QJ
LU 2
(N
OJ
3
T3
a>
x:
o
00
oo
X)
a>
x:
o
re
re
a>
x:
CD
C
•I—
X3
o
u
o
re
x:
3
CO
re
a-
re
L.
X)
re
ai
i_
a.
CO
re
u
XJ
c.
-------
0£
X
LU
LU
O
10
CD
O
re
a>
x
O)
ta-
re
t.
Ol
o
0
z
LU
rs
0
LU
b-
LU
0
O
s:
Q-
LU
Q£
rs
C/*5
i^
LU
s:
LU
^>
H-H
1—
0
UJ
r^
CD
O
01
1
LU
O
1
If
•r-
C
Ol
»^-
t/1
Oi
(/i
.,_
re
t
_c
0
•f—
c~
5
to
•r—
E
(_
Ol
Q.
-O
O>
CO
O
*
CO
A
cv
o-
>^
Q
4->
C-
o
CL
OJ
fy
•
C
O
*n*
4->
3
"o
to
Oi
(_
XI
re
TJ
o
a;
CL-C
0
(_
CL
^-
O
«fr
14-
o
to
3
4-5
re
to
o>
-C
4-'
XX
O
re
i_
H-
xs
c
i re
E to
re t-
c. oi
Ol 4->
0 «-
t. re
^"
i™~ 4-5 "O
i— c re
••-
C C- JC
re o 4J
<*-
•!-
C Ol
re o>
U Of.
c
o «_
•i- O
1 *
O XJ
CO O)
^^
L. OJ
o t.
»-
tO O
(U
O Ol
O Ol
t_ l_
CL re
r- 0
re
•r—
>
OJ
L.
4^
•^.
dJ
CL
r— *
re
t_
oi
4->
re
E
r«.
i—
•r*-
<»-
re J2 o
O"i Oi O^
1 II
LU LU LU
O O O
O C
•r- • re
x: t_ u
3E OJ "^
4-5 *4—
^— v t- «^
to re c
> — 3 Ol
t ^~ ir-
O) bO
4-5 tO
t_ ••- X3
re .c O)
3 4-> l/>
O" 'i-
x) re
i/i a; t_
^ ^^*
O *O -C
•^- g^* O
> ^_) >r~
o> -f- x:
(- c 5
CL -i-
^
E to O)
O 2 4-*
f_ • Ol (-
M- to -i- re
O) > 3
CO 3 Ol O"
31 l/l C-
0) to co
•i— -^- 4-5 v—
> •!- -C
a- 4-5 E 4->
«_ c t-
to o >
r— t Ol •
OX) Q. !_ to
to a o>
oi to •* «d- 3
t- •!- O O tO
c re ^t~ *^~ oo
3 L. M7, \£r -r-
*~~~ *—*• ^~^
•^ *r~ *^"
N •r— -r—
v_^ »r—
* —
"U
O^
1
LU
O
• •
t_
o>
4_>
t_
•n~
j^~
^_>
ai
c
•i—
^.
3
"O
(/)
c
o
«^-
4.3
3
r—
O
to
O)
«(^
o
^~
t^.
y^*^
>
•r—
v—'
1
E
O
o
«^
CL.
LU
(4^
O
o>
u
c
re
4->
CL
a;
o
o
re •
CD
4-> 0
c c
re re
O 3
•r- t/1
r— tO
CLT-
Q.
re o
1 *
t_
O Ol
c
(/I •!-
CLX3
t- re
o o>
O r-
0 «
4-5 10
±2
cv c
3 OJ
a E
•
(O
en
c
•r~-
^_>
1—
3
(/)
0>
L.
»
to
4-5
c
Ol
o
u
^£
o.
LU
Vf_
0
Ol
o
c
re
4»)
CL
o- •
0 r-
o re
re •>-
c
to (li
Q-X
O 4->
° *P
0 «-
4-* QJ
CL
a>
3 C
c: T-
•
^3
C
O ^3
•^ 0)
re c
X) OJ
c E
OJ E
E O
E U
O O>
0 t-
Ol
L- o
O •!-
I/I
4-5 3
•f— r~
Eo
c
a; -^
a.
0) 3
c o
•r- -C
3 4->
to -c-
to 4
c^-
c
to O
CL
o re
c
O Ol
4>j "^
Ol t-
3 O
C t-
•
O
•
to
c
o
4_i
>r_
^
C
o
o
t^.
o
to
c
o
4^
re
0
•^
*f—
*^"
"CJ
o
E
4->
•i—
E
Ol
a.
•
C
3:
re
i_
X)
4->
^
to
c
o
•^.
^ *
re
o
•^
r^-
Q.
CL
re
O
4->
O!
3
O
•
X!
<*
CO
A
CM
.— 1
cr
o
r-t
1
LU
O
re
<-
o
XI
0 U
c — •
re «i-
> o
XI •*
re to-
^ x
0 O
00
t_ •
a> o
.a n
E cv
3 U>"
C
t.
O) QJ
-F" ^^
4-> C
3
t_
O
*f— ^^
C^
tO 4->
4-> re
tO
tO C
C O
re 4-5
Ol
Jp"
4-* •
V)
4-J ^!
0 C
-------
oo
ce.
ce.
LU
X
LU
LU
O
CO
OJ
u
re
at
OJ
E
re
(_
01
O
Q-
o
LU
ID
Cr
1 I 1
LLJ
C£.
U_
UJ
O
O
00
s:
Q_
00
LU
ct:
•"•^
oo
^^
LU
^"
LU
^>
i— t
I
O
LU
••"3
CD
0
O
I— 1
1
r-
1 *
O
oj
i * «^~^
o •
C (U
Q. Q.
j>j
OJ jj
•P T3
C
i. re
o
<*- <-
c o:
^~
re •
Ol CO
t- T3
•r-
""^
o
.—1
t— 1
1
LU
O
c
O
•r"
4-*
TO
U
.f—
M-
•r—
4~>
c~
OJ
"D
•o
OJ
o
c
re
•^j
re
<*-
o
t_
Ol
JO
E
3
C
re o
LU re
i
E
re
L.
01
O
t..
Q.
l
r—
•i- -1
U.
C
re
flj
OH)
T3
Ol L
0
*;
co
CJ
"
1-1
o-
*
LU
OJ
i— l
1
^
UJ
o
>^
r^
^^ "O
CO (U
-
U_
^3 1
— i C
^>
ai
U_ c-
Z 4->
0 >>
I— ( (4—
U- •!-
I— i 4J
z c
t n oj
*~~* ^D
00 i— i
E •
0 E
o re
L.
^f O
C3 O
^J t-
CC' Q.
ai 4->
> c
•r- Oj
o ai
jj_)
•r-
00
^>
oo
^.
i
a.
0
'a;
>
(U
OJ
r~ • •
+J CO
OJ
Ol CO
c re
•t- O
00 T3 CO
Ol
i— l
>-
LL.
1
OJ
a.
i^_
o
t_
OJ
"i
3
C
a>
^^
c
re
c
o
•1—
[ \
u
re
i ^
c
CD
E
ai
o
c_
o
c
ai
OJ
to
re
o
x..x
o>
c
"^
c
Ol
a.
(/)
•r—
C
o
•r—
^ ^
O
re
^j
c
0)
E
OJ •
(J ^ — >
t- 01
o c
ll_ If—
C O
flj Ol
c
JC 0
o
•T- CO
JC •!-
^
4_)
l~ C
O O)
^ E
CO >
a- oo
c.
T5 *f-
TI3 O
m
>^
c «-
•r- O
CO C
CO OJ
OJ >
t- C
O> *l-~
o
t_ ^~
o >-
0
4-> CD
t ^— ^
O
Q. (-
k
•t
1- <»-
a> o
^J
t- 01
^3 C
3 •!-
^J" C
c
JC •!-
^_ ^^
o
O- 4^}
O
•o c
OJ
4-> CO
o re
ai jc
i »
at c
-o o
CO •!->
C O
o re
>r.
4-^ H *
re c
i— flj
0 E
•r- OJ
> 0
•P O
c t-
re c
U O)
•r»
(I— t—
•^ re
c E
O) t-
•i- O
CO <4-
^^x.
*^-
v —
LU
CJ
•— 1
1
^
UJ
0
c
o
•f—
1 *
o
re
•p
c
a>
E
a,'
0
c_
o
c
OJ
^_
*o
E
o
^>
-C
"O
ai
CO
CO
a>
^^
^^
re
CO
OJ
•^
CO
^-^-
•r-
•f—
**^
<*-*.
CO
Q.
t-
o
0
c.
o
^£
Q_
UJ
t^
€U
JT
jj_>
•^
QJ
N^^>
LU
O
OJ
t— 1
1
^
UJ
o
c
o
•r-
4_^
o
re
4_>
C
a>
E
_
C
0)
r—
*O
E
O
M—
>^
Xi
^3
a;
f—
O
>
(/I _O
x— ^
*r—
•^
•r-
*^--
LU
O4
?-"*
1
L> "^
E
01 OJ
• Q.
H-
> i
i— 1
C- <-
OJ
Q) 4->
CO «4-
•i- re
2c
C «s
O) O)
JC 0
-l-> C
o re
•r—
CO i —
•r*
Xv^-
z. "o.
(U
OJ
JC
o
to
oo
<
a'
u
re
re
OJ
JC
01
c
o
u
o
to
N
•n-
re
OJ
o
CO
1X3
O
C
i—i
*
-------
oo
r—I
T3
OJ
TO
(-
CD
O
a.
o
z
III
u_i
o-
LU
U.
LU
O
O
O
00
s.
Q-
00
LU
CtL
OO
c^
LU
TL
LU
^>
K- t
1—
O
LU
r"0
cc
c
•*
CO
OJ
f,
r- 1
o-
*
LU
CO
r- <
1
^£
LU
O
4J
C
OJ
E
QJ
0
O
n-
c
QJ
p"** •
00 >
cr> co
t— i
•o
>• QJ
U. 'I-
*•— ^ *l
•r"
QJ 4->
to c
TO CD
CD -0
•r-
O
'E r^?
re 5
C QJ
>> C
0
i r-
00 00
C£ CTi
c »-i
t—
_j u.
i— i i_
> o
U-
r-
z
— i CO
U- C
1-1 O
C£ 4-J
1-1 0
tvO TO
E
TO
*
CD
O
t_
^1" Q.
C
^" 4-3
co- c
QJ
QJ E
> QJ
•i- O
4-> t-
0 O
QJ <4-
<4- C
TO
re en
T3 M-
O CO
4-> Q)
>
>— c
TO •!-
o -o
Iv
a: ••-
> M-
•r—
4-* ^ '
TO C
r- C
3 E
E QJ
3 O
u t-
o
t_ c
O QJ
a.
OJ M-
t- 0
* t_
t ^)
QJ JD
4-> E
t_ 3
TO C.
3
cr
sz. *~^
O -i-
TO *•— -•
LU
LU
J2
CO
t— 1
1
^£
LU
O
JC
o
•r- C
J= QJ
H3
«- •!->
0
QJ
^3 ^"^
QJ
0 O
OJ C
^>
a> c
•D o
V) W->
c o
o *o
»^-
1 ^ » V
fO C
r- OJ
0 E
•r- a;
> u
i.
4-> O
C M-
ro c
O QJ
•t—
*4— p—
•i — TO
C E
CD l_
•r- O
CO "4-
.^-^
•r—
•r-
*—*
LU
0
co
r- 1
1
^£
LU
O
c:
o
•r—
jjj
0
TO
4J
C
QJ
g
QJ
O
t_
O
14-
c
QJ
P—
TO
E
O
*4—
>^
x:
"O
Q.
CO '
^~^
>r»
•r—
•r-
^~*
LU LU
-D QJ
co co
,— I <— 1
1 1
^* ^c
LU LU
0 0
C
o
jjj
o
TO
4->
C
QJ
E
QJ
0
C-
o
"4-
C
QJ
r— -D
TO QJ
£ >
{^ r~~
0 O
<4— CO
QJ
>) »-
jQ
•C CO
QJ -r-
^— C.
O (I)
trt JT
-\ *r~
«/> -D (/)
*>~*+.
> ^^>.
•i~ >
*— *• •*— '
E
TO
C_
CD
O
c_
ex
QJ
o
c
TO
•r-
r—
Q.
E
O
o
«^
ex
LU
Z
* •*.
CO CO
OJ OJ
•1 «
1— 1 »— 1
cr o-
^j- LO
t— i i— i
i i
^C ^C
LU LU
O O
CO CD TO
QJ C \ C
4J M- 40 O
TO -O C T-
4-> -r- TO 4J
00 QJ > I- O
«=c 4-> o en c
(-
1 O
t- >> O CO T- C-
QJ J2 4-> C 4J O
^2 IOO
E "O t- -r- 3 CO
3 QJ TO 4-> *- I— i
C E QJ O 40 LU
t- >, TO CO
QJ O C >>
f ^- CO £- O i-
4J C. 4-> O
•> a. QJ c c
4-> 3 •> TO 3
QJ QJ CT- — * f" r—
CD t_ QJ >- 4J O
t- QJ 1- O >
TO 2 CC t- to
4J r— QJ CD QJ
CO TO CDJT C T-
4J 5 4^ r" 4-J *r— 4^
CO OJ O •!- O 4-> -i-
C -r- 4-> TD QJ r—
•r- > C a' •!-
TO QJ QJ QJ CO E JO
cn t_ j= a. E -i-
re 4-> TO s~ co
4J CO t- O C
•jr »4-> CD<4- O
C CD C CO O Q.
O T- O QJ J- OO to
•r- CO -r- 3 O. LU QJ
CD t_ en cr o «-
QJ QJ QJ QJ O O-
ct > cc «- 4J z
o >>
>, >i CD O) QJ O
-C jc JT c -C TO 3 i—
4-> JC 4-> 3 4-J O TO
C- 5 t- r- CO CO >
O O O T- -r-
OL i. Q- C CO 3 3
QJ O QJ M- to QJ cr
ex. 4- oc: - — • TO c Q)
^_>
•r-
•r— «r—
r^ 5
a.
E to
O 4-!
o c
QJ
to E
- QJ
r-
-*
CO
C^J
«
T-H
0
TO
LD
t—>
1
^^
LU
0
O
-|--»
QJ
to
C
O
Q.
to
QJ
t_
C.
>r—
OJ
40
TO
T3
1
O
4_)
l_
TO
CD in
>> i—<
i
•o «c
QJ LU
E O
^
o c
M— *r—
t_
QJ "O
a. QJ
4_>
CO C
C 3
O O
•r- O
4_)
O CO
TO 4->
CO
•— QJ
TO 3
4J CT
O QJ
1— t-
m
3
T3
QJ
O
CO
oo
H-
<
QJ
JT
O
TO
TO
QJ
CD
C
O
U
O
TO
O)
N
TO
C
QJ
O
to
QJ
3
CO
TO
TO
<_
T3
TO
C
QJ
Q.
tn
OJ
TO
-------
o
oo
(X
I—t
«c
Li-
Li.
re
i_
en
O
a.
•z.
LU
o
UJ
u.
UJ
0
o
o
CO
Q-
OO
UJ
a:
oo
^^
UJ
51
U.'
1— 1
J3
UJ
•-3
00
o
CO
CM
I— 1
o-
f^*.
1 — 1
1
(,_
O
L.
CU
JD
E
3
CU
f"
•*->
*i
(/I
^ *
CU
c_
re
•t-j
^ •*
en
C
•p.
re
Cn-O
re cu
Q.
« o
C i—
O 0)
•1- >
en cu
cu -o
ce.
^} •*-*
JD C
CU
« E
J^ Qj
o a-
t5 trr
1- 0)
1- <
cu
en
a> •
> to
o -c
0 C
re
E <-
re
en O
0 T-
t- •!->
E a. re
re >
c_ to (-
o
E to
3
C r—
re
CU 4->
JZ. C
4J CU
E
• c
•!-> O
OJ l-
CTl-i-
^ >
re c
•(-> CU
4-> r-
to re
C JD
•i— "r-
re L-
Cn i '
re
t_
•• O
C *f-
o
Enr-
, to
JD a.
0
^c in
o **^
re t-
t- o
h- X
co
CM
«t
o-
CTv
i— i
1
«c
UJ
0
re
u
•r—
C
jr
o
cu
^
^-
o
<+~
10 to
+-^ 4-*
to c
d) CU
3 E
cr c
Qj £—
t- ai
«»- o
O en
t- r-
ai re
JD JD
E -i-
3 t-
C 4J
cu E
JZ O
4-> C.
tf^
#1
c: 73
o cu
•r- >
Cn'r-
cu cu
o: o
cu
^^ c.
JD
CU
« o
>» c
M~ re
-»-> in
C •!-
a1 tn
T3 to
i— • re
JD
CTi
t— (
1
«=c
LLJ
o
cu
to
c
o
CL
cu
J_
c
•r-
c
cu
re
4-> cr
l-H
to i
c <
O UJ
•i- O
4_>
to -i-
4J CU
V) O
•r- CU
to t-
to
re t/i
^ ^
^— (/)
re cu
O 3
•i- cr
c cu
jc: c.
o
CU O
[— .{_>
x-^v
•f—
>^^>
-------
a:
KH
<
oc
UJ
H-
X
OJ
TO
C_
O)
•D
1— t
1-
o
UJ
CD
o
^
CO
ev
r.
o-
^£
UJ
o
•0
E
s_
o
if_
t_
• • j^~
H— O^'*~N
O ••- 4->
10 OJ
C_ t_ CD
QJ Q) t-
J3 > TO
E O 4->
3
C JC 4J
o to
QJ -r- C
JC JC •!-
4-> ^ TO
O)
•• l_ TO
C O
O
re >i
_c? J^ -°
•i
t_ •!-
O ^—
CL
CD
CC
JZ
••-
CD TO 4^ E
o •!- T- e
1_ i— 5 O
Q. Q. t_
E V) -r-
QJ O 4-' >
E UJ 3 TO
0 0-r-
O CD (1) CD
L. t- t_ •
«t 3 «rt
a. to CD TD S
UJ C JT C TO
Z UJ 4J TO r —
^
CO
*
CM
,_r
o
O 5
00 C CD
0) TO C
3 4-> ^
CT V) •!-> L.
O) -r- C O
t- t/) TO •
CO i- OO t/1
C71 TO CT1*— * ,•!-
3 *^~ 'P"" i- r—
r— "D 4-> TO -r—
O -r- O 4-> JZ
C > 3 C -r-
•r- O t- 3 tO
— ' (- 4-> i— C
CL to O O
a; c > a.
+->(/) o to
TO c o en ai
•o o c t_
1 •!- C •!-
O 4-> TO 4-> >>
+-> O JC 0) O
I (Q 4_> QJ c
1- E CD
TO t- t- i—
O! O QJ t- TO
>iU- JC O >
4J H- -i-
«/1 O 3
4J .^ cr
- to UJ
3 O E O •—
crcc TO a. TO
ai t- z: c
t- en 01 o
C O QJ ••-
.— -r- t- C 3 C
O Q) 0 0 3
\— CL4-> 10 <»-
.— -
Ql
C ^^
•i- Q)
>
QJ O
4-> jC
TO TO
^5
1 •!-
O -r-
4>> *v— •
1
C- 1
TO
>>UJ
O
•a
QJ C
E -r-
t_
o -c
H_ Q;
S- 4->
QJ C
Q. 3
O
(/I O
c
O tO
4-> in
0 Q)
TO 3
cr
•— QJ
TO (-
4_)
O 0
h- 4J
^~.
•r-
•r—
v_--
I
s
o
-------
in
c
o
•r-
•P
•i—
C
•r—
M-
(1)
O
XJ
c
re
QJ
o
c
re
•P-
P—
CL
E
O
o
in
re
E
re
c
CTi
O
c_
CL
re
•i—
•rj
QJ
E
JZ
O
re
a'
>^
C*
-r^
a.
•^
4-
•p-
4_>
c
QJ
X
•p-
c
QJ
QJ
JO
QJ
re
JZ
JZ
E
re
CT>
o
t_
a.
a;
o
c
re
•p-
P—
CL
E
O
o
to
QJ
•t—
p
•p-
P_
•p-
0
re
Lu
p_
re
u
QJ
QJ
Lu
O
•P-
JC
jt
(/)
re
QJ
u.
^£
1
—
to
re
QJ
u.
re
X,
•r—
^
o
•i —
u.
CL
E
re
L.
CD
O
t_
f\
—
(f_
• o
e£
Lu u.
O QJ
-P
JZ t_
+j re
•p- 3
? 0-
C XJ
O t-
10 -P JC
QJ re -p
0 C.
t- QJ QJ
3 CLJC
O O -P
to O
U C
CJ -P-
o c
> •!- tO
QJ
QD »-P-
in 4->
to E -p-
to re t-
re t- o
p- CJVp-
0 0 t-
t- CL
• CL
CT> X
• Q/ QJ
a- jc JP
• — -P U
a-
xi jo "a
in
>- XJ
Lu QJ QJ
•P (/)
CT> U QJ
C QJ JZ
•p- p- -P
u. QJ
3 tO M-
X) 0
QJ
tn jo x;
QJ QJ
•i — r— 't—
4-> P- 4-
•r— •! — *r~
p- 5 -P
•r- O
o in c
re a;
4- -P- QJ
•p jo
i — «P-
re (~ P—
u. O p-
a, -P- -P-
TD t— 5
QJ CL
Lu
QJ C
t- V) C
O QJ -p-
4- JZ CT>
1— " QJ
in or
QJ
•r- • QJ
-P ^- JZ
•p- e -P
i- re
o u. x:
•p- CT C
u. o re
CL u.
r> tc
-P OC
C u.
Qj *p~ >~
E et Lu
u a, cn
t- JZ C
O 4-> T-
4- u.
C C 3
QJ -p- XJ
a/
c
o
•*
<£>
00
>-
Lu
C •
•r— ^~~*
QJ
QJ 4_>
QJ I/)
u. re
JZ 2
•p
to
M- 3
O O
XJ
1 — t_
re re
•P N
o re
•P JZ
re x:
•P_
O p—
•P O
to
XJ
QJ X
•P C
•p- re
E
•p- f_
p— Q/
•p
a; re
JO 3
p— *
P— - L
•P" »p-
^ ^c
to •
QJ CT>
•p- •
P QJ
•t— ^— ^
u.
O in
>P- jr
u, re
CL u.
a,' o
- O
Lu 4-
XI
QJ
•P
•P Xi
•P- C
E TO
JO
3 -P
to «/)
0
C O
QJ
QJ .
JO CO
C
QJ -p-
> i_
re QJ
r- ,
C S
C? t-
u.
CL t-
C
VC 4-
c
i—1 tO
1 C
o
QJ
(-
^
O
o
g
c
4->
c
QJ
>
a'
u.
CL
O
4->
in
in
QJ
C
• p-
p—
QJ
F
•P-
•P
4-> •—
Or- p-
c re -p-
c 5
o o
XJ •!- C
4-> QJ O
u o +-> •
•p- o o re aj >s
JZ P- 4-» C O O
2 'I— C 1— 1
"XJ E TO
in to QJ t_ xj c
QJ QJ C QJ -p- re
O -P- -r- P 3 JC
t_ 4-> E OJ CT> +J
3 -P- t- XJ
O x (U C QJ
CO to O t-
p— QJ -P- CL O
(- CLX) JC 3 E
0 E I—
c o c xj o
•p- O QJ QJ C
E QJ • to
c ja re re o
>>M- QJ jC 4->
4-> TO QJ t-
•p- 4-> > re c XJ
r— f- re o QJ
•p- QJ JC E M- 4->
o o re rx-p-
re to «- a> E
4- o QJ en a: -P-
4-> t- O i—
p- 3 t- JC
re QJ 4-> CL O QJ
t- 3 re re JD
QJ x; QJ re ai
XJ 4- -P- r—
QJ JC XJ C r—
LU O QJ QJ -r- •!-
•p- ^ ^ ^
1 JZ CT to
5 T- p- a> -P
= c re o to
in •> 3 3 -p- T-
QJ 4J Xi 4- p—
O 3 «- -P- 4-
u. JO QJ > 0 JZ
3 JZ -P- U
o to 4-= XJ E re
to QJ O C TO LU
O -p- t_
t- t- f_ en
O 3 O C O •
CO TO f- IO
•p- in to CLOO
E c c
P O QJ > Lu
C -p-3 4-> 4-> •!-
re re p c 4-> c
o E re re o M-
•p- CL O OJ
4-4- -p- Q-«t
•p- O QJ 4- in Lu
C O -P- OJ O
cn to c c t.
•p- c re a? >,
to O «P- *P- QJ JO
•p- i — in jc
>~,P CL 4-> P
p- ••- E >, 0
p- c o i— x; QJ
re •!- OP- c -r^
4-> 4- re re jo
C QJ «4-> 3
QJ XJ QJ C ^C in
E CL QJ Lu
c - >, E C in
O to p c -p-
(- E 0 >>jz
•p- re >\ t_ jo P
> u. 4-> T-
C cn-p- > >> c
Lu' O P- C P- O
I_ -r- QJ 4->
>-, CL O C X:
p- re >,-p- QJ
P- re 4- p- c 3
re -i- i — -p-3 to
•r- x; •> re to
4-5 QJ tO -P- X3
QJ O C TO QJ
O QJ O P
Q- QJ re O QJ O
= E 4- CLJC 4->
0) E
JC -P-
^
QJ E
u.
re <:
JC
o •
•p- «n
JC •!-
3E in
re
c -C
0
•p- TO
f-T) »r—
QJ XJ
a: QJ
E •
JC 1 C
O •!- O
re 4J i-
QJ p- CT)
3 QJ
c E o:
TO JZ
to u
QJ C TO
•p- O QJ
4->
•p- XJ C
P- QJ M-
•p- C_
(J QJ QJ
re x> i/i
4- -P- O
in a.
p- C u.
re o 3
C. O CL
QJ
XJ c to
QJ QJ -P-
Lu JZ JZ
5 P
OJ
O QJ O
JZ -P- 4-
1— 4J
•P- XJ
1 •— QJ
= O ^
,—
»~—
ro
^j
C
£
c
o
•p-
^
c
UJ
TO -P-
(4 4_)
C
P QJ
c x:
re •<-
o
•p- QJ
4- .0
•n*
c X3
•p- "3
in o
JC
>, in
p— i/)
TO a;
4~* *P~
C p
QJ -p-
E p-
C -p-
0 0
t- re
>
C p-
QJ re
u.
>, QJ
P- XJ
P- QJ
re 4-
•P-
4-> ^~^
c c
QJ I-H
p — -
O
CL C
QJ
4-1 4_>
to
O 4-
= E 0
» •
QJ
XJ
3
p.—
O
C
•1—
to
c
o
•p-
4->
TO
C
•p-
QJ
•P
QJ
XJ
QJ
to
OJ
JC
4->
CT!
C
•p—
\s
re
E
c
•P—
40
C
3
O
O
o
re
0
4J
c
•p-
c
QJ
\s
re
4->
ai
JO
o
4-J
tn
t.
O
4->
O
re
u.
QJ
O
C
re
•p-
P—
CL
E
0
O
c
o
c
4J
c
re
0
•r—
•^<
C
01
(/I
c
•r—
^
o
^
o
re
P—
o
•p-
>
4->
C
re
u
I4_
•p-
c
CT> •'
in TO
t_
re CTI
o
m t_
•p- CL
>» TO
4J •!-
•r- XJ
r— QJ
>r- ^
O
TO QJ
4- 1-
O
QJ E
JZ
o
t.
QJ QJ
JZ C
4-> 0
a
JZ C
3. T-
^—^
1-H
• •
>^
^
r—
•r—
O
*D
*+—
QJ
JZ
4->
4->
TO
E
TO
u.
CTl
0
u.
CL
JZ
o
re
QJ
c
•1—
in
QJ
o
t-
3
o
I/!
c_
O
•P^
re
E
4-
O
t_
QJ
JO
E
3
C
QJ
JZ
4-5
*~,
cvr
-------
r —
ro
40
c
cu
E
T3 C
CU O
3 t-
E ro to •!-
TO •!-
t. TJ •!- C
en • *• cu cu
o cu E cu
I- > 1 XI r—
•» Q. T- T— 1—
0) 40 40 i— ro
ox: ro r— r- t-
C O M- 3 -r- CU
TO ro 4J E 5 >
•r- CU T- O
r— C O tO
tC T- i— i C CU
•r- LU O XT
O 40 Z -r- 40
o to c 4->
1 CU CU CU ro Cn
co Ex: c c
O t- CU 4-> •!- -r-
C 3 O E >
O t- <_ t_ O
M- in o cu cu <-
O <»- TD 40 CL
t- c c cu E
>i O O) 3 T3 •!-
t- c
o T- o en cu t-
4-> E T- C CO C
co x: T- cu «f-
•1-40 Q. 4-5 X:
x: c ro ro 40 co
TO t- t- c
TO o en en ro
•r- O >) C r—
to *f- CU 40 -r- D.
TO »f— en »i— i —
x: c t- T- o
en >^ o ro T—
t- •!- O -i- E Cn
o to c L. cu
CU CL C 40
«- >, en .,- ro
o r— «c x: L.
40 i — en x> 40
ro ro c -i- cu t/i
r— 40 ro x: co
0 C 3 =
•r- CU C TO C
> E T- cu ro
C: X? o f—
40 o x> cu o-
ro t_ cu > o
CU -t- -O ••- 40 40
CL > 3 CU C
cu c i— o ro cu
L. CU , O CU -i- E
c t~ t- cu
TO >, -r- CU CD
i — to 40 ro
tO r— CO ro •!- C
"~ M- '"" 02:
>V 40 >) >,
40 C 40 4-> CU CU
r— 40 r— 1— 40 C
•r- o • • •!— «i— ro
O CL >, O O • C •!-
TO 40 ro ro E o t—
<4_ (f. *f— (f_ (|_ CU o
Or- 40 CU E
CU f- CU CU to O O
c~ t. O f~ f" >^ C! CJ
40 cu ro 40 4-> co TO
x: "4- -o >>
t- E i. c. en T- 40
CU3CUCU CUC3 i-
x: c x: x: x: -i- CD • .—
40 40 40 40 J* VD -r-
cu cu cu xj cue t- OG o
_f j^ ^j _^r c -f"1 fO ^ fO
^t 4"-1 CO ^ T3 3>> «- -^ ^~ l_l_
+J Ll
£- i—
*•*•—- **"•— .^-*- .*~~ - ID C fO
CO n- LO <£> U- •!- t-
flj
•c
cu
U_
=
f—
TO
c
CO O
x: ro M-
o c: cu 40
ro o t- T-
CU "I™" TO X!
4-5 "O CU
c: ro cu ro c_
•r- t- x: o
CU 40 •* y"
tO CL CU
cu o c o
•I- O T- C •
4-5 O TO O
•i- CO XJ 40
r— C CU •!- CU
•r- M- -r- 3
o 40 en «
ro co ••— co
-
C 40 ro LL.
ro >><4- c
O 40 O CU to C
•r— *r~ E Cn»r—
CU
to C E >»
i — "C3 CU X3
>> ro a: o
r— I- -r- •— -r- -0
r— CU <4- CU "C CU
ro T3 -I- c o 3
40 cu 40 c: T- to
c u_ c o t- to
cu cu to cu ••"•
E r- -D t- CL
O C CL "XJ
f- O CO CO
•i— -r— tO 5*>- r—
> en cu o Z3 r —
c cu t~ c o •«-
cu or -o cu s: s
•D en
CU x: o c
40 40 "o r~~ ro
O i — TO CO f—
CU >, 3 L 40 CL
r— O O CU C
CU _r~ "CJ CU CU
co T: co at E to
CU LL, CU CU
><— o. to cu .c
O O C i. t- 40
i — TO C en
>, CU r— <4- TO «»-
40 > O- O
•t- cu en cu
i— X5 C O 40
•I- • •!- C C
x; a,1 co c ro cu
ro -C CU •!- ••- E
CL u TO r— CL
TO O M- t. CL O E
M- 0 CU t-
-o cu o •• o > en
c t- cu cu o
TO TO E O r— T3 L.
TO C TO CX
CU CO f- TO T- C
t_ c: OT40 40 O 3
3 TO O to C CU
4-5 r— C- *r— CU CL' *f~
O CL CL co 40 o >
3 to O C CU
u cu ro ro CL ro c£.
40 tO -r- -D
tO CU "C r— - •"!- r—
x: a TO co 3 ro
40 H- E O c en 40
c •.- o c
cu cu c ••— "ei cu
E • x: x: 40 cu E
CU C 4-> 0 0 i— C
en O CU CU -r- O
TO -i- XT 40 CL TO t-
C CD 40 tO 40 -r-
TO CU •!- >4~ C CU >
E a: $ o •.- "c c
LU
^2
cu
4-5
ro
!„_
cu
c
cu
CD
CO
ro
f.
c
o
•1—
+^
ro
£
t-
o
l^_
c
1^-
o
*,—
l(—
*r~
0
a>
CL
CO
cu
40
•f—
to
"T^
cu
•f
TO
4-5
cu
X)
^o
ro
c-
4^
CO
C
ro
cu
E
O.
3
1
^
O
r—
,—
o
M-
T3
C
ro
C
O
•1—
40
ro
c
•r-
•C5
t-
O
o
>> cu
TO
T5 40
c
c cu
O 3
to cr
t- CU
CU CO
CL X}
3
n tvo
40
3 »
O 4->
XT, O
TO cu
•f— ^
cu o
> L.
r— CL
0
> C
c cu
•r- >
•r-
>, en
r- ro
TO
t- c
cu o
c
CU 40
en c
cu
CO >
40 cu
^
O CL
>«- 3
CU 2
O
s f—
CU r-
> 0
•r~ *f—
4->
C • t-
TO to O
40 tO
tO CU CD
JC O C
3 O -i-
co L- a.
= CL O
o
x: Q. to
O 3
3 1 >,
, O TO
OH- 1-
c cu
CU t- 40
cn o c
TO M-
cn
TO •>- CO
CU CL t-
r- O T-
0 <4-
CU to
x: cu
4-5 r— X:
TO 40
O 40
40 O co
40 C
•O TO
CU CU CU
40 x: E
+0 40
•f— —
E t- -c
to o cu
C <4- 40
TO ro
t- 40 -r-
4_i L_ 4_)
O -r-
•c •»- c
C <*- >—<
TO CU =
•
O)
c
o
T3
to
TO IO
3 *r"
CL tO
3 •!-
i x:
2 40
o
i — CO
r— —
o to
t)_ t— 1
LU
t_
o t-
c
CD Ll_
C
•r-
CL •
O 4-5
O 3
10 CL
C
CU i-
>
•r- 40
40 to
c ro
TO r—
40
CO tO
x; 40
3 ••-
to
cu
x: -o
O TO
E
x:
2 to
TO
t- x;
O
t- <
CL
CO UJ
40
o x:
a o
•r-3 -r-
o x:
c. 2
CL
^.
>4- O
O «f-
<- 40
cu o
X5 CU
E -0
3 0
c~ t_
CL
CU
x: >,
4-5 C
ro
cu
C CO
•t- C.
E ro
I- CU
cu E
40
f\ ) ~
VL* —
cu
O 4->
40 CU
r—
CO CL
•r- E
O
TO O
•C co
•r- 3:
CU
CU -t-
x: >
40 CU
a;
i
4-'
-o o
CU CU
40 •!-}
c: O
3 I-
O D-
O =
•
r—
P—
TO
O
CU
C
o
x:
CL
CL
3
|
^
O
r—
^—
o
M-
P—
P—
TO
L.
O)
c
cu
en
CO
40
•r-
to
«t
LU 40
C
t~ cu
0 E
u_ cu
o
t_
• o
L- <4-
QJ C
4-> LU
40 1
CU C
•— 0
40
c t
cu
E ro
c t_
o en
o
to f~
•— ' n.
LL'
U. r—
P_
CU -r-
x: Li.
40
>> c
r— TO
P—
TO CU
«- en
a> x;
c: cu
cu t-
cn c
to
c
o
to
•r-
O
cu
•o
cu
c.
a>
x:
c
O
•r—
40
TO
3
40
•r-
CO
t_
cu
x:
40
o
>^
c
ro
c.
o
«v
CO
en
c
40
cu
(U
E
2>^
0
c
cu
en
ro
t
cu
40
c
•r-
»
to
C
O
•r—
[ ^
ro
CO
cu
>
c
o
o
CL1
C
o
x:
CL
CU
r—
CU
40
ft
to
CU
40
40
cu
r~~
40
c
cu
E
£
o
o
to
cu
•o
3
o
c
•r-
—
^
CL
•r-
^
CU
Qi
^J
CU
cu cu
c to to
O 5 CU
CU T3
>^ »r-
•— > x:
c cu o
0 I- -r-
x:
co «C 2
r— Q.
TO LU CU
3 CO
cr cu o
cu t- x:
cu 40
40 x:
•r- 3 4->
E 0
c_ c
cu •
CL to «
CO T3
x: cu cu
o o -c
ro o 3
LU t- r—
CL 0
c
* 2 >r~
c cu
O •!- CU
•r- > J3
CO CU
•f— 1— ~C5
O r—
CU CU 3
•o x: o
40 x:
ro co
40
CU 3 T3
_* o cu
ro x: 3:
E en cu
3 T-
O 0 >
40 t_ CU
x: i~
t- 40
CU >)
X> IO i —
t- CU r-
o ••- ro
40 3
C •!- 4->
•r- > O
•r- ro
"D 4-5
CU O CU
i. ro <-
cu cu
x: 40 5
40 c:
ro cu x:
en t_ o
0) T-
en H— x:
c <«- 3:
•f— *r-
cu x; co
Xi r—
>t- ro
CO O IO
••- o
40 CL
C to O
0 •!- t_
•r- tO CL
40 a
TO O CU
E O co
t- 0
O >>x:
<4- TO 40
c E
*"" S r^
•> cu c
CO > •
ro cu = en
CL' t- •> C
r— 40-1-
cu c c;
40 XT CU CU
ro 40 E cu
£ c
«x: O O
t- en o co
O 3
0 0 r—
cu x: c ro
•C 40 = •!-
ro 40
E c: ro -I-
cu c.
CD > cr T-
c cu -i-
•F- C
CL' 3: 4-5 ro
.C (U i —
•r- 3 >>
CU > CO r—
C- CU CU C
ro t- t- o
-------
•
to
OJ
c
•r—
r_
0
4-3
c
o
•f—
4_)
13
r—
0
(/>
CD
t_
XJ m
c c-
4-3 re QJ
Xi in 4-3 *
C QJ « t_ C
o xi -c re o
O- QJ 3 •!-
in i — m in cr 4-3
QJ re re *f-— re
S- 3 re 4-3 O
^- XJ X t- C •«-
4-> CO
in 1—"
3
E cc
LU
in LU
0-Z
t_ i— i
O C3
o z
LU
CD
X H-
4-3 0
1 — 1
f~ Q£
U 1—
x: i— i
5 0
0 LU
4-3 :n
i-
m
C LU
O OL
•r- LU
4-3 :r
•r- 3
c to
O LU
0 CO
^f_
t~ 0
o
1 1 '
c to
o o
'r— ^E.
4-3 H—
re
0 Z
•i— i— <
-
Xi —1
o z
EO
cr-i- o CD "*-
XJ
CD C
x re
4-j
in
c c
O 0
•^
CD 4-3
— ' > 3 CD 3 -r-XJ O
>d- T- in t- cr X)
ox) re QJ o
«=t c •> m E
•r- in >>X>
LO C CD 3 «
oc o O x in i—
cr, 4-3 -i- 4-3 re
,-H 4-3 cn T-
X> -i- i- C C
QJ QJ XJ CD T- QJ
X 4-> C 4-3 I- XJ
4-> re o t. 3
i — o re x5 *-
if- QJ 3 O
o t- xi o~ m
t- a. a-
— ^ QJ re QJ t- o
X) t- X> X O C
• — re c 4-> C-) re
10 re 3
in 4-3 c CD in
x c in •!- x in
Q. O 4-> •!-
re -r— 14— XJ
i_ 4-3 O CD >, 4J
re XJ c t- E
t- c o o c t-
re CD •!— O- O Q-1
O. E 4-> QJ -i- CL
E CL t- 4->
«- O O O QJ
CD o XJ >*> re XJ
XJ Q, TO r— 3
c t_ co i—
3 x: o c o
< c c
LU
— ^
CO
CO
1— t
o
1—
I—
2^
LU
"XJ 1—
r— QJ Z
re 4-3 HH
•i- C-
C O Ll-
CU O-O
XJ CD
t- LU
4-3 0
•r- CD I— i
e t- i-
s_ re c
CD Z
O- cn
CD ^t
t- 3
O cn CD
cni)_ 10 z
c
*^-
t_
•^-
3
cr
QJ
t_
QJ
m
0
X
4-3
QJ
t_
re
—
in
QJ
3
m
10
I '
c~
re
o
»^
00
o c co
•r- re t— i
4-3 O
re -r- LU
XJ f- C£
C T- O
Q) C U_
fcnuj
•i- CD
O CO
o «C
QJ CL
C_ • LU
4_)
«t M- 0
CL E H-
LU «-
a' Q
in Q.Z
CD O
•i- re CL
If- tO
•r— Cn LU
c c cc
OVr-
•r- 3 O
in in t—
m
e T- o
(- LU
CD CD C£
4-3 C- t— *
C ^>
QJ W- 0
X CD LU
t— Xi C£
CL CD QJ QJ -i—
LU £ £_ >
E re T— m
CD O QJ 4-3
t- O cn o T-
Q^ Q QJ 0^ E
X 1- 3 t- L-
5 cn CD
CD • CL
in 5 -i- QJ
4-3 • C
C CD 4-3 T- O
QJ I- C *— -
§QJ re QJ
f- (J 1 1 ^J
o 5 -i- c re
o i*- re E
QJ *r- E
c in c £_ m
•r- 0 Cn O C
X ••- X> O
>•> 4-3 in •>-
•— >, in
o o re QJ o
C XT t- QJ
X! 4-3 CD O
QJ • E
4-> QJ XJ
in cn QJ QJ •
QJ i- 4-> f- C
«_ re o re o
QJ r~ C •!—
4-> O >> 4-3
c in QJ Q) O
•<- i- x; x: re
Xi 4-3
QJ XJ Q>
t- X3 i— C >
re QJ 3 QJ •!-
in O x 4->
CD o x: 5 M-
3 CL co in
O in O
U 4-3 i- CL
• Q.I—' CD cn
4-> 4J -i-
C CD t_ XI
CD x • re
E 4-3 in 3 m
QJ CD O~ r—
CD M- O re
t- O •!- 4J 3
cn 4-3 c cr
eC (/I O QJ QJ
o re 3
If- T- t- CT =
O 4-> O. QJ in
in in c
E ••- 4-> X 0
3 «- C 3 •!-
X! QJ CD in 4-3
C 4-3 E 3
re o a' c i—
t_ re cn-t- o
o t, re m
E re c: 4-> QJ
QJ x: re o C£.
S. 0 E C =
re re
E
c
c o
CD -r-
a: 4J
Xi re
c
in cn
re •!-
x in
CD
^-^ XJ
1 '
r- XJ
O CD
i- O
i— C
CL re
E >
•i- XJ
re
t
o ^
0
•^- ^-
0 C
r—
Q. • •>
x CM
E re KT-
0 if-
in CD
>, m
• *r- 0
r— -r- x:
re i- 4-3
S re
re in QJ
c_ in t-
xj CD re
X 0
4-3 CD in
•i- C CD
2 in
4-3 O
CO Q.
o c c_
•r- 3
4-3 4-3 CL
re 3
OX 4->
•r- C
r— * CD
O. in E
CL C 4-3
re t- ••-
a> E
i- o E
0 C O
o u
•> =
•i- O C
XJ 4-3 O
C -r-
O XJ 4->
o i- re
re o
4-3 Cn -r-
v- CD if-
E t- •.-
«- 4-3
CD C C
C-'i- OJ
X!
T- re
••- r- >
XJ o_ x>
X! CL «t
re re =
t—
re
4-3 r— 0
c re -i-
QJ 4-3 X
me a.
QJ QJ re
*- E t-
Q. c cn
CD O O
t- L. CD
•r- CJ)
4-3 ^
re c re CD
C 4-3
QJ x. re
c u QJ
03 C
E i"~
O in QJ
O !_ XJ
cn o
C E 4-3 XJ
•i- re re c
c t- o re
CD Cn.,-
X O XJ >i
4-> t- C H-
cn CL-I- i-
C 4->
CD re QJ C
.. C > CD
re 4-3
•r— r— XJ f- in
$ 3 i— O C
O m 3 re
i— CD O CD CD
•— t- x > E
O in -r-
If— r— 4-3 *•— "^
i— c re • «-
QJ •!- 04-3^—0
x 3: — M- c c
4-3 • cn. — o M-
cm QJ re -i- E
if- o xi ce 3 4-3
O -i- C cr C 1-
4-> re re CD o
QJ re i— 014-3
C O 4-> C C 4-3 J-
O >r- QJ -r— «i— re O
c
o 10
r- QJ
r- IK
> •!-
r- 0
XI CD
a.
CD m
X
4-3 X
0
4-3 •.-
re x
J;
| ^
C 4-3
CD C
E CD
CD E
cn 3
re o
c o
re x;
E
if- "re
o c
•— if-
re
> CD
0 X
CL
^> ^5
re CD
c
10
a' CD
> >
re re
X X
o o
4-3 4-3
• — in
CNJ C
re
XJ QJ
c E
re
^-~.
9\ L
C C
0 C
•r- »r—
4-3 E
re
c i_
cn . o
•i- C
cn O t-
QJ -r- O
if- 3: X in -1-5 XJ 4-3 T-J
4-3 i- 4-3 3 4-3 re
QJ 4-3 cn v c E
CD C C S CD •
E 01 -r- E E
x; 4-3 cn re CD c
.C T- o 40 t_ cn O
o QJ e cn re -i-
•r- XJ 4-3 O O C 4->
x CD o if- c_ re o
3> 4-3 o *- l_ COC O
Q_ XJ O O ^" O 'r—
•%_ >, re if- T- •!- 4->
4-3 m 4-3 re
co -i- aim re-re o
^ t- x:E uco T-
o 4-> re -i- o O M-
in -i- t_ if- T- i — •!-
c i- CD cn fr- cnp— 4J
re CL >o 4-3Qjre c
i— CD t- C CC CD
CL in T- Q. CD if- X!
i— X> CD H- v-
4-3 C CD r— «r- X. re
c o X) re 4-34-* xi
QJ T- O X> in QJ
E cn o O CD if- U
QJ CD 4-3i— UOX3 C
cn ct c c re
re c t, re CD re >
C CD O O > t- XJ
re x m^ — xiot- re
;E 4-> re x re E re
QJ C .— C
re c t-re *t_i — re
CD o a> o o
t- XJ c m re
re re t- to i~ QJ 4-3 -r-
i- QJ CD 3 4-> r— 4-3
o «- x if- cn i 3 i-
QJ <. |— o CD in c
CL 10 C CD i— i
co o o «: o i- =
re re
«- o E
O T- •
If- 0
CD C -i-
4-1 QJ 4-3
re xj o
3-1- re
re x; c
> QJ O
QJ O T-
C 4--
QJ re re
XI > O
x> ••-
r- re if-
r— *r-
•F- CD 4-3
2 x c
4-3 CD
4-3 X!
re CD -i-
X 3
4-3 m XJ
C- QJ
Q, 3 O
CL O- C
>, re
4-3 O >
4-3 X!
x re
C r-
re QJ c
i— > re
4-3 QJ
CD i— =
S CD
t- 4-3
t_ 0 QJ
O4-3 f—
O 0-
re CD E
CD (- O
<- -r- 0
re x- =
•
QJ
cn
L.
re
x:
O
m
X!
c
O
if-
QJ C
i— QJ
X E
re CD
4-3 0
•r- L.
3 0
10 <4-
C C
3 LU
(- 1
O
•^ E
x; re
c t-
re cn
O
CD (-
r— CL
Xi
re i —
4-> r-
3 Lu
I/)
XJ
m c
re re
Q)
(- CD
re cn
XJ
CD CD
X t-
4-3 C
CD
cn
t- X> XJ
re c CD
xi re 4->
o E «-
in O CD O
•r- O in CL
XJ re CD QJ
c QJ t- in
i— T- o re
r— CD O
re 4-3 re Xi
o = •—
c_ c • •• o re
O CD 0
if- CD 4-' Q- M-
t- •!- LU CD C
re , re u
C t- Xi QJ
3 O CD in 4-3
O C XJ C
O « O CD O •>
O 4-> 3 -^- ^^
re -i- in in 4-3 c~
E re in o o
LU L. •<- re 3:
^^ QJ Xi
CO Q. Q) t_ 4-3 QJ
.— 1 4-3 QJ C 4-3
re re XJ QJ *r-
XJ QJ t- E in
C CD t- O CD
re > 4-> u cn •
re CD t- c • — -
CNJ X CD > O -i- «—
i O re 4-3 c 3 x:
«c 4_> re QJ . — re
LU re t- u o
O **• CD 4-> in c: -r-
O t- IO O.-I- r—
in ^~ re T- t- CL
CD CO- C O >> 0-
t- o -r- cj; i— re
3 Ct -r- £ ,-
m 3 -c XJ re QJ
re o Q.
in 3 cn c if- . — in
CD to CD re cn
CT>X! QJ CD t- •!- C
«- CD c e 4J ••-
re £_ o i— c XJ
x ••- = re re QJ
O 3 C C
in cr-i- o
•r- QJ -i-
XJ t_ 10 4-3
QJ U
>> QJ cn re
If— ^> ^.
•i- re re 4->
4-3 -c c:
C >, O QJ
QJ QJ in E
XJ X ••- CD
•t- 4^ XJ U
O X XJ O
4-3 cn QJ if-
34-3 C
X) o re CD
,
X -i- -r- X:
re E 4->
O 1- -r- X>
t- QJ XJ QJ
XJ. CL C 10
CO 10
re 3 o CD
u
in CD 4-> X!
•i- (- T- x;
re E re
— <
m|4-> QJ in
a; re CL a>
4-3 X 4->
••- 4~' X -i-
m| 4-3 in
C 4J QJ
•r- 10 O
E X; O
•i- 3 «-
(- 10 CL
O
C C
t- QJ C
0 CD T-
XI 4->
i — re
•i— tn cn
> re -i-
•i- x: 4-3
O *f—
C i—
re o
•r- QJ
t- 4-> X
O U 4->
re
•> c
IO QJ -i-
o_x
L. 4-J C
O O
0 C -i-
•r- 4-3
CD re
X C Q.
4-3 O •!-
•i- O
>> 4-3 •*""
x; re 4-3
CL t-
xi T- re
CD O Q.
3 -i-
in 4-3 Xi
in t- c
•i— re re
0.
!_ •
CD O QJ 4-3 -i- t_
4-3 o c 4-> in re
o re -i- >, CL
QJ in T- QJ in . — CD
XT -i- i— X CD C t-
(— XJ CL H- X> O 0-
-------
QJ
QJ
>
•r—
_j,_%
fO
L_
+_>
(/)
•r"
C
•^
E
•o
•
CD t_
J=. CD
l^
x: o
"P" p—
5 re
c
TJ -i-
CD 14-
•p-
i— re
CL
E TJ
O QJ
0 i.
OJ
OO 4->
re c
X: QJ
I- 10
a1 re
cn_c
re 4->
x: c-
U 3
OO O
•P- O
TJ
CD
OJ .C
1 *
*
OO i —
c re
re t.
QJ t-
E QJ
««-
= CD
OO S-
c
o re
•r"
4-> <*-
0 0
re
a>
4-> 00
c re
CD U
E
QJ CO
O XT
o
<4- C
C -p-
OJ
r_ t-
re o
E
L. L.
O QJ
t_
^o C^
X!
1 *
TJ 00
QJ -p-
> 00
i— QJ
0 0
00
QJ TJ
i- C
re
00
QJ QJ
4-> OO
•r- re
00 CD
3 t *
E «-
t- O
QJ
QJ
QJ T3
X: C.
1— O
•
to
ai
en
t_
re
.c
o
00
•PJ
^j
QJ
^_>
.,_
E
CD
CL
C
3
c.
0
4-
t_
O
^_>
•p-
C
o
E
0
CD
re
E
oo
Q.
•i—
t
4_>
^j
^—
QJ
t|_
r— •
r_
(C
CO
OJ
T3
^3
P—
O
c
*r—
£
t/)
C
O
•p-
I *
re
cn
.^.
i %
00
QJ
C
TJ
r—
CD
•p-
t$_
1 *
C
CD
E
CD
U
O
c
_QJ
E
QJ
CD
_c~
h-
T! .C
QJ 4-*
•~^ t_
cn QJ i 44_
C JC 4-> O
•p- 4-> X:
L. re cn CD
O cn.r- (_
4-> 1 p- -P- O
•p- E
c Q- t_ re
O UJ QJ cn <_
E > •<- 0
C O 4->
QJ O OO QJ
C i— Q) C
T- TJ re ^ o
4-> QJ -p- C
3 oo t- v- tn
o re QJ 4-1
t- x) re TJ QJ
F— QJ
•> «- C QJ E
•c OJ re -r-
QJ XT 44. -c
I- 4-> <4- C
QJ QJ I-H 4.) re
> X: C
O 2 • QJ C
0 — "-*• E O
OO OO QJ •<-
•r- TJ C
TJ QJ O 1- O
> •!- o re
QJ 'r- 4_> *4—
t. QJ re c 4->
re o r- QJ c:
QJ O QJ
OO I— »p- QJ E
QJ > C QJ
en c o o
t- O QJ (-
re 4-> i— to o
x: re .c re ii-
0 E -r- C
00 t- oo TJ QJ
•r- O OO QJ
TJ M- O 4-> i —
c o. c re
TJ ••- 3 E
QJ CO S-
4-> 0 O 0 O
4-> -i- <*-
•i- <4- 00 QJ
S_ 0 -r- QJ
QJ QJ 4J i — f-
CL CL t- i— •!-
c oo re T- 3
3 Q. f cr
o a-
O TJ •!-
•p- QJ -p- 4->
x: 3 oo « re
3- T; 4-> a. .c
3 *P~ 4->
C C O t_
.r- QJ 4-> QJ
y/ C C*
>, re o TJ o
4-> 4-> t- p-
•p- C- <4_ QJ 00
> QJ -r- T-
•p- T> TJ <«-
4-> C QJ =
o 3 > re — -
in OJ >-> oo
XJ CL o .0 ••• -
t— -r- QJ
QJ t- t- TJ OO
•I— 4-> QJ l_
>*- C 2 O
"COO 4->
* E <4- -P-
3 00 t- >
o .* o oo
(- U <4- T- 4J
QJ C C
QJ x: T- c re
T) O O U
3 C •!- •!-
r- -O O 4-» <4-
o r- re -p-
CT QJ J_ P- C
•p- -p- O O cn
44*- *p- *p-
oo c > in
CL4-> O =
•p- C T- T5
(_ QJ 40 (. E
4-> E re QJ t-
o E > a>
QJ C. i. C 4->
in O O o
QJ If— If— OO QJ
x: C c -p- x:
1— QJ -p- TJ 1—
•rj
^_
re -P-
2
Xi QJ
e~
TJ 4-^
CD
4-^ *l
re o
c;
Cn 4_>
•p- c:
in CD
QJ C
^^j O
CL
«- E
O O
O
4-> re
oo
•p- t_
p- O
>, to
4-> QJ
•p- a>
t- 3
O >4-
•p- QJ
«- o:
CL
QJ
00 > U
•c i-
O 3
x: 0
C. CD
4J
re p-
2 re
u
4- -P-
Ql 4->
J ^ ^_
O 0
s~ re
o
00
T) re
C"
re >>
4-) *p~
CD (-
S O
re 4->
3 •
o re ^
C P~ QJ
•P- re 4->
o to
Q) O >,
cnp-
•p- 4_> -p-
re TJ re a;
•r- 4->
t~ P- t/0 0
QJ re -p-
4-> cn « c
•p- QJ p- Ql
«- p- re o
O p- t- OO
•p- QJ
cn TJ TJ
c: c CD c
•p* ^ u_ re
5
O 0
r—
o
l^.
00
U-
*
t/)
•
^3
CD
.C
4->
C
O
00
ai
•p-
o
OJ
CL
oo
•^j
CD
t
CD
cn
c
re
•c
c
QJ
C
re
c_
o
t_
QJ
O
O
TJ
C
re
i ^ *
re *-~-
•p~ OO
XI *P~
re P-
x:
QJ
c- re
QJ 4J>
cnoo
c
re re
Ti
C C
QJ O
x: t-
u o
•r-
_f— 4-^
S
p— cn
•— c
••- fO
•^
c c:
o
>^
P-—
^~
fO
c_
QJ
C
QJ
cn
re
CD
c_
re
c
re
cn
r;
•p-
QJ
X!
in
re
0 «
oo to
• 3
0 4J
co re
CM 4J
to- in
t- c
QJ O
C 4J
3 re
c
«C cn
CL -P-
ui to
QJ
XI
•C QJ
QJ 0
•P- C
t»- re
•p- >
[ ^ T*
c re
CD
"O *^~^
•p- U
oo «*
t- 0
QJ *t
^_>
re cn
S c
•p"
o >
4-j re
c x:
•P-
C-
c o
0
CLP-
3 re
to
CD O
cn Q.
t- oo
re -p-
_^" ^^
0
00 L.
•p- O
"D *4—
P- QJ
re p-
cn xJ
QJ re
p— 4^
p~ *p*
•P- 3
00
C C
<: 3
0
QJ
t_
3
OO
O c:
4-J QJ
CD O
> 4-J
•P-
4-* 4-*
re c_
•p- 0
+-* *4—
tr_ C)
C QJ
C
r— re
re
c: QJ
O TJ
•P- 3
OOp-
QJ O
gy C
•p"
re
TJ
o 's
o
| * C~
t- 00
re i —
D.
00
00 QJ
re cn
L
c re
-li O
re to
4-> -P-
•c
•p~ p-~
re
c cn
O QJ
•p- p—
4-) P~
O -P-
re
t.
4-> re
C p-
QJ .p- •
E EI— .
QJ -p- *—
O 00 00
t. •
O cn c
>t- C C
C -P- -P-
QJ l_ 4J
t- 0
c: QJ re
re 4->
QJ QJ
x: TJ x:
O 4-J
*p~ ^o
r" o lj_
s o
QJ
C O OO
O C 00
CL re QJ
3 -P- C
p- QJ
CL' CL t-
cn E re
«- 0 ?
re o re
x:
o t. o
00 QJ -r-
•P- -C P-
TJ re x;
O 3
p- t- CL
re X;
cn QJ
QJ QJ 4->
p- > re
p- QJ 3
•p- -p- cr
x: OJ
C O T3
«c re re
O
•
£_
CD
TJ
L.
O
r— '
re
o
• r—
^j
3
»r-j
C_
0
CD
•r—
4_J
re
^ i
00
•^.
c
'i
TJ
re
oo
3
O
•p-
>
a>
t_
CL
re
"^
CD
re
'o
>
00
(O
c~
c~
O
•p-
JC
2
t_
CD
Cn
c.
re
o
•p-
•c
r—
(O
Ol
a>
r—
P_-
*i—
C
<:
o
4-*
.^
E
CD
Q.
O
1 *
CD
o
re
<_
re
CL
E
O
o
QJ
U
cr
re
o
•p-
if_
>r-
c
cn
•p-
00
re
t^_
o
in
I ^
o
re
CL
E •
•p- --^ — ^
o
QJ •^_-
00 ^J
«- 0
QJ *fr
>
•c t.
re o
QJ -^
> cr
4-^ «^-
re c
3
E C
3 O
O •<-
^J
c- u
O QJ
to
re i_
3 4J
T> TJ
•P- C
> 3
TJ -0
C QJ
re
x: >
4-J QJ
3 CD
QJ OO
cn re
s_ x:
re
x: C
r^
P- 00
•p- QJ
00
c re
00
^.
U-
cn
c
•p-
^j
c
QJ •
CL CD
in
•4- re
o oc
4-> O
OO -P-
•p- E
p- re
c
OJ >,
JC d
i *
^>
Cn oo
c
•p- L_
p- QJ
•p- TJ
CL c:
E 3
O
o r-«
oc
r-H U.
c:
• • 'p-
oo
QJ TJ
t- QJ
3 4->
to c_
re o
CD CL
E QJ
£_
O
5 oo
4-> QJ
OO
t- re
o o
if_
^
TJ QJ
CD cr
00
3 C-
o
OO «P-
•r~
**-^
> CM
00
^j
<4- C
o re
c •
0 >,
•p- (L
4J O
•P- 4-)
C C
•p- QJ
<4— >
QJ C
TJ "P-
QJ >-
x: o
r- CD
cn
cr
•p-
TJ
cr
QJ >-
Q.O
CO
00
•p- QJ
p"
C 4->
0
•p" cr
4J -P-
O
re T>
QJ
1 ^ "PJ
C 3
4-> QJ P-
QJ
^_)
0
C
in
re
r"
c
o
•r-
^_)
O
re
4_>
c
QJ
E
QJ
O
O
(4.
c.
CD
r-"
CD
£
t^
o
x:
o
Iyff
^
L.
O
^3
CD
O
^J
CD
T!
00
c
O
•r~
_|. i
ro
^—
o
•f—
^
4J
C
fO
o
•r—
v
•p-
c
cn
•f—
00
E 0
QJ c:
O -P-
c
0 QJ
c re
CD
VD
QJ OC
c~ ^^
4-> r-t
***^
<4- O
O P-4
QJ M-
0 O
cr
re oo
3 re
to
oo QJ
•p- TJ
re
4-> E
3
x: oo
cr
« 0
^3 »r—
4_)
QJ 14-
TJ 0
00 OO
•i- er
O
^* *p"
t/o j '
re
re c
x: 'i
0 t-
•p- QJ
p" 4^
2 QJ
O
t v_ ^
o
<4-
•
oo • — -
QJ cn
oo cr
re -P-
o o
cn
QJ C
to O
O
x: oo
4-J *P~
OO 4->
C C
re QJ
QJ E
E Q.
O
r r~ •
= C QJ ^ — ^
QJ > >>
e ^ QJ L.
t- re TJ o
QJ 4-> 4-J
4-> QJ C
C OO OJ
QJ QJ re >
X CD <-> C
t— xh-"p-
-------
CN
c
o
in
cu
CT
c
4-> 4-> •> in 4->
•i- • -i- cu E o c
c
(r-
CT
C
i— O CU CU -i- 4J
•r-
g~ r
"~ 4-3
14- M- .a > JD o
cu
TD
• ^>
> 00
oo
r-^
t~ 1 00
o re cr>
1- r-H
C 4-> 1
O VI :>-
•r- v- U,
4-> C
•r- T- QJ
C E .C
C ^-^
i— i re
i o r-~
>- 00
^_>
•1—
t—
^
c
*^-
•o
cu
01
c
o
CL
in
CU
L.
t-
•c re
O t.
r- CU E t- CL
3 .c a.
O^ 4->
re 4-> 4-> 4
p (/)
t- -i- -r- C 4->
C71 3 ^
O •!-
U C
— ^'
in
in
re 40
c
4J ••- l_ C Ei— CU
c
cu
E
3
o
o
•o
cu
CL U U
o c
s: c re t_ i_
i ^
t_ re
QJ -i- 4-»
r- QJ
> >
CT-O i— c; co
c
4_)
re <~* cu
0 E t~
t- 0 QJ
•• CU J2 O <4- •(
a-
u
c
re
o
CU
E
•4-
t- QJ -r-
QJ CT
•>> r-~
j re
r- .C
L_ -^
O I- TJ O (-
C
•r-
in
3
" V) XT
C C CT
O CU 3
r— 4»>
L.
Q. 4J
U. T— CT- *4— E ••— O CT •»—
re 1-1
3t *r- 1
CU -
C T- li-
CU 3 O
4J
i — t_
4J re o
• • CU C »r—
V) CU •!— t-
cu E E a.
•r- «f—
i- .C t- "-
O o O in
CT-i- i—
cu jr u re
4J jfc O i-
re ^.
o vo >— cu
cc •>- <*- •
o ^-. > cu r-
3 1-1 ••- s_ CC
4J — O <-~ CTv
C t--
<4- i— i L. V) 1
C 0 I- >-
If— QJ Li
in O "C 4->
4-> C I- CD
in «/> re re z
•i- re 31—1
in •> cr a:
c « to -c • rs
o v> cu re <£> o
O Q.' tn CU OO
to re :c — uj
i re o •— i cc
>> o o --^z
1_ CU 4-> O <£
o c > i— t :r:
4J O t- -D O
C" *i— 4_> QJ *l—
QJ 4~> re <- o I—
> o «- s- o
C re 4-> CU in Z
i-i in «4- re
CT-r- CU 0
—- c c <- -D _i E
>-•!-••- cu o re
O TJ E f- vi c «-
cc c ~o o o m CT
— • cu re i— oo o
CL T3 U C.
t- CT> CU >- fi-
re i — c 3 4-> DC
QJ i — CO in O O CU
>, re u?- to c i— o
•.- z c
*f— M— M— X5 LI i re
O O O IO C > -r-
c- re z •—
CT 4J 4-> CU •— i Q.
C to tfl T3 • — • E
•i- •>- -i- t- «/> >- O
C f— i— O CU O O
c .i- ec
•i- re re cu r— «f
CT > CLUJ O.
QJ ' — • ^-^ -i— CL T* Lij
cc i—i CM 4J re 1 — z
t
cu
Q.
t/>
—
re
£_
O)
0
Q.
4-> o x: c to
re 4-> 4->
c
CT C — - V
r- CU QJ •
«/)•!-> O J
r— (/I
>, re
i-
r- O
P +->
re E
01 cu
QJ QJ
r— t^.
01
* 03
+J r~
r- 03
r- -O
O3 *^~
3 4-
D"4->
*^s^
L. Q,
QJ 4->
4-> re
re 4->
3 V5
cu cr.
c c
f— T-
>^ QJ ^ » QJ ^> c E Q.
O
C
cu
re
cu
i >
re
i *
4-> T3 -^ CU CU in
in
•^
VI
> C
40 4_> T- in
4/1-1- O 4-> CT
re
«/) re o c •(
D 4J
1- t_
C
t- O
CU i-
4-> CU
cu >
<»- XJ CU
re -i- c cu
o
^_s
r— C 4->
re o cu QJ
V) i- C CU
cu
= cu
cu >
oo too4->OE cu -r-
cu
4-*
i|_
o
c
o
•r-
| >
re
3
^~
re
>
QJ
c
03
l/>
*O
X>
C
»^-
<4-
(U
U
^j
_f
O)
•r-
LO
^
cu
c
40
CL re
t- 4->
<- in -i- in « CT c
o
M-
ii«
U
re
cu
u
c
re
^_2
(/)
•r^
to
I/)
^3
o
•4-j cr •
•r- 0
E i *
re cu cu
t- o
CT C «
o re c
l_ 4-> O
CL V) -i—
C QJ CTT- Q. X! •!- 4J
re t- cu > i
QJ QJ
o <: 4-> i-
o _i o
O QJ 4->
c a: T-j c
re uj o QJ <
o t- E
» CL 3
• t- 3 CL-I-
O TJ in 4->
QJ QJ tj
•1-3 o -c re
o o o
c_ c_ re cu
CL CLUJ U
c
o CT re •
•r- C • 4->
«t- T- 4-> I/)
•r- 4J O -i-
o re «=£ vi
QJ (- in
CL CU in re
to CL CU
O n- QJ
CU O x:
TD -O CU 4J E
3 (- CL re
r— re oo c t-
o -a T- CT
C C "D JC O
•r- re QJ 4-> t-
4-> t- i- Q-
>, 10 QJ 5
re CT c
E • c c. re
• re 3 •!-
TJ CTTD O "D =
C « C U C
re QJ uj o i—*
JJ 3
^^ in
QJ
M V)
re re
M
/o -c
cu
re c
•r-
o <*-
i_> cu
C-
re cu
•— t-
i- re
E
in • c
E 0
in CU •!-
"~ 4-' 0
i re
*-> V)
c to =
QJ CU QJ
E ^- tJ
CU "C C
cu -c re
t- re 4->
CT V)
re o •!-
40 i/i
< in
a. «/i re
jJ QJ
^ t. i —
— 3 re
re in u
r: re -i-
i- 0, C
t- E £
1— 0
5 "D QJ
C 1-
< re =
CT on re
C V) >
•i- re L-
i— QJ
CL •> in
E 4-> CU
re o t-
in «t
O)
re v) .c
QJ 4J
« t_
• 3 C
CTTD O
• QJ
CU u in
O E
» t_ re
VI O- t-
4-> CT
c cu o
cu > t-
E •- Q.
C 4->
o re i—
(_ t_ re
•t— 40 40
> in c
c ••- cu
QJ C E
•i- C
CEO
o -o «-
*r— ^ re cu
CU CT CT
to c c:
QJ 'i- -i-
t- CL C
O C
t- i— 3
•r- Q; t-
cu >
x: cu c
4-> t ••-
-------
CO
rH
L
Schedule Leading to
Final FY 1987 SPMS Measures for OFA
1. AA includes preliminary draft measures 2/28/86
in draft guidance package and sends to
OMSE, OECM, Regional Administrators and
HQ program offices with specific
information explaining the changes to
and purpose of revised measures
2. OMSE, OECM, RA and HQ program office 3/24/86
comments due to OFA
(If at this time, no issues are
identified for elevation, OFA will
finalize measures and submit them
through AA to OMSE and OECM. If
issues are identifed, OFA will
work to resolve them during this
phase and implement the remainder
of this schedule.)
3. AA circulates draft measures to 4/1/86
OMSE, OECM, RAs and HQ program
offices
4. RAs and HQ program officials 4/9/86
officials notify OMSE and OFA
of any issues to be elevated
5. OFA/OMSE/OECM/Regions resolve 4/16/86
issues (DA meeting if necessary)
6. AA submits final measures to 4/21/86
OMSE and OECM
------- |