NEIC
MULTI-MEDIA NONCOMPLIANCE PROFILE
Region VIII
June 1988
National Enforcement Investigations Center, Denver
CIS. Environmental Protection Agency
Office of Enforcement
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING
MULTI-MEDIA NONCOMPLIANCE PROFILE
Region VIII
June 1988
Information Management Branch
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver Colorado
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CONTENTS
INTRODUCTION 1
WATER (PCS) 4
NONCOMPLIANCE DEFINITION 4
RETRIEVAL SPECIFICATIONS 4
AIR (CDS) 6
NONCOMPLIANCE DEFINITION 6
RETRIEVAL SPECIFICATIONS 6
HAZARDOUS WASTE (HWDMS) 7
NONCOMPLIANCE DEFINITION 7
RETRIEVAL SPECIFICATIONS 8
FACILITY INDEX SYSTEM (FINDS) 10
DISCUSSION 11
FIGURE
1 Noncompliance Profile Process 3
2 Distribution of Significant Noncompliers and Multi-Media
Violators 12
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INTRODUCTION
In recent years, the National Enforcement Investigations Center (NEIC)
has developed an automated process for identifying those facilities which are
not complying with environmental regulations across media within a specific
geographic area. Eventually, this effort expanded in scope to include the entire
United States and attempted to disclose corporate noncompliance. This
resulted in the development, in late 1986, of what were termed "Potential
Noncompliance Profiles" for all 10 Regions. Following receipt of that report, the
Region IV Deputy Regional Administrator requested that the Region IV report be
updated for Fiscal Year 1986. Computerized data processing is essential to a
facility noncompliance identification process due to the volume of data to be
examined for 10 Regions in air, water and hazardous waste. NEIC recognizes
that data availability and quality from the program databases [Air - Compliance
Data System (CDS), Water - Permit Compliance System (PCS), Hazardous
Waste - Hazardous Waste Data Management System (HWDMS)] may vary from
very good to very poor and that the quality of the report is largely a direct result
of the quality and reliability of the data. Acknowledging these limitations, the
purpose of the noncompliance profile is to provide a comprehensive, automated
strategy using the best available technology to identify facility multi-media
noncompliance.
Prior to the Region IV project in May 1987, database retrieval selection
logic were finetuned to more closely approximate the criteria for "significant
violation/noncompliance" for each media (i.e., air, water, hazardous waste).
Using Strategic Planning and Management System (SPMS) measures as a
guideline, database documentation for CDS, HWDMS and PCS were reviewed,
and regional program staff with knowledge of the appropriate databases were
consulted. In April 1988, NEIC's noncompliance profiles were cited as part of
the Office of Pesticides and Toxic Substances' (OPTS) Compliance Monitoring
Strategy for section 313 of the Superfund Amendments and Reauthorization Act
(SARA), Title III. After discussion with the Office of Compliance Monitoring
(OCM), selection logic were modified to describe a universe of facilities which
would support the regional neutral administrative inspection schemes (NAIS)
proposed to select facilities for section 313 inspections. The resulting data
retrieval selection criteria are described below.
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The air, water and hazardous waste data used in preparing this report
are maintained in their respective database systems CDS, PCS and HWDMS.
Along with the media data outlined above, EPA ID number and facility name
data were retrieved from FINDS (Facility Index System). These systems reside
on EPA's IBM 3090 mainframe computer at Research Triangle Park (RTP). After
retrieval from the databases, the data were processed further on the 3090 using
a combination of NEIC computer programs written in FORTRAN and FOCUS.
Figure 1 is a graphical representation of the integrating process.
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KSO 5/26/88
COMPUTER RETRIEVAL
FINDS
HWDMS
PCS
CDS
COMPUTER MATCH
BY I.D. NUMBER
TABLE 4
FACILITIES COMMON
TO 2 PROGRAM
DATABASES
TABLE 1
SIGNIFICANT VIOLATORS IN AIR
(CAA/CDS)
TABLE 2
SIGNIFICANT NONCOMPLIERS IN
WATER (CWA/PCS)
TABLE 3
SIGNIFICANT VIOLATORS IN
HAZARDOUS WASTE
(RCRA/HWDMS)
FIGURE 1
NONCOMPLIANCE PROFILE PROCESS
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WATER (PCS)
NONCOMPLIANCE DEFINITION
Significant noncompliers in this media are those active National Pollutant
Discharge Elimination System (NPDES) permitted facilities (excluding general
and standard permits) designated as major dischargers with: (a) at least one
instance of reportable noncompliance (RNC) between October 1, 1986 and
December 31, 1987 for a particular effluent measurement [excluding Discharge
Monitoring Report (DMR) nonreceipt violations], or (b) at least one instance of
reportable noncompliance between October 1, 1986 and December 31, 1987
for a particular compliance schedule violation (excluding compliance schedule
report nonreceipts).
RETRIEVAL SPECIFICATIONS
To retrieve the facilities which met either noncompliance description, the
following retrieval specifications were established for both effluent violations
and compliance schedule violations.
Effluent Violations:
Permit Type Indicator (PTYP) absent
Facility Inactive Code (IACC) equal to A (active)
Major Discharge Indicator (MADI) equal to M (major facility)
Measurement/Violation Monitoring Period End Date (MVDT)
greater than or equal to October 1, 1986 and less than or equal to
December 31, 1987.
QNCR Measurement Violation Detection Code (SNCE) present
but not equal to N (DMR nonreceipt)
Compliance Schedule Violations:
Permit Type Indicator (PTYP) absent
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Facility Inactive Code (IACC) equal to A (active)
Major Discharge Indicator (MADI) equal to M (major facility)
Compliance Schedule Violation Date (CVDT) greater than or
equal to October 1, 1986 and less than or equal to December 31,
1987
QNCR Compliance Schedule Violation Detection Code (SNCC)
present but not equal to N (Compliance Schedule Report
nonreceipt)
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AIR (CDS)
NONCOMPLIANCE DEFINITION
Significant violators in this media include those operating PSD, NESHAP
(except asbestos removal sources), NSR and NSPS Sources and operating
SIP Sources with a Source Compliance Status in violation for any quarter
corresponding to the period October 1, 1986 through December 31, 1987.
RETRIEVAL SPECIFICATIONS
To retrieve the facilities which met the above noncompliance definition,
the following retrieval specifications were established for the non-SIP and SIP
noncompliers.
Air program code (APCD) equal to 6 (PSD), 8 (NESHAP), 7 (NSR) or
9 (NSPS):
Air program status (APST) equal to Blank or 0 (operating) and not
equal to D, R or S (asbestos removal)
Source Compliance Status (SCMSO) for the specified period
equal to any of: 1 (in violation with no compliance schedule),
6 (in violation but not meeting compliance schedule), 7 (in
violation but unknown with regard to compliance schedule), B (in
violation with regard to both emissions and procedural
compliance), or W (in violation with regard to procedural
compliance). SCMSO is retrieved and then processed by the
FOCUS program to select the codes.
Air program (APCD) code equal to Blank, 0 or 1 (SIP):
Air program status (APST) equal to Blank or 0 (operating)
Source Compliance Status (SCMSO) for the specified period
equal to any of: 1 (in violation with no compliance schedule),
6 (in violation but not meeting compliance schedule, B (in
violation with regard to both emissions and procedural
compliance), or W (in violation with regard to procedural
compliance). SCMSO is retrieved and then processed by the
FOCUS program to select the codes.
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HAZARDOUS WASTE (HWDMS)
NONCQMPLIANCE DEFINITION
Significant noncompliers in this media include those facilities occurring
in one of the following categories:
Land disposal facilities with land disposal units that are in opera-
tion, in post-closure care, or closing prior to certification.
• Treatment, storage and disposal facilities (TSDFs) other than land
disposal facilities with Incineration, storage and/or treatment units
that are new, operating or closing but not yet certified, with a RCRA
permit application or permit status of operating facility/permit
candidate, RCRA permitted facility, permit withdrawal candidate,
RCRA permit denied or other, or facilities with underground
injection wells or clean-closed land disposal units with a RCRA
permit application or permit status, as above, and interim status
capacity process code for container storage, tank storage, tank
treatment or other treatment submitted on a Part A that has not
been found not to exist, or an incinerator submitted on a Part A
that has been verified as existing or not submitted on a Part A but
found to exist.
Generator handlers only, facilities that notified as large quantity
generators, have not claimed a RCRA nonregulated status, and
are presumed not to be involved in any treatment, storage or
disposal activity.
These facilities have had at least one Class I groundwater monitoring, closure/
post-closure, compliance schedule or landban violation which was discovered
by an evaluation conducted between October 1, 1986 and December 31,
1987.
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8
RETRIEVAL SPECIFICATIONS
To retrieve those facilities which met the above noncompliance definition,
the following retrieval specifications were established.
Land disposal facilities, as described above, where C305 equal to
D and C1105 not equal to 9
Treatment, storage and disposal facilities other than land disposal
facilities, as described above, where C305 equal to I or S and
C1105 equal to 1, 2, 4, 8, A, 0 or O or C305 equal to U or C and
C1105 equal to 1, 2, 4, 8, A, 0 or O and C1801 equal to S01, S02,
T01 or T04 and C1804 not equal to L and C1804 equal to B or R
• Large quantity generator handlers only, as described above,
where C303 fails and C305 fails and C1101 equal to 1
Class of violation (C2331) equal to 1 (Class I violation)
Date of Subsequent Evaluation (C2313) greater than or equal to
October 1, 1986 and less than or equal to December 31, 1987
and at least one of the following:
Indicator of Groundwater Monitoring violations (C2332)
equal to X (indication of one or more groundwater
monitoring violations and no releases) or B [violation/
releases in both the 'X' and 'R' categories were reported,
with 'R' being an indication that a release addressable by
3008(H) or state-equivalent authority was detected but no
violations were discovered]
Indicator of closure/post-closure violations (C2333) equal to
X (indication of one or more closure/post-closure violations)
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Indicator of one or more financial responsibility violations
equal to X or B (indication of one or more financial
responsibility violations)
Indicator of Compliance Schedule Violations (C2336) equal
to C (handler is not on schedule with a corrective action
compliance schedule in an order or a permit)
Indicator of Landban Violations (2339) equal to X or B (one
or more landban violations)
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10
FACILITY INDEX SYSTEM (FINDS)
Having met the specific noncompliance criteria defined above, facilities
from the three media databases were matched against FINDS data, using EPA
identification number (EPA ID) as the common link. A facility was defined by a
unique identification number. This was the EPA ID number, if one existed.
Where there was no EPA ID, a facility was defined by a unique NPDES number
in PCS or a unique State-County-Source number in CDS. Thus, for facilities
appearing in one or more media database(s) and also appearing in FINDS, the
unique identifiers are the EPA ID's; the names of these facilities are the FINDS
names (Tables 1,2,3 and 4).
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11
DISCUSSION
Table 1 (Significant Violators in Air, 102 facilities), Table 2 (Significant
Noncompliers in Water, 55 facilities), Table 3 (Significant Violators in
Hazardous Waste, 21 facilities) and Table 4 (Facilities Common to Two
Program Databases, 0 facilities) are produced by attempting to match facilities
by their EPA ID numbers. Lack of EPA ID numbers, particularly common in
CDS, hindered the identification of facilities in noncompliance in more than one
media. Facilities whose EPA ID numbers occurred in only one program
database, as well as those facilities without EPA ID numbers, appear in
Tables 1, 2 and 3. Facilities whose EPA ID numbers occurred in two program
databases appear in Table 4 (where applicable). Based on the match of EPA
ID numbers, no facilities occurred in more than one program database. The
results of the data integration process are represented graphically in Figure 2.
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DISTRIBUTION OF SIGNIFICANT
NONCOMPLIERS IN REGION VIII
MULTI-MEDIA VIOLATORS (MMV)
VS. OTHER VIOLATORS IN REGION VIII
HWDMS
21
NO MULTI-MEDIA
VIOLATORS WERE FOUND
IN REGION VIII
FIGURE 2
REGION VIII
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TABLE 1
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05/2S/H8
NONCOMPLIANCE PROFILE - REGION VIII
SIGNIFICANT VIOLATORS IN AIR
IO_NO STCOSRCE NAME
C00007057342 06U4O00006 AOOLPH COURS COMPANY
C009B12B4624 06022000046 AOULPH CUORS PAPER
4611600001B 4611HOOOOI" AJAX INC
WY0043608752 52070000002 ALLIEO CHEMICAL CORP GfcEEN
52230000005 52230000005 ALLSTATE (CT-T21)
UTD980374425 461 18000030 AMAX SPCCIALTY METAL
4601200001'. 46012000014 AMER I C AN CUMOO I T 11- S
UT0089492B54 46090000004 AMQCO OIL COMPANY
06006000005 06006000005 ANDERSON CONST.
NDD9B03309S5 35076000013 ANG COAL GASIMCATIN
35076060013 35076060013 ANI, CU&L GASIMCATIN
COD037539129 0600200000*1 ASAMFHA OIL INC
46008000015 4600800P015 H J FLUU«
43IB2000004 <>3ia200000« dAPNbS HAY f. t-ftO CD
«|6008000005
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^INCOMPLIANCE PROFILE - BFGKJN VIII
ID.NO
UTD070926B1 1
52046000020
NUD98n33l I* 1
NDU9803M 169
WY09B0375497
06096060003
PS164060023
4 11 14000010
46026000031
WY0094154499
52052000007
43064000002
52230000657
WY09B0375596
NDD08(1233470
WV0036016921
UT0009076415
UT0980374557
CP0980285449
CD0980285977
COO9HO?B5<»44
COD9B02B6059
COOOB14T0403
46122000050
46122080050
46100000007
ND09803M136
46090000115
46122000068
52230000634
46120000020
HT0001683580
MTUOB3709774
271 10060006
46122000052
46122000075
43064000001
06088000024
06088060024
06088090024
060B800002S
46028001001
461 18000001
UT0980374839
UT0039322B87
46122000066
UTD041308222
UTD007939424
STCOSRCE
460900000 10
520<-&00002n
35O700O0023
J5070060023
5202600UOOI
06096060003
061 64060023
431 14000010
46026000031
520?6000003
5205200000T
43064000002
52230O0065T
52070010002
351 34000004
52044010004
46090000049
46122000019
06184090003
06152000002
061H4 000003
06184000007
06180000009
461 22000050
46122060050
46100000007
351 14000001
460900001 15
461 2?00006B
522 30000634
461 20000020
27143000005
271 10000006
271 10060006
46122000052
46122000075
43064000001
06088000024
06089060024
060BU090024
06068000025
46028001001
461 18000001
46090000006
46023091001
46122000066
461 12000001
46122000057
SIGNIFICANT VIOLATORS IN AIR
MAME
KENNhCOT CJPPtK
KN ENERGY
KOCH - MCKEN/IE CNTV UAS PLANT
KOCH MCK GAS PLANT
LA PACIFIC RIVERTON
LA PACIFIC-KHEMMLING
LA PACIF IC-OLATHt
LITTLE RIVER LUMHER
LOMA* EXPLORATION
LOUISIANA PACIFIC - ULrrtGO" PL
MAhATHUN GAS PLANT
MIL8ANK ALFALFA P<00
NORTHERN IMP CT-22RA
PACIFIC PtL BRIOif-R
PHILLIPS TIOGA PLANT
PITTSBURG t MIDWAY
POHTLANO CFMtNT COMPANY 0
PROVO CITY POWER CO
PSC CU - COMANCHE
PUULIC s^Rvice co — CAMto STATI
PUBLIC SfcKVICE C'J — COMANCMfc
PUE.^LO MCTALS pRoces
RALSTON PURINA CO - PROTEIN PR
HAYLUC
PAYLOC
rtEOMONO CLAY t SAL T
RCYAL (JAK FNTFPPHISF
SALT LAKb StG
SAVAGE HKUS.
SCHbkcR BWOS CT-634
SIMPER LUM1ER
STAUFFtR CHEMICAL
STO'JE CUNTAINER
STONE C'JNTAINLR
SUNSFT RAIL
TfcLEFLEX
TWIN BROOKS ALFALFA
UNOCAL UPGRADE PLANT
UNOCAL UPGRADE PLANT
UNOCAL UPGRAUE PLANT
UNOCAL-RETORT
UPL HUNTINGTON
UT OEPT NAT RFSOURCE
UTAH MLTAL WORKS
UTAH POMER t LIGHT HUNTINGTON
UTAH VALLEY MED CTR
UTfcLITE CORP
W.ri. CLYDE CONST CO
CITY
MAGNA
CASPfcR
AKNtGAkU
AKNbGAKD
RIVERTUN
KKEM^LING
OLATHE
PItOMUNT
RURAL
OUBOIS
CODY
MILBANK
WHFATLANO
PUINT UF ROCKS
TIO(,A
KtMMERER
SALT LAKE CITY
PROVO
PUEBLO
PALISAOE
PUEbLL)
PIJF3LO
LAMAP
PAYSON
PAYSUN
RtDMONO
DICKINSON
PT. UF MOUNTAIN
AMERICAN FORK
CASPER
MAESF.R
SILVER BOM
MISSUULA
MISSUULA
LFHI
SPANISH FORK
TMIN BROOKS
PARACHUTE CREEK
PARACHUTE CRbEK
PARACHUTE CREEK
PARACHUTE CREEK
HUNTIMbTON
SALT LAKE CITY
SALT LAKE CITY
HUNTINGTON
PROVO
COALVILLE
SPRINGVILLC
STATE
UT
WY
NP
NU
WY
CO
CO
SI)
UT
wv
WY
SU
MY
WY
NO
HY
UT
UT
cn
en
cu
co
cn
UT
UT
UT
NO
UT
UT
WY
UT
MT
"T
IT
UT
IIT
SO
CO
CU
CO
CO
UT
UT
UT
UT
UT
UT
UT
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NONCDMPLIANCE PROMLF - Rb&lON VIII
ID.NO
UT00679BU912
46090000 Id 3
46090000184
460900001S4
$2043060002
S2042090002
MYD00708919(j
STCUSRCE
46100010002
46090001m 3
46090000184
46090000154
52042060002
52042090002
52042000002
SIGNIFICANT VIOLATORS IN Aid
NAMF CITY
WESTERN CLAY
WESTERN FIUEROLASS
WESTERN PIPE
WOLFF EXCAVATING
WYCON CHEMICAL
WYCON CHEMICAL
WYCON CHEMICAL COMPANY
AURORA
SALT LAKfc CITY
SALT LAKb
NQPTH BECK ST
CHEYENNE
CHFYENNE
CHFYENNE
STATE
UT
UT
UT
UT
WY
TOTAL NUMBER OF f-ACILITIES =
102
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TABLE 2
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NUNCOMPLI ANCE PROFILE - REGION VIH
NPDFS
SIGNIFICANT NONCOMPLIEKS IN »IATtR
CITY
STATF
C0n0121«.2051
SOD000951B73
C0r>073«i03610
SDOOOO0038<.5260
UTn000852079
SDD9BOnB7<.l5
C0l)0739802H186
UT0022365
UT002«,392
C0002l2«iS
COOOZ02t>'5
UT002097>3B
C0002hfa20
NDOOZObBl
UT002O095
C0003<<1<>2
ND0022870
COOOZl'i'tO
C00000230
SD002 )<•)<>
UT0000051
SD0020796
UT0000281
UT0020<>19
UT0020893
UT0020222
UT00217<>1
UT0021 717
C00001 I0UbN
CHAMBERLAIN
CLIMAX
COLORADO SPRINGS
COLUMBIA FALLS
CRAIG
CRAIG
CRAIG
CRAIG
CRAIG
CRAIG
COMMERCE CIIY
DENVER
DEVILS LAKE
OUCHESNE
CRAIG
FARGO
FT LUPTUN
EMPIPE
HURON
GARFIbLD
DbAUdOOD
HYRUM
MOAa
MORGAN
MORONI
SYRACUSE
PRUVO
COMMERCE CITY
BOULDER
RANL-FLY
RAPID CITY
RICHMOND
HOODS CROSS
rfOOOS CROSS
PARK CITY
SPANISH FORK
SAINT GEORGE
CU
SO
CO
SO
UT
UT
CO
CO
UT
UT
SO
CJ
CJ
MT
CU
CO
CU
Ci)
en
CM
C.I
CJ
Nfl
or
en
NU
cu
CU
so
ur
su
UT
UT
III
UT
UT
UT
CO
CO
CU
so
UT
UT
UT
UT
UT
UT
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NJNCDHPL1 AIMCE PKUFtLi - RtblON VIII
ID_NO
CUDOO07
CQ003n1832
SDGOOU281
C000217I7
MT00201R<>
MT0020S32
SIGNIFICANT NONCOMPLIERS IN WATER
NAMt CITY
bTANOARO MbTALS LUKP SUNNYSICE
TRINIDAO — CITY Of- MONUMENT LAK
UNITED POWER ASSOCIATIUN
USAF - ACADEMY
USAF - ELLSWORTH PASE - b«c
UStJOR-LEAOVILLF OHAIN TUNNEL
WHITFFISH--C ITV f)(-
WOLF POINT—CITY OH
S ILV/ER10N
THINIUAO
STANTON
COLGRADQ SPRINGS
RAPID CITY
LbAOVILLE
WHITLFISh
POINT
STAT6
CU
C'l
NU
CU
SD
CT
MT
"T
TUTAL NU^HfR UF FACILITIES -
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TABLE 3
-------
05/25/38
NONCflMPLIANCt PROFILE - rtkGION VI I I
SIGNIFICANT VIOLATORS IN RCRA
ID_NO
COU000694869
C00007057961
COD05
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TABLE 4
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INFORMATION I NT fcuit AT I ON - WESION VI II
, .-.- :• , • - , . .11 ••• -f ' ^t-f-.^-f
II) NUMnf
OiiAS- -
FINOS
HnU"S NAIF
PCS MAMfc -
CDS NAM1- -
OnAS1- CITY
RCMA -
WATrR -
A IR -
REPORT CONTAINS THfc FOLLOWING INFORMATION:
TH^ FPA 10 JUM-Jf-R IF AVAILABLE. IF NO tPA ID
NU*>tR IS AVAILAOLE. tITH = K THF NPt)tS NUMOE1 FROM PCS (IF THAT
FACILITY rfAS FOUND IN PCS), OR THE STATF-COUNTY-SOURCE CODE
FROM CDS (IF T.UT FACILITY V.AS FOUND IN CDS) IS DISPLAYED.
NAMt OF THF cPA OATA'USE F"QM WHICH THE ID
IN T-ir P^CVIUUS CULUMN WAS TAKEN.
THfc FINDS HACILITY NAMF (IF THAT FACILITY MAS
1-UU.MI) IN FIUOS)
THE FIRST TEN CHAKACTfcRS 'IF THb
FACILITY NA«1F (IF THAT FACILITY WAS FOUND IN HWDMS)
THE FIRST TfcN LHARACTFRS OF THE PCS FACILITY
NAMt (IF THAT FACILITY WAS FOUNT IN PCS).
THE I-IWST T = N LMARACTbRS OF THE CDS FACILITY
NAME (IK THAT FACILITY ^Aj FOUND IN CDS).
THE CITY WHICH APPhAKfcU I'J THF 04TAHASE
LlSTfcJ KJ THF 'DUASE1 COLUMN.
AN 'X1 IF THE FACILITY rfAS FOUND IN HHDMS
AN 'H- IF THE FACILITY HAS FOUND IN PCS
AN •*• If THE FAC1LT1Y WAS FHUND IN CDS
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F AC ILUUS WHICH MfcET NONC0MPLIAIMCE CRITERIA AND ARE CUMHDN TO PRDC.RAM DATABASES
ID NUMBER DBASE FINDS NAME HwOMS NAME PCS NAME COS NAME DbASF CITV RCRA WATER AIR
No facilities were found to occur In more than one program database.
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