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SEPTEMBER
1996
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FOR MORE INFORMATION ON THE
ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT,
CONTACT:
Judy Heckman-Prouty, EPA Region I
Telephone: (617) 565-3269
Facsimile: (617) 565-1141
E-mail: heckman.judy@epamail.epa.gov
Meg Kelly, EPA Headquarters
Telephone: (703) 603-7188
Facsimile: (703) 603-9167
E-mail: kelly.margaret@epamail.epa.gov
Craig Weeks, EPA Region VI
Telephone: (214) 665-7505
Facsimile: (214)665-7446
E-mail: weeks.craig@epamail.epa.gov
PREPARED FOR:
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Technology Innovation Office
Washington, D.C. 20460
and the One-Stop Reporting and
Public Access Project Team
WORK ASSIGNMENT NUMBER: 051
DATE PREPARED: September 11,1996
CONTRACT NUMBER: 68-W5-0055
EPA WORK ASSIGNMENT MANAGER: Meg Kelly
TELEPHONE. (703) 603-7188
PREPARED BY: PRC Environmental Management, Inc
PRC WORK ASSIGNMENT MANAGER: Patricia Reed
TELEPHONE: (703) 287-8845
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EXECUTIVE SUMMARY
IN JULY 1994, THE UNITED STATES (U.S.) ENVIRONMENTAL PROTECTION
Agency (EPA) announced the creation of the Common Sense
Initiative (CSI). Six industry sectors were chosen to begin the
initial phase of the initiative. In the petroleum refining sector, the
One-Stop Reporting and Public Access Project Team has
completed its project. This Executive Summary describes the
project team objectives, membership, the approach taken, the
results obtained, and the recommendations developed.
This Executive Summary was prepared by the project consultant,
PRC Environmental Management, Inc. (PRC), and reflects PRC's
observations. This document also is die product of successful
consensus-building and cooperation among a wide variety of
stakeholders representing government, environmental and envi-
ronmental justice organizations, community, industry and labor,
and other stakeholders. Project team members believe that much
can be learned from the process they adopted, and that their
findings, conclusions, and recommendations can lead
to real "common sense" changes that result in cleaner,
cheaper, and smarter environmental protection.
Additional information on the One-Stop Reporting and
Public Access Project, including the final report,
can be obtained from the resources identified on
the inside front cover of this document.
PETROLEUM REFINING SECTOR ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT
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EXECUTIVE SUMMARY
PROJECT
JliAiVI
Lois Epstein
Environmental Defense Fund
Karen Granata
Toledo Department of Public Utilities
Dennis Parker
Conoco
Mark Perry
Marathon Oil Company
Texas City, Texas
Wayne Roush
Shell Oil Company
Wilma Subra
Louisiana Environmental
Action Network
Steve Thompson
Oklahoma Department
of Environmental Quality
EPA SUPPORT STAFF
PROJECT CONSULTANT
Judy Heckman-Prouty
Meg Kelly
Craig Weeks
United States Environmental
Protection Agency
Patricia Reed
Carrie Capuco
Michael Rolen
PRC Environmental
Management, Inc.
One-Stop Reporting and Public Access Project
Sources
US Rettmvl CipiCBJi. Jiti. 19K
National P*K4«m.
1*92 TTGER/Ltt* Ffl«S
PETROLEUM REFINING SECTOR
ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT
Printed on Recycled Paper
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EXECUTIVE SUMMARY
COMMON SENSE INITIAII^E
ONE-STOP REPORTING;!
OVERVIEW OF THE
COMMON SENSE
INITIATIVE
IN JULY 1994, UNITED STATES (U. S.) ENVIRONMENTAL PROTECTION AGENCY (EPA)
Administrator Carol Browner announced the creation of the Common Sense
Initiative (CSI). CSI is EPA's highest-priority effort to implement the President's
regulatory reinvention mandate. CSI reflects EPA's commitment to setting strong
environmental standards, while encouraging common sense, innovation, and
flexibility in how standards are achieved. The goal of CSI is cleaner and cheaper
environmental protection, which may be achieved by modifying existing
environmental statutes, regulations, and policies or by developing entirely new
options. The approach is tailored to the specific concerns within an industry and
among stakeholders associated with that industry, in contrast to the "one-size-fits-
all" approach to environmental regulation that has been the norm in the past.
The objective in establishing CSI is to bring together representatives of federal
agencies; state and local governments; environmental and environmental justice
organizations; community, industry, and labor; and other stakeholders to examine
the full range of environmental requirements affecting industry. The six industry
sectors that EPA has chosen to begin the initial phase of this initiative are listed
below:
1. Auto assembly
2. Computers and electronics
3. Iron and steel
4. Metal finishing
5. Petroleum refining
6. Printing
For each industry sector, EPA formed a team of representatives from numerous
stakeholder groups. Teams are co-chaired by EPA Assistant Administrators and
Regional Administrators.
Elliott P. Laws, EPA Assistant Administrator for Solid Waste and Emergency
Response, and A. Stanley Meiburg, Deputy Regional Administrator for EPA Region
IV, are the current co-chairs of the Petroleum Refining Sector Subcommittee. The
subcommittee has 23 members, all of whom are appointed by Administrator
Browner.
The Petroleum Refining Sector Subcommittee at present has formed two project
teams:
E The Equipment Leaks Project Team addresses issues related to
loss of process fluids/vapors through equipment leaks.
E The One-Stop Reporting and Public Access Project Team
addresses regulatory reporting requirements that govern air
emissions and the public's access to and understanding and use
of the information provided in those reports.
This document focuses on the findings of the One-Stop Reporting and Public
Access Project.
PETROLEUM REFINING SECTOR
ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT
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EXECUTIVE SUMMARY
THE PROJECT TEAM CONDUCTED A PILOT PROJECT TO FACILITATE ANALYSIS OP A
"real world" scenario. The pilot facility was identified by soliciting volunteers
based on criteria developed by the project team. The Marathon Refinery in Texas
City, Texas was selected as the pilot facility for this project.
THE ONE-STOP
REPORTING AND
PUBLIC ACCESS
PROJECT
The Marathon Refinery is a medium-sized (capacity of 70,000 barrels per day
[BPD]) and middle-aged (1930s) petroleum refinery. It is located in an area whrre
the public had shown a willingness to participate in the project: the Texas City/
LaMarque, Texas area has an existing Community Advisory Panel (CAP) of local
residents that serves seven facilities in the Texas City area, including the Marathon
Refinery.
The goals of the pilot project are threefold:
Eliminate redundancy, duplication, and obsolescence in the
reports of air emissions.
Facilitate the access to and understanding and use of reported
data among the affected community.
Translate the results of the pilot project into issues to be
considered further and recommendations to the CSI Council.
The project focused on selected federal environmental (EPA) and Occupational
Safety and Health Administration (OSHA) and state (Texas) air emissions
reporting requirements (there were no applicable local requirements).
The project team was made up of representatives of many stakeholder groups,
including representatives of refining companies, staff members of state and local
environmental regulatory agencies, and members of local and national public
interest and community groups.
In addition to the members of the project team, several other groups of individuals
provided their advice and viewpoints during this project. Information was sought
from all those individuals, in addition to the project team, so that the observations
could be developed fully into options acceptable to most, if not all, stakeholders.
Those parties include:
r Staff of the Marathon Refinery
C The Texas City/LaMarque CAP and its facilitator
n Regulatory personnel of the Texas Natural Resource Conservation
Commission (TNRCC)
D Staff of EPA Headquarters, EPA Region VI, and the EPA Office of
Air Quality Planning and Standards
IT Staff of the American Petroleum Institute (API)
D Members of the Texas City/LaMarque community
PETROLEUM REFINING SECTOR
ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT
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EXECUTIVE SUMMARY
IN LATE NOVEMBER 1995, PRC (THE PROJECT CONSULTANT) BEGAN TO ASSIST THE
project team in implementing the One-Stop Reporting and Public Access Project. To
PROJECT achieve the goals of the project, the project team identified and implemented the
APPROACH following general approach:
E3 Solicit project team members who are representative of the
stakeholder community.
D Scope a narrow focus for the project and project approach.
D Enlist a pilot facility and communicate to that refinery the
incentives and parameters of the project and how EPA would
apply policies (such as enforcement) during the project period.
D Identify the members of the existing CAP and enhance, if
necessary, the membership to cover additional interested groups
to ensure that, to the extent possible, the representatives of the
community reflect the diversity of issues and needs in the
community.
D Meet with community representatives in the vicinity of the
Marathon Refinery to obtain their views on their information
needs and the degree to which they have access to and
understand and use the reported air emissions information.
D Conduct research on federal and state regulations that establish
reporting parameters for air emissions that are applicable to
refineries in general and to the pilot refinery in particular.
D Work closely with the Marathon Refinery to verify applicable
reporting requirements and obtain information on the practices
of and burden of fulfilling the reporting requirements.
D Develop a database to help organize, analyze, and classify the
reporting requirements for air emissions.
D Prepare and present status briefings to the community and
members of the CSI Subcommittee and Council.
D Document the procedures and processes applied throughout the
project to facilitate transfer to future endeavors.
D Develop observations and formulate recommendations that
incorporate information from the project team, the Marathon
Refinery, regulatory agencies, and representatives of the
community.
Q Prepare briefings and a final report.
PETROLEUM REFINING SECTOR ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT
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EXECUTIVE SUMMARY
SOLICITING
PUBLIC INPUT
ALTHOUGH THE REGULATORY ANALYSIS COULD BE CONDUCTED ACADEMICALLY TO
identify the areas of redundancy and overlap in the regulations, the project team
determined that the only way to identify public information needs and the
accessibility of the information that is currently available is to ask the community.
The project team benefited from the availability of the CAP as a means of
communicating with the community.
Consequently, with the assistance of the professional facilitator already associated
with it, the Texas City/LaMarque CAP was consulted about its information use
and needs with respect to air emissions reporting requirements. The CAP is
composed of both members of the community who work or have worked at the
local refineries and chemical plants and those who work or have worked in other
local businesses. The members include health professionals, financiers, engineers,
teachers, ministers, and representatives of many other groups. The CAP meets
monthly with several industry liaisons (facility management) to discuss issues of
interest to the local community that are directly affected by industry.
In March 1996, members of the project team attended a meeting of the CAP to which
several other individuals had been invited. For this project, the project team
realized that it was advantageous to include persons in the community who were
not currently serving as members of the CAP. That group was called the
Community Advisory Panel Plus (CAP+). The other individuals invited included
local emergency response personnel, state enforcement officials, representatives of
labor, representatives of local churches, and local environmental officials.
(However, representatives of labor and of local churches were not able to attend the
meeting.) At that March 1996 meeting, the project team discussed the access of the
CAP+ to air emissions reports and its understanding and use of that information.
Because the project was new to the CAP+, follow-up telephone calls were placed to
all who attended. From that information, combined with the information gathered
during the meeting, a set of preliminary observations about community access to
and understanding and use of air emissions reporting information was developed.
The preliminary observations then were presented to a larger group at a public
meeting hosted by the CAP+ in early June 1996. The opportunity to participate in
this project through the June meeting was advertised in local newspapers - both
Spanish and English; posted in flyers throughout the community; posted in the pilot
facility's newspaper and on bulletin boards; distributed by direct mailings to
community environmental groups; and offered in person, as flyers were distributed
door-to-door. In addition to the 15 to 20 CAP+ members, another four members of
the public who are not members or regular observers of the CAP attended the June
meeting. Their views were considered by the project team as findings and
recommendations were developed.
J_
PROJECT SCOPE
THE FOCUS OF THE PROJECT DELIBERATELY HAS BEEN KEPT NARROW. THE PROJECT TEAM
made a distinction between "reporting" and "recordkeeping" requirements related
to air emissions. Although some of the reporting requirements are met by drawing
on records that must be kept regularly, many more records must be kept at the
facility. Because the goals of reporting and recordkeeping differ, the participants
agreed that the pilot project would focus only on reporting requirements.
PETROLEUM REFINING SECTOR
ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT
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EXECUTIVE SUMMARY
The project team decided to identify and analyze not only environmental (EPA and
state) regulations that require air emissions reports to regulatory agencies, but also
applicable air emissions regulations promulgated by OSHA. These regulatory
reporting requirements include reports made to employees, as well as those made
to the appropriate OSHA authorities. Further, the analysis included only those
regulations that were determined to be applicable to the Marathon Refinery on
December 31,1995.
The project team discussed the difference between required air emissions reports
and required notifications (such as notification of startup). The group agreed that
the scope of the project would include notifications, in addition to periodic reports,
because the notifications contribute to the volume of paperwork submitted to
regulatory agencies.
The project team also agreed to categorize as reporting requirements tools
developed by state or local agencies, such as the Inspection Protocol Guidance (IPG)
report required by the TNRCC. Therefore, the three areas under review were
statutes, regulations, and guidance.
The project team agreed to the following exclusions: 1) accidental release
reporting under sections 311 (the Material Safety Data Sheet [MSDS]) and 312
(Emergency and Hazardous Chemical Inventory Forms) of the Superfund
Amendments and Reauthorization Act (SARA), and notifications required
under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) section 103(c) because they were beyond the scope of
this effort; 2) the asbestos National Emissions Standards for Hazardous Air
Pollutants (NESHAP) (40 CFR Part 61, Subpart M) because of its unique nature;
and 3) the requirements under development under CAA section 112(r), risk
management reporting, because the proposed regulation was expected to
change during the project.
SUMMARY OP KEY FINDIN&
f£J
KEY FINDINGS
FOLLOWING is A SUMMARY OF THE KEY FINDINGS AND RECOMMENDATIONS DEVELOPED
by the One-Stop Reporting and Public Access Project Team. These findings and
recommendations are based on the Marathon Refinery pilot project that addressed
specific federal and state environmental air emissions reporting requirements and
on input from the Texas City /LaMarque community where the Marathon Refinery
is located. The findings are presented in conjunction with the project goals to which
they are related.
ELIMINATE REDUNDANCY, DUPLICATION, AND OBSOLESCENCE IN THE
REPORTS OF AIR EMISSIONS.
Air emissions reports are required by statute and regulation for a number of
purposes, and stakeholders have different uses for the reported data. Purposes of
reporting air emissions data include:
PETROLEUM REFINING SECTOR
ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT
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EXECUTIVE SUMMARY
Ei Demonstrate compliance with federal, state, and local statutory
mandates to ensure the protection of human health and the
environment
U Provide information to the public
S Provide information necessary to ensure proper and
adequate federal, state, and local emergency prevention,
preparedness, and response
Air emissions reports are used by 1) industry, 2) regulators, 3) environmental
organizations, and 4) citizens. Uses of air emissions reports include demonstrating
progress in emissions reduction and providing facility performance information.
The regulatory environment affecting air emissions reporting in the petroleum
refining industry is complex. To conduct the regulatory analysis portion of the
project, a database was designed using Microsoft Access software. The
database was constructed by identifying 445 separate reporting tasks or
reporting requirements* that are outlined in federal environmental and OSHA
and in state of Texas air emissions regulations. (There are no local air
emissions reporting regulations for this refinery.)
It is important to note that while a "universal" list of 445 reporting requirements was
developed:
II Not all of those reporting requirements are applicable to any one
refinery, because requirements are contingent upon the type and
age of equipment used, and the types of processes undertaken at a
facility
H Statements regarding the number of reports prepared cannot be
made because the relationship between the number of reporting
requirements and the number of reports produced was not
examined
Once the "universal" database was developed, PRC worked closely with the
Marathon Refinery to identify and verify the reporting tasks that were
applicable to the refinery and a subset of reporting tasks was identified as
applicable to the Marathon Refinery. All subsequent analyses were con-
ducted by using the database of reporting tasks that apply to the Marathon
Refinery.
* For example, a quarterly report, required under the New Source Performance Standards (NSPS), Subpart J, 40 Code
of Federal Regulations (CFR) Part 60.1G7 (c) (1) through (6), mandates completion of such reporting tasks as. report
any 7-day period when the average emissions rate of sulfur dioxide emission standards were not met and report
any 30-day period when sulfur oxides data collection requirements were not met. Such reporting tasks are counted
separately in the database and in the analysis because they are distinct actions.
8
PETROLEUM REFINING SECTOR ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT
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EXECUTIVE SUMMARY
Analysis of this database resulted in the following general observations:
Approximately 51 percent (227) of the
air emissions reporting requirements
contained in the "universal" database
are applicable to the Marathon
Refinery, which is a medium-sized,
middle-aged facility.
Air Emissions Reporting Requirements
That Apply to Pilot Facility
Total = 445
Approximately 86.3 percent (196) of the
air emissions reporting requirements
applicable to the Marathon Refinery are
required under the Clean Air Act. The
remaining legislative drivers are: state
of Texas, 7.5 percent (17); SARA, 0.9
percent (2); the Resource Conservation
and Recovery Act (RCRA), 0.9 percent
(2); and OSHA, 4.4 percent (10).
Legislative Drivers for
Pilot Facility
Texa«7.5%(17)
SARA 0.9% (2)
i RCRA 0.9% (2)
* OSHA 4.4% (10)
Approximately 45 percent (102) of the
air emissions reporting requirements
applicable to the Marathon Refinery are
reported on a per-occurrence basis.
Approximately 38 percent (86) of the
requirements are reported on a regular
basis (5.3 percent annually, 26 percent
semiannually, and 6.6 percent
quarterly), and approximately
17 percent (39) are reported on a
one-time basis.
Report Frequency for
Pilot Facility
Regular
Basis'
38% (86)
•5.3% (13) Annually
26% (59) Scmbnnually
6.6%(15)0u«t1arty
Each
Occurrence
45% (102)
One Time
17% (39)
Total =227
Many of these reports are submitted to demonstrate compliance. However, if a facility is in
compliance, such reporting may be viewed as unnecessary. Alternatives should be explored to
identify other options for demonstrating compliance and goodwill. Other findings regarding the
process of regulatory reporting include the following, which have not been prioritized:
PETROLEUM REFINING SECTOR
ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT
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EXECUTIVE SUMMARY
| In the opinion of the Marathon Refinery environmental coordinator, three main
JL environmental air emissions reports are the most time-consuming to prepare: the
annual TRI, the annual report prepared in response to the TNRCC Inspection
Preparation Guidance (IPG), and the annual state emissions inventory. Two of
these three most time-consuming reports appear to be used by regulators, and
the TRI is used by the public (but to a limited extent by the Texas City public).
The project team noted the inverse relationship between the relative percentage
of requirements imposed on the pilot facility under SARA Title HI (0.9 percent)
and under the Clean Air Act (86.3 percent) and their respective use by the
public.
jThe EPA project consultant and refinery were unable to easily conduct a
i« comparative analysis of the cost (regulatory burden) of completing
environmental air emissions reporting requirements, using EPA estimates
developed when the regulations were established and estimates of actual
experience provided by Marathon Refinery staff. Therefore, this pilot project
demonstrates that it would be extremely difficult to compare with any degree of
accuracy the actual regulatory burden with EPA estimates.
3j There is vast inconsistency regarding timing and frequency of reports,
J which leads to confusion on the part of the pilot facility and additional time and
resources expended to comply with the varying frequency of report requirements.
The age of equipment currently contributes to the regulatory requirements that
> apply. (For example, over time, separate regulations were developed to address
tanks having different construction dates, which is confusingfor facilities that have
numerous tanks of various ages.) It is not apparent why this age issue needs to
continue to be addressed through separate regulations.
analysis of air emissions reporting regulations led to the conclusion
that the air emissions regulatory reporting requirements exhibit less
redundancy and more complexity than originally anticipated. However, it
should be pointed out that a thorough analysis and review of the Marathon
Refinery's files was not conducted to identify all cases of redundancy.
FACILITATE THE ACCESS TO AND UNDERSTANDING AND USE OF
REPORTED DATA AMONG THE AFFECTED COMMUNITY.
Presented below are comments gathered from the CAP+ meeting and the
community meeting held in Texas City, Texas. During the two community
meetings, some members of the community expressed the following views,
which have not been prioritized:
1 The Texas City/LaMarque CAP, with its neutral facilitator, may be able to
1, help the public understand and have access to air emissions data reported by
the refinery. For example, the annual TRI data summary report is prepared
by local industries and presented to the CAP.
^ Some members of the community have a desire to receive air emissions
^information in terms of how such emissions affect their health.
10
PETROLEUM REFINING SECTOR ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT
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EXECUTIVE SUMMARY
The current regulatory reporting system does not provide a comprehensive
view of air reporting at the facility. There appears to be a great deal of
information on air emissions from specific units, but the system does not
require comprehensive and consistent reporting on the entire facility.
The air emissions information currently reported may not be in a form
understood by and readily available to the public.
Some members of the community are generally more interested in episodic
events that impact the community. However, the public may not be aware of all
episodic events that have occurred.
Some members of the community are interested in obtaining release information
I that currently is reported to regulatory agencies but is not part of the Toxics
Release Inventory (TRI).
TRANSLATE THE RESULTS OF THE PILOT PROJECT INTO ISSUES TO
BE CONSIDERED FURTHER AND RECOMMENDATIONS TO THE
CSI COUNCIL.
The project team developed the following recommendations, which have not been
prioritized:
'! Test the Microsoft Access "universal" database of air emissions reporting
I requirements with interested parties. Issues to be resolved in implementing the
pilot project include:
ffl Maintaining current regulatory data
H Offering electronic access on the Internet
H Developing an appropriate designation for the tool,
such as guidance
2 Develop and test at a pilot facility a new air emissions reporting system that is
sector-based. Such a new system would be based upon a semiannual status
report that would record accomplishments over the past six months and project
planned activities for the coming six months. Issues to be resolved in
implementing the pilot include:
H Formats (the report could be broken down in different ways,
such as by tanks or fugitive emissions, or could be in checklist
or "fill-in" format similar to that of tax forms)
Hi Types of report requirements (such as separate reports for
routine or periodic reports and episodic reports, as designated)
H Schedule (to ease the regulatory agency's burden of review, a
revolving schedule could be developed for industries so that
different six-month intervals are assigned to different refineries)
11
PETROLEUM REFINING SECTOR ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT
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EXECUTIVE SUMMARY
H Public accessibility (solicit public input on the format and content
of the report and identify ways to make the information accessible,
such as on the Internet)
j Develop a pilot project that addresses multi-media regulatory reporting
J requirements for a petroleum refinery.
During this project, the project team identified several logical follow-on efforts, which
have not been prioritized:
@ Create consolidated reporting requirements for refineries to ease the burden on
industry while providing the same level of environmental protection and
needed information to regulators and the general public.
H Address the inability to compare the EPA estimates with the actual reporting
burden.
1 Evaluate whether there could be better indicators (or one indicator per facility)
of health effects for the public.
B Improve the way new regulatory requirements are established: do not write
regulations in a vacuum, and consider the results of the pilot project to avoid
creating an even more complex regulatory structure.
H Provide the CSI Council a list of lessons learned on this pilot project to facilitate
information transfer to other groups and efforts. (Lessons learned include
involving multiple stakeholders, using a real facility in an evaluation, and
keeping the approach and scope simple).
H Consider selecting one electronic format that does not change from year to year.
Facilities invest in changing formats and systems, and men the requirements are
altered by regulatory agencies.
II Evaluate whether there are other ways to make regulatory agencies comfortable
with the compliance status of facilities. Assess programs and approaches such
as the Environmental Leadership Pilot (ELP) Program and self-audits.
PETROLEUM REFINING SECTOR
12
ONE-STOP REPORTING AND
PUBLIC ACCESS PROJECT
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Hold Kick-off
Meeting with
Marathon
Refinery Staff
Begin Data
Collection and
Analysis
to
1
Continue Data
Collection and
Analysis
J
Meet with
Community
Advisory Panel
Present Preliminary
Findings
Refine Preliminary
Report
Refine Findings
and Draft Report,
Obtain Input
from Expanded
Audience
Present
Findings to Petroleum
Refining Sector
Subcommittee
*Y Revise Draft Report,
\ V Prepare Draft
if; s Executive
^\ Summary
Finalize Report and
Executive Summary,
Present Findings to
CSI Council
Implement
Recommendations
D
Implement
Recommendations
* The project team met all deadlines, and plans to implement
recommendations in late 1996 and in 1997.
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