oEPA
               United States
               Environmental Protection
               Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER: 9595.00-1

TITLE:  Facility Management Planning/
      Multi-Year St-tNitegies
APPROVAL DATE:

EFFECTIVE DATE:

ORIGINATING OFFICE:

O FINAL
                             05/06/86
                              OSW
                DRAFT

                STATUS:
           [  1
               REFERENCE (other documents):
A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review &/or comment
D- In development or circulating

          headquarters
  OSWER      OSWER      OSWER
VE   DIRECTIVE   DIRECTIVE    Dl

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          United States environmental Protection Agency
                Washington, DC 20460
OSWER Directive Initiation Request
                                                            1. Directive Number

                                                              9595.00-1
                             2. Originator Information
   Name of Contact Person
      Lillian  Bagus
                 Mail Code
Office
                               OSW
Telephone Code
   382-2233
   3. Title
      Facility Management Planning/Multi-Year  Strategies
   4. Summary of Directive (include brief statement of purpose)
      SUBJECT:   Multi-Year Strategies;  Document  provides guidance on
      how to  develop Multi-Year Strategies  (third  step of facility
      management planning process).  Audiance:   Regions and States.
   5. Keywords
      Strategy,  Multi-Year, Federal Management Plan/  PA/SI
   6a. Does This Directive Supersede Previous Directive(s)?
   b. Does It Supplement Previous Directive(s)?
                                       No
                                       No
                                 Yes   What directive (number, title)
                                 Yes   What directive (number, title)
                                      Draft Gui Fac Mgmt Pin
   7. Draft Level
       A - Signed by AA/DAA
             B - Signed by Office Director
      C - For Review & Comment
         D - In Development
8. Document to be distributed to States by Headquarters?


Yes
\

No
This Request Meets OSWER Directives System Format Standards.
9. Signature of Lead Office Directives Coordinator
10. Name and Title of Approving Official
Date
Date
   EPA Form 1315-17 (Rev. 5-87) Previous editions are obsolete.
OSWER          OSWER               OSWER              O
      DIRECTIVE         DIRECTIVE        DIRECTIVE

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                                                  OSWER POLICY DIRECTIVE NO.

                                                 9595-00x4   *
32
      1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                      WASHINGTON. D.C. 20460
                            'i   \) \i

MEMORANDUM

SUBJECT:  Facility Management Planning/Multi-Year Strategies
FROM:     Bruce Weddle, Director
          Permits and State Programs Division (WH-563)
          Office of Solid. Waste                      ,-

          Lloyd Guerci, Director               ~"-
          RCRA Enforcement Division (WH-527)
          Office of Waste Programs Enforcement

TO:       Hazardous Waste Branch Chiefs,  Regions I-X
          Enforcement Branch Chiefs, Regions  I-X


     Attached for your use and comment is draft guidance  on  the
development of multi-year strategies.  As you know,  development
of multi-year strategies is the third step in the facility
management planning process, after screening  and individual
facility analysis.  The facility management planning process
is designed to encourage coordination among State and EPA
enforcement and permitting entities.  The multi-year strategy
is a State-by-State synthesis of projected permitting and
enforcement activities over the next three to five years.   If
you intend to use the multi-year strategies in developing your
SPMS commitments due August 15, 1986, it  would be advisable  to
have the strategies completed prior to that date.

     This draft guidance on development of multi-year
strategies should be used for current planning_ purposes.  We
invite your comments on this guidance, as well as the facility
management planning guidance dated July 12, 1985. Please
transmit any comments you may have to Lillian Bagus  (WH-563B,
Office of Solid Waste) by May 30, 1986.

     Several Regions and States have expressed concern  that
parts of the facility management plan and the multi-year
strategy, especially those parts dealing  with prospective
enforcement activities, may be released as part of a public
document.  OGC is currently reviewing this issue, and a
separate memorandum addressing these concerns will be sent
to you.  All decisions on release of information must be  in

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accordance with the Freedom of Information Act and should be
made in consultation with the Regional FOIA Officer and Office
of Regional Counsel.

     We also are developing a computerized management tracking
system for your use in the facility management planning process.
This tracking system will be designed for use on personal
computers and is scheduled to be ready by September 1986.  The
tracking system will be offered to interested Regions and States,
but its use will not be a national requirement.

     Any comments or questions on the attachment, the evaluation
of the facility management planning process, or the management
tracking system may be directed to Lillian Bagus at FTS 382-2233.

Attachments

cc:  Permits Section Chiefs, Regions I-X
     Enforcement Section Chiefs, Regions I-X
     State Programs Section Chiefs, Regions I-X

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              GUIDANCE ON MULTI-YEAR STRATEGIES

     The multi-year strategy is a synthesis of all projected
permitting and enforcement activities for the next three to five
years.  The strategy should incorporate all significant activities
listed in any completed facility management plan (FMP), as well as
planned activities at facilities (new as well as existing) for
which FMPs have not been prepared.  A separate strategy should be
developed for each State, and the Region should combine the State
strategies to project and plan the Regional workload.  Particular
attention should be paid to whether the strategy indicates that
the Region and States will meet the 1988 deadline for land disposal
permitting.

     As stated in the FMP Guidance, the multi-year strategy should
be a flexible tool for management.  The strategy should be reviewed
on a periodic basis and revised as necessary to reflect changes in
the facility management plans, changes in the status of the facility,
or changes in priorities.  Not all changes in the facility manage-
ment planning process (e.g., an inspection) will require changes in
the FMP or the multi-year strategy.  Only those changes that signi-
ficantly impact on workload or scheduling should result in changes.

     After combining the activities in individual FMPs and
including other planned activities, Regional and State managers
may discover that more work is planned during a specific period
than available resources can accommodate.  If this is the case,
the schedule for planned activities should be adjusted to reflect
both available resources and program priorities.  If an activity
cannot be completed when originally scheduled, the affected FMP
should be revised.

     The development of FMPs and multi-year strategies, taken
together, can be used as a planning tool to adjust workloads
according to priorities and needs.  This may serve to even the
workload and allow scheduling flexibility to utilize available
resources as efficiently as possible.  For example, rather
than scheduling the great majority of land disposal permit
issuance for FY 88, it may be possible to complete a number of
the less complex and less controversial permits in FY 87 while
"up-front" work is completed on the permits to be issued in
FY 88.

     Although no specific format is required for the multi-year
strategy, it may be useful for planning purposes to include
those elements analogous to the FY 87 SPMS commitments.  Also,
any activity or facility that represents a significant workload
should be included in the strategy.  For workload planning
purposes, the lead agency (State or EPA) should be indicated for
each activity.  Examples of these activities are:  processing
a closure plan; processing a State enforcement action which
assesses penalties; and issuing a §3008(h) order to a storage
facility for which no FMP was prepared.  The Regions and States

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may want to include EPA oversight activities (e.g., EPA review
of State draft permit) in the strategies.  This would result in
a more detailed schedule that more accurately identifies when
the activity will be completed.  The strategies should be updated
prior to negotiation of State grant commitments each year,
in addition to any necessary revisions during the year.

     Attached is an optional format for a multi-year strategy.
It can be adjusted to fit individual Regions and States and to
accommodate any management tracking system currently in use.

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                                 MULTI-YEAR STRATEGY FOR THE STATE OF
                                                                                               Date:
   List
    of
Facilities
(EPA ID No.)
        FY 1986
    3rd
4th
                     Scheduled Major Actions

                         FY 1987
1st
2nd
3rd
4th
FY 1988
FY 1989
FY 1990

ABC Dumping
ACB 123456
789

Big AL's
Landfill
ACB 987654
321







s\*
RFA
Conducted


E|**
3008 (h)
Order
Issued













E|
RI
Plan
Approved








S|
Technical
Review of
Permit
Completed
E/S|
RI
Conducted

























E/S|
Draft
Permit
Issued












E/S|
Public
Hearing


ll
Corrective
Measures
Approved

E/S|

Draft
Permit
Issued


E/S|
Final
Determi-
nation
on Permit
E/S\
Public
Hearing


E/S|
Final
Determi-
nation
on Permit


































  * c=
    S=State;
** P=
    =EPA

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           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                    OSWER POLICY DIRECTIVE NO.
                       WASHINGTON. D.C. 20460
                                                  59595100^1
                                                        OFFICE OF
                                               SOLID WASTE AMD EMERGENCY RESPONSE
                               12 1985
MEMORANDUM
SUBJECT;

FROM:
TO:
Facility Management Planning

Lloyd Guerci, Special Assistant
RCRA Enforcement Division (WH-527)
Office of Waste Programs Enforcement'

Bruce Weddle, Directcu-1^
Permits and State Programs Division (WH-563)
Office of Solid Waste

Hazardous Waste Branch Chiefs, Regions l-X
Enforcement Branch Chiefs, Regions I-X
     Attached for your use and comment is draft guidance  for
Facility Management Planning.  This draft addresses only  the
first two planning steps (screening and facility analysis) in
detail; guidance on preparation of the multi-year strategies
will be available in the near future.  As you know, the primary
goal of Facility Management Planning is to encourage  coordinated
use of permitting and enforcement authorities to bring facilities
into compliance with RCRA  (as amended by HSWA) as early and
effectively as possible.

     We have attempted to keep this draft guidance simple and
easy to follow.  It is not intended to be the definitive  guidance
on Facility Mar.-afjeHnsnt Planning and doss not include  many details
that will ultinately be necessary to implement the process
(e.g., information en processing surface impoundment  retrofitting
waivers and other HSWA previsions for which final.guidance has
yet to be developed).  Rather, it should be used:to establish the
general objectives and scope of coverage for facility management
planning.  While ;a suggested format is included, it is for .Illustration
only and othsr approaches or formats are acceptable as long as
they meet the <;oal? of this guidance.

     Several Regions have  commented on the need to preserve the
confidentiality of certain aspects of faqility management plans.
Decisions regarding which  information may be released must be
made on a case-by-case basis, in consultation with your FOIA
Officer and Regional Counsels.  In general, however,  we suggest

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                               -2-


that information that is purely factual or a record of previous
decision  (e.g., the information outlined in the facility analysis
section of the guidance) can be released if requested/ while
the sections of the plans regarding possible options for the
future and tentative strategies (e.g., sections of this guidance
describing a discussion of prospective actions and tradeoffs, and
identification of proposed actions) may be withheld.  In addition,
of course, information concerning enforcement action may also be
withheld when necessary.  The final guidance will address the
issue of  confidentiality in more detail.

     Because of the short lead time available for FY 1985 facility
management planning, this draft guidance may be used immediately
to begin  screening and developing the facility analyses.  We are
concerned that the initial screening process will result in a
time consuming review.  This step is intended to be a very brief review
that can  be accomplished in less than a few work hours in many
cases.  Therefore, please keep that intent in mind as you use
this draft.  In addition, we solicit your specific comments on
ways to more clearly explain that purpose in the guidance.

     This document provides guidance on how facility management
planning  should be conducted.  Please refer to the FY 1985 revised
RIP and the FY 1986 RIP for further implementation guidance.

     Comments on this draft should be directed to Bryan Wilson
(OSW) at  FTS-382-4534 or Lori Heise (OWPE) at FTS-473-9360 by
July 31.  In addition, we would appreciate receiving copies of
any relevant guidance that has been prepared by Regions or States.
If there  is sufficient interest, we will be happy to distribute
the "Regional/State examples for use by other Regions and States.

Attachment

cc:  Permits Section Chiefs, Regions I-X
     Enforcement Section Chiefs, Regions I-X
     State Program Section Chiefs, Regions I-X

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         DRAFT GUIDANCE FOR

    FACILITY MANAGEMENT PLANNING
       Office of Solid Waste
Office of Waste Programs Enforcement
             July, 1985

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I.   INTRODUCTION AND OVERVIEW OF PROCESS
     The Hazardous and Solid Waste Amendments of 1984 have
a tremendous  impact on the RCRA permitting and enforcement
programs.  More than ever before, enforcement and permitting
authorities overlap.  In addition, a major side effect of the
the Amendments is that EPA and the States are now partners in
every permitting action and many enforcement actions, even in
authorized States.  Facility management planning has been
developed by  the Office of Solid Waste and the Office of
Waste Programs Enforcement to facilitate the close cooperation
among State and Regional permitting and enforcement staffs
that will be  crucial for implementation of the Amendments.

     The facility management planning process is outlined in
the Draft Revised National Permits Strategy (NPS) and the FY
1985 and FY 1986 RCRA Implementation Plans (RIP).  As stated
in the FY 1986 RIP, this approach requires upfront planning
between those responsible for permitting and those responsible
for enforcement (both at EPA and in the States) in order to
develop facility specific plans leading to compliance with
the RCRA requirements.

     As described in the revised NPS and the RIPs, facility
management planning is a three step process:  initial screening,
preparation of individual facility plans, and development of
multi-year strategies.  Individual facility plans will be
prepared for all environmentally significant facilities
according to schedules described in the RIPs.   The plans are
flexible, working documents which should be revised as
necessary to reflect changing situations.

     Development of a plan for a typical facility should
require no more than two to four workdays per facility by
staff representing Regional and State permitting, enforcement,
and other appropriate offices (such as Offices of Regional
Counsel or State Attorney General), working jointly to complete
the analysis.
Initial Screening

     The initial screening will be conducted to identify
facilities for which FMPs must be developed (i.e., environmentally
significant facilities).  Section II of this guidance, "Initial
Screening", elaborates on the criteria to be used to determine
whether or not a facility is environmentally significant.

     Some facilities do not require facility management plans
because it is unlikely that coordination between enforcement
and permitting will be necessary.  For example, there are

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facilities that are high priority  for permit processing and
have only a snail likelihood of an enforcement component..
These include applications  for research, development, and
demonstration permits; and applications for new facilities. •
In addition, some facilities, such as those not seeking or
subject to permits, may be dealt with by enforcement without
facility management planning.

     Facilities that do not require FMPs will be included in
the multi-year strategy.
Facilty Management Plans

     The second step in the process consists of three parts.
First, the individual facility analysis outlines the current
regulatory status of the  facility and summarizes available
information.  In addition, the analysis will identify information
that is not available but must be obtained or developed.
The second part of the planning process is the consideration
of prospective solutions  to the problems identified in the
analysis and of the variety of tools available to EPA and
the States to implement the selected options.  The final
part is the development of an individual plan summary which
gives a timetable for key elements of the plan and identifies
the lead office for each  action.

     Section III of this  guidance includes a questionnaire
which is designed to aid  review of the relevant information
about a facility.  There  are also worksheets for evaluating
the options available for each facility and a sample format
for the plan summary.
Development of the Multi-Year Strategy

     The third step in the facility management planning  •
process is the development of a multi-year Facility Management
Strategy.  The strategy is a State-by-State summary of
projected permitting and enforcement outputs over the next
year, incorporating the results of the individual facility
plans as well as planned actions  for those facilities for
which facility management plans were not required.

     Strategy development is an iterative process.  After the
FMPs and other planned solutions  are combined into a Strategy
certain adjustments will need to  be made to accomodate resource
and time constraints.  The Region and the State will need
to make choices among the various options to ensure that the
final Strategy can be implemented with available and anticipated
resources.  When choosing between options, the planning team
should take into account relevant guidance, policies, and

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statutory requirements.

     As in the case of the individual facility plan, the
Strategies are flexible documents which can and should
be revised as necessary to reflect new information, changing
priorities, completion of intermediate solutions on which
later solutions depend, and individual facility solutions.
Relationship of Facility Management Planning to SPMS

     The Facility Management Strategy will provide a basis
for determining yearly Regional and State commitments for the
Strategic Planning and Management System (SPMS).  This will
be addressed in each year's SPMS commitments and reports.
See the revised FY 1985 RIP and the recently issued FY 1986
RIP for priorities for developing FMS and for a complete
description of SPMS measures.
Use of this Guidance

     This guidance is intended to provide assistance to the
Regions and the States in implementing the facility management
planning process.  It offers several sample formats and
describes the breadth of scope and depth of coverage which is
expected in the facility management process.  It should be
considered a foundation upon which individual Regions and '
States may build in addressing their individual facility
management planning needs.  None of the charts or forms is
mandatory.  They are offered as examples only, and may be
modified as appropriate.

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II.  INITIAL SCREENING

     The purpose of the initial screening is to identify those
facilities which are environmentally significant and, therefore,
require Facility Management Plans  (FMPs).  The determination of
"environmental significance" rests with the Region and State
personnel who are most familiar with the particular facility.
However, certain criteria should be applied to provide a nationally
consistent definition of environmental significance.

     In some instances it is readily obvious, even with incomplete
information, that a facility is environmentally significant.  How-
ever, a conclusion that a facility is not environmentally significant
cannot be reached without a reasonably complete picture of the
facility.  Attachment A is a list of possible sources of information
on a facility.  These sources can be used to support the initial
screening and analysis stages.

     As previously stated, the criteria for determining environ-
ment significance are the ones listed in the National Permit
Strategy.  The factors listed below the criteria are offered to
assist the reviewers in applying the general criteria to specific
facility situations.

     Each treatment, storage and disposal facility should be
evaluated.  The criteria listed below provide a guide.  The rela-
tive weights of these factors may vary from case to case, subject
to the discretion of Regional and State facility planners.  Prior-
ity considerations are designated by an asterisk (*).  In some
instances, a single factor (such as violation of ground-water
monitoring requirements (interim status, permit application or
permit or actual contamination of ground water) may be sufficient,
regardless of the applicability of other factors, to require a
FMP for the facility.  In these instances, which are expected to
predominate at land disposal facilities (landfills, land treatment,
surface impoundments for treatment, storage or disposal, waste
piles and underground injection wells) the screen should be
conducted very quickly, and perhaps by only one member of the
planning team.  In other cases, while a single criterion may not
trigger additional analysis, the presence of several factors may
warrant the preparation of a FMP.

     0 Facility is a recipient of wastes from a CERCLA site

     e Facility may pose a potential public health or environment
       threat from releases.

          *-  The facility was evaluated as a potential CERCLA
              site and the evaluation showed evidence of:
              — environmental damage
              — ground-water contamination
              — close proximity to population or drinking water
                 source

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                                                 DRAFT
     *-  The facility is or was  the  subject of a Federal or
          State CERCLA action

0 Facility violated environmental  standards or disregarded
  RCRA regulations  as evidenced  by designation as a Signi-
  ficant  noncomplier or High Priority Violator for enforce-
  ment action.

  *-  The facility  has failed to properly evaluate facility
      hydrogeology, to properly  install wells or properly
      monitor.

  *-  The facility  is a significant  noncomplier

      The facility  has been known  to violate other environ-
      mental laws as evidenced by  releases to air or surface
      water.

   -  The facility  has not  closed  units properly, has not
      fully completed post-closure permitting properly, or
      has closed in accordance with  regulations but substantial
      contamination remains.

0 Facility is suspected or  potential source of ground-water
  or surface-water  contamination (e.g., ground-water quality
  assessment has identified presence of hazardous waste con-
  stituents) or other contamination  by prior or continuing
  releases of hazardous wastes.

   *- the facility  is known to be  contaminating the ground
      water as evidenced by:
      — initiation of assessment  or compliance monitoring
      — physical evidence  of contamination.

   *- The facility  has known  or  suspected solid waste manage-
      ment units.

    - The facility  may have released hazardous constituents
      into the  ground water,  surface water, or air, as evi-
      denced by the likelihood of  or reports of spills, odors,
      odd-tasting water, or other  unusual occurrence at or
      near the facility.

0 Facility poses significant  environmental or health risk,
  determined on the basis of:

    -  proximity to population centers and/or aquifiers and
         surface waters,

    -  facility size,

       amount,  nature, and  complexity of waste handled, and

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                                                               fc«
   -  age of facility.

0 Degree of public concern about the facility:

   - congressional inquiries
   - organized local citizens groups,
   - high volume of public mail, or
   - local public official concern.

0 Anticipated financial insolvency or inability to
  properly close and conduct post-closure monitoring
  and maintenance.

  *- The facility has declared financial insolvency
     as evidenced through:
         application of modeling against financial
         test data, and
     —  information from institution providing
         financial assurance.

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III.  DEVELOPING THE PLAN
Part 1 - Evaluating the Facility

     The purpose of this part of the planning process is to
review the environmental and regulatory status of the facility.
The questionnaire format on the following pages is designed
to assist the reviewers in systematically addressing all
relevant information about the particular facility.  The
questions center on those areas of concern that will most
likely require coordination between Regional and State
enforcement and permitting staffs:

     — ground-water monitoring at regulated units
     — prior and continuing releases from solid waste
        management units
     — the adequacy of a facility's Part B application and/or
        closure plan, and
     — requirements of the Hazardous and Solid Waste Amendments
        of 1984.

     When completing the questionnaire, it is suggested that
the reviewers note any additional information which is not
specifically covered by the questions and highlight any
missing information which is necessary to evaluate the
facility.  The major problems and missing information will
form the basis of the analysis conducted under Part 2.

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                            FACILITY ANALYSIS
                                                                  f)P
                                                             Date:
Facility Name

EPA I.D No:

Facility Address

Facility Cbntact
Facility Status:
Interim status        Y     N
Permitted             Y     N
Receiving Waste       Y     Some Units
Closed                Y     Sbme Units
Commercial            Y     N
CERCLA waste          Y     N
New unit(s) proposed  Y     N
                                                              N
                                                              N
FACILITY DESCRIPTION
Process Description (e.g., chemicals produced,  production processes) and
general description of waste management processes
CHRONOLOGY (optional)
Attach chronology or narrative summarizing significant events and information
related to the facility that may be used for multiple purposes, including
informing other FMP team members of relevant facts.

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          *******************  UNIT DESCRIPTION  *******************  -


     UNIT
   IDENTIFIER         TYPE OF    Received waste     WASTE TYPE(S)   STATUS*
     CODE              UNIT          after:
(keyed to site map)             11/19/80 I  7/26/82
                         	Y or N  I  Y or N	


 EXAMPLE:

      A             landfill       Y         Y         F006         active


      B             SWMU           N         N         unknown      closed
  *e.g., active,  inactive,  closed,  under constrution

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            GROUND-WATER MONITORING AND RELEASES AT REGULATED UNITS
The purpose of the following questions is to determine  the compliance status
of the facility with respect to Part 265 and Part 270 ground water nonitoring
requirements
1. Does the facility have regulated units subject to interim status ground-water
   monitoring (surface impoundments, landfills, or  land treatment units)?
   a.  Yes - List by each unit by
             identifier code*
   b.  No  - Skip this section
   c.  Under Dispute  (explain)
2. Is the facility operating under a waiver  from ground-water nonitoring require-
   ments?

   a. Reviewed and adequate     	    COMMENTS:
   b. Reviewed and not adequate 	
   c. Not reviewed              	
   d. Adequacy under dispute    	


3. Has the owner/operator performed a detailed site-specific study of the hydro-
   geology beneath the site including:

   a. a progran of soil borings or rock corings?                           Y   N
   b. water level monitoring to determine ground-water flow direction?     Y   N
   c. hydraulic conductivity measurements                                  Y   N

   COMMENTS:
4. Has the hydtogeologic study yielded enough information to make reasoned decisions
   regarding well placement and depth?

   	  a. Yes for all regulated  units
   	  b. Yes for some units (list  exceptions by code)
   	  c. No

   COMMENTS:
* Use coding system established on previous page on "Unit Description" chart

                                   10

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                                                                           -
5. toes the study provide gpod hydrogeo logic information about areas underlying
   solid waste management units as well as areas underlying regulated units? .

   Yes       No        COMMENTS:
6. Has the owner/bperator installed a sufficient  number of downgradient wells at
   adequate locations and depths to immediately detect the migration of hazardous
   waste from regulated units into the uppermost  aquifer  (defined as the first
   saturated hydrogeologic formation that could serve as  a potential pathway for
   contaminant flow)?

   	  a. Yes at all units
   	  b. Yes for some units (list exceptions by  code)
   	  c. tto
   	  d. ton't Know


7. Has the owner/operator installed a sufficient  number of background wells at
   adequate locations and depths to characterize  the spatial and temporal variation
   of ground water unaffected by the facility?

   a. Yes  	       b. Vb  	       c. CDn't  Know 	


8. Has the owner/operator established and maintained  a ground-water sampling
   protocol that yields representative samples and maintains the integrity of
   the sample in light of the chemical parameters to  be analyzed (e.g., does the
   equipment minimize de-gassing)?

   Yes  	     No  	   Don't Know  	

   COMMENTS:
9.  Has the owner/operator detected  leakage  from any regulated unit(s)?
    a) Yes 	 (list units)
    b) to  	
    c) Detected leakage,  source unclear

    COMMENTS:
                                     11

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10.  If not, is the owner/operator's monitoring system technically adequate to
     detect leakage should it occur?

     NOTE:  When evaluating adequacy, consider not only inadequacies that would
     constitute violations of the regulations (e.g.   insufficient number of
     wells), but any problem at the site that may be  compromising the ability of
     the system to detect leakage (e.g., inability of four  indicator parameters
     to detect level and type of contamination suspected at site).


     Yes for all units  	   Yes for some units	    No  	

     COMMENTS:
11.  Co the inadequacies identified  in question 10 represent violations of the
     Part 265 ground-water monitoring regulations ?  Explain.
12.  If leakage has been detected,  has  the owner/operator assessed the plume(s)
     for hazardous waste constituents (Appendix VII) using appropriate techniques
     (at a minimum direct  sampling  down gradient from the point of leakage)?


                 Incomplete assessment  	  Complete assessment  	
13.  Has the owner/operator characterized any plume(s) with respect to all
     Appendix VIII constituents as required by S270.14(c)(4)7


                 Incomplete charaterization   	   No  	
                                     12

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                                                                         Dfo
14. The owner/operator's permit  application includes plans for which of the
    following Part 264 ground-water monitoring/cleanup program(s)?

    a. Detection monitoring  §270.14(c)(6) 	
    b. Compliance nonitoring $270.14(c)(7)     '
    c. Corrective action     S270.14(c)(8) 	
    d. tone of the above
15. Does the owner/operator's permit application include proposals for any
    Alternate Concentration Limits  (ACLs)?

    a. Yes, all proposals deemed adequate     	
    b. Yes, some proposals  deemed inadequate  	List:
    c. Yes, all proposals deemed inadequate   	
    d. Review not complete                    	
    e. No
16. Given the compliance status of the facility's interim status monitoring system
    and the validity or non-validity of any ACL proposals, has the owner/operator
    submitted plans for the appropriate Part 264 ground-water program?

    	 a. Yes
    	b. No - inadequate Part 265 monitoring may be masking leakage; detection
                 monitoring may not be appropriate program.
    	c. No - ACL demonstrations inadequate, should have submitted corrective
                 action program
    	d. No for other reasons (explain)
         e. Not sure
17. If the answer to  16 is "yes," is the ground-water program that is proposed
    adequate?

      Yes 	  Partially adequate  	  totally inadequate  	


     Explain deficiencies:
                                  13

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18.   Identify what actions, if any, EPA or the State has taken to  bring  the  facility
      into compliance with Part 265 and 270 ground-water monitoring requirements
      (e.g., NODs, S3008(a) order, etc.)?
19.  Identify what actions, if any, EPA or the State has taken regarding releases from
     regulated units (describe by unit).
         PRIOR OR CONTINUING RET .RASES FROM SOLID WASTE MANAGEMENT UNITS


The purpose of the following questions is to determine whether or not there have
been or may have been prior or continuing releases of  hazardous waste or hazardous
constituents from solid waste management units which would require corrective action
under Sections 3004(u) or 3008(h) of RCRA as amended by HWSA.

The purpose of the analysis is to determine:

   a) Do such units exist?

   b) Have there been prior or continuing releases of  hazardous waste or constituents
      from such units?

   c) Are releases presenting potential environmental  threat that would warrent
      corrective action?

   d) If the above questions cannot be answered,  what  additional data, information or
      investigation is needed to  yield clear yes or  no answers?
                                   14

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The following sources of information should be consulted before answering questions
regarding prior and continuing releases form solid waste management units:

    1.  Any response to the Solid Waste Management Questionnaire sent.to facilities
    2.  CERCIA $103(c) Notification information
    3.  CERCLA or RCRA PA/SI information
    4.  Part A and Part B permit applications
    5.  Previous inspection reports

    (look especially for: evidence of past waste disposal practices not currently
     regulated under RCRA such as pile of waste or rubbish, ponds or surface
     impoundments that might contain waste, active or  inactive landfills; evidence
     of discolored soils or dead vegetation that might be caused by a spill,
     discharge or disposal of hazardous wastes or  constituents; any reference to
     tanks that are used for waste storage which are located below grade and could
     possibly leak without being noticed by visual observation.
1.  Are there solid waste management units (SWMUs)  at the facility?

    a. Yes                    	
    b. No evidence of units   	
    c. Maybe                  	
2.  If the answer to question 1 is "maybe," provide the information that prompts
    suspicion that there may be SWMUs?
3.  Is there any reason to doubt the information which the applicant has submitted
    on the questionnaire re: the existence of  Solid Waste Management Units and the
    possibility of continuing or prior releases of hazardous wastes or constituents?

         Yes	  No	


    Areas of doubt:
                                 15

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4.  If the answer to question 1 is "yes", describe what  is known about each
    SWMU in terns of the wastes present and when the wastes were placed in the
    unit(s). (State whether a PA and/or SI has been undertaken and when. Reference
    reports on each where applicable).
5.  If there is a ground-water nonitoring network  installed at the facility (to
    monitor regulated units), to what extent is the network capable of monitoring
    releases from each SWMLJ?

              SWMU                           CAPABILITY
6.  Are the parameters being monitored adequate to detect contamination from
    each SWMU?

    	 a. Yes
    	 b. Yes some units (list units)
    	 c. Don't know enough about wastes
    	d. No


7.  Is the sampling and analysis methodology adequate to detect contamination from
    each SWMU?

    	 a. Yes
    	 b. Yes some units (list units)
    	c. Don't know enough about wastes
    	d. No


8.  Are there other environmental monitoring systems at the facility (air, surface
    water, soil, leak detection systems)?

    	a. Yes	> Describe:
    	b. No
        c. Don't Know
                                   16

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9.'' Are'the existing nonitoring systems considered  capable of detecting releases
    from the SWMUs?

    	 a. Yes
    	 b. Yes some units (list)
    	c. No
    	d. Don't know


10. For those SWMUS known to be present,   available information indicates:

                                                                     LIST BY UNIT CODE:


    a. Releases of hazardous waste or constituents  have occurred       	

    b. There is evidence that releases may have occurred               	

    c. Releases of hazardous waste or constituents  have not occurred
    d. There is insufficient information to determine whether releases
       of hazardous waste or hazardous constituents have occured.
11. Summarize any release in terms of  the extent of release, the media involved
    (ground water, surface water,  soil,  air)  the constituents of the release,
    the unit(s) involved, and any  other  pertinent information.
12. Describe what additional information or testing is needed to determine if the
    releases suspected  in question 10 have indeed occurred (answer may refer to PA
    and/or SI and/or RI,  etc.).
                                  17

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 14.  Describe the potential threats that facility poses to health or the environment.
      Describe information needed to assess the significance of these threats.
                          CERCLA/RCRA INTERFACE
1.  After reviewing the CERCXA totification form, the RCRA Part A and Part B
    appplicat ions it appears that:


     	a. The RCRA units and CERLA units are one and  the same
     	 b. The RCRA units and CERCLA units are  clearly different units
     	 c. There is overlap between the RCRA and CERCLA  units some are the same
             and some are different
     	d. Not applicable
2. Is this facility included on the CERCLA National Priorities List?     Y    N


3.  Has a CERCLA PA/SI been completed for this site                      Y    N

     If yes, summarize briefly the findings focusing on environmental
     contamination, environmenatal threats and wastes  found:
                                18

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             PERMIT AND CLOSURE STATUS, ISSUES AND ACTIONS NEEDED
The purpose of the  fallowing questions  is to identify the degree to which the
applicant's stage in the permit process will affect the type of actions necessary
at the facility
1.  Key Dates    (Future dates may be noted as expected)
PART B:
CLOSURE:
  a) Date Part B called
  b) Date Part B received
  c) Date First NOD sent
  d) Date first revised Part B received 	
  e) Date 2nd NOD sent   	
  f) Date of Enforcement Actions for Deficient Part B
  g) Date 2nd Revised Part B received 	
* h) 	
* i) 	
* j)	;	
  a) Date closure plan submitted (by unit)  	
  b) Date comments sent to o/o (by unit)    	
              c) Date revised closure plan submitted (by unit)
              d) Date closure plan approved (by unit) 	
              e)
              f)
PC PERMIT     a) Date post-closure permit called
              b) Date post-closure permit received
             *c)
    * Fill in further processing/enforcement actions that have taken place
                                 19

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2.  Summarize the principal Part B deficiencies or issues that remain unresolved:
3.  Summarize the principal closure/post-closure deficiencies/issues that remain
    unresolved (by unit).
4.  Is the facility targeted by the National Permit strategy as a high priority
    for final permit determination (FY86 priorities include existing commercial
    incinerators; expansion of facilities to provide alternate treatment or
    incineration capacity; and research, development, and demonstration permits)

       Yes        K>
5.  Is the facility targeted for expanded public participation?
       Yes
                                20

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6.  In light of outstanding permit deficiencies, the presence or absence of
    solid waste management units with prior or continuing releases,  and  the priority
    given this facility in the National Permit strategy, issuance of a permit
    to this facility (operating or post-closure) is likely to take  from     /  /   ;
                                                                        • date

          Time
    a.  0-6 months

    b.  6-12 months

    c.  12-18 months

    d.  18-24 months

    e. more than 24 months
7.  After referrring to the attached chart, summarize the Hazardous and Solid Waste
    Act Amendments that apply to this facility (note especially the requirements
    related to: 1) retrofitting surface impoundments by 1988;  2) exposure assessments
    for landfills and surface impoundments; Corrective action  and financial assurance
    for prior releases.
                                    21

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                        INFORMATION GAPS
     List those pieces of infornation that were identified as
missing from State or EPA files and which are needed to address
permitting and enforcement issues at the facility.  Describe
why it is needed.
                               23

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                                                                 ^
Part 2 - Considering the Solutions to Address the  Problems           <

    The purposes of this section are:  (a)  to provide  a means to
evaluate the possible solutions to the specific  problems raised by
the answers under Part 1 and (b) to identify the short-term
(FY 1985-1986) and long-term (FY 1987-1992) objectives for the
facility.

    The chart on the following page is offered as  a possible
mechanism to use in considering the solutions to the problems.  The
problems identified in Part 1 would be listed in the first column,
grouping them by subject matter.  In the second  column, the reviewers
would list the solutions to the problems.  The solutions should be
consistent with the SPMS measures.  In the  third column, the tools
available to EPA and/or the State to accomplish  these  solutions would
be listed.  Attachment B provides a selection of tools available to
EPA which may be used to resolve several of the  problems found at
facilities.  Attachment C is an inventory of federal tools.

    The last column is intended to provide  a condensed assessment of
the pros and cons or related concerns associated with  the various
tools as they pertain to the particular facility.  Issues such as
timeliness of the action, resources, and "standard of  proof" required
for an enforcement action may all be addressed in  this section.  The
discussion under "Comments" should take into account appropriate
permit and enforcement guidance issued by EPA Headquarters.

    The spaces for short-term and long-term objectives are provided
to summarize the expectations for the particular facility.  These
objectives provide the basis for developing SPMS commitments.

    It is suggested that, after consideration of the pros and cons of
the various tools, the one chosen to resolve each  identified problem
be highlighted by underlining or other method to distinguish the
selected tool.  This will facilitate the transfer  of that information
onto the plan under Part 3.  An example of  a completed chart is
provided on page 19.

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                                                       EXAM
                                           (bnsidering Options for Addressing
                                                  Identified Problems
        MAJOR PROBLEM                                                     POTENTIAL
         IDENTIFIED                               SOLUTION                  TOOLS                 COMMENTS
SHORT TERM OBJECTIVE:  Compliance with ground water requirements by 1986

LONG TERM OBJECTIVE:   Permit issued by FY 88

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                                                        EXAM*
                                            Cbnsidering Optic   Jbr Addressing
                                                   Identified Problems
         MAJOR PROBLEM
          IDENTIFIED
          SOLUTION
 POTENTIAL
   TOOLS
           COMMENTS
1.  Facility not in compliance with
    Part 265 GWM regulations; there-
    fore inadequate Part B
Compel facility to determine
whether leakage has ocurred
and extent of contamination
as quickly as possible
a) NOD
PRO: less resource intensive

CON: may not compel compliance
     due to history of non-oomp-
     liance
                                                                          b) S3008(a)    PRO:
                                                                                        CON:
                                                                          c) S3013
 SHORT TERM OBJECTIVE:  Compliance with ground water requirements by 1986

 LONG TERM OBJECTIVE:   Permit issued by FY 88
                                                    can use combined authorities
                                                    of Parts 265 and 270  to
                                                    accelerate generation of
                                                    ground  water data  needed
                                                    for permit processing. Can
                                                    also assess penalties for
                                                    past violations.

                                                    may be  delayed  by  administra-
                                                    tive hearing process
                                               PRO:  not bound  by ground water
                                                    monitoring regimen in  the
                                                    regulations. Can compel
                                                    investigation with greater
                                                    flexibility in  sampling
                                                    parameters and  frequencies

                                               CON:  may be more difficult  to
                                                    make showing of potential
                                                    substantial hazard to  public
                                                    health or  environment.
                                                    Cannot assess penalties

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Part 3 - Establishing the Plan

    The purpose of the individual plan is to summarize the  results of
the analysis under Parts 1 and 2, to describe the tools chosen  to
achieve the solutions to selected problems,  to establish a  timetable
for accomplishing the solutions to the problems,  and to identify
which office is responsible for that action.  The plans for all
facilities will be combined to make up the core of the Facility
Management Strategy.

    The chart on the following page is a possible format for the plan,
An example of a completed form follows the model  format.

    When using the chart, the reviewer would list the solutions and
the tools to accomplish those solutions agreed upon as a result of
the analysis completed in Part 2.  The respective lead office would
also be identified.  This may be accomplished by  establishing a code
system, as illustrated in the example, or narratively.
                                               t
    The-example format provides space for indicating the quarters
(for the remainder of the current and upcoming fiscal year)  or  the
years (for subsequent fiscal years) during which  the particular
solution or tool would be tracked.  The time tables should  be
detailed enough to be used to develop SPMS commitments.   Solutions,
in most cases, would be indicated by their completion dates.  Tools,
however, may require start dates, completion dates,  or both.

    It is important to keep in mind that the statutory deadlines for
making final determinations must be observed (i.e.,  all land disposal
facility final determinations must be completed by November 1988).
The indications should be as specific as necessary to serve Regional
and State planning and scheduling needs.

    Finally, the estimated resource cost associated with planned
actions should be identified.  This will assist in the  iterative
process of developing a Facility Management  Strategy which  is
consistent with available resources.
                            27

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                                                       FACILITY MANAGEMENT  PLAN


 Solutions and             Lead          PY85                   FY86
 Tools	Office     3rd     4th     lat    2nd    3rd    4th      FY87     FY8B    FY89

 Solutiont

 Tool»


 Solution:

 Tool t


 Solutions

 Tool:


 Estimated
 Resource Cost
 per action



 E = EPA, RCRA Enforcement
 P = EPA Permits
 C = EPA CERCLA Enforcement
 SE = State RCRA Enforcement
 SP = State Permits
 SC = State CERCLA Enforcement
to
oo

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                                                               EXAMPLE

                                                      FACILITY MANAGEMENT PLAN
Solutions and
Tools
Lead'
Office
    FY85
3rd     4th
1st
   FY86
2nd    3rd
4th
FY87
FY88
FY89
Solutiont   Bring facility  SE
into compliance with Part
265  ft (270.14(c)(4) GWM
requirements

Toolt  }3008(a)
>rder
5olutioht  Develop broader
lublic participation       SP

Tooli   Conduct field
assessment

Toolt   Prepare public
involvement work
slan
solutioni   Complete PA/SI   E
for SWMU's

Foolt   }3008(h) order	
Estimated
Resource Cost
oer action
            45wd
         75wd
        5wd
5 • EPA,  RCRA Enforcement
P =« EPA Permits
: - EPA CERCLA Enforcement
>E «= State RCRA Enforcement
            SP • State  Permits
            SC - State  CERCLA Enforcement
             I - Initiate  solution or tool
             F • Finish solution  or tool
 tt>
 \o

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                                                     Attachment A
                          SOURCES OF DATA FOR
                     FACILITY MANAGEMENT PLANNING
Compliance History
     -  high priority violator
     -  number of compliance orders
     -  significant noncompliance
     -  violations of other laws or regulations
     -  types of violations

Part B Information
     -  type of facility
     -  commercial versus onsite
     -  releases indicated.
     -  completeness of groundwater monitoring  data
     -  requirement for double liners

Compliance Monitoring and Enforcement Log
     -  types of violations
        enforcement actions

Major Facility Status Sheets
     -  inadequacy of financial information
        inadequacy of groundwater monitoring systems
        inadequacy of closure or postclpsure plans

Other Environmental Permits Which Apply to  Facility
     -  NPDES
     -  PSD
        State permits (solid or industrial  waste)

Results of facility site visit
     -  number and type of violations
     -  owner/operator approach to permit process, demonstrated
        willingness to cooperate
     -  distance between existing interim status activities and what
        must be in place for permit
                              30

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Additional information requested in response to or  required by  HSWA
        SWMUs present; apparent completeness of data on  SWMUs
     -  releases exist; apparent completeness of data on releases
     -  corrective measures already underway
     -  exposure assessment data

Information on ERRIS and other Superfund databases
     -  PA/SI or RI/FS results
     -  enforcement actions
     -  notification under CERCLA §103
     -  Hazard Ranking System Score
     -  other data showing population exposure,  threats  to human
        health or the environment

State files (depends upon authorization status)
     -  compliance history
     -  permitting history
     -  releases or spills
        state CERCLA actions/information/multi-site cooperative
        arrangements
     -  solid waste management unit information
     -  groundwater information

Personal knowledge of Regional and State staff

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                                             Attachment B
        A SELECTION OF TOOLS TO ADDRESS PROBLEMS
       RAISED DURING FACILITY MANAGEMENT PLANNING
  Problem

Evidence of release
Suspicion of release
Imminent hazard
Financial insolvency
No release
Incomplete Part B with
respect to ground-water
information
Incomplete Part B with
respect to information
other than ground
water
          Tools

§3008(h) Order
§3013 Order
final determination
post-closure permit

§3013 Order
final determination
§3008(a) Order if GWM
violation
§3007 letter or inspection
RCRA PA/SI
post-closure permit

§7003 Order
CERCLA §106 Order
fund-financed removal action
§3008(h) Order

§3008(h) §106 Order
Fund-financed removal or
remedial action

final determination
post-closure permit

§3008(a) Order
§3013 Order
§3008(h) Order
comprehensive ground-water
inspection
post-closure permit.
Notice of intent to deny
permit

§3008(a) Order
NOD
§3007 letter or inspection

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                                                     Attachment  C
                      INVENTORY OF TOOLS AVAILABLE
                     TO ADDRESS IDENTIFIED PROBLEMS
Permit Tools
    -  additional information request
       Notice of Deficiency
    -  post closure permit application request
    -  draft permit
    -  notice of intent to deny
    -  notice of availability of closure plans
    -  preparation of public involvement work  plan
    -  field assessment conducted
    -  public meetings
    -  public hearing
    -  permit issuance
    -  permit denial
    -  approval or denial of closure  plan

Compliance Monitoring and Enforcement Tools
    -  §3007 information letter
    -  compliance evaluation inspections (CEI)
    -  comprehensive ground water evaluation (CME)
    -  sampling inspection (SI)
                              33

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    -  §3008(a) order or civil action issued for  a  violation of
       permit or interim status rtandards

       §3013 order issued to collect additional information

    -  §7003 order or civil action for imminent hazards

    -  §3008(h) corrective action order
                for information gathering
            —  to conduct PA/SI
            —  to conduct RI
            —  to undertake corrective measures

    -  CERCLA §106 order or civil action for imminent hazards.

    -  §3008(d), §3008(e) or CERCLA §103(b)  criminal action for
       knowing violations
Other Tools
    -  Preliminary Assessment/Site Investigation  (PA/SI)

       RCRA Remedial Investigation (RI)

    -  CERCLA §104 removal action
                               34

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                                                     Attachment  D
Principles of Facility Management Planning

A Facility Management Plan should be:
.Simple


Flexible
Built on Existing
Systems
Detailed
Time-oriented
A Cooperative Effort
Goal-oriented
It should clearly identify the key
steps to be undertaken.

The plan should not be set in
concrete, but should be flexible
enough to adjust to changes in the
facility, in actions taken at the
facility, or in the schedule.

The plan should be developed in the
context of existing planning and
management structures - not a "new
reporting system," but looked on as a
way to more-comprehensively address
existing systems.

The plan should describe work on a
quarterly basis of the current and
next fiscal year, but may be less
detailed for later years.

The plan should identify tentative
time frames when the next step depends
on completion of a former step.

The plan should be developed jointly
with region and state - permitting and
enforcement personnel.  CERCLA staff
and other necessary personnel should
also be involved as necessary.

The plan should identify problems at
the facility and the solutions to
those problems.
                            35

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