UST Program Compendium
ci p 1 Protection Agency
Storage ‘i an
1M’th 1991
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çID 8r4 1 ,
UNITED STATES ENVIRONMENTALPR0rECTI0N AGENCY -
______ WASHINGTON D C 20460
1. —..—-
-4 ’
4 PRO1V’ -
— ; ‘C: f O
JAN 231996
MEMORANDUM OFFICE OF
- SOLID WASTEANDEMERGENCy
\ SUBJECT: UST and LUST Trust Fund Compendiums Update RESPONSE
FROM: Shushona C1I’ ’ -’ L&i’iJ
cvf’ i Office of Underground Storage Tanks
TO: Addressees .— I
// 1 -’ 4 - — r ’ -
/,“Attached you will find two sets of the latest updates for the conipendiums. The second
df of updates are for your 1 egional Counsel compendiums. Theè üpdates include documents
Pissued through November 3, 1q95. There are a total of two docunlents that need to be added to
your compendiums. You will’also find revised tables of contents and abstracts lists.
If you have any quest ons about your updates, please contact me ai .o8sg or refer
to your April 1991 introduction to the UST and LUST Trust FundCompendiums
Attachments:
Andrea Beland Ri
Derval Thomas R2 ‘
Rose Nino R3 , ,
GloriaLove R4 1 L ’ ‘ f
Vera Conwell R5
Timber Wynn R6
Lee Danials R7
Theresa Bahrych R8
Larry Woods R9
Vicky Stansbury RIO
John Heffelfinger. HQ t With only J. UST Trust Fund updates
Mimi Newton HQ With only one set of updates
Lee Tyner HQ *With only one set of updates
Jane Souzon HQ *With only one set of updates.
() i Recycled/Recyclable
Punted wIth SoylCenola Ink on paper tl.at
cont ne al Iea 50% uecyded fiber
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Table of Contents44’ ’
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/)14- ’4J 2 DPj £
, ‘ZIi— -‘ - --
UST PROGRAX COXPENDIUX
Title Date
PROGRAM X NAGEXENT
Grant Guidance
FY92 State UST Program Grant Guidance 5/29/91
FY91 State UST Program Grant Guidance 3/30/90
(OSWER Directive 9630.6)
Workload Xod.1s -
UST Work - a - Budget* 6/89
Revisions to the FY 1990 Workload Model 2/21/89
Reporting
FY95 Fourth Quarter UST Activity Reports 11/3/95
FY95 Third Quarter Activity Reports 8/8/95
FY95 Second Quarter Activities Reports 05/22/95
FY95 First Quarter Activities Reports 02/03/95
FY94 Fourth Quarter Activities Reports 11/08/95
FY94 Third Quarter Activities Report 07/29/94
STARS and 3rd Quarter Activities Reports 8/21/92
FY94 Second Quarter Activities Report 05/13/94
FY94 Correction to First Quarter Activities 03/23/94
Report
FY94 First Quarter Activities Report 03/22/94
FY93 Fourth Quarter Activities Report 11/23/94
Deletion and addition of FY 1992 STARS Measures 1/2/92
Final Draft FY 1993 Agency Operating Guidance 1/2/92
Leak Detection Measures and Definition for FY 92 11/22/91
1 (01/23/96)
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Title Date
PROGRM( X 1 G ENT (continued )
Reporting
Annual Underground Storage Tank Survey 1991 7/3/91
P1—90 SPMS 12/21/89
Final Definitions for Measures of National 9/26/89
Program Progress
Final FY 1990 SPMS Measures and Responsiveness 2/1/89
Summary
Final Fl 1989 Agency Operating Guidance and 2/23/88
SPMS Measures
Program Goals and Progress
UST/LUST Program Strategic Framework (Final draft) 4/27/93
Development of Regional Action Plans for Fl 1993 8/11/92
Fl 1992 Final Operating Plan 2/7/92
Fl 1994—97 Strategic Plan for the Office of. 2/4/92
Solid Waste and Emergency Response
Final Criteria for Approval FY92 Regional State 10/18/91
Improvement Projects and Final UST/LUST Goals
in Priority Program Areas
OSWER Annual Report, Fl 1989 3/90
OSWER Strategic Plan, Fl 1992-1995 11/30/89
Transition Tasks Lists 1/30/89
(OSWER Directive 9610.5—1)
OUST Strategic Plan (Draft) 9/88
Fl 1989 - Fl 1990 Transition Strategy for the 4/1/88
Underground Storage Tank Program
(OSWER Directive 9610.5)
2 (12/13/95)
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TE ICAL
General
Revision of the Compendium of OUST’S Written 2/19/93
Interpretations
Request for Leak Detection Exemption or Deferral 11/18/92
for EXXON Dehydration Facility
Sununary’and Compendium of OUST’S Past Written 10/31/91
Interpretations of Technical Regulations
Releases
Petroleum Tank Releases Under Control: A 6/89
Compendium of Current Practices for State UST
Inspectors
Corrective Action
UST/LUST National Native American Lands 7/7/93
Policy (OSWER Directive 9610.15)
Interim Guidance for Conducting Federal-Lead 7/31/89
Underground Storage Tank Corrective Actions
Petroleum Releases on Indian Lands
(OSWER Directive 9610.9)
Guidance for Conducting Federal—Lead 7/25/88
Underground Storage Tank Corrective Actions
(OSWER Directive 9360.0—16a)
Cleanup of Releases from Petroleum USTs: 4/88
Selected Technologies
‘Leak Detection
Regulatory Interpretation: Leak Detection 10/5/92
Exemption or Deferral for Exxon Dehydration
Facility
Questions and Comments Regarding Leak 7/2/92
Detection Issues
3 (12/13/95)
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Title Date
A Technical Update on “Catastrophic” Line Leak 8/14/91
Detectors and the UST Regulations
TECHNICA l 1 . IContinued
Leak D.t.ction
What Constitutes the Portion of the Underground 7/25/91
Tank that “Routinely Contains Product”
Automatic In-Tank Monitors 6/26/91
FINANCIAL RESPONSIBILITY
Guidance
Final Guidance Entitled: Monitoring the Financial 8/12/93
Soundness of Approved State Assurance Funds
(OSWER Directive 9650.14)
Final Guidance for Reviewing State Funds for 11/17/&9
Financial Responsibility
teaX, /,. 9/p;z
STATE PROGRAM APPROVAL
Guidance
State Program Approval Handbook 3/89
(OSWER Directive 9650.8)
Suggested Procedures for Review of State 3/89
UST Applications
(OSWER Directive 9650.9)
0 T LE 7% 5r 4 P oa q#i A-,j. r &’ c _
Targeted Improvement Projects (TIPs)
Fl 1991 Regional State Improvement Projects 7/28/92
Compendium
Approval of Fl 1992 Regional State Improvement 1/30/92
Projects
TIPS for Fl 1990 2/15/90
TIPS Compendium • 1988—90
TIPs for Fl 1989 12/16/88
4 (12/13/95)
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Recent Court Decisions Related to USTs 12/8/92
UST Federal Field Citation Enforcement 4/9/92
(OSWER Directive 9610.4)
Guidance for Federal Field Citation Enforcement 3/20/91
(OSWER Directive 9610.13)
Final U.S. EPA Penalty Guidance for Violations 11/14/90
of UST Regulations
(OSWER Directive 9610.11)
UST/LUST Enforcement Procedures Guidance Manual 7/90
(OSWER Directive 9610.11)
Fl 89-90 Compliance and Enforcement Strategy for 1/5/89
the UST Program
(OSWER Directive 9610.8)
5 (12/13/95)
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lIST P’SDGS M QENDUS(
Abitracta
Titi . [ Abat áàt1 Dat .
Grant Quidanes
F! 92 State UST Program Grant Guidance 5/29/91
(Provides criteria and procedures for allocation of
grant funds for State underground tank program
activities in F! 92.]
F! 91 State UST Program Grant Guidance 3/30/90
(Provides criteria and procedures for allocation of
grant funds for program activities in F! 1990.1
Workload Mod.ls
UST Work-a-Budget 6/89
(Provides case information to use in developing a
State UST program budget.]
Revisions to the FY 1990 Workload Model 2/21/89
(Explains workload model to be used in distributing
FTEs to Regional Of fices.]
Reporting
FY95 Fourth Quarter Activities Report 11/03/95
(Provides the Fourth Quarter F! 1995 corrective
action and leak detection resports activities.]
FY95 Third Quarter Activities Report 08/08/95
(Provides the Third Quarter FY 1995 corrective
action and leak detection reports activities.]
FY95 Second Quarter Activities Report 05/22/95
(Provides the Second Quarter F! 1995 corrective
action and leak detection reports activities.]
FY95 First Quarter Activities Report 02/03/95
[ Provides the First Quarter F! 1995 corrective
action and leak detection reports activities.]
FY94 Fourth Quarter Activities Report 11/08/94
(Provides the Fourth Quarter FY 1994 corrective
action and leak detection reports activities.]
1 (12/13/95)
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Title tAbstracti Date
PROGRAM ) GRM NT (continued )
Reporting -
FY94 Third Quarter Activities Report 07/29/94
(Provides the Third Quarter Fl 1994 corrective
action and leak detection reports activities.]
FY94 Second Quarter Activities Report 05/13/94
(Provides the Second Quarter FY 1994 corrective
action and leak detection reports activities.]
FY94 Correction to First Quarter Activities Report 03/22/94
(Provides the First Quarter FY 1994 corrective
action and leak detection reports activities.]
FY94 First Quarter Activities Report 03/22/94
(Provides the First Quarter Fl 1994 corrective
action and leak detection reports activities.]
FY93 Fourth Quarter Activities Report 11/23/93
(Provides the Fourth Quarter Fl 1994 corrective
action and leak detection reports activities.]
STARS and 3rd Quarter Activities Reports 8/21/92
(Provides the third quarter Fl 1992 corrective action
and leak detection reports activities.]
Deletion and Addition of Fl 1992 STARS Measures 1/2/92
(Explains changes in the leak detection compliance
and enforcement measures.]
Final Draft FY 1993 Agency Operating Guidance 1/2/92
(Provides the final draft language for the UST
program for the Agency operating Guidance and STARS
measures.]
Leak Detection Measures and Definition for Fl 92 11/22/91
(Reporting forms and definitions for leak detection
activities.]
Annual Underground Storage Tanks Survey — 1990 7/3/91
(Explains how the annual survey is to be conducted.]
2 (12/13/95)
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Titi. (.Abatz.ctj - Dat
PBOGRN ) 1IAQ NT (continu .d )
R.porting
FY90 SPMS 12/21/89
[ Correction of SPMS and Quarterly Activity
Reporting Forms — December 7, 1989.1
Final Definitions for Measures of National Program 9/26/89
Progress
[ Defines measures used to evaluate program progress.]
Final F? 1990 SPMs Measures and Responsiveness Summary 2/1/89
(Outlines SPMs measures to be used for F? 1990 and
responds to Regional comments.J -
Final F? 1989 Agency Operating Guidance and SPM5 Measures 2/23/88
(Final version of UST portion of Agency Operating
Guidance.]
Program Goals and Progr.ss
UST/LUST Program Strategic Framework (Final Draft) 4/27/93
(provides the Final draft language to develop
strong state and local programs.]
Development of Regional Action Plans for FY 1993 8/11/92
(Suggested analytical approach for developing
Regional Action Plans.]
F? 1992 Final Operating Plan 2/7/92
[ Provides the UST and LUST program appropriation
to the Regions.]
F? 1994 — 97 Strategic Plan for the Office of Solid Waste 2/4/92
nd Emergency Response
(Presents OSWER’s long term strategic plan including
success measures.] I
OSWER Annual Report, FY1989
(Pages 34 — 41 included. Reports current status of
UST program and activities undertaken by OUST in
most recent fiscal year.]
3 (12/13/95)
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Titi. (Abstract) Data
PROGP.M4 NAGfl NT (continu.d )
Program Goala and Progr.as
OSWER Strategic Plan, FY 1992 — 1995 11/30/89
(Pages 53 - 55 included. Describes UST program
activities in relation to OSWER long—term plan.]
Transition Tasks Lists 1/30/89
(Identifies activities to be undertaken by the
implementing UST agency.]
OUST Strategic Plan (DRAFT) 9/88
(Long-range plan outlining OUST 1 5 role in
implementing the national UST program. DRAFT]
Fl 1989 — Fl 1990 Transition Strategy for the Underground 4/1/88
Storage Tank Program
(Identifies activities to be undertaken as UST
program shifts from regulatory development to State
implementation.]
TEC iICAL
General
Revision of the Compendium of OUST’s written interpretations 2/19/93
Summary and Compendium of OUST’S Past Written 10/31/91
Interpretations of Technical Regulations
(Provides technical interpretations in question
and answer form. Also has associated letters and
memos from which the questions and answer are
based upon.]
Leak Detection Exemption or Deferral for Exxon 11/18/92
Dehydration Facility
(Request for input on the technical and regulatory
interpretation on leak detection procedures.]
Rleasea
Petroleum Tank Releases Under Control: A Compendium of 6/89
Current Practices for State UST Inspectors
(Provides assistance to States in training UST
inspectors and identifies ways to evaluate options
for controlling UST releases.]
4 (12/13/95)
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Title (Abstract) Date
TECIDIICAL (continu.d )
Corrective Action
UST/LUST National Native American Lands Policy 7/7/93
[ Provides guidance concerning the implementation
of the UST/LUST program on native american lands.
Interim Guidance on Conducting Federal-Lead Underground 7/31/8 9
Storage Tank Corrective Actions for Petroleum Releases on
Indian Lands
(Outlines responsibilities and acflvities to be
undertaken in carrying out Federal response to
releases on Indian lands.]
Guidance for Conducting Federal-Lead Underground storage 7/25/88
Tank Corrective Actions -
(Provides guidance with regard to approval,
funding, and managing Federal-lead corrective
actions.]
Cleanup of Releases from Petroleum USTs: Selected 4/88
Technologies
(Provides information on costs, efficiencies,
and limitations of UST corrective action technologies.)
Leak Detection
Request for Leak Detection Exemption or Referral 10/5/92
for Exxon Dehydration Facility
[ Response on leak detection exemption or
deferral for Exxon dehydration facility.]
Questions and Conunents Regarding Leak Detection 7/2/92
Issues
(Provides technical interpretations for leak
detection questions from Region 10.]
A Technical Update on “Catastrophic Line Leak 8/14/91
Detectors and the UST Regulations
[ Provides clarification on the requirements
fo line leak detectors according to EPA’s
regulations.]
5 (12/13/95)
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Titi. (Abatractj Dat
TECENICAL (eont.tnu.d )
L•ak D.t.ction
What Constitutes the Portion of the Underground 7/25/91
Tank that “Routinely Contains Product”
(Provides clarification for EPA leak detection
requirements on what constitutes the portion of an
underground tank that “routinely contains product”]
Automatic In—Tank Monitors 6/26/91
(Provides clarification on an in—tank in the test
mode serving as a precision test.]
YINMJCIAL RISPONSIBILIT !
Guidancs
Final Guidance Entitled: Monitoring the Financial 8/12/93
Soundness of Approved State Assurance Funds -
(OSWER directive 9650.14)
(Provides guidance to EPA Regional Office regarding
monitoring state assurance funds that have been
approved by EPA to act as financial responsibility
compliance mechanisms for owner and operators of
underground storage tanks.]
Final Guidance for Reviewing State Funds for Financial 11/17/89
Responsibility
(Outlines criteria to be used in approval of State
financial responsibility funds.]
STATS PBOGRN APPROVAL
Guidanc
State Program Approval Handbook 3/89
(Provides guidance to staff involved in State UST
program approval.]
Suggested Procedures for Review of State UST Applications 3/89
(Outlines criteria to be used in evaluation
of State program approval applications.]
6 (12/13/95)
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Title (Abs tractj Date
STATE PROGRAM APPROVAL (continued )
Targeted Inprov. nt Projects (TIP.)
F? 1991 Regional State Improvement Projects 7/28/92
Compendium
(Provides list of projects and one page summaries
of each. Formerly known as TIPs.)
approval of FY 92 Regional State Improvement Project 1/30/92
[ Outlines process for approval of state improvement
projects. Does not include Region specific
attachment one.]
TIPS for F? 1990 2/15/9p
(Outlines procedures for using TIPS funds for F?
1990.]
TIPs Compendium 1988—90
(Summaries of all TIPS to date.)
TIPs for F? 1989 12/16/88
(Outlines procedures for using TIPS funds for F?
1989.]
ENTOR NT
Favorable Memorandum Opinion and Order re: Citizen Suit for 12/8/92
Leaking Underground Storage Tanks Containing Petroleum: Zands
vs. Nelson (II) , (S.D. Ca].. 1992
(Provides summaries of two recent court decisions
related to the regulations of USTs.
UST Federal Field Citation Enforcement 4/9/92
[ Provides a revised guidance on using federal
field citations as an enforcement tool.]
Guidance for Federal Field Citation Enforcement 3/20/91
[ Provides guidance on using federal field citations
as an enforcement tool.]
Final U.S. EPA Penalty Guidance for Violations of UST 11/14/90
Regulations
(Provides guidance on calculating civil penalties
against violators of UST regulations.]
7 (12/13/95)
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Titi. (Abstract I Dat
ENTOR IT (Continud )
UST/LUST Enforcement Procedures Guidance Manual 7/90
(Provides guidance on taking enforcement actions
against violators of UST regulations.]
Fl 89—90 Compliance and Enforcement Strategy for the UST 1/5/89
Program
(Presents the strategy for compliance and
enforcement for the UST program.]
8 - (12/13/95)
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Prsjrs4ea1 so fl-. niae
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UST/LUST PROGRAM
STRATEG IC FRAM EWORK
FINAL DRAFT
APRIL 27, 1993
UST/PN/PG/93- I
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QUESTIONS ABOUT ThE DRAFT STRATEGIC FRAMEWORK
0. Whit Is th. purpose of the USTILUST Program Strategic Framework?
A. To establish a common understanding about 1) what EPA Is trying to accomplish in its work with State an
local UST/LUST programs, 2 how we generally intend to do it, and 3) how we’ll measure progress. It also should
be helpful in explaining the program to the new political leadership in EPA, to other EPA and State managers and
staff, Congress, and other customers.
0. What’s included in the framework?
A. There are brief statements of program mission and overall strategy. Then for each priority area there are goals.
strategies, and progress indicators. Again, these are just ways of saying what we are trying to do, how we will do
it, and how we will measure progress.
0. What priority areas are covered?
A. Leak detection compliance and enforcement, corrective action streamlining, and State program approval have
been EPA’; j rioritiea for several years. The framework also includes a section on preparation for the 1998
compliance deadline, which EPA is beginning to plan for.
0. Is there anything really new here?
A. Most of t tc n tn frei work should be very familiar to people who’va been around the orn ram for the
last few years, although this may be the iivsi time they’ve been pulled together in one pl ’- gram
progress Indicators are a new concept, but again, the Ideas ate . new.
0. What are program progress Indicators?
A. They are chöckJist of items for gauging the progress that States are making In gotting their programs
apo’ ed, streamiining weir c s ”a oet3*’ prograr , us uuilding strong leak detection compliance and
enforcement programs. Re&ong would probably apply the indicatora once a year, such as before grant
negotiations, in order to acknowledge improvements and diagnose the States’ assistance needs for the coming
year. Our intention Is that this wiU not rquire any additional reporting by States.
0. What is the purpose of these indicator;?
A. First, they will help establish s shared understanding of th. elements of a high-quality State program in our
priority arese, Secor.d, they will helo Regional Offices and Headquarters Identify assistance needs. Third, they
diii heip Headquarters assess and cori municate to Congress and others the progress of the national program.
.0 States already submit a tot of d: . o EPA on corrective action and leak detection enforcement activities. Isn’t
that enough for EPA to gc. y in assessing progress?
A. The numbers can be usoful In assessing trends over time, but can’t be the sole buls for characterizing
performance. A mix of qusBiativo and quantitative factors Is more useful for EPA and, if It helps us get more
support from Congress and provide better assistance will ultimately be more helpful to the States.
0. Does this signal a change in EPA. phiosophy for the program?
A. No. Our program Is succeeding because of Its unique approach—State-lead with EPA support, flexible, and low
in reporting requirements—and these things shouldn’t change. It signal the reality that our program is going
to be in tough competition for limited resources In the 1990’s. We may need to incrementally change our
management systems In order to be clearer about our long-term direction, more skillful In targeting our
improvement efforts, and mors effective In communicating results.
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r ‘:i .-,nmer tal problem In the United States.
j Strong State and local programs — Success can only be achieved through effective
on by State and local USTIt.UST programs. EPA must build or improve program capacity and
nitor progress.
.‘rovlde flexlbllfty — The program must be flexible In how States and locals achieve program
coals and how owners and operators meet program requirements.
3. StrIve for constant Improvement — EPA. States, and locals should constandy examine and
improve their work processes to improve program quality. Similarly, EPA and States and locals
should create a climate conducive to develop and encourage use of improved UST-related
technologies and practices by the private sector.
4. RecognIze and share successes EPA should foster information exchange on effective State
and local program practices in order to accelerate Improvements and avoid rework.
GOALS. STRATEGIES. AND INDICATORS
I. CORRECTIVE ACTION STREAMUMNG
A. Corrective Action Streamlining Goal - Scientifically-sound, rapid, and coat-effective action at all
UST release sites requiring corrective action through the use of streamlined processes, effective
technologies, and Improved cross-program coordination.
B. Corrective Action Strsantiinkig Strategy:
1. Constantly examine and Improve State administrative and oversight processes to reduce
waste and delays.
• EPA wIE promote development of State and local guidance and oversight systems
that allow fast action on all sites while focusing oversight on those posing highest
risk. Fast action at low-risk sites may include rapid determination that no active
remedlation is necessary.
• Ares priority for EPA assistance Is to ensure that all States and locals have
processes in place and that they work.
• Longer-term . frons should strive for Improvements In process efficiency and
effectiveness.
2. Promote routine use of non-traditional technologies for site assessment and remediatlon
through demonstration prolects, information exchange. and outreach while minimizing
transfer of contamination from one media to another. EPA will focus on broader use of
technologies that are proven but currently used on a limited basis.
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2
3. Oversee and support Stats financial assurance funds. EPA must monitor State funds to
ensure that they remain effective as approved FR mechanisms and achieve cleanups.
Additionally EPA will help States us. their funds to meet other program objectives:
speeding up action at all sites, reducing cleanup costs, promoting Improved technologies.
monitoring and promoting compliance with prevention requirements, etc.
C. Corrective Action Progress Indicators — The following indicators will be used to assess State
progress in streamlining corrective action programs.
— Adequate statutory and regulatory authority
— Documented processes
— Prioritlzation system that Is documented and used
— Regularly taking enforcement actions
— Adequate staff training
— Data management capability to retrieve site-specific data
— Clear written guidance for o/e’s
— Regular outreach to consultants
— Generic enforcement documents available to staff
— Ongoing streamlining efforts
— Effective, non-traditional technologies routinely allowed
— Action without CAP allowed at low-risk sites
— State funci processes encourage timely corrective actions
U. LEAK DETECTION COMPUANCE AND ENFORCEMENT
A. Leak Detection Compliance and Enforcement Goal — Owners and operators routinely and
correctly monrr r all r quiou - ‘ nks and piping for leaks In accordance with the regulations.
B. Leak Ce ... .. .ompllanc and Enforcement Strategy
1. Full complianc, will require strong Stats and local compliance and enforcement programs.
In the long run, each State provides an adequate field presence by using well-trained
—inspectors with the authority and ability to build formal enforcement cases in addition to
field citations.
2. In States unable to develop strong Inspection programs In the near term, EPA will sssist
In the development of alternative compliance mechanisms, including tank tagging or
permitting programs, compliance mailings or other targeting methods, end tying State
cleanup fund eligibility to compliance with technical standards.
3. Direct Federal enforcement will focus on tanks in States with low or Ineffective compliance
and enforcement activity and should be targeted. EPA will emphasize the use of field
citations end use formal enforcement where necessary.
4. EPA will promote the technical effectiveness of leak detection technologIes. EPA wilt
Increasingly rely on consensus code-making bodies to evaluate and regulate (through codes,
standard practices, and protocols) the technical effectiveness of leak detection methods.
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C. Leak Detection Progress Indicators — The following indicators will b. used to assess State and
local progress In developing strong leak detection compliance and enforcement programs.
— Functional databas.
— Recent inventory update
— Outreach to all ol e ’s
— Technical assistance to ole’s
— Sufficient authorities, procedures, & activity to meet State Program
Approval enforcement objective
— Effective compliance monitoring activity
— Effective level of field presence
— Targetinglprioritizatlon system that Is documented and used
— Adequate training for existing and new Inspectors
— Issuance of formal enforcement actions
— Streamlined enforcement procedures
Ill. STATE PROGRAM APPROVAL
A. State Program Approval Goal — All States will develop sufficient authorities and capabilities to
be approved by EPA to operate in lieu of the Federal program.
B. State Program Approval Strategy
t. EPA will provide all possible assistance to States desiring to apply for program approval.
2. EPA will wherever possible apply the SPA approval requirements flexibly while ensuring that
mandatory elements, such as enforcement authorities, are met.
3. EPA will use all available incentives to motivate States to apply for program approval. For
States making progress, these could include the promise of additional assistance from EPA
staff or contractors after SPA and financial bonuses through grants or cooperative
agreements for making progress or getting approval. For States that are dIsinclined ornot
making progress toward SPA, EPA will us. targeted and intensive EPA inspections and
enforcement.
C. Stat. Program Approval Progress Indicators - The following Indicators will be used to assess
Stat. progress toward program approval.
— Statutory authority to develop program
— No4eu•strlngent technical regulations
— No4.u.strlngent FR regulations
— Legal authorities for adequate enforcement
— Procedures to adequately enforce
Complete progrom description
MOA negotiated with Region
— Final application submitted
— ‘Tentative State Program Approval
Program approved
— Adequate resources for compliance and enforcement
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4
IV. 1998 UPGUDINGIREPLACEMENT COMPLIANCE
A. 1998 UpgradlnglReplac.msnt Compliance Goal — Owners and operators will upgrade or replace
their tanks to meet new tank standards by the 1998 deadline.
B. 1998 UpgradIng/Replacement Compliance Strategy
1. Make clear technical guidance and outreach materials availabl, beginning in 1995 to
regulators, owners and operators, and vendors so that they are aware of the requirements
and understand the compliance options.
2. Develop strong State and local compliance and snforcsment programs to ensure that
upgrades, replacements, and closures are performed properly. Thu will build on efforts to
develop Stateltocal formal and informal enforcement capability for leak detection
enforcement, with the expectation that Stats compliance efforts wIN begin to encompass
the upgrade/replacement requirements later in the decade.
3. Encourage and assist in the development of State financial assistance programs and
Federal/State tax incentive programs to encourage upgrades or replacements win before
the 1998 deadline and promote compliance by the deadline.
4. Encourage development of effective contractor licensing and certification programs.
C. 1998 Upgrading/Replacement Compliance Progress indicators (to be developed)
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OSWER DIRECTIVE 9610.15
These and other activities are described in the Transition
Strategy (OSWER Directive 9610.5) and Transition Task List (OSWER
Directive 9610.5—1). Even in those cases where a tribal program
is developed or a tribal-state agreement is signed, the region is
still responsible to ensure that the basic UST requirements are
met and all activities are conducted in accordance with EPA’s
Indian Policy.
ACTIVITIES
There are a wide variety of activities that can be
undertaken to further implementation of the UST program on Native
American lands. These activities will be pursued with
appropriated LUST monies and with personnel funded by both the
UST and LUST appropriations. The specific activities pursued in
any region will depend on factors such as the number of tribes,
their existing and potential ability to implement the program,
number of tanks on tribal lands, and emergency response needs.
Below is a list of activities that in general are high priority.
Regions should select from among these and amend then as needed
to achieve the highest possible success generally and
specifically as applied to any tribal nation.
1. Tank Inventory: update the tank inventory on Native
American lands consistent with the October 2, 1992
memorandum on the “Inventory of UST5 on Indian Lands”;
2. Outreach: continue and expand, where possible, efforts
including circuit riders, information dissemination,
training, and information seminars;
3. Corrective Action: ensure that corrective actions occur
in a timely fashion. Regions are to oversee
responsibl, party-lead corrective actions to ensure
that appropriate corrective actions proceed at all
sites. When necessary, regions also are responsible
for directing federal-lead corrective actions on a
priority basis consistent with OSWER Directive 9610.9
(Interim Guidance on Conducting Federal-Lead
Underground Storage Tank Corrective Actions for
Petroleum Releases on Indian Lands);
4. Streamlining: examine corrective action and other
regional Indian lands-related processes to determine
ways to itreamline and make those processes more
effective and efficient consistent with OSWER Directive
9650.13 (Streamlined Implementation of UST Corrective
Action Requirements);
4
-------
OSWER DIRECTIVE 9610.15
5. Enforcement: ensure adequate enforcement consistent
with the UST program’s emphasis on voluntary
compliance. Regions are encouraged to use field
citations where appropriate and to follow applicable
guidance, including the Office of Enforcement’s
memorandum on “Interim Guidance on Review of Indian
Lands Enforcement Actions” (October 21, 1992),
concerning appropriate enforcement responses for
tribally owned and/or operated facilities;
6. Program Development: identify opportunities for and
facilitate development of tribally administered
regulatory and clean-up programs, including those
administered through tribal consortia, based on tribal
willingness, authorities and funding; and
7. Tribal—State Agreements: facilitate negotiation of
tribal-state agreements for those tribes expressing an
interest in such agreements. Regions also should enter
into three—party agreements with tribes and states as
appropriate.
While a variety of activities can and will be undertaken,
regions are still responsible for ensuring that program
priorities are pursued. The priorities for the UST program are
corrective action streamlining, leak detection compliance and
enforcement, and state program approval. The first two of these
are directly applicable to the UST/LUST program on tribal lands.
Formal state program approval under Subtitle I of RCRA is not
applicable in the form that it currently applies to states.
Tribal program development, which was discussed under
Implementation Strategies, is comparable to state program
development prior to the approval process. Direct tribal program
development is one of the implementation approaches listed above
that regions are encouraged to pursue with interested tribes.
The nature and extent of a tribal program will vary considerably
depending on such factors as the number of tanks, funding
sources, and experience with other environmental programs.
Regions will need to work with tribes and tribal consortia to
help develop a program most applicable to the tribes’ needs,
preferences and capabilities.
FUNDING -
In recent years, Congress has been appropriating $500,000 to
implement the UST program on Indian lands in the Leaking
Underground Storage Tank Trust Fund appropriation. The vast
majority of these funds have been spent by the regional offices
for direct implementation activities such as registering tanks,
overseeing corrective action by responsible parties, and
5
-------
OSWER DIRECTIVE 9610.15
conducting cleanups where responsible parties were unknown or
unable to do the corrective action. The Resource Conservation
and Recovery Act, as amended, presently contains no provision for
directly funding tribal UST programs in the same manner that
state programs are funded.
CONCLUSION
This policy statement is consistent with the UST program’s
policy of flexibility in program development and implementation
by state, local and tribal governments. Regions have the ability
to achieve UST program goals and objectives by undertaking a
variety of activities. The selection of specific activities is
at the discretion of the region and will be based on the needs
and capabilities of tribes and tribal consortia. Although
existing and potential future federal resources for program
implementation are limited, EPA is committed to achieving
protection of human health and the environment. EPA also is
committed to supporting tribally administered programs that can
be operated with their own authorities and funding, working with
tribal consortia, and serving as a facilitator for development of
tribal-state agreements as appropriate.
6
-------
• .iID
j UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
QO1t
OFFICE OF
AUG I I 1992 SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Development of Regional Ac n Plans for Fl 1993
FROM: David W. Ziegele, Director
Off ice of Underground Storage Tanks
TO: UST/LUST Regional Program Managers
In discussing progress in drafting the Regional Action Plans
(RAPs) for Fl 1993 with several of you, it became clear that a
suggested analytical approach to the substantive content of the
RAPS would be helpful. With this in mind, I’ve drafted a list of
diagnostic questions for each of the Leak Detection Compliance
and Enforcement and 1 Corrective Action Streamlining priority
areas. Also attacll 4 is a copy of the most recent diagnostic
checklist for State Program Approval; this comes from OSWER
Directive 9650.12, “suggested Procedures for Review of State UST
Applications.”
In case you haven’t already completed your RAP.; I suggest
you consider these questions and how you would answer them for
each State. The RAPS do not have to include an explicit list of
answers to these questions, but it would be useful if the RAPS
demonstrated that these questions and barriers have been
examined.
Please remember that, as agreed to at the RPM meeting
following the RBC meeting in Minneapolis, draft RAPs are due at
the upcoming August RPM Meeting. If you have any questions about
the diagnostic questions or the Regional Action Plans, I would be
happy to discuss them with you. Please call me at 703-308—8850
or Josh Baylson at 703—308—8887.
Attachments
cc: UST/LUST Regional Branch Chiefs
OUST Management Team
OUST Desk Officers
UST/PNI/PG/92-3
— -- ,,--
-------
DIAGNOSTIC QUESTIONS FOR DEVELOPING REGIONAL ACTION PLANS - -
LEAK DETECTION COMPLIANCE AND ENFORCEMENT
QUESTIONS POSSIBLE ASSISTANCE ACTIONS
Does State have a reasonably If not, provide assistance
complete inventory? with inventory improvement.
Does State have tJST regs? If not, provide assistance
(also see SPA diagnostic
checklist).
Does State have enforcement If not, impose grant
procedures? conditions and/or provide
assistance.
Has State notified 0/0’S of If not, assistance to
requirements? develop/modify outreach
materials, do mailing.
Has State done self- If not, assistance for
certification mailings? mailing.
Does State have enforcement If not, provide assistance on
targeting scheme? setting up targeting system;
consider borrowing schemes
from other States.
Does State have inspectors on If not, conduct Federal
board? inspect ions to motivate
legislature and UST program.
Are inspectors trained through If not, provide inspector
an ongoing inspector training training, including joint
program? inspections, and assist in
setting up training program.
Has State followed up mailings If not, and if State has
with inspections? trained inspectors, impose
grant conditions or provide
assistance in setting up
inspection plan.
Does State want to do formal If not, call or meet with
enforcement, but not get State AG’S office to get
adequate attorney support? support; conduct Fed
enforcement to motivate AG;
have State consider field
citations.
Does State have field citation If not, recommend and provide
program? assistance for State field
citation program.
-------
DIAGNOSTIC QUESTIONS FOR DEVELOPING REGIONAL ACTION PLANS - -
CORRECTIVE ACTION STREAMLINING
QUESTIONS
Does the State have corrective
action regs in place?
Is the State allowing the use
of field measurements for at
least some portions of site
assessments?
Does the State approve the use
of non—traditional assessment
and reinediation technologies
(e.g., SVS, SVE, bioreme-
diation) as quickly as it
approves conventional methods?
Have State managers and staff
received basic TQM training?
Has the State analyzed its
current CA process to identify
and streamline steps that
introduce significant delays?
Are you convinced that the
State’s streamlining efforts
have produced measurable
improvements in performance?
.
Does State have clear and
concise site assessment and
corrective action guidance for
consultants and contractors?
Has State met with consultants
and contractors to explain
guidance and procedures (i.e.,
consultants’ days)?
Do the State’s site prioriti—
zation and CA processes allow
cleanups to proceed with a
minimum of delays imposed by
the State, particularly at
low-risk sites?
POSSIBLE ASSISTANCE ACTIONS
If not, provide assistance,
with focus on promoting
streamlined procedures.
If not, provide training on
field methods; peer match with
States using field methods.
If not, identify specific
barriers and target
assistance; sponsor demo
projects; peer match with
States using newer
technologies.
If not, arrange for training,
using Regional staff, HQ
staff, contractor.
If not, help to plan and
support improvement projects
to streamline these steps and
to measure reductions in
cleanup times.
If not, encourage or help the
State establish performance
measures and goals; provide
assistance and promote proj-
ects to help achieve goals.
If not, assist in guidance
development. Use as
opportunity to introduce
streamlined procedures.
If not, assist in arranging
consultants’ day. Encourage
review of guidance for clarity
or process improvements.
If not, assist with priority
system development or changing
oversight procedures; peer
match with States having
priority-setting programs that
encourage fast action.
-------
OSWER Directive 9650.12
EXUIBIT 1: DIAGNOSTIC CHECKLIST FOR STATE PROGRAM APPROVAL
The following checklist may be used by Regions assisting their States in
the development of State program approval applications. Regional staff can
ask State program officials the questions listed below relating to the various
components of the application. The boxes below each question identify
specific barriers that may prevent the State from obtaining sufficient
authorities or developing complete application components. The checklists
also outline suggested assistance measures to overcome the identified
barriers.
For example, consider the first question, NDoes the State have the
statutory authority to develop and implement a no less stringent UST program?”
The first barrier identified is lack of authority. If the State or Region
considers State statutory authority to be inadequate, they would study the
assistance measures to determine which would enable the State to obtain
sufficient authority. The second barrier identified is lack of interaction
with the State Attorney Genera].s Office. If this is also a barrier for the
State, the State and Region would again consult the assistance measures to
find solutions. Only when all barriers to a given State Program Approval
component are determined not to apply to a State should the analysis proceed
to the next question on the checklist. The barriers identified in remaining
sections of the checklist should be approached in a similar fashion.
This checklist should be viewed as a starting point from which Regions
can begin to assess and improve the State program approval status of their
States. Even in cases where a particular barrier does not pose a problem for
the State, the assistance measures should be reviewed, because they could
contribute to improvements in the State program.
4
-------
OSWER Directive 9650.12
1) Does the State have the statutory authority to develop and Implement
a no less stringent UST program?
BARRIER: Lack of authority
ASSISTANCE:
o Review existing State authority and provide comments on where authority is
lacking.
o Review and comment on draft language for statutory amendments.
o Offer to speak to legislators, testify at bearings, or otherwise support amendments
to grant or enhance necessary State authorities.
BARRIER: Lack of interaction with State Attorney General’s Office
ASS! STANCE:
O Offer to meet with Attorney General to encourage greater involvement in UST
program.
o Bring Attorney General’s Office into the team structure at the beginning of the
process.
5
-------
OSWER Directive 9650.12
2) Does the State have regulations that meet the “no less stringent”
criteria?
BARRIER: Regulations do not meet “no less stringent” criteria
ASSI STANCE:
o Review e sting regulations using SPA objectives and provide comments on how
deficient items could be amended to meet no less stringent requirements.
o Review and comment on draft amendments.
BARRIER: Inadequate State resources to develop UST regulations
ASSI STANCE:
o Reaffirm that States may adopt the Federal regulations by reference, which
requires considerably less time and money than developing their own.
o Inject Federal resources into State programs, conditioned on completion of an
approvable final SPA application by a specified date.
o Encourage and/or provide greater contractor assistance.
6
-------
OSWER Dir.cttve 9650.12
2) (contInued)
BARRIER: Lack of Interaction with State Attorney General’s Office
ASSI STANCE:
o Offer to meet with Attorney General to encourage greater involvement in UST
program.
o Give a grant to Attorney General’s Office to assure State attorney time.
O Encourage AG’s Office to designate a particular staff attorney to work extensively
on UST program issues.
o Bring AG’s Office into the team structure at the beginning of the process.
BARRIER: No financial responsibility regulations
ASSISTANCE:
o Emphasize that States do not need to have State funds to meet the financial
responsibility objective (some States may not develop regulations because they
believe they must have a fund in place).
o Help States develop financial responsibility regulations and State funds (if
desired), by improving understanding of financial responsibility issues, sharing
information from States that have approved regulations and/or funds, and
providing onc-on-one or contractor assistance.
7
-------
OSWER Directive 9650.12
3) Has the State Attorney General developed his/her statement for
inclusion in the final State Program Approval application?
BARRIER: Inadequate State Attorney General preparation and
submittal
ASSISTANCE:
0 Offer to meet with Attorney General to discuss the purpose of AG Statement
and stress its importance.
0 Review draft and provide detailed comments on deficient items.
0 Suggest that State complete a comparison of its regulations to the SPA objectives,
in order to facilitate Attorney General’s review and ‘no less stringent
• determination.
0 Bring AG’s Office into the team structure at the beginning of the process.
8
-------
OSWER Directive 9650.12
4) Does the State have adequate enforcement procedures to Implement
an effective UST program?
BARRIER: No procedures In place
ASSISTANCE:
0 Suggest low-cost methods or approaches to implementation and enforcement
activities (i.e., those included in the capabilities matrices).
O Assist State in developing written enforcement procedures or review draft
description of enforcement procedures and provide detailed comments.
BARRIER: Inadequate State Attorney General preparation and
submittal
ASSISTANCE:
o Offer to meet with Attorney General to encourage greater involvement in the
UST program.
0 Bring AG’S O ce into the team structure at the beginnng of the process.
9
-------
OSWER Directive 9650.12
4) (contInued)
BARRIER: Lack of interaction with Regional UST Attorney
ASS! STANCE:
0 Offer to meet with Regional UST Attorney to encourage greater involvement in
the UST program.
0 Bring Regional UST Attorney into the team structure at the beginning of the
process.
BARRIER: Inadequate State resources to develop procedures
ASS! STANCE:
o Testify to legislature on the importance of funding the UST program; elevate the
priority of the program.
O Inject Federal resources into State programs, conditioned on completion of an
approvable final SPA application by a specified date.
o Meet with Attorney General to encourage greater and earlier involvement in the
UST program.
10
-------
OSWER Directive 9650.
4) (contInued)
BARRIER: Inadequate Regional program review
ASS! STANCE:
0 RPM should define priorities for Regional program staff.
BARRIER: Lack of enforcement authority
ASS! STANCE:
o Review existing procedures and provide comments on where authority is lacking.
o Suggest statutory amendments or review and comment on draft statutory
amendments.
BARRIER Disagreement among team members on standards for
“adequate” enforcement procedures
ASSISTANCE:
0 Refer to capabilities matrices for examples of acceptable enforcement procedures.
0 Offer to meet with Regional UST Attorney to work out substantive
disagreements regarding what is adequate.
11
-------
OSWER Directive 9650.12
5) Have the State and Region negotiated a Memorandum of Agreement?
BARRIER: Lack of agreement between agencies that share
responsibilities
ASSI STANCE:
O Offer to meet with all responsible agencies so agreement can be reached.
o Review draft Memorandum of Agreement and provide detailed comments.
BARRIER: Inadequate State preparation and submittal
ASS! STANCE:
O Refer to boilerplate MOA in SPA Handbook as a model that can be largely
copied now and adapted to meet particular State conditions later.
O Inject Federal resources into State programs, conditioned on completion of an
approvable final SPA application by a specified date.
12
-------
OSWER Directive 9650.12
6) Has the State produced a program description for Inclusion In the
final State Program Approval application?
BARRIER: Inadequate State preparation and submittal
ASSISTANCE:
o Provide sample program descriptions completed by other States to be used as
models. Refer States to relevant section in SPA Handbook .
o Review a draft program description and provide detailed comments and
suggestions for coopletion
o Encourage and/or provide greater contractor assistance.
13
-------
ST
1 0 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
3 WASHINGTON, D.C. 20460
¼ PRCØ ’
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
CEB 1 1992
MEXORANDUM
SUBJECT: Fl 1992 Final Operatin lan
FROM: David Ziegele, Director
Off ice of Underground S orag Ta s
TO: UST/LUST Regional Branch Chiefs
UST/LUST Regional Program Managers
I am enclosing the Fl 1992 final operating plan for the
Regions for UST and LUST appropriations. The LUST funds are
based on the appropriation of $64.2 million for State cooperative
agreements. The Regional allocations for cooperative agreements
were provided in my November 21, 1991 memorandum, “Final Fl 1992
LUST Trust Fund Allocation.” The UST grants are based on an
appropriation of $8.91 million. We are in the pr9cess of
appealing this appropriation to restore it to the full $9 million
that we have received in previous years. In the meantime, I
suggest that you award the UST grants to your States based on
$8.91 million. If we are successful in our appeal, we will work
with you to determine the most expeditious process to award the
funds to the States.
In addition, I understand that the Regions were allotted 80
percent of their UST funds in the first quarter, 10 percent in
the second quarter, 5 percent in the third quarter, and 5 percent
in the fourth quarter. Since the UST funds already have been
allotted to the Regions, you will need to negotiate with your
Regional Comptroller’s Office to obtain full access to your funds
before the end of the fiscal year. In some cases, it may be
appropriate to negotiate with other offices in your Region to
obtain funds they have available now in exchange for UST funds
for their use during the last two quarters of the fiscal year.
This final operating plan should enable you to compare
Headquarters data to your Regional allotments. Please feel free
to call me at (FTS) 678—8850 or Dana Tulis at (FTS) 678—8891 if
you need any further assistance.
Attachments
cc: OUST Management Team
OUST Desk Officers
UST/PM/PG/92—2
Pruuild on Rec’,cled Paper
-------
PAGE 1
APPROP: 2* ______ TABLE ID: ALLT
Pt: APCO2G REPORT lO s DAVE4
APCD2B LPST-REGS
10 PC&B
17 PFTE
AH: 01
RP!O: 01 REGION 1
APCD2B UST-REGS
10 PC & B 168.600 16,521
11 PFTE 0 0
18 OP TI 0 0
AN: 02 166.600 16.521
RPIO: 02 REGION 2 168,600 16.521
APCO2B UST-REGS
10 PC * B 176.700 60,000 36.163
17 PFTE 0 0 0
18 OPFTE 0 0 0
AH: 01 176.700 60,000 36,263
QPIO; 01 REGION 3 176,700 60.000 36,263
APCO2B UST-REGS
10 PC*B
17 PFTE
21 TRAVEL
25 CONTRACTS
27 OTHER EXP
All: 04
RPIO: 04 REGION 4
APCOZB UST-REGS
10 PC & B 172.6% 56,751 26.221
17 PFTE 0 0 0
16 OPFTE 0 0 0
All: 05 172,696 58,751 28.221
dPIO: 05 P T1 1 5 172.896 58,751 26.221
AP O2B 1
11/29/91
IRIITED STATES ENVIROtIIENTAL PROTE . AGENCY
OPERATING PLAN IM*IJAL VS QUARTERLY) VS ACTUAL
BY APPROP, PE, RPIO, AN
APPROVED PLAN POSTED PLAN CUI. OBLIGS OPEN
UtICIIT,’UNOBL. X OP
POSTED
AM8JAL
QUARTERLY
(ROLLUP)
COMMITS.
BALANCE OBLIG..CMT.
01
208.500
0
206.500
*08,500
28,697
0
26.697
26.697
70,800
0
70.800
70.600
57,300
0
0
57,300
57.300
02
03
04
05
0 179.803
0 0
0 179.803
o 179,803
0 152,279
0 0
0 0
0 152,279
0 152,279
0 140.437
0 0
o 0
o 140,437
0 140,437
0 200,621
o 0
0 3.595
0 2,500
0 500
o 215.216
0 215,216
o 144.675
0 0
0 0
0 144.675
o 144,675
10.1
0.0
10.1
10.1
7.2
0.0
0.0
7.2
7.2
15 • 1
0.0
0.0
1 5.I
15.1
12.5
0.0
39.,
0.0
0.0
13.2
13.2
12.0
0.0
0.0
12.0
12 • 0
251,300
0
7.700
2.500
500
85,400
0
2,600
800
100
42.679
0
4,305
0
0
262.000
08,900
46.784
262.000
86,900
46,764
06
-------
11/29/91 I IITE0 STATES ENVIROIIIENTAL P \G ENCT PACE 2
OPERATING PLAN (AMJAL VS QUARTERLY) . ACTUAL
BY APPROP. PE, RPIO. AU
APPROP: 2* S&E TABLE ID: ALLT
PE: APCDZB REPORT ID: DAVE4
APPROVER PLAN POSTED PLAN C%1T. OBLIGS OPEN
IIICTIT/IIIOBL. X OP
POSTED
A IHJAL
QUARTERLY
IROLLUP)
COISIITS.
BALANCE OBLXG..CMT.
10 PC 1 5 201.900 66.600 30.561 0 171,339 11.1
17 PIT! 0 0 0 0 0 0.0
AN: 06 201.900 66,600 30,561 0 171,339 11.1
RPIO: 06 REGION 6 201,900 66,600 30,561 0 171,339 11.1
APCOEB UST-REGS 07
10 PC $ 5 156,800 53,300 31.091 0 125,703 14.6
17 PU! 0 0 0 9 0 0.0
AN: 07 156.600 53.300 31.097 0 125,703 14.6
RPIO: 07 REGION 7 156,800 53,300 31.097 0 125.703 14.6
APCDZB lIST-PEGS 06
10 PC & 5 247,500 64.100 53,214 0 194,286 15.8
17 PIT! 0 0 0 0 0 0.0
16 OPFT ! 0 0 0 0 0 0.0
23 TRAVEL 7.700 2,600 4,676 0 3,025 45.0
25 CONTRACTS 1,000 300 315 0 665 26.2
27 OTHER EXP 9,000 3,000 375 0 6,625 3.1
26 5 11! TRAVEL 1,200 400 0 0 1,200 0.0
AN: 06 266.400 90,400 56,579 0 207,821 16.2
RPIO: 08 REGION 6 266,400 0,4O0 58,579 0 207,821 16.2
APCO2B lIST-PEGS
10 PC I 5 190,000 64,600 22.259 0 167,741 6.6
17 PIT! 0 0 0 0 0 0.0
21 TRAVEL 9,600 3,300 1.819 0 7,961 13.6
25 CONTRACTS 1.500 1.500 0 0 1.500 0.0
27 OTHER EXP 1,000 1,000 0 0 1.000 0.0
AN: 09 202,300 70,400 24,076 0 176,222 6.6
RPIO: 0 REGION 9 202,300 70,400 24,076 0 178,222 6.6
APCD2B UST-REGS 10
10 PC I 5 147,900 52,700 19,006 0 128.894 9.0
17 PIlE 0 0 0 0 0 0.0
18 OPITE 0 0 0 0 0 0.0
21 TRAVEL 11,400 3.800 2.968 0 8,432 19.5
25 CONTRACTS 400 100 0 0 400 0.0
AN: 10 159,700 56.600 21.974 0 137,726 9.7
-------
BIICO2C LIST ST.GRTS
41 GRANTS/LOANS
AH 01
RPIO: 01 REGION 1
BNCOZC LIST ST.GRTS
41 GRANTS/LOANS
AN: 02
RPIO: 02 REGION 2
BNCOZC UST ST.GRTS
41 GRANTS/LOANS
M I: 03
RPIO: 03 REGION 3
BHCDZC UST ST .GRTS
41 GRANTS/LOANS
All: 04
RPIO: 04 REGION 4
SNCD2C LIST ST.SRTS
41 GRANTS/LOANS
AN: OS
RPIOx 05 REGION I
BNCO2C UST ST.GRTS
41 GRANTS/LOANS
AN: 06
RPIO: 06 REGION A
BNCD2C LIST ST.GRTS
41 GRANTS/LOANS
AH:07
965,300
965,300
965,300
965,300
965,300
965,300
1.287,000
1.267.000
1.287,000
965,300
965,300
965,300
804,400
604,400
804,400
643,500
643,500
772,200
772,200
772,200
772,200
772,200
772,200
1.029,600
1.029,600
1,029.600
772.200
772.200
772.200
643,500 0
643,500
643,300
514,800
514,600
323,100
523,100
323,100
322.800
322,800
0 296.000 322,800 14.9
0 965,300
• 965,300
0 965,300
0 1,267,000
0 1,287,000
0 1,281.000
0 965,300
0 965.300.
0 965,300
0 804,400
0 804,400
0 804,400
0 643.500
0 643.500
11/29/91
UNITED STATES
ENVIRCIRIENTAL PROTEt
AGENCY
PA( F. 3
OPERATING PLAN
I AIOIJAL
VS
QUARTERLY) VS ACTUAL
BY
APPROP,
Pt,
RPIO, All
APPROP:
25 &
TABLE
ID:
ALLT
P2: BNCOZC
REPORT
ID:
DAVE4
01
APPROVED
PLAN
POSTED PLAN C%1I. ODLIGS OPEN
IRICIIT/UNOBL. X OF
POSTED
AMIJAL
QUARTERLY
CO ISIITS.
BALANCE OBLIG. .Cffl.
IROLLUP)
0 642,200
0 642,200
0 642,200
o 296,000
0 296,000
618,600 495,000
616,600 495,000
616,600 495,000
20.8
20.8
20.8
14.9
14.9
02
03
04
Os
06
07
U
I
0
0
0
0
0
0
0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0
0
0
0
-------
11/29/91 (SIlTED STATES EWVIROIIIENTAL ..-. .. ENCT PAC,E 4
OPERATING PLAN (AISIUAL VS qUARTERLY) vs ACTUAL
BY APPROP. PE, RPIO, AM
APPROP: 25 AC & C TABLE ID: ALLT
P2: BNCDZC REPORT ID . DAVE4
APPROVED PLAN POSTED PLAN Cl11. OBLIGS OPEN
UNCIIT/ISIOBL. X OP
POSTED
AIHJAL
RUARTERLT
(ROLLUP)
CO II1TS.
BALANCE OBLIG. ‘alT.
RPIO; 07 REGION 1 643.500 514.800 0 0 643.500 0.0
BNCDZC ( 1ST ST.GRTS 05
25 CONTRACTS 6.000 6.400 0 0 8,000 0.0
41 GRANTS/LOANS 957,300 765.800 0 0 957,300 0.0
AN: 06 965.300 772.200 0 0 965.300 0.0
RPIO: 08 REGION 8 965,300 772,200 0 0 965,300 0.0
BNCDZC (1ST ST .GRTS 0
41 GRANTS/LOANS 1.051,600 841.200 0 0 1,051.600 0.0
AM: 09 1,051,600 841,200 0 0 1,051,600 0.0
RPIO: 0 REGION 9 1.051.600 841,200 0 0 1,051,600 0.0
BNCD2C (1ST ST.GRTS 10
41 GRANTS/LOANS 643.500 514.600 0 0 643,500 0.0
All: 10 643,500 514,800 0 0 643.500 0.0
RPIO: 10 REGION *0 643.500 514,800 0 0 643,500 0.0
*1’ P2 TOTAL: N ZC 8.910,000 7,127,700 0 938,200 7.971.800 3.3
-------
1 2/19/91
APPROP: TABLE ID: ALLT
PE: FPYV2B REPORT ID: DAVE4
PPYV2D GUIDE—LUST
10 PC&B
17 PFTE
26 OPFTE
21 TRAVEL
25 CONTRACTS
27 OTHER EXP
41 GRANTS/LOANS
AN: 01
RPXO: 01 REGION 1
FPYVZB GUIDE-LUST
10 PC&B
17 PFTE
16 OPFTE
21 TRAVEL
25 CONTRACTS
41 GRANTS/LOANS
All: 02
RPIO: 02 REGION 2
FPYV2B GUIDE-LUST
10 PC&D
17 PFT(
16 OPFTE
21 TRAVEL
25 CONTRACTS
27 OThER EXP
41 GRANTS/LOANS
AN: 03
RPIO: 03 REGION S
FPYV2B GUIDE-LUST
10 PCIB
17 PFTE
21 TRAVEL
41 GRANTS/LOANS
AN: 04
UIITID STATES INVIROIIIEHTAL PRO!! AGENCY
OPERATING PLAN IAIHJAL VS QUARTERLY) VS ACTUAL
BY APPROP, PC, RPIO. All
01
APPROVED PLAN POSTED PLAN CIAl. OBLIGS OPEN
IJIC1IT/UIOGL. X OF
POSTED
AMIUAL
QUARTERLY
(ROLLUPI
COSEIITS.
BALANCE CBLIG..CUT.
PAGE 5
02
03
04
255.500
0
0
50,700
400
400
4.729.100
255.500
0
0
50,700
400
400
4,729,100
34,203
0
0
6 ,2S8
0
0
0
0
0
0
0
0
0
0
221,297
0
0
42.442
400
400
4,729,100
3.3
0.0
0.0
4.1
0.0
0.0
0.0
5.036,100
5,036.100
42,461
0
4. 93.639
0.2
5.036,100
5.036,100
42,461
0
4.993,639
0.2
163,900
0
0
33,100
2,500
5,743,200
163,900
0
0
33,100
2,500
5,743,200
32.447
0
0
6,929
60
0
0
0
0
0
0
0
131,453
0
0
26,171
2,420
5,743,200
4.9
0.0
0.0
5.2
0.6
0.0
5.942.700
5,942,700
39.456
0
5,903,244
0.2
5,942,700
5,942,700
39,456
0
5,903,244
0.2
261,900
0
0
19,300
44.600
41,500
7,590,100
261,900
0
0
19,300
44,800
41,500
7,590,100
29,464
0
0
10,059
30
0
0
0
0
0
372
195
5
0
232,416
0
0
6,869
44,575
41,495
7,590,100
2.6
0.0
0.0
13.5
0.1
0.0
0.0
7.957,600
7,957,600
39.573
572
7,917.455
0.1
7,957,600
7.957,600
39,573
572
7.917.455
0.1
242.700
0
45,400
8,247,100
242,700
0
45,400
8.247,100
48,236
0
7,996
0
0
0
0
0
194.462
0
37.404
6,247,100
5.0
0.0
4.4
0.0
8,535,200
6,535,200
56,234
0
6,478,966
0.2
-------
11/29/91 IkIITED STATES ENVIROI(1!NTAL SEtCY
PAGE 6
OPERATING PLAN (A288JAL VS QUARTERLY) VS ACTUAL
BY APPROP, PE, RPIO. All
APPROP: ZF LUST TABLE IDz ALLT
PE: FPTV2B REPORT ID: OAVE4
APPROVED
PLAN
POSTED PLAN WI. ODLIGS OPEN
IIIC 1IT/ MOBL. Z OF
POSTED
AMBIAL
QUARTERLY
COISI ITS.
BALANCE OBLIB. .CNT.
(ROLLUP)
RP!O: 04 REGION 4 6.535.200 6.535.200 56,234 0 6,476,966 0.2
FPYV2B GUIDE-LUST 05
30 PC I B 276.000 278,000 46.285 0 231,715 4.!
I? PFTE 0 0 0 0 0 0.0
21 TRAVEL 56.700 56.700 16.916 0 41,784 7.2
25 CONTRACTS 44.500 44.500 0 0 44,500 0.0
27 OTHER EXP 27.300 27.300 0 0 27,300 0.0
41 GRANTS/LOANS 12.880.900 12.880,900 0 2,400.000 10,480,900 4.7
AN: OS 13,269,400 13,289.400 63,201 2.400,000 10,826.199 4.6
RPIO: 05 REGION 5 13.289.400 13.269,400 63,201 2,400.000 10,826.199 4.6
?PYVZ B GUIDE-LUST 06
10 PC & B 206,500 208.500 31.863 0 176,637 3.8
17 PFTE 0 0 0 0 0 0.0
21 TRAVEL 36,700 36,700 3,179 0 33,521 2.2
41 GRANTS/LOANS 7.361,100 7.361.100 0 0 7,361,100 0.0
All: 06 7,606.300 7,606,300 35,042 0 7,571,258 0.1
RPIOs 06 REGION 6 7,606.300 7.606.300 35,042 0 7,571.258 0.1
FPYV2B GUIDE-LUST 07
10 PC & B 175,000 175,000 28,040 0 146,960 4.0
17 PFTE 0 0 0 0 0 0.0
21 TRAVEL . 43,800 43,800 2.421 0 41,379 1.4
41 GRANTS/LOANS 4,066,700 4,066,700 0 0 4,066,700 0.0
AM: 07 4.305,500 4,305.500 30.461 0 4,275,039 0.2
RPIO: 07 REGION 7 4,305,500 4,305,500 30,461 0 4,275,039 0.2
FPYV2B GUIDE-LUST 08
10 Pc £ B 276,000 276,000 62,862 0 213,138 5.7
17 PFTE 0 0 0 0 0 0.0
2! TRAVEL 55,800 55,800 7.886 0 47.912 3.5
25 CONTRACTS 18,600 18,600 0 1.000 17,600 1.3
27 OTHER EXP 1.000 1,000 0 0 1,000 0.0
26 SITE TRAVEL 400 400 0 0 400 0.0
41 GRANTS/LOANS 3,517,200 3,517.200 0 0 3,517,200 0.0
AH; 08 3.669.000 3,66 ,000 70,750 1.000 3,797.250 0.5
-------
11/29/91 R HU) SlATES ENVIROIIIENTAL PPOTEC1 ION AGENCY
PAGE 7
OPIRATIP PLAN I ANRIAL VS . .Y) VS ACTUAL
BY APPROP. Pt. R. AN
PPQOP: 2F LUST TABLE 10* ALLT
FPYV2B REPORT ID . DAVE4
APPR !0 PLAN POSTED PLAN CI II. ONLIGS OPEN
(RIDIT/IRIORL. Z or
POSTED
AMRIAL
QUARTERLY
(ROLLUP)
CON IITS.
BALANCE OBUG..C 1IT.
R?IO: 06 REGION 8 3.869.000 3,669,000 70,750 1.000 3.797,250 0.5
PVV2D GUIDE-LUST 09
IS PC & B *15.000 *15,000 *1.466 0 107,512 3.2
I? PFT! 0 0 0 0 0 0.0
21 TRAVEL 43,000 43,000 11,621 0 31,379 6.6
jt GRANTS/LOANS 6,506,800 6,506,800 0 0 6,506,600 0.0
M: 09 6.764.800 6,764.600 39.108 0 6.723.692 0.1
2P 10: 09 REGION 6.764,800 6.764.600 39.108 0 6.725.692 0.1
cPvV2a GUIDE-LUST 10
IS PC & B 206,700 *06,700 36.512 0 166.166 4.7
I? PFTE 0 0 0 0 0 0.0
IS OPUE 0 0 0 0 0 0.0
21 TRAVEL 36,000 36.000 9.996 0 26.004 6.9
15 CONTRACTS 5,000 5,000 80 0 4,920 0.4
1? OTHER EXP 2.900 2,900 0 0 2,900 0.0
11 GRANTS/LOANS 3.551.200 3,551,200 0 0 3,551,200 0.0
p .11: 10 3.801.000 3,001.800 48.568 0 3.753.212 0.3
IIO; 10 REGION 10 3.801.000 3.801,800 48.586 0 3.753.212 0.3
-------
.10 S .
-..ltI I •
j UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D C 20460
‘C
gqq’ ,
— 1 .: . :E\c
MEMORANDUM
SUBJECT: FY 1994-97 St egic 1a for the 0 fice of Solid Waste
and Emergency pons
FROM: V on R. Clay
I Assistant Ad Inistrator
TO: Regional Administrators
Assistant Administrators
I am pleased to send you OSWER’s Strategic Plan for
Fl 1994—1997. This plan is the product of a joint Headquarters,
Regional and State review of the Fl 1993—96 plan. While we have
retained the same basic objectives from the previous plan, we
have refined our strategies for achieving those objectives. we
have also added additional success measures, building upon our
environmental indicators work. In addition, this plan describes
how OSWER’s strategic goals support the goals of the Agency’s
Strategic Direction and of the draft Agency-wide Strategic Plan.
I am confident that we have mapped out a strategy that will
serve our waste management programs well in the coming years. As
this plan indicates, OSWER will promote risk reduction, including
supporting Regional strategic plans, streamline and better focus
our programs, encourage pollution prevention and waste
minimization, and fulfill our statutorily mandated
responsibilities.
Many thanks for the support your offices have given OSWER in
preparing this plan. Please contact Susan Absher at FTS 260-4510
if you have any questions.
Attachment
cc: ASTSWMO
Work group members
UST/PM/PG/92—l
P,,nted on qecvc
-------
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
S TRA T
EGIC
FY 1994-1997
PLA
N
January 1992
-------
OSWER Strategic Plan FY 1994 - 1997
TABLE OP CONTENTS
PAGE
Introduction . • • , • • • • • •
I. Long Term Foundation . . . 2
A. Mission
B. Fundamental Principles
C. Operating Guidelines
II. Moving Towards the Putur. 5
A. Cross-program Challenges 5
B. Environaental Indicators 9
C. Major Program Objectives . . . . . . . 10
1: Waste Minimization 13.
1.1 Increase Source Reduction Activities 11.
1.2 Increase Markets for Secondary Materials . . . . 14
1.3 Foster State Source Reduction and Recycling . . 16
1.4 Encourage Pollution Prevention . . . . . . . . . 18
2: Environmentally Bound lasts Management . . . . . . . 20
2.1. More Rational RCRA Subtitle C Program 2].
2.2 State Capacity Planrtirtg 25
2.3 Sound Management of Special Wastes . . . . . . . 27
-------
2.4 Appropriate Management of Industrial Wastes . . 2
2.5 Proper Management of Municipal Wastes 31
2.6 Make Greater Usa of Innovative Technology . . . 33
2.7 Effective Superfund Response Actions 36
3: Prevent Harmful Releases . . . 38
3.1 Improve Release Prevention . . . . . . . . . . . 38
3.2 Reduce Catastrophic Releases . . . 41
4: Prepare for and Respond to Hazardous Releases . . . 43
4.1 Integrate OSWER Cleanup Programs 4)
4.2 Improve Site Identification and Remediation . . 45
4.3 Enhance State Cleanup Capabilities . . 49
4.4 Improve Response to Releases .. . . . . . . . . . 51
III. pp.ndiz: Current and Potential Inviron ental Indicators
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O ws Strategic PleD, PT 1994 — 1997
Introduction
This document is intended to serve three purposes. The
first is to provide OSWER staff and managers with a cotu on
understanding of our mission, the underlying values we hold as
fundamental to our programs, and specific criteria to be used in
making day—to-day operating decisions. The second is to provLde
a forum or mechanism for OSWER’s management to discuss the
direction of their programs and, in combination with other Agency
planning efforts, lay out a clear road map to the future. The
third is to help external entities understand OSWER’s mission and
intended actions over the coming years.
The first section of the document lays out OSWER’s long tert
mission and the principles it will use in achieving the mission.
The second section identifies six major challenges we face n the
coming years and then describes in detail the major program
actions we are taking to both address these challenges and
achieve our long term mission.
This Fl 1994—1997 plan is OSWER’s third strategic plan. In
preparing this plan, the work group decided that fine-turu.ng
rather than wholesale revisions to last year’s plan was called
for. Our tour major objectives - minimizing waste, proper
management of wastes, preventing harmful releases and prepar.ng
for and responding to releases - remain valid and broadly
applicable goals for OSWER’s programs. Accordingly, the work
group reviewed and revised the Fl 1993—1996 plan from the
standpoint of the six challenges we had identified during the
previous planning cycle. These cross-program challenges are
described in Part II of this document.
We also revised this plan in light of current Agency poi :y
on strategic )lanning and its connection to budgeting and
tracking progress in achieving our environmental goals. ThLs
strategic plan reflects and complements the goals and object :es
in the EPA Strategic Direction and draft Agency-wide strateg.:
plan. This OSWER plan specifically describes how our goals ar
strategies relate to EPA’s priority areas. Further, this pian
relates both the progress we have made to date, and our pLans :
the future, to develop measures of progress for achieving c
goals. Finally, we will us. thl.s pLan as the basis for the
“action plan’! for our Fl 1994 u qet proposal. Thus, this
strategic plan will play a crt :aL role in shaping OSWER’s
programs in the coming years.
-------
OSWZR Strategic Plan FT l9 4 - 1997 Page 2
I. Long Tsr Poiandation
A. Mission Statement
The mission of the Office of Solid Waste and Emergency
Response is to protect human health and the environment from
unacceptable risks posed by solid and hazardous wastes as well as
the release of oil and chemicals into the environment.
Specifically, the program will act to:
1.. Minimize the quantity and toxicity of waste created by
commercial, domestic, and governmental activities;
2. Ensure environmentally sound management of solid and
hazardous wastes;
3. Prevent harmful releases of oil and hazardous substances
into the environment; and
4. Prepare for and respond in a timely and effective manner
to releases of hazardous materials into the environment.
B. Fundamental Princioles
The following fundamental principles are the foundation
for OSWER’s programs. They are commonly shared values which
we espouse. Our current activities may not always fully
conform to these principles and in this sense, they also
form indirect goals to be achieved through this planning
effort.
1. Highest-risk sources must be addressed first.
2. Ecological risks are equal in importance to human
health risks.
3. Avoiding or managing environmental contamination
is preferable to cleaning up releases after the
fact.
4. All environmental media and ecosystems form an
interrelated whole: our act ions should strive to
protect the environment and human health across
all media.
-------
OSIER Strategic Plan FY 2994 - 2997 Page
5. Use of sound scientific principles and information is
critical. Scientific or other environmental infor atjon
is a national and international asset, vital to the
success of environmental programs.
6. Continuous improvement of quality and productivity is
essential to achieving our goals.
C. Operating Guidelines
The following operating guidelines are decision criteria
intended to guide staff and management in the day-to-day world.
They are derived from our fundamental principles, but are more
specific. If followed, these operating guidelines will help
ensure the principles are attained and our long term mission
achieved.
1. Government at all levels (Federal, State, local and
Indian Tribes), and the regulated community share
responsibility with OSWER for implementing programs
established under OSWER’s statutes. Actions taken by
OSWER should foster trust among these entities and
recognize differences in State, local government and
Tribal capabilities, needs and priorities.
2. OSWER’s goal is full State/Tribal responsibility and
capability for program operations, while EPA shifts
toward a standard-setting and technical assistance role
in support of State/Tribal programs.
3. Interactions with all stakeholders in OSWER’s mission
should be based on an open dialogue and an effective
exchange of information. Actions should be clearly and
effectively communicated to affected parties.
4. In many cases, EPA Headquarters, the Regions and States
are each other’s clients. Actions should be fully
coordinated with affected parties and should support
each other’s respective responsibilities.
5. Employees are our rnost valuable resource and must be
accorded a full, open opportunity to identify
weaknesses and propose Lmprovements to operations or
products. They must also be accorded participation .r
activities affecting OSWER’s working environment, and
given the opportunity to improve their knowledge and
skills.
-------
OSW!R strategic Plan 1! 1994 - 2997 Page
6. Actions should be kept simple, understandable, and
easily implemented. They should incorporate arid
analyze a broad spectrum of creative solutlorts and
approaches using the flexibility available under the
law, including sound industry trends, market and
economic incentives, and implementation beyond the
Federal level. OSWER should encourage the regulated
community to take actions beyond the minimum required
by law.
7. Actions should foster and net inhibit new technological
developments. They should advance the use of
state-of-the-art science and engineering in deriving
solutions to problems.
8. Actions, including the generation and/or collection of
data, regulatory requirements, and program management
decisions, should be coordinated with other media and
programs to ensure problems are not merely transferred
to other environmental media but rather support source
reduction of waste and Agency and OSWER-wide goals.
9. OSWER’s actions should strive to ensure environmental
equity for minority and low income communities.
10. Actions should meet Federal statutory obligations while
retaining sufficient flexibility to address priority
risks as warranted.
11. Actions should improve laws that may be reauthorized Lri
the future by promoting innovative or practical
concepts in upcoming reauthorization discussions.
12. Our actions in response to situations with immediate
environmental concerns should be timely to stop the
ongoing spread of contamination where feasible.
-------
OSWER strategic Plan kY 1994 — 1997 Pigs
II. Koving Tovards the Putur.
This section is divided into two parts. Part A discusses six
major challenges OSWER faces. Part B describes in detail the
major program actions we are taking to both address these
challenges and achieve our long term mission.
A. Cross-program Challenges
OSWER identified six major challenges cutting across all our
programs that must be addressed in the coming years to better
achieve our long term mission. To a degree, they represent
hurdles we must overcome to accomplish many of our current
objectives —— but they also represent a change in focus and
direction for the future. They reflect considerable discussion
by OSWER management and the directions suggested by the Agenda
for Action, internal reviews of the RCRA and Suparfund programs,
and the Science Advisory Board report on risk.
These challenges formed the basis for this year’s revisions
to OSWER’s plan. Work groups composed of Headquarters, Regi.onal
and State staff reviewed and made recommended changes to the plan
from the standpoint of the various challenges. A major effort
was devoted to the first three of the challenges: 1) develop an
integrated waste cleanup program, 2) define the State role in
waste management and 3) use environmental (both ecological and
human health) risk as the criteria for choices and priorities.
This plan reflects the efforts of the work groups to better
integrate these challenges into the strategies and success
measures for OSWER’s four major objectives.
The other three challenges were also discussed - integrate
pollution prevention into all sectors of society, create a
national consensus on waste management goals, and create a
national understanding that “it’s my problem, too”. Our plans
for these are discussed directly below.
These six challenges reflect OSWER’s recognition that neither
EPA nor the States have the resources or ability to completely
address the nation’s waste disposal problems. Solving these
problems requires a recognition that the problem and its solution
do not solely belong to the government, but are a shared
responsibility of consumers, government and the private sector.
We must more clearly define the ro es of these parties, eliminate
-------
OSWER Strat.gic Plan FT 2994 2.997 Page
or temper many of the external factors impeding our progress, and
go beyond the existing, often adversarial, public/private sector
relationship..
Integrating pollution prevention, building a national
consensus and creating a national understanding require OSWER to
move beyond its traditional constituencies and normal channels of
communication to a more active role in public outreach and public
education, enhanced State and local capacity building, greater
reliance on market and economic approaches, and improving our
science and knowledge base. OSWER’s proposed Fl 1993 budget
contains activities which would enable us to progress in these
areas. Our proposed investments include: a pilot environmental
extension service to educate small communities and businesses
(often overlooked in our outreach activities) on recycling,
pollution prevention and meeting regulatory requirements;
resources to develop and delegate programs on Indian lands; and,
a substantial portion of our Fl 1993 request would support our
ability to assess ecological risk, develop indicators of
environmental results and develop economic incentives for
recycling.
Assuming we are successful with our Fl 2.993 request, the
activities we undertake to address the three challenges will be
further enhanced by plans for Fl 1994. In Fl 1994 we will seek
funding to support additional public education and outreach
effbrts, and to further our risk assessment and environmental
indicator work. Additionally, we will foster a national debate
on the national goals of EPA’s waste management program. Public
opinion polls have shown there’is serious disconnect between the
public’s perception of risks associated with waste management and
that of the Science Advisory Board. A debate that involves all
our various constituencies could help coalesce public opinion on
what EPA could be doing differently to allay public concerns.
1. Develop better integrated waste cleanup programs.
OSW ’s strategic plan envisions that by 1997 the Agency will
have made substantial progress toward better integrating the
Superfund, petroleum spill, and various RCRA cleanup programs.
This includes the development of )oint, fully integrated pol .cies
and guidances on selected, appropriate issues. One result of a
better integrated program would be a regulatory framework for
cleanup programs that provides incentives for the private and
public sectors to remediate waste problems rather than leaving
them in place.
-------
OSWER 8tratsgic Plan TY 1994 — 1997 Pigs 7
OSWER’s vision for the future includes a more streamlined
cleanup program that uses past experience and new science to
standardize key components of the cleanup process and achieve
quick initial risk reduction, reduced costs, more effective
cleanup solutions, and reduced overall cleanup time. This
standardized and streamlined program will be designed in such a
manner as to provide continuing incentives to foster innovati.ve
technology.
2. Clearly define State and EPA roles in waste management and
cleanup.
EPA’s goal in administering environmental programs always has
been that the States would have overall responsibility for
day-to-day operations. States are much closer to environmental
problems allowing them to better determine priorities with
limited resources. Over the last ten years there has been much
debate over who should do what and how. Failure to define the
State role and shift direct responsibility to States has impeded
program implementation.
The OSWER Strategic Plan for Fl 94-97 lays out expectations for
and articulates the roles of EPA and the States in implement .ng
OSWER’s mission and goals. Mowever, lack of sufficient resources
can impede program implementation at the State level even where
roles have been well defined. This plan recognizes that a
successful partnership needs to be tailored to each State’s
capability and needs, and that shared program implementation ay
make the most effective use of Federal and State resources i.n
some cases.
Note: In most cases the word “State” in this plan can be read
as applying to Indian Tribes as well. In those cases
where we need to distinguish between the two, the plan
includes language specifically addressing Tribes.
3. Environmental risks become one of the major criteria for
making choices and setting priorities.
OSWER will increasingly set priorities for addressing hazardous
waste issues on the basis of their relative risk, both actual and
cotential, not only to human health but also to ecological
processes. In ascertaining relative risks, OSWER will consider
the contributions of all relevant media to the ultimate risk.
The potential hazards posed by these wastes are the same whether
they exist at abandoned dump sites or are currently being
generated and treated, stored, or disposed of at functioning
-------
osizi Strategic Plan PT 1994 • 1997 Pigs
waste facilities. Therefore, OSWER will coordinate the
decision-making on relative risk for CERCLA, oil spill, chemical
accident prevention and RCRA issues.
OSWER will also articulate the decision making process with
regard to competing priorities so that it is equally understood
by States, Regions and other EPA offices. This approach to
priority—setting will affect many aspects of our programs,
including waste minimization activities and enforcement and
regulatory decisions. As recommended by the Science Advisory
Board report, we will continue to emphasize the need for high
quality basic and applied research to better elucidate the nature
and extent of the risks posed by wastes.
4. Integrate pollution prevention into all sectors of society.
Preventing the creation of pollution is not a role for any one
institution, but for all segments of society. It is one of
OSWER’s long terms goals. The most important role we and other
parts of the Federal government can play is educating industry
and consumers about the important benefits that can be derived
from pollution prevention. The goal of such an effort would be
to inculcate a national culture where corporate and social
decisions regularly consider environmental effects.
What are the major outcomes we want of this cultural change?
First, we want to see industry and Federal agencies institute
company and agency-wide programs that prevent or reduce pollution
at the source. Second, we want Federal and State programs to.
assist industry through information and technology transfer
programs; we also need technical assistance programs for small
businesses, as well as targeted efforts for those industries,
wastes and geographic areas where we can obtain the greatest
environmental benefits. Third, we want States and local
governments to institute recycling programs for municipal solid
waste, and possibly industrial solid waste. Fourth, we want the
Federal government to target education and awareness programs n
pollution prevention to all, sectors of society with the goal of
achieving a cultural change Lfl how society addresses waste
management. Finally, we want to see the per capita amount of
industrial and municipal solid waste decrease between new and
1997.
5. Create a national consensus on waste management goals.
We should strive for a national consensus on the goals and
underlying premises for a waste management and remediation
-------
OBJER strategic Plam FT 1994 — 1997
program. This would help close or reduce the gap between publLc
expectations and what is practically achievable. it would
provide a better public understanding, direction, and support f r
the nation’s waste programs. To achieve this we must attempt to
forge a common understanding of the nature of the problem, the
costs (both financial and social), and the technical limits of
potential solutions. Such a common understanding includes the
awareness of: the information that is and is not available about
risk; the practical limitations on our ability to limit risks;
the effect of risk reduction on achieving other social goals; the
national scope of problems (e.g., waste disposal capacity); and
the trade—of fs between analysis and action.
6. Create a national understanding that “it’s my problem too.”
Solving the environmental problems in this country and abroad is
not the sole responsibility of the government. Neither the
Federal nor State governments have the resources and/or ability
to deal with these problems alone. Industry, professional
organizations, environmental groups, academia and citizens must
recognize these problems are not “government problems” but “our
problems” and share the responsibility of dealing with them. A1.
the stakeholders must recognize their respective roles in the
protection of the environment and work together to prevent
pollution and solve environmental problems. OSWER must work with
all stakeholders to achieve this end.
B. Environmental Indicators
Addressing the above challenges is expected to result in
significant improvements in environmental quality. OSWER is
committed to collecting and reporting data on relevant indicators
that measure improvements to the environment as a result of EPA
and State actions 1 as well as those of the public and the
regulated community. For instance, the Office of Solid Waste
will use the RCRA Information System (RCRIS) and the Biennial
Reporting System to collect hazardous waste data to report on
indicators for waste minimization, safe management of waste and
corrective action. The Offic. of Emergency and Remedial Response
has a similar program in plac. to collect and report data on
relevant indicators associated with cleanup activities for
removal and remedial actions. Also, the Chemical Emergency
Preparedness and Prevention Office is working with the
Administrator’s National Advisory Committee on Environmental
Policy and Technology (Chemical Accident Prevention Committee) t:
define measures of progress in preventing and mitigating cherU. a
accidents.
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O8WU strategic P1&m FY 1994 - 1997 Page
A list of OSWER’s current and proposed environmental
indicators is found in the appendix. These indicators represeflt
a subset of the success measures found throughout this plan.
Data collection for other success measures identified in the plan
will be developed as additional resources allow.
C. Malor Proaram Oblectives: 1994 - 1997
The individual objectives described in this section are key
actions OSWER is undertaking or will undertake to achieve our
long term mission. They are grouped by the four main components
of our program.
1. Minimize the quantity and toxicity of waste created by
commercial, industrial, and governmental activities.
2. Ensure the environmentally sound management of solid and
hazardous wastes.
3. Prevent harmful releases of oil and hazardous substances Lnit
the environment.
4. Prepare for and respond in a timely and effective manner to
releases of hazardous substances into the environment.
We have sharpened our focus on the necessary steps or
decisions that must occur to implement these objectives as well
as on the measures of success. Some of the measures relate
directly to environmental cleanup or protection, while others are
surrogates.
These objectives are not organized by, nor do they directly
follow from, the six cross-program challenges discussed above.
However, the strategies for achieving these objectives address
the challenges; and they reflect the paradigm shift laid out i.n
the Science Advisory Board’s recommendations on risk - i.e.,
viewing environmental problems a. a whole and making planning
decisions based on relative rLsk. Future strategic plans wi i
ref lect our ongoing efforts to better define and lay out the
steps necessary to address the cross-program challenges.
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O8WER Btrat.gic Plan TY 1994 1997 Pagi
1. WABT! XINTJII2ATLOI
OBJECTIVE 1.1 Significantly increase source reduction
activities by industry and municipalities to
prevent the generation of hazardous,
municipal, and industrial solid wastes.
D.scriptien
Minimizing the volume and toxicity of wastes ultimately disposed
of is the single—most effective means of protecting public health
and the environment from exposure to pollution. In the Pollution
Prevention Act of 1990, Congress declares the national policy of
the United States to be that pollution should be prevented or
reduced at the source whenever feasible. Success in increasLng
source reduction activities to prevent waste generation is not
limited to industry. All sectors of society, including Federal,
State, and local governments, as well as the general public, can
positively influence source reduction.
OSWER’s waste minimization goal supports most of the key ther es
in the Agency-wide Strategic Plan. The overarching purpose of
our waste minimization goal is pollution prevention. The
techniques we employ to further waste minimization and enhance
pollution prevention include: an information transfer progra n
the States (Building State and Local Program Capacity);
developing and distributing outreach materials (Education and
Outreach); conducting research to identify and evaluate source
reduction methods (Improving Science and Knowledge Base);
developing market and. economic incentives to foster source
reduction (Greater Reliance on Market Mechanisms and Economic
Incentives); and, creating incentives for waste minimization ‘.n
regulations for hazardous waste listings and management and
encouraging pollution prevention technologies in enforcement
settlement agreements (Strategic Implementation of Statutory
Mandates).
Strategy
OSWER will provide national leadership on source reduction
of municipal, hazardous and industrial wastes. We will
provide the necessary tools to States to increase source
reduction activities by industry and municipalities. We
will undertake these activities at the national level and
will communicate to our constituencies the benefits of
source reduction.
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OSWER Strategic Plan TT 1. 94 • 1.997 Pigs 12
We will give priority to source reduction of those wastes
that pose the greatest risk of exposure to human health and
the environment. To enable us to do this, we will analyze
available data using ongoing surveys, regulatory development
efforts and research to identify those high risk wastes
which are the best candidates for source reduction. We will
undertake the following activities, with particular emphasis
on providing the necessary tools for the States to foster
source reduction activities:
1. Develop forums for the Agency to communicate the
benefits and success of source reduction to our
constituencies.
2. Establish and maintain technology and information
transfer programs with the States to provide guidance,
training and technical expertise to enable them to
implement source reduction programs.
3. Develop and distribute to States and Tribes guidance
and outreach materiAls on the benefits of source
reduction and on good source reduction procedures.
4. Establish and/or maintain strong networks with industry
to conduct joint projects such as research,
conferences, process or technology evaluations and
outreach projects.
5. Develop market and economic incentives to foster source
reduction practices.
6. Develop information that allows the Agency to identify
and target opportunities that present the greatest
reduction of risk. These targets may include specific
industrial sectors or Large volume - high toxicity
waste streams.
7. Promote the us. of pollution prevention technologies in
enforcement settlement agreements to convince industry
this is a worthwhile endeavor.
B. Incorporate waste ainimizat on into the hazardous waste
regulatory program by promulgating listing decisions
that create incentives for waste minimization.
9. Conduct research to ident&fy and evaluate source
reduction methods and processes where technological or
economic barriers currently exist.
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OSWER Btrat.qic Plan PY 1994 - 1997 Pegs 13
10. work with industry to (a) improve packaging design and
(b) characterize the nature of toxic substances in
waste streams to determine how they can best be
measured as well, as removed.
.j.. Work with other EPA offices to establish voluntary
guidelines for environmental labeling, including
improvements to and increased numbers of pesticide
labels.
12. Establish methods of measurement for source reduction.
This will allow the Agency to judge the progress being
made in reducing the generation of hazardous and
special/industrial solid wastes.
13. Foster more effective source reduction activities
through better intra-EPA communication.
14. Develop data to track trends in waste toxicity for
long—term environmental indicators.
Succass M.asurss
1. Continual increase in the number of firms using source
reduction and improved packaging design practices.
2. Increase in the number of enforcement settlement agreements
that incorporate pollution prevention technologies.
3. Continual reduction in the volume of hazardous, municipal and
industrial solid waste normalized by per capita, production,
value added or by other appropriate measure.
4. Increase in quantity of municipal waste subject to source
reduction and recycling, by waste stream.
5. Annual reduction in the quantity of municipal solid waste
disposed of or sent to incinerators and landfills.
6. Improvements in municipal solid waste management through
comparison of landfilling, ncineration, recycling and source
reduction rates over time.
7. Increases in numbers of hazardous waste generators with
source reduction programs. by .thOd.
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OSIER atrat.gic P1& VT 1 S4 - 1q97 Pag•
OBJECTIVE 1.2 Increase significantly the number of markets for
secondary materials for hazardous, municipal and
industrial solid wastes.
Description
If wastes must be generated, then recycling them in an
environmentally safe manner offers the most beneficial us to
society and the environment. However, if markets for recovered
materials do not exist, or these markets are limited in size and
scope, then encouraging recycling can create false expectations
and cause large pileups of secondary materials in storage.
Therefore, the challenge to EPA is to identify and create
incentives for industry to safely use secondary materials in
their production process, thus fostering recycling.
Strategy
The overall strategy for significantly increasing the number of
markets for secondary materials involves the following
activities, some of which are similar to those found in
Objective 1.1 for source reduction. However, the difference
occurs in the challenges presented to EPA, the States and
industry. While technological barriers exist in certain
industrial sectors, the primary challeng, for source reduction is
in the economics of this option vis—a—vii recycling, treatment,
or land, disposal. For recycling, th. challenge is in creating
economically viable m k ti for secondary materials such that
recycling does not raise false expectations. Becaus, of the
interstate nature of secondary markets, EPA will provide
leadership by analyzing which industrial sectors, materials, and
localities have the potential and demand for secondary materLals.
The States, in turn, can use such information to communicate to
their own industrial and municipal constituencies.
1. Identify targets of opportunity; i.e., problem industrial
wastes, large volume — high toxicity waste streams, or
particular industrial sectors.
2. Develop a strategy to establJsh an outreach program to
promote materials recovery where t is environmentally safe
to do so.
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QSWER Strategic Plan 7Y 1994 1997 Peg.
3. Identity and, if feasible, resolve regulatory barriers to
expanding and increasing markets for secondary materl.als
that can be recycled in a sound manner.
4. Establish methods of measurement for recycling.
5. Develop a standardized, practical definition for sound
recycling.
6. Develop a methodology to measure success of material
separation activities for municipal solid waste.
7. Develop Federal procurement guidelines for high volume or
hard to manag. wastes.
8. Conduct research related to industries having technology
problems that must be overcome before markets for secondary
materials can be expanded.
Success Measures
1. Annual increase in the quantity of waste recycled through
secondary markets.
2. Continual increase in the number of secondary market firms
practicing environmentally safe recycling.
3. Continual increase in the volume of hazardous, municipal and
industrial solid waste entering secondary markets for
environmentally safe recycling.
4. Annual reduction in the quantity of hazardous and municipal
solid waste disposed of or sent to incinerators and
landfills.
5. Increased number of procurement guidelines with secondary
market components published.
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O8WER Strategic Plan F? 1.9 4 - 2 97 Page
OUEBTIVZ 2.3 Foster the development and management of effectj.ve
State source reduction and recycling programs.
Del er iptie
Minimizing the quantity and toxicity of waste created by
commercial, individual, and governmental activities is not
strictly the domain of the Federal government. States have a
vested interest in developing their own programs. They are i uch
closer to understanding the dynamics of their waste generators
and are better able to target source reduction and recycling
programs to eliminate priority waste generators.
S tn tegy
Achieving this objective is based on providing technical
assistance to States, including:
1. Conducting surveys to gather information that targets
opportunities,
2. Providing technical and administrative guidance art how a
State should develop and manage a waste minimization
program,
3. Providing staff expertise in designing and developing
State clearinghouses, and
4. Providing EPA guidance and outreach materials on the
development and management of source reduction and
recycling programs.
Success Measures
1. Continual increase in the number of States with viable
hazardous and municipal solid waste source reduction and
recycling programs.
2. Annual increases in every State in the amount of hazardous
and municipal, solid waste recycled in an environmentally sour.
manner.
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OSWER Strat.qic Plan FT 2994 - 1997 Fag.
3. Annual increases in the number of firis in each State w .th
improved packaging design.
4. Annual reduction in each State in the quantity of hazardous
and municipal solid waste disposed of or sent to combustior
devices and landfills.
5. Increased number of procurement guidelines published in
each State.
6. Increases in quantities of waste avoided, by industry and
waste type, due to waste minimization by industry.
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oswu strategic Plan FT 1994 — 199? Pag•
OBJECTIVZ 2.4 Encourage pollution prevention through the
coordinated use of permitting and enforcement
authorities.
Description
Historically, the Agency has reviewed permits or has conducted
compliance inspections at generator facilities or at treatment,
storage, and disposal facilities by isolating those components
directly related to waste management. As the RCRA progi m has
matured, we have become aware of the direct relationships that
exist among the factors of production, production processes, and
the quantity and toxicity of waste generated. We will capitalize
on these relationships to maximize the value of permitting and
compliance operations as “tools” for fostering source reduction
or recycling.
Strat.gy
EPA will develop and provide the necessary information (technica
guidance, training and technical expertise) to the States to
enable them to foster source reduction or recycling through
permitting or compliance/enforcement actions. During 1993 OSWER
will identify those industries (targets of opportunity) that have
the greatest potential for decreasing the volume and toxicity of
their waste, and continue to implement a RCRA Enforcement
Pollution Prevention Strategy. A survey to assess training and
gi.aidance needs for enforcement personnel in the Regions has been
developed and training will begin in 1993.
For F? 94—97, the following activities will be undertaken:
3y 1994
o Evaluate the effectiveness of pollution prevention conditions
in several cas. examples of settlement agreements. In 1994-
97, identify additional candLdates so that increasing numbers
of settlement agreements Lnc]uds pollution prevention
conditions.
o Issue policy statement to serve as guidance for Regional
permit writers on role of poLlution prevention in permits.
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OSWER strategic Plan py 1994 1997 Pigs
o Complete guidance and training materials for permit writers
that allow them to review total plant operations and to
identify opportunities for decreasing waste generation by
priority targets.
o Complete training for enforcement personnel in the Regior s
for RCRA enforcement pollution prevention activities.
o Collect data to provide a better indication of reduction or
avoidance of environmental risk based on permitting and
enforcement activities.
o Continue to analyze targets of opportunity based on volurne,
toxicity and potential human health and ecologic risks from
exposure to hazardous waste.
By 1995—97
o Establish and maintain a clearinghouse of information on
opportunities and practices of incorporating pollution
prevention in permits and inspections.
o Establish a national program of total plant operational
reviews for permitting and inspection operations with
priority given to higher risk facilities.
success Xsasu:.s
1. Increasing number of settlement agreements and permits,
wherever appropriate, that incorporate pollution prevention
conditions.
2. Reduced volumes and toxicity of waste in industries
targeted for combined enforcement and permit activities.
3. Increasing numbers of inspections to target facilities with
the greatest potential for environmental benaf its.
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O8WER Strategic Plan FY 1994 1.997 Page
2 • VIBO1O ThLLY SOUJD I UG T
The United States produces approximately three billion tens
of hazardous and northazardous wastes per year. Managing these
wastes demands significant economic and administrative resources.
while the dangers associated with improper management of
hazardous waste are well known, improperly managed municipal or
industrial waste may also threaten public health and the
environment by contaminating drinking water supplies, releasing
toxic vapors into the air, causing explosions, or otherwise
polluting the environment. Special wastes are generally
considered to present lower toxicity risks, yet some are produced
in large enough volumes to present significant environmental
problems.
OSWER’s Strategic Plan for achieving our goal of
environmentally sound management of wastes embraces all the key
themes in the Agency-wide Strategic Plan, Of prime importance is
Strategic Implementation of Statutory Mandates, and our plan lays
out strategies for making the RCRA hazardous waste program more
effective and rational and for designing industrial and spec .aL
waste programs that make best use of scarce resources.
Examples of how this OSWER goal relates to other key Agency
themes include: providing States with the tools needed to
effectively implement the hazardous waste program (Building State
and Local Capacity); reaching a joint EPA—State definition of
success for the hazardous waste program and communicating
accomplishments to the public (Education and Outreach);
developing hazardous waste staff (Better Management); developl .rg
regulations that create incentives for pollution prevention and
recycling (Pollution Prevention and Greater Reliance on Market
Mechanisms and Economic Incentives); improving communication f
and developing incentives for innovative technologies for source
control and ground water remediation (Improving Science and
Knowledge Base); and, sharing information about innovative
technologies with the internatLonal . environmental community
(International Cooperation).
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OSWER Strategic Plan PT 1994 - 2.99,7 Pigs 2:
OBJECTIVE 2.2. Create a more effective and rational RCRA
Subtitle C program.
Description
The EPA and State RCRA Subtitle C (hazardous waste) programs
have made tremendous progress over the last ten years in
putting into place a comprehensive national regulatory
structure. However, the RCRA regulatory program is probably
the most complicated and complex of any in the Agency. Many
rules are difficult to interpret, and therefore cumbersome
to implement. Similarly, the Agency has been challenged to
address the sometimes competing priorities of prevention
versus cleanup, hazardous waste versus municipal solid
waste, waste minimization versus proper waste management,
etc. The rules have also produced perverse results at times
by unintentionally discouraging both cost-effective and
environmentally sound waste management practices.
Strategy
Our strategy for achieving this objective is based on the RCRA
Implementation Study’s recommendations. Creating and
implementing a more effective and rational RCRA Subtitle C
program relies upon a sound partnership between EPA and the
States whereby EPA provides the national leadership, regulatory
standards and necessary tools, including assistance with settir.g
priorities based on risk, for the States to effectively imple ertt
the RCR.A program on a day—to-day basis. The nature of this
partnership will vary from State to State depending upon an
individual State’s capabilities, workload and resources.
Given the magnitude of the RCRA program, a major component of
making the program more effective and rational will be for t .e
Regions and States to set priorities that address facilities
posing the highest risks to human health and the environment,
either through prevention activities, such as permitting and.
compliance inspections or through corrective action activities.
EPA and the States will develop and maintain an effective work r;
partnership, tailored to each State’s capability and needs, : a
makes the most effective use of Federal and State resources.
targeted to the most significant r sks, and uses the most
appropriate permitting, enforceesnt and corrective action
authorities.
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OSWER Strategic Plan FT 1994 - 1997 Page 2
Achieving this objective will also depend on:
1. Establishing and communicating clear priorities based upon
environmental benefits to be gained and risks to be reduced,
avoided or eliminated.
2. clarifying and defining mechanisms and requirements for
setting priorities and effectively communicating these to
the Regions and States.
3. Continuing joint EPA/State efforts to develop, implement and
utilize environmental indicators as measures of
environmental progress. Using these indicators to
communicate the program’s accomplishments to each other, the
public and the regulated community.
4. In conjunction with the States, balancing prevention and
cleanup efforts, setting permitting, compliance inspection
and corrective action priorities using a risk-based
approach, wherever possible.
5. Revising existing regulations or developing new regul ations
that create incentives for environmentally sound pollution.
prevention and recycling practices.
6. Speeding up State authorization.
7. Attracting, retaining, and developing staff.
8. Developing more and better environmental data to make nore
rational decisions based upon reductions in environmental
risk.
9. Incorporating pollution prevention activities into
enforcement case settlements.
10. Encouraging States to take timely and appropriate
enforcement actions and to use the RCRA Civil Penalty Policy
in assessing penalties.
11. Deterring non-compliance through vigorous use of sanctions
and penalty assessments based upon consideration of the
benefits derived from non-compliance.
12. Maximizing the efficacy of th. enforcement program through
targeting environmentally sigiuticant waste handlers and
deterring them from violating RCRA requirements.
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OSWER Strategic Plan PT 1994 1997 Pigs
1.3. Conducting additional research to identify hazardous wastes
posing the highest risks to human health and the
environment.
14. Using non-traditional and creative approaches, including
economic incentives.
15. Providing technical support and analyses to Congressional
staff and promoting dialogue with affected parties on RC A
reauthorization.
Success Measurse
To achieve this ob ective, a variety of specific actions n ust be
completed, such as training staff, authorizing States to carry
out MSWA, and revising high priority regulations.
1. EPA and the States issue high quality, environmentally
protective permits in a timely fashion.
2. The regulated community more fully understands regulatory
requirements and voluntary compliance increases.
3. States develop RCRA programs that continually provide for
and achieve environmental result5.
4. Increased public understanding of improvements made in
handling wastes and of RCRA’s accomplishments.
5. Environmental indicators show progress
(a) Improvements are demonstrated through evaluating the
number and status of facilities:
(i) having adequate ground waster monitoring systems,
(ii) being in detection or compliance monitoring, and
(iii) having no further action taken after an RFA/RFI.
(b) The number and percent of facilities using designs,
operating methods and closur, practices to control releases
increases; specifically, Lncreases in:
Ci) the number and percent of operating and closed
landfill regulated units with minimum technology
designs,
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OSWER Btrat.qic Plan FT i.994 Page
(ii) the number of incinerators with acceptable air
pollution controls in place, and
(iii) the number of inactive units and facilities that
have completed closure, by facility category.
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OSWER Strategic Plan FY 1994 — 1997 Page
OBJECTIVE 2.2 States actively plan for adequate capacity to
ensure the safe management of their wastes.
Description
The existence of safe capacity for managing hazardous wastes .s
essential. Insufficient capacity or excessive restrictions or
interstate waste flows could seriously disrupt the hazardous
waste system, including its great potential to slow Superf d,
RCRA, and TJST site cleanups. Public concern, along with
statutory requirements for adequate state hazardous waste
capacity, compel the Agency to develop and implement a strong
outreach and technical assistance program to ensure the conti.nue
availability to all States of safe disposal and treatment
capacity, combined with effective waste minimization programs.
Strategy
The following steps will be taken to achieve this objective:
1. Develop, maintain and continue to improve a national data
base of waste generation, management and capacity
information. Use the data base to help States identify
waste management shortfalls.
2. Work with the States to maintain or develop viable capacity
assurance plans.
3. Work with States to permit new, environmentally acceptable
facilities as appropriate to ensure safe capacity.
4. Throughout the 1994-97 timeframe, address, as appropriate,
issues arising from State restrictions on interstate
movement of hazardous waste and incinerator moratoria.
Success Measures
1. As indicated under the mast. MLnLmization goal, States WLL:
have implemented strong east. nimization programs, whose
effects can be systemat a ’ evaLuated.
2. Sufficient data exist on azar eus waste management systems
to allow States to make Lnfor!ted decisions regarding the
need to site or expand management facilities.
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OSIER Btrstsgic PLan PY 1994 - 1997 Pigs
3. States are able to site facilities to ensure adequate
capacity for their wastes either in-state or through “fai.r
share” agreements with other States.
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Ostu Btratiqic Plan F! 1994 1997 Page 27
OBJECTIVE 2.3 Special wastes are managed by EPA and the States
in an environmentally sound manner.
Description
The Agency has classified several categories of wastes as
“special wastes”. These include mining and mineral processing
wastes, wastes from oil and gas exploration and production, and
other large—volume wastes. The Agency needs to respond to
statutory and/or court-ordered mandates to study and develop an
appropriate State/Federal program for regulating these wastes.
strategy
The steps for achieving this objective are as follows:
1. Recognizing existing State programs, issue guidelines and/or
regulations for mining and mineral processing wastes by
1994, and issue guidelines for oil and gas wastes by 1996 as
necessary, or identify and implement non-regulatory progra ts
as a viable alternative.
2. In each year (1994—97), continue to work with the States and
interest groups to determine national and individual State
program needs, and provide technical assistance as necessary
for program implementation.
3. During 1994-97, develop and implement a solid waste
enforcement strategy that provides for targeting those types
of facilities and materials with potential for the greatest
reduction in environmental risk.
4. By 1996, assist in the development of enforcement components
for EPA and State programs that manage mining and mineral
processing waste.
- 5. Incorporate elements in information management systems which
would allow some measurement of environmental benefit or
avoidance of risk.
Success Measures
1. The majority of State mining and mineral processing progrars
are consistent with the gi. deUnes/regulations that have
been issued.
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O8W!R Btratsgi Plan F! 1994 - 1997 Pigs
2. StateS are implementing and enforcing adequate special waste
programs such that, to the maximum extent possible, Federal
intervention is not required.
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OSIER Strategic Plan TY 1994 • 1997 Peg.
OBJECTIVE 2.4 Industrial Subtitle D wastes are appropriately
managed in all States.
Os script ion
The size of the industrial non-hazardous waste universe is many
times larger than the hazardous waste universe. EPA is comnjtted
to characterizing this universe and exploring a range of
cost-effective program management structures that provide
incentives for waste minimization and improved waste managerient.
Strategy
By the middle of 1992, EPA will have scoped out a strategy for
characterizing the industrial D universe by (1) facility types
and sizes, (2) characteristics of wastes generated, (3) waste
management and minimization practices, and (4) existing
incentives for behavior. During 1993 EPA will gather and analyze
data needed to characterize the nature of potential risks
targeted during the scoping stage.
Following this effort, EPA will:
During 1994
o Work with States to develop a State lead strategy for
industrial non-hazardous wastes and facilities,
including any necessary enforcement elements.
o Identify State—lead implementation priorities.
Durina 1995
o Facilitate State .mpLementation, including enforcement.
o Facilitate implementation training with States.
During 1996—97
o Continue State impLe entatLon.
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OSWfl Strategic Plan PT 1994 1997 Page
Success Measures
1. States are implementing and enforcing adequate progra ts such
that federal intervention is not required.
2. Changes, ever time, in quantities of industrial Subtitle D
waste managed by various methods (incineration, land
disposal, etc. vs. recycling).
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OSWER Strategic Plan 1? 1994 — 1997 Page
OBJECTIVE 2.S Ensure the proper management of municipal solid
wastes in all States.
Description
By statute, States are responsible for implementing the
Subtitle D program under criteria and standüds developed by EPA.
The objective of Agency activities is to encourage steady
progress toward building virtually full State capability by 1995.
EPA and other Federal Agencies signed an MOU in 1991 regarding
responsibilities for solid waste managinent on Indian lands; as
part of our Federal trust responsibilities on Tribal lands, £?A
will provide assistance and necessary enforcement on these lands.
Strategy
1. Clearly define roles of States, Indian Tribes, Regions, and
Headquarters in Subtitle D implementation, permitting,
enforcement, compliance monitoring and State approval.
2. Assure States have the primary responsibility for
implementing this program.
3. Develop and maintain an expert technical work force in the
Regions and Headquarters to provide assistance to States,
particularly with adopting the revised Subtitle D criteria.
4. Work with the States to enhance their technical capabilities
and to promote timely and high-quality applications to
administer the municipal waste program. Process State
applications and approve adequate programs in a timely
manner.
5. Increase work with Tribes and other Federal agencies with
solid waste management responsibilities to improve or deve .:p
Tribal solid waste programs.
6. Use Federal enforcement where State or Tribal programs are
inadequate.
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OSWER etrategic Plan VT 1994 1197 pig.
Success Xeasurss
1. All States are approved to implement their own municipal
solid waste landfill permit programs by 1995.
2. All adequate Tribal municipal solid waste landfill permit
programs are approved.
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OBWER Strategic Plan FT 1994 - 1997 Page
OBJECTIVE 2.6 Make greater use of innovative technology for si.te
remediation and corrective action.
Description
Increasing the application of innovative technologies for source
control and ground water remediation is an integral part of all
of OSWER’s programs. Innovative technologies offer the potential
for increased options for cleanup levels achieved, the pernanence
of the action taken, or lower cost.
Strategy
Our efforts to increase use of innovative technologies are
predicated on improvements in the processes by which they are
developed, evaluated, selected, marketed, and implemented.
1. Improve communications and awareness about innovative
technologies among key players, domestic and international.
These groups include the Regions, States, responsible par .ies
and owner/operators, technology developers, consulting
engineers, ether Federal agencies, and the international
environmental community.
2. Identify disincentives for decision makers to develop and use
innovative technologies, such as regulatory and statutory
impediments, time delays associated with conducting
treatability studies, public uncertainty about new
technologies, increased cost in RI/FSs associated with
examining innovative technologies, lack of sufficient cost
and performance information, and the risks associated with
choosing innovative technologies with limited data.
3. Develop and implement an action agenda of activities
necessary to reduce or eliminate these disincentives.
4. Develop new and enhance existing incentives to reward risk
taking by industries that use innovative technologies. Do
the same for EPA decision akers who consider innovative
technologies in CERCLIA feasibility studies and select
innovative technologies in Superfund Records of Decisions cr
in RCRA and UST Corrective Actions.
5. Examine the extent to which incentives vary between CERCLA
fund-lead and enforcement-lead cleanups to ensure that
maximum incentives are being offered in both situations.
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OSWER Strategic Plan 1? 1994 - 1997 Pigs
Also, examine and address incentives and disincentives
existing in RCRA and UST corrective action programs.
6. Increase State and industry capabilities through focused,
multi-party technical assistance projects. Explore with the
States, professional societies, and trade associations
opportunities for exercising leadership in technology
innovation. Ensure States and industry have access to
comprehensive and current data on innovative technologies
including costs, performance, and market opportunities, both
domestic and international (with an emphasis on opportuxuties
in Eastern Europe and Pacific Rim nations). Improve
technology permit processes or conduct pilot projects with
States to help them evaluate and introduce innovative
technologies using sites and authorities under their direct
control.
7. Realize the potential posed by Federal facilities for the
• development and application of innovative approaches to
hazardous waste remediation. Work with the Regions to
encourage innovative approaches by Federal facility managers.
8. Utilize the Federal Remediation Technologies Roundtable to
maximize sharing of available Federal experiences and provide
opportunities for joint demonstrations or complementary
technology evaluations.
9. Encourage development and use of facilities where innovative
treatment technologies lacking full-scale performance data
can be evaluated in a timely and objective manner.
10. Extend demonstrations to innovative monitoring and
measurement technologies.
11. Provide States with revised LUST Trust Fund guidance to
encourage the use of innovative approaches to address
correctiva action at leaJc ng underground storage tanks sites.
Success Measures
1. Widely recognized and access b1e mechanisms exist for the
capture, synthesis, and dLsss Lnation of information on
treatment technology perfor anc.: and, market opportunities
are available, both domest caUy and abroad.
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OSWU Strategic Plan FT 1994 • 1997 Page
2. More technologies move from “innovative” to “available”
status due to:
o An increase in treatability studies as part of the RI/FS or
RF I / CMS.
o An increase in development and demonstration activity
especially by States and industry.
3. Innovative technologies are selected in increased percentages
of CERCIJI Records of Decision and Removal Action Memoranda.
4. Increased use of innovative technologies in RCRA corrective
action orders and permits and UST cleanups.
e
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OBIER Strategic Plan 1! 1994 1997 Page
OBJECTIVE 2.7 Ensure the long—term effectiveness of resportse
actions under Superfund.
Description
Before the 1986 Superfurtd amendments, many response actions
either reduced risk by controlling the migration of contaminants,
or left residual contamination. The amendments placed a higher
importance on more permanent solutions.
Strategy
1. Encourage the use of permanent remedies.
o Through technical assistance, guidance, enforcement oversight
and management measures, encourage the use of treatment
technologies that permanently reduce the volume, toxicity, or
mobility of significant contaminants.
• Develop and implement management systems and information
transfer mechanisms that promote (a) technology transfer to
the States and private industry to assist in development of
remedial alternatives and (b) more consistent remedy
• selections by the private sector.
2. Evaluate the effectiveness of remedies being used.
o Develop and implement a data collection and analysis protocol
to evaluate the long term effectiveness and reliability of
remedies.
o Conduct 5—year reviews of the effectiveness of actions.
Success X.ssur.s
1. Remedies are generally consistent with expectations of
cleanup goals.
2. Increased use of treatment technologies as a percentage of
the total Records of DecLsLon and Removal Action Memoranda
each year.
3. Five-year reviews of completed remedies show continued
effectiveness of remedies chosen.
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O8WE& Strategic Plan FT l9 4 — 1997 Page 37
4. Ir creased quantities of waste managed per nanent1y or
remediated.
-------
O$WZR Strategic Plan FY 1994 - 1997 Peg.
3, PR.! VU? Wl VL RELEAS 18
Accidental releases of petroleum and hazardous substances cart
be caused by a variety of factors, including human error,
equipment malfunction, and transportation accidents, and can
result in significant adverse health and ecological effects.
Because the extent to which a community is vulnerable to serious
emergencies depends on many different local conditions, States
and local communities, with EPA assistance, will be responsible
for implementing many aspects of this program.
OSWER’s third goal, preventing harmful releases of oil artd
hazardous substances into the environment, shares common elements
with several of the Agency’s key themes. In addition to its
inherent Pollution Prevention theme, this goal supports:
Education and Outreach through communicating accident prevention
practices to targeted audiences; Better Management by promoting a
holistic method for managing all elements of chemical process
safety (hazard identification, prevention plans and response);
Improved Science and Knowledge Base through developing arid
implementing technologies to improve accident prevention;
Building State and Local Capacity by providing guidance and
training to State and Local Emergency Planning Committees; and,
Geographic Targeting through a strategy to reduce the number of
harmful releases in high risk/high volume locations.
OBJECTIVI 3.1 Improve release prevention practices and
technologies.
D.scriptio
Congress recognized the importance of minimizing risk to the
public in the new accidental release provisions of the Clean Air
Act and the Oil Pollution Act of 1990. The Clean Air Act
provision, build on the SARA Title III requirements for
disclosure of chemical hazard information and the use of the
information to protect the pub1 ic. These are primarily State
programs. The Oil Pollution Act builds on Section 31.1. of the
Clean Water Act and is primar Jy a Federal program.
Strategy
OSWER’s strategy for improving accLderlt prevention practices and
technologies will focus on the sharing of information on the
causes of accidents and ways to prevent them, on stakeholder
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Cewu Itrat.gic Plan PT 1994 - 1997 Page 3g
initiatives to develop and implement creative practices and
technologies, and on the philosophy of continuous vigilance and
improvement. In sharing information, the Agency will identify
and use the most effective communication mechanisms for the
target audience and will work with other stakeholders in joint
efforts.
1. Continue to develop a consensus among stakeholders on the key
elements of risk management and prevention, and on methods
and approaches for taking prevention actions beyond the
minimum required by law. Establish a framework for the
development of reasonable guidance and regulations.
2. Meet the mandates of the Clean Air Act by promulgating
reasonable prevention, detection, correction and response
regulations and providing guidance useful to the regulatad
community.
3. Identify high risk chemicals and industries for the
development of creative prevention practices, techniques, and
technologies. Leverage resources by working with key
stakeholders, such as the American Institute of Chemical
Engineers and the American Petroleum Institute, to develop
and communicate these practices and technologies.
4. Build the capability of State Emergency Response Committees
and Local Emergency Planning Committees to understand and use
information on the management of chemical risks by providing
guidance and training in anticipation of Clean Air Act
requirements.
5. Encourage States to accept delegation of the Clean Air Act
prevention program and small business assistance program by
offering guidance, training and technical assistance. Focus
especially on the capabilities needed to use and audit risk
management plans. Approve sound and effective State
progxams.
6. Identify ways to encourage prevention practices among smalle
operations, which often do not recognize the hazards.
7. Work closely with international organizations and bilaterally
along our borders to identify promising prevention practices.
technologies, research, guidance, standards and codes and to
inculcate the principles of risk management into corporate
cultures. Implement the guiding principles on accident
prevention and Council Acts developed by the OECD and
transfer prevention principles to developing nations via
LINE?.
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OSWER Strategic Plan FT 1994 1997 Peg.
8. Identify approaches for measuring success in this area by
using the expertise of the Chemical Accident Prevention
Committee of the Administrator’s National Advisory Council on
Environmental Policy and Technology. This advisory body will
examine methods for evaluating program success and make
recommendations to the Agency on indicators.
9. continue to collect data on accidents involving high
risk chemicals and industries, a. well as information on
prevention and risk management practices.
During the coming year, we will be defining EPA’s
responsibilities for preventing petroleum releases under the Oil
Pollution Act and working with other Federal agencies in
executing their responsibilities.
Success Measure
An increasing number of major facilities have conducted
formalized hazard evaluations and developed and implemented risk
management plans to reduce the accidental releases of hazardous
chemicals and oil. We will be developing ways to measure the
effectiveness of these risk management programs.
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O8WER strategic Plan FT 1994 1997 Page
OBJECTIVE 3.2 Reduce the number of catastrophic or harmful
releases of oil and hazardous substances,
particularly to high risk/high volume locatior s.
D.scriptien
The recently enacted Oil Pollution Act shows a heightened
Congressional interest in “worst case” situations. These
incidents are also a major theme in SARA Title III and in sons of
the chemical accident prevention—related requirements of the new
Clean Air Act legislation.
In addition, in the Underground Storage Tank (UST) program, all
tanks must meet Federal leak detection requirements by 1993. The
TJST program will use these requirements as the foundation in
developing strong State compliance and enforcement programs.
Strategy
1. Implement regulations under the Oil Pollution Act for
facility response plans and review and approve
individual facility plans.
2. Work with States and LEPCs to focus on high risk/volume
locations.
o Identify environmentally critical or high—value
areas for special attention.
o Develop profiles of likely catastrophic releases,
such as industries that pose the greatest risks,
and focus investigations on attempting to find
such sites (i.e., Acute Risk Facilities) and take
appropriate emergency planning and enforcement
actions.
3. Work with States and LEPCs to identify and use
financial incentives for Lndustr es to prevent
releases.
4. Work with States to identLfy problems which, if not
corrected, could result tn future Superfund sites; and.
develop a strategy for addressLng these situations.
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OSWER strategic Plan FT 1994 1997 Page 42
Work closely across media and cleanup programs to
identify problems that may pose significant risks.
o Develop a targeted site discovery program for
early identification of Superfund sites.
5. Work with States to increase UST leak detection
compliance rates, either through direct Federal
enforcement or in conjunction with States, in those
areas with the largest number of tanks and lowest State
enforcement activity 1
Success Measures
1. The incidence and size of oil and hazardous substances
releases are continuously reduced.
2. The environmental damage resulting from these releases
declines ever time.
3. UST leak detection compliance rates improve over time.
I
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Oawu strategic Plan FY 1994 — 1997 P eg• 43
4’ PUPAR3 FOR M D DJSPOWD TO ThZARDOUS mIASIB
Harmful releases may occur at (1) facilities that currently
treat, store, or dispose of hazardous wastes, (2) sites that
previously handled hazardous wastes, and (3) facilities handling
petroleum and hazardous substances. EPA, the States, and
responsible parties are required to clean up hazardous sites or
releases under CERCLA and RCRA. In addition, the new Oil
Pollution Act strengthens Federal authorities under the Clean
Water Act to handle releases from operating petroleum facilities
and transporters.
OSWER’s fourth goal is to prepare for and respond in a
timely and effective manner to releases of hazardous materials
into the environment. Our strategy for achieving this goal
supports these key themes in the Agency—wide Strategic Plan:
Cross-Program Integration through our emphasis on batter
integrating OSWER’s, and the Agency’s, cleanup programs; Improved
Science and Knowledge Base by fostering the use of improved
cleanup techniques and technologies, and collecting population
exposure data; Build State Capacity through enhancing State and
local capability to oversee and manage cleanups, and providing
guidance and training to State and local emergency planning
staff; Better Management by using TQM to streamline the
corrective action process for leaking tanks; and, Education and
Outreach through ensuring broad community involvement in planni.ng
for and responding to hazardous chemical and petroleum releases.
OL7ECTIVI 4.2 Better integrate OSWER’s cleanup programs.
Description
In design and purpose, CERCLA, the Oil PollutionAct, RCRA’s
hazardous and petroleum waste subtitles, and certain aspects of
the Clean Water Act created cleanup programs that address similar
problems. Yet, policies, regulations, procedures and other key
components are often developed separately by each program,
leading to inefficiencies. Therefore, OSWER will work to
integrate the relevant aspects of these programs to ensure the
wisest us. of EPA and State staff and resources. In addition to
the OSWER-specific activities descrLbld below, OSWER has lead
responsibility for the cross-Agency nLtiative on contaminated
media.
-------
OUER Strategic Plan Fl 1994 — 1997 Page 44
$ tx ’s t .gy
Prior to Fl 1994, OSWER will:
1. Complete the Environmental Priorities Initiative,
2. Develop joint CERCLA/RCRA strategy and policy on lead
in soil cleanups,
3. Develop joint policy on cleanup of ground water
contaminated with DNAPL’s, and
4. Develop better integrated technical training programs.
1994 — 1997
As new cross—cutting issues arise, OSWER’s remedial programs
will work closely together to develop integrated policies,
standards and training programs to address them.
Success Measures
1. More efficient management due to consistent program
• guidance in key policy areas.
2. Shared staff knowledge and expertise.
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OSIER Btrat.gic Plan FT 3.194 1997 Page 45
OBJECTIVE 4.2 Improve identification and remediation of
hazardous and petroleum waste sites.
Description
A major theme identified in the Science Advisory Board
Report, the Superfund Management (“90 Day”) Study, the
Superfund 30 Day Study, and the RCRA Implementation Study
was the need to identify and address the worst sites first,
while accelerating cleanups. Both the cost of clean up and
the length of time to complete cleanup are far greater than
were initially anticipated. As OSWER’s cleanup programs
continue to develop, we must (1) reduce costs at sites, so
that more sites can be addressed each year, (2) reduce the
time from identification of contamination to effective
response, (3) and focus on the highest risk sites first.
Strat.gy
1. Develop a risk-based approach that standardizes
Superfund risk management decisions and uses comparable
standards and criteria across programs to identify the
most environmentally significant facilities or sites.
Use the Environmental Priorities Initiative to speed
identification of priority facilities or sites.
2. Continue to implement RCRA site stabilization strategy.
3. Streamline remedy selection process through increased
standardization of key components and the development
of presumptive cleanup standards.
4. Focus Federal and State cleanup resources on the
highest risk sites. But, recognize that States may not
always be able to address the highest risk sites first
because of the transact ona] needs of the regulated
community.
5. Move the worst portions of the highest risk sites into
cleanup or response quLck y.
6. Provide rapid remedial respons. capability in
redesigned emergency response contracts to accelerate
cleanup of NPL sites. Red .ace program management and
overhead costs in Superfund contracting.
-------
OSIER atrat.qic Plan FT l 94 — 1157 peg. 46
7. Increase use of CERCLA enforcement authority to
accelerate remedial actions.
8. Continue biennial assessments at NPL sites to identify
immediate threats and ensure sites are safe.
9. Develop owner/operator performance standards for
responsible party cleanups.
10. Identify, foster, and rapidly spread the use of faster
and more effective cleanup techniques and technologies
to sites, responsible parties, and cleanup contractors.
11. Ensure timely and efficient implementation of Potential
Responsible Party (PRP) remedial action projects
through accelerated CERCLA enforcement actions and
enforcement oversight.
12. Increase involvement by responsible parties in
implementing response/remedial actions through use of
CERCLA enforcement tools and techniques.
13. Enhance State and Federal capability to oversee
responsible party cleanups.
14. Under the integrated time line, use enforcement and
permitting tools to reduce the use of RCRA and State
funds for clean up.
o Improve C CLA potentially responsible party
searches through guidance and training.
o Issue model orders for all response actions and
evaluate them to improve their effectiveness.
o Increase use of unilateral administrative orders
as necessary to accelerate PRP cleanups and
settlements
15. Increase use of CERCLA enforcement authorities to
facilitate timely settlement and accelerate responsible
party cleanups.
16. Increase reimbursement/cost recovery of Superfund Trust
Fund dollars by aggressively seeking treble damages and
indirect costs where applicable.
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OBWER Strategic Plan PT 1991 — 1997 Page 47
17. Continue to streamline the processes and reduce the
time required for corrective actions at leaking
underground storage tank sites.
Success Niasur..
1. Demonstrable annual progress toward achieving faster
time frames, including, for example, decreased time
from initiating an investigation to commencing the
initial response or remediation and decreased overall
time from site identification to final response or
remediat ion.
2. Reduced average cost over time with no loss of
effectiveness.
3. Increased number of environmental pathways in which
environmental progress is documented annually.
4. Reductions in costs to manage waste.
5. Reduced time required for PR? settlements and PRP lead
cleanups.
6. Increased number of Superfund Memoranda of Agreements.
7. Annual increase in the number of sites addressed with
removal or stabilization actions.
8. Increasing percentage of response/remedial actions
taken by responsible parties.
9. Site completion targets are met.
10. Increased percentage of compliance by PRP5 with
enforcement actions.
11. Increased number of CERCL.A pre-remedial and remedial
settlements with PRP5.
12. Earlier and more numerous CERCL.A settlements with
collaterally responsible parties (i.e., De Minimis ,
municipalities).
13. Increased pursuit of cost recovery actions against non-
settlors and non-compliers.
14. Increased level of Superfund costs recovered.
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081!R Strategic P1a VT 1994 — 1997 Paqi 43
15. Steady decrease in LUST trust fund sites as a
percentage of total underground storage tank sites.
16. Increased number of nigh priority sites with RFIs,
CN$5, work plans, stabilization or actions initiated
(RFIS imposed/completed, Corrective Actions
begun/completed).
e
-------
OSWER strategic Plan PT 1994 1997 Page 49
OBJECTIVE 4.3 Enhance State capabilities to clean up
hazardous and petroleum waste sites.
Description
States play a crucial role in cleaning up the nation’s waste
sites:
o In the underground storage tank program, States perform
a fundamental role;
o Congress intended RCRA Subtitle C corrective action to
be delegated to the States; and
o The Superfund program has been building toward
developing State-run programs so that more sites can be
addressed sooner.
Over the next five years OSWER will place increasing emphasis on
enhancing State capabilities to manage day-to-day operations.
Strategy
1. Establish the Agency’s position on the States’ role
under CERCLA. Determine whether Superfurtd is
essentially a Federal program in which the States play
a major but supportive role, or whether Superfund is a
shared program in which States can take en a lead role
like that available under RCR.A.
2. Assist States in building capabilities through core
program cooperative agreements, training, staff
exchanges and pilot projects.
3. Encourage the development and routine updating of
Superfund Memoranda of Agreements (SMOAS) to ensure
mutually satisfactory worki.ng relationships between
Regions and States.
4. Authorize more State corractLVe action programs under
HSWA. Assist States in app y ng for authorization and
streamline the applicat ort precise. Clarify roles of
Headquarters, Regions and States i n the authorization
process and more fully deL.gats authorization decisions
to the Regions. StandardLze cr tLcal authorization
criteria and communicate to key players. As discussed
in Objective 4.1, there is a close connection between
-------
O8TER atrat.qic Plan FT 1994 — 1997 Pegs 50
the RCRA and Superfund programs; delegation of HSWA
corrective authority could support other actions
associated with delegating Superfund program
responsibilities.
5. Identify State and Regional impediments to increased
involvement in terms of resources, staff, and technical
expertise. Provide strong technical assistance in
addressing these impediments.
Succsss Measur..
1. Continuous increase in the number of States running
Superfund and the various RCRA programs.
2. Increasing number of States authorized to manage the
RCRA Subtitle C corrective action program.
3. Increasing number of States with approved programs to
manage the LIST Subtitle I program, as well as further
development of the well-established working programs
not yet approved.
4. For non—delegated States, increasing State resour:es
dedicated to augment existing Federal programs.
5. Increasing number of State-conducted non-NPL response
actions.
6. Enhanced State capabilities resulting in:
a. increases in quantity of contaminated media
managed (treated, contained, or removed), and
b. increase in amount of ground water pumped and
treated.
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O8WER Strat.gic Plan PY 1994 - 1997 Pag. 5].
OBJECTIVE 4.4 Improve the preparedness of Federal, State, and
Local entities to respond to releases of
petroleum and hazardous material into the
environment.
D.ecription
Accidental releases of oil and/or hazardous substances can happen
anywhere and at any time. Federal, State, and local responders
must be prepared to handle releases of oil and hazardous
materials into the community. Local communities, in particular,
must be prepared since in most cases they are the first on the
scene.
strategy
Under Title III of the Superfund Amendments and Reauthorizat .cn
Act of 1986, States and communities have the primary
responsibility for developing and implementing emergency planr .rg
and response programs. The Federal role is to support State and
local programs and to provide a national capability for
responding when events exceed State and local capabilities.
1. Use information on chemical hazards more effectively to
prepare for and prevent chemical accidents. Develop and
support Title III information management systems such as
CAMEO for us. by State and local planners and responders.
2. Help State Emergency Response Commissions and Local Emergency
Planning Committees increase their capabilities by providi.ng
the proper technical assistance, training and guidance.
3. Coordinate a consistent training and technical assistance
program for States and local communities.
4. Develop, improve, and test Federal plans for responding
hazardous material releases.
5. Improve the operation and •tf.ctiveness of the National i-i
Regional Response Teams by iax s1zLng the involvement of
States and by increasing State, local, and private-sect:
awareness of the National Response System.
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OSWfl Strategic PLan FT 1.994 - 1997 Pig. 52.
6. Improve EPA’S response coordination for significant hazardous
materials emergencies through continued support of the
National Incident coordination Team and its Emergency
Operations Center.
7. Take enforcement actions and support State enforcement
capabilities as necessary to increase compliance.
8. Develop and collect data for environmental indicators to
assess (a) the number of people protected as a result of
actions taken to control actual or imminent exposure, and
(b) changes in the number of people exposed or potentially
exposed to contaminated ground water, surface water, soil
and air.
The Oil Pollution Act of 1990 establishes a primarily Federally
managed program to address releases of petroleum. We are
defining EPA’S responsibilities for responding to petroleum
releases under the Oil Pollution Act and working with other
Federal agencies in executing their cleanup responsibilities.
Regions vii ]. be developing area response plans for petroleum
releases, and will coordinate with State and local plans and work
with all oth.r concerned parties. EPA will also be developing
guidance for and implementing new, strengthened enforcement
authorities provided by the Act.
success Measures
1. By 1995, all State Emergency Response Commissions and 90% of
all local emergency planning committees vi].]. be operating
effectively. For State commissions, “operating effectively”
means among other things:
• coordinating and supervising local committees (ensur .ng
they in turn are “operating effectively”);
o having active technical assistance and training
programs to support the local committees;
o managing Title III data and making it available to the
public;
o reviewing and comment ng on local plans to foster
improvements;
o undertaking compliance and enforcement activities; and
o ensuring broad communLty involvement.
-------
APPENDIX
Current and Potential Environmental Indicators
-------
POTENTIAL RCRA ENVIRONMENTAL INDICATORS
q
-------
SUPERFUND ENVIRONMENTAL INDICATORS
A. Reduce Immediate Threats at NPL and non-NPL Sites
Possible data sources:
- sites with removal, treatment or containment
- sites with alternate water supply; number and type of
people
- sites with population relocated; rtwnber and type of
people
— sites with security provided (fences, guards, etc.)
B. NPL Sites with Progress Toward Permanent Cleanup Goals (fully
achieved, partially achieved and cleanup underway)
Data sources: land, surface water and groundwater
C. Amount of Contaminated Materials that have been Treated,
Stabilized or Disposed of at MPL and non—NPL Sites by Bringing
Technology to Bear
Possible data sources:
- volume of waste handled
- sites with treatment technologies applied
- categories of primary contaminants addressed
-------
EXHIB [ T ES.I.
SHORT-TELSI RCRA INDICATOR CATEGORIES
Finalize Us: of shorr.term indicators in Octo6er 1991
Begin gathering data in Novem&r 1991
Begin reporting in cem r 1991
RCRA Cate o, of Indicators
Program Goal
Wait. Trends In Waste Quantity Generated
%lin lm lzat ion
Examples:
• Changes in quanzuy of wane genernze4 by zndusoy, by e.. ‘io’-”ia! ed v
per capita. pr ucnon 4 or value added.
• Changes in mwuclpal solid waste manag,me,v.. companso ts of landfillhng.
incincranon. recycling, and source reduction razes over nm.
Safe Quantity and Percent of Wait. Managed by Method 1 by Type of Wait.
Management
£sampks:
• Changes in quantities of waste incinerated, land d tpose4 recycied etc. o’.er
rune.
• P ofiLu of the change from land.based to tankage.based management.
• Changes in the quantities of waste noted pnor tolar4 disposaL
• Quantities of lai’44isposed wastes managed in nwumwn tecMolo 4flUS.
Number, Percent, and Status of Facilities Monitored sad Evaluated
- M niber of faQilnes with adequate grouiid-waw ’ monizonng systems.
• Wwnber of faciLities Zn detection or compliance nioiwonng and beyond.
- Nwnher of faciLities with rio fwther action after an RFA or RE!.
Corra 1In Number and Status of Auessment, Stabillatlon, and Clesnup Actions
Action Initiated or Completed
Exampk.
• Nwnber of hzf#u p’tcvuy sues with RF!& CMSs, w * plaits, or acUcrs
initiated or comp ted.
DRAFT. November 2, 199* - sir Internal R.’1 Only’’’
-------
E !IB [ T ES.2.
MEDILM.TERM RCRA ND CATOR CATEGORIES
Dew/op Us: of ‘nos:pronnwtg indicojor by December 1992
Develop xwuta1 implementation plan by Decem 1992
Poutbiyrepoesii. F l 1993 or Later
RCRA
Program Goal
Category of Indl ton
Waste
Minimization
•
.
Number of Waits Streams and Quantities of Some Specific Wastes Addressed by
Waste Minimization Programs
£rwnples
• Qua?uuy and number of hazardous waste szreantz subject to source reducno,
and recyc1zn
• Qisannsy of municipal waste subject to source reduction and re ckng by
waifs meam.
‘Number of Entitles Implement ing Waste MIalmIzitlo. Piugrims
£rampie.
• Number of hazardou, w4flf generozoir with source reduction progranu. o
• method (C g.. hou.selceepi.ng vs. process change).
Quantity of Waste Prevented Due to Waste Minimization ActMt les
£ramp /e.
• Qua uw,’ of waste avoided due to wage minimization, by industry. waste.
Safe
Management
Number and Percent of Facilities Using Designs, Operating Methods, and
Closure Practices that Minimize .leam
£
• Number and percent of opereu&ng and closed land-based regulated units vith
minimum :echnolo ’ deszps.
• Number of incznera:oir ii’ h acceptable air pollution con#o/s in place.
• Number of inactive units lid facüwes that have completed adequate closure.
by facility catqof .
Corrective Quantities of Waste or Co.te.iaated Media Treated or Removed
Action
£ramples.
Quantity of consartwta:ea -w iced (treate4 contained. rernoved
Gallons of ground ware’ .ri vea ‘a treated.
s DRAFT- “lov.mber 2, 1991 • I” Internal Revies 0e1y’
-------
E I1BIT £5.3.
LONG ER.TERM RCRA IN DlC TOR C TEGO RIES
Refine uithcawr categoric and idennfr most p’vm&iutg iiidãcatori by December 1992
Conduct pilot sDAdies ta axseas data availabiliiy Janua,y - June 1993
Report on resulis of pi 1 ce sasdies and pr*s.ri proposal for ‘taflonal rrpo, ng of select rndicato, by
December 1993
Col1 data and begin ‘eporring in FT 1994 and byond
RCRA
Program Goal
Category of Indicators
WOSIC
Minimization
Trends In Waste Toxicity
Examp les.
• Changes ut the generazzen of acwe hazaFdogdf wastes.
• Mass of hazardous coiirnxuents discharged in wastes.
• Changes ui torscwj/conce&ranone as a result of waste u”t iz non pro’ec:s.
Safe
Management
Number and Percent of Facilities Located In Areas bat Minimize Releases.
Exposure, and Eaviroimental Damage
£zarnp les:
• Number and percent of acnt’e and inactive facilities located ui senszn ’e
CAVVOAPPI CALS (e.g., /loodplauts, wetlandi).
• Population denmies swrowiding facilities by indwzzy, operannq status.
nwnber of uicwrazoi with acceptable air pollution conifots in place.
- Nwnber of inactive wuu and facilities that have completed adequate
closure, by facility cazegoty.
Releam and Naturwl.xtaatof Coetamludon from Wast Management
£ramp les:
• Number and percent of facilities w h off-sue ground-water con:amuiazion.
• Number and percent of facilities with ground-water concentrations in e.rcess
of accepted standards e g. MCLs. Subpart S action levels.
- Number of spttlt. apdo.uont. or irar sportanon accidents resulting in releases.
Waste Management Capscie
Lwmp le
- Capacity by t pe .‘ .‘ue “.“ ngentenL . by State, and by type of waste.
(Safe management indicai:r .c ’t c on the next page.)
‘ ‘DRAFT- November L 1991 . nr Internal Review Only’’’
-------
coørr £S4 ( It) —
LONG .1tLS1 RCL C4D(CATOR CATEGORIE3
RCRA Cataory 01
P ç.a Coil
5th Occwi.., Q sm , L To dt7 01 Ril uis bos S(uqe.eii Facilities
MUISS.sIt
(essi)
• Ca an uo and of co.vanwwna ut ,uwidwasr ç z ,$om
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6
,\ \ ,cOS? 4 ,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
Q I 1 8 1991
MEMORANDUM
SUBJECT: Final Criteria for Approving FY92 Regional State
Improvement Projects and Final UST/LUST Goals
in Priority Program Areas
FROM: David Ziegele, Director
Office of Underground Storage T nks
TO: Regional Program Managers
We have incorporated comments received on the October 4
memoranda that presented DRAFT criteria for approving FY92
Regional State Improvement Projects and DRAFT UST/LUST goals in
priority program areas. You will find FINAL copies of these
two documents in Attachment 1 (Criteria for Approval) and
Attachment 2 (UST/LUST Goals).
I want to thank those who commented on the draft documents
and report briefly some of the comments. The only comment
regarding the Criteria for Approval addressed the relative sizes
of the discretionary and priority pots. Although this commenter
felt the discretionary pot needed to be larger to produce more
State program development projects, I believe we need to stick to
our commitment to the national priority areas, which have been
identified as areas needing special focus because they are not
otherwise receiving sufficient attention.
The primary comments on the goals for priority program areas
noted that the FY92 goals and measures were announced too late
(especially relative to grant negotiations with States) to allow
RPMs to address them successfully in FY92. However, I believe
the consensus at Cape Cod was that we need to do what we
reasonably can during the current fiscal year, while admitting
that we would have been in a better position to do more if these
goals and measures had been firmly in place earlier. As a result
of the work we are doing now regarding project and goal planning,
we will be positioned more effectively next year to coordinate
grant negotiations and priority program goals.
EJST/PM/PG/91—1
Pnnted on Recycie Paper
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—2—
A concern was also raised regarding the feasibility of the
reporting measures for release detection. We agreed at Cape Cod
to do the best we could this fiscal year in terms of reporting
data, with the realization that the data would be soft in spots.
Nevertheless, we wanted to begin focusing on release detection
data as a means toward making more informed planning and
management decisions in the future.
Finally, I want you to know that I am sending your Regional
UST Branch Chief (under separate cover) a copy of today’s
memorandum. Again, thanks to all of you for contributing at Cape
Cod and elsewhere toward the development of the attached final
documents.
Attachments
cc: OUST staff
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ATTACKMENT 1
CRITERIA FOR APPROVAL
FY92 Regional State Improvement Proj eats
(October 18, 1991)
As we agreed at the Cape Cod RPM meeting, each Region has
access to two initial funding pots in FY92:
* A discretionary pot of $20,000, and
* A priority pot of $80,000
The discretionary pot allows Regional Program Managers maximum
flexibility in identifying projects they feel are necessary to
develop State UST/LUST programs. The priority pot focuses Agency
resources on three national priority program areas: corrective
action streamlining and new technologies; leak detection
compliance and enforcement; and State program approval. To
reviQw the priority areas, please refer to the attached final
FY92 goals and measures of progress for the three national
priority program areas.
Additional funding for priority projects may be available by
April 1992, if some Regions have not made use of their initial
allocation or if Headquarters identifies carryover money that can
be used for Regional projects.
Criteria for Discretionary Projects
Projects being funded from the $20,000 discretionary pot
need to meet minimal approval criteria:
* Project must be dedicated to improving State performance
* Regions must commit adequate staff time to oversee and
manage the project
Examples of approvable discretionary projects appear on page 5.
Criteria for Priority Projects
Projects being funded from the $80,000 priority pot need to
meet some additional criteria beyond those required for
discretionary projects:
—1—
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* Project proposal needs to show how the project will help
a State meet one of the three national priority goals
* Project proposal needs to indicate how the progress
of the project will be measured or documented
Examples of approvable priority projects appear on page 5.
Mechanism for Proposing Projects
You will find on the next page a short form that will enable
Headquarters to decide quickly if a proposed project meets the
approval criteria described above. (The form as it appears on
page 3 includes explanatory notes; a “blank” version of the form
appears on page 4 and can be photocopied for your use.) Ideally,
there should be no major mismatches between Headquarters’
expectations and what you have proposed. If we feel that a
proposed project does not clearly meet approval criteria, there
is an opportunity for discussion (by telephone) to resolve the
problem during the negotiation process in December.
A few narrative sentences should be sufficient response for
the information requested on the proposal form. The limited
space provided on the form should allow you to use only enough
specific detail to clarify your response. Some examples of the
kind of responses that would communicate most clearly your
expectations for the proposed project appear on pages 5 and 6.
Once you have received approval for a project, you will need
to begin the Agency’s standard paperwork by preparing (as you did
last year) an action request form and statement of work for each
work assignment (or a change request for reprogramming). We will
be preparing a brief guide to processing an approved project from
action request or change request to completion of project. This
guide will be available by the time you need it in late December.
—2—
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PROPOSAL FOR FY92
STATE IMPROVEMENT PROJECT for Region _______
1. Which State or Stat.. will participat. in this project:
2. A. Cost of project is: ____________
B. Indicat, anticipated funding vehicle:
EQ contract _____
Stat. grant/cooperative agreement
Other ( identify )
3. Circle project type: Discretionary or Priority
(Note: for discretionary projects, you do not need to
answer questions 6 and 7 below]
4. A. If this is a discretionary project, briefly describe the
proposed project’s purpos. and customer;
B. If this is a priority project, how will the project help
the State meet one of the three national priority goals:
(See pages 5 and 6 for examples of how questions 4-7
might be answered]
5. Who in the Region will manage the project; how much of this
person’s time will be dedicated to the project; and when will
the project begin and end (approximately)?
(Indicate here Regional staff in FTEs and, if
possible, by name. At this point, you should be
reasonably sure that the State will also commit
adequate staff to this project. In addition, indicate
the approximate duration of the project by giving
anticipated start-stop dates]
6. How was the need for the project determined:
(Indicate here how you identified the appropriateness
of this project in meeting the program needs for a
particular State]
7. How will the project’s progress be measured or documented:
(Indicate here the kind of practicable follow-up that
would demonstrate what effect the project has had]
—3—
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PROPOSAL FOR FY92
STATE IMPROVEMENT PROJECT for Region _______
1. Which Stat, or State. will participate in this project:
2. A. Cost of project is: ____________
B. Indicat, anticipated funding vehicle:
EQ contract _____
Stat. grant/cooperative agreement
Other ( identify )
3. Circle project type: Discretionary or Priority
(Note: for discretionary projects, you do not need to
answer questions 6 and 7 below]
4. A. If this is a discretionary project, briefly describe the
proposed project’s purpose and customer;
B. If thi. is a priority project, hew will the project help
the State meet one of the three national priority goals:
5. Who in the Region will manage the project; how much of this
person’s time will be dedicated to the project; and when will
the project begin and end (approximately)?
6. How was the need for the project determined:
7. How will the project’s progress be measured or documented:
—4—
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Examples of Responses to Questions on Proposal Form
4. A. If this is a discretionary project, briefly describe the
proposed project’s purpose and customer:
* The State has recently hired several new inspectors to
monitor tank installation. This project will provide
training so that the State can educate inspectors on
proper tank installation.
* The State wants to begin collecting annual tank fees, but
the notification data base has not been updated in three
years. This project will provide contractor support to
conduct a renotification effort and the subsequent data
entry.
4. B. If this is a priority project, how will the project help
the State meet one of the three national priority goals:
* This streamlining project will help the State document
its existing cleanup oversight processes, and identify
opportunities to improve the process by eliminating waste
and delays. If additional funding is available in April,
we will propose implementing some of the improvements
identified in this project.
* This leak detection training project will help State
inspectors prepare for an inspection and enforcement
initiative in several counties having the majority of the
State’s tanks.
* No standardized requirements exist for owners/operators
explaining what they need to include in a corrective
action plan (CAP). This project will enable a contractor
to survey other States with standard CAP guidelines,
present findingB and recommendations to the State, and
work with the State to produce guidance and outreach
materials.
* This project will enable a contractor to review the
State’s capabilities to meet the seven SPA performance
objectives necessary for the State’s application for
State Program Approval.
5. Who is committed to carrying out the project:
* Project will use one Regional staff person half time for
6 months (0.25 FTEs), probably using Dan Doright, with
some assistance from Debbie Dogood.
—5—
-------
6. How was the need for the project determined:
* This State is one of the “MasterCard” states with very
low activity in leak detection enforcement and
compliance. At our request, they have agreed to do a
compliance mailing.
* In last year’s streamlining project, staff and management
in the State agreed with us that one of the biggest
delays in their cleanup process was soil disposal
permitting. At that time we committed to design and
implement some improvements this year based on a new
approach to soil disposal permitting being used in
another State.
7. How will the project’s progress be measured or documented:
* The leak detection training course will be delivered to
at least 20 inspectors; training participants will
evaluate the course at its completion; and Region will
monitor the progress of the State’s enforcement
initiative.
* In follow-up actions, the State will monitor how l ong it
takes them to review and approve corrective action plans
and they will aggregate the data they collect in a graph
that they will update monthly.
—6—
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FY92 Process at a Glance
October 4, 1991 RPMs receive DRAFT “Criteria for Approval”
October 11, 1991 RPMs’ comment on DRAFT received by HQ
October 18, 1991 RPMS receive finalized “Criteria for
Approval” and begin identifying FY92
projects. RPMS can use desk officers for
advice on clarity and completeness of
proposals.
December 6, 1991 Proposals due at HQ from RPMB
(To ensure fairness of the process and
consistency of decisionmaking, this
deadline must be firmly held)
Late December 1991 RPMs receive approval from HQ and begin
processing action request form and
statement of work for work assignments
(or change request for reprogramming)
Late April 1992 Region must have demonstrated progress
toward project start-up (not yet defined]
to secure committed funding; otherwise,
money for that project will be returned to
communal pot to be made available to
others. HQ will assess status of projects
and inform Regions if additional funding is
available. If funding is available,
Regions can submit additional project
proposals using the FY92 Project Proposal
forms.
June 1992 Review the FY92 process and approval
criteria for fine tuning and improvements
Early October 1992 RPMB’ proposals due for FY93 improvement
(possibly earlier) projects; process can begin early since
approval criteria and general process now
clearly understood
Late October 1992 HQ decisions regarding FY93 projects can be
(possibly earlier) made not long after the beginning of the
fiscal year
—7—
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ATTACHMENT 2
U8T/LU ST GOAL8 IN PRIORITY PROGRAM AREAS
(October 18, 1991)
The following goals in priority program areas will serve as
a road map for us as we undertake our work in FY92 and future
years. Also, these shared goals will ensure a connection between
your Regional improvement projects and the FY92 goals and
measures of progress. Listed below, for each of the three areas,
are the long-term goal, the FY92 goal, and the FY92 progress
measures,
State Program Approval
Long—Term Goal -- Approve all States and territories by FY 1995
(with recognition that a few may take longer)
FY92 Goal -— Increase current pace of program approvals
FY92 Progress Measures -- Use revised checklist developed for SPA
study; complete it early in year and at end of year for national
progress assessment.
Release Detection Com 1iance and Enforcement
Long—Term Goal -- Make proper leak detection a routine part of
UST ownership and management
FY92 Goal —— Increase the compliance and enforcement activity in
States with the largest number of USTs and low State enforcement
activity (“MasterCard States”).
FY92 Progress Measures -- “Yes/No” checklist to be developed by
HQ; will be completed early in year as “snapshot” and compared to
data reported quarterly by States for national progress
assessment. It is acknowledged that State data may be rough
during the early reporting periods.
Corrective Action Streamlining
Long-Term Goal -- Make cleanups faster, cheaper, and more
effective, in order to improve protection of public health and
the environment, reduce the backlog of sites requiring cleanup,
and minimize the adverse economic impacts of UST releases.
—1—
-------
FY92 Goal -—Improve the capabilities of regulators, the cleanup
industry, and the regulated community to do corrective action by
increasing the use of new technologies and streamlined approaches
for site assessment and remediation.
FY92 Progress Measure. -- To keep track of the following:
o The number of confirmed releases, cleanups initiated,
and cleanups completed.
o The number of States with ongoing efforts to streamline
their corrective action programs;
o The number of corrective action improvement projects that
have produced documented improvements;
o The number of States hosting corrective action training
or technology demonstration projects, or who are revising
their guidance to encourage the use of new technologies
or corrective action approaches.
Regions will do “snapshot” early in the year; RPMs and desk
officers will update it semiannually.
—2—
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United States Office of S0IId Waste and EPNG8.O1 .7259
Erwlrcnmentah P otecdon Emetgency Reepones March 1990
Agency Weshinglan, DC 20460
EPA Office of Solid Waste and
Emergency Response :
Annual Report, Fiscal Year 1989
UST/PM/FG/90- 1
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CHAPTER 5
UNDERGROUND STORAGE TANKS
Over five million underground storage tanks (USTs) containing petroleum products or
hazardous chemicals are in use in the United States. Approximately two million of these tanks
have come under ACRA Subtitle I regulations; about 15 percent of these regulated tanks
(300,000) are estimated to be leaking (see Exhibit 13). The Office of Underground Storage
Tanks (OUST) has worked with local and State governments to develop a national program to
address this problem.
During FY 1989, the major regulatory framework for the national UST program was
completed: technical standards, State program approval, and financial responsibility
requirements went Into effect OUSTs primary regulatory activities during F? 1989 Consisted
of developing a proposed rule that provides local governments with an assurance mechanism
to comply with financial responsibility requirements. frJso durIng 1989, OUST undertook a
variety of activities to build and Implement an effective LIST program nationwide. This report
describes OUSTs major efforts this fiscal year In the are of regulatory sctMty and program
implementation. The description of these activities foa .ises on two underlying principles on
which OUST believes that the LIST program must be built - ‘franchising’ and ‘continuous
improvem.nr.
ExhIbi 13
Number of R.giiatsd and Lsidng
Underground Storage Tanks in U.S.
5 rraon
40% (2 nmw )
18% (300 .000)
IofiUSTsILk fed5tat,s.5rn& n
Asg’ w r c A IS I Mted lISTs e sd to be Isskk g
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Franchisins
OUST’s application of franchising principles to the UST program is based on the belief
that the work done by State and local governments Is the key to Improving tank management
over the next decade. In the long run, State and local government regulation of UST systems
will be more successful than Federal regulation. This Is true for several reasons: the large
number of facilities to be regulated; the special characteristics of the regulated community; and
the nature of the regulatory work to be performed. Franchising works by using the strengths
and knowledge of both the franchisees - the State and local programs that ‘run the business’
day-to-day — and the franchiser — in this case, EPA, who delivers national advertising, policy,
and crucial support services. The franchising approach differs from most other EPA regulatory
program approaches in that it emphasizes the States’ role In enforcing regulations and
developing innovative ways to further improve the national program, while pladng EPA in a
role that emphasizes support of the State programs.
Continuous lmorovement
The other cornerstone on which the OUST program Is being built is ‘Continuous
Improvement,’ or, ‘Total Quality Management” (TOM). Continuous Improvement Is based on
several key concepts that OUST believes will contribute significantly to Improving UST
management These indude focusing on the customer - those for whom EPA or a State or
local agency Is providing a seMce or product; relying on the experts - those in the office or
in the field who actually do the work; analyzing work processes - understanding how the real
work of tank regulation and management gets done; and continuously improving those work
processes to eliminate wasteful activities and thereby reduce time spent on the process.
REGULATORY ACTIVITiES
Technical Standards
The Federal technical standards rule for UST systems went into effect on December 23,
1988. This rule establishes standards for design, construction and Installation; general
operating requirements; release detection standards; release reporting, investigation, and
confirmation; release response and corrective action requirements, and out.of .seMce UST
systems and closure requirements. The release detection requirements for tanks Installed
before 1965 took effect December 23, 1989; those for tanks installed between 1965 and 1969
become effe in December 1990. PublIcation of the new requirements was accompanied
by a major outrch campaign that included numerous slide presentations and the distribution
of over 200,000 copies of a booklet entitled ‘Musts for USTs, ’ which summarized the
requirements In simple language.
State Prowam Anorcvi Standards
The State Program Approval rule also went into effect December 23, 1968. ThIs rule
establishes requirements for the approval of State UST programs to Operate in lieu of the
Federal requirements. The criteria for approval of State programs are designed to result In as
little unnecessary disruption to ongoing State initiatives as possible. To meet program
approval requirements under the rule, States must have In place requirements that meet
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36 -
Federal objectives for each of seven program elements. The regulation provides flexibility for
evaluating the stringency of State regulations and the adequacy of enforcement under State
programs. Through this approach, OUST is seeking to maintain its flexibility to approve a
variety of State programs and to encourage States to use innovative as well as traditional
approaches in achieving compliance.
FinancIal Res onslbllitv
The final financial responsibility rule was published in the Federal Register on
October 26, 1988, and went into effect In January 1989. This rule requires owners and
operators to have sufficient resources to pay for the clean up of leaks and spills. In addition,
the rule requires that funds be available to pay.for the costs of third-party damages associated
with petroleum releases. In January 1969, the requirements were In effect for all petroleum
marketing firms ownIng 1000 or more USTs, and all large ($20 million or more net worth) non-
petroleum-marketing firms. In October 1989, the requirements became effective for all
petroleum marketing firms owning 100-999 USTs; In April 1990, firms owning from 13 to 99
USTs will be Induded, and in October 1990, all remaining facilities. Publication of these
requirements was accompanied by a major outreach campaign that Included, among other
activities, the distribution of over 200,000 copies of the booldet ‘Dollars and Sense,’ which
summarized the requirements In easy to understand language.
Financial Assurance for Municlosifties
Under the schedule for phased compliance published In the October 1988 financial
responsibility rule, local government entitles were given 24 months from the promulgation date
to comply. In the rule, the Agency stated its intention to develop a financial test In the interim
that would allow local governments to demonstrate that they have the requisite financial
strength and ability to pay for the costs associated with UST releases. The main regulatory
work this past fiscal year has been the development of such a financial test for municipalities.
The Agency recognized that there were hiiportant differences between governmental and
private entitles: unlike private entitles, municipalities have taxing authority as an assured
source of revenue; munIcipalItIes are geographically foced - they cannot leave the State to
avoid an obligation; and furthermore, municipalities have a very low incidence of bankruptcy.
In developing the rule, the Agency sought to keep the rule as flexible as possible to allow local
governments a variety of choices in demonstrating financial responsIbility, and to keep the
mechanisms as simple as possible to reduce the administrative burden on local governments
as well as the or local agency responsible for implementing the regulation. OUST
anticipates that nil, will be proposed this winter and hopes to promulgate the final rule
before the end of FY 1990.
Reoort to Conoreas on Exernot Tanks
A large number of heating oil and motor fuei tank systems are exempt from regulation
under SubtIt e I of RCRA. OUST completed a background document containIng Information
about heating oil and motor fuel tanks that are exempt from regulation under Subtitle I of
RCRA. This report presents Information on the technical characteristics of exempt tanks and
the risks these tanks pose to human health and the environment. In addition, OUST has
submitted a report to 0MB that summarizes the findings of the background document.
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37 -
discusses additional non-technical considerations, and presents recommendations as to
whether these tanks should also be regulated under Subtitle I.
IMPLEMENTATiON ACT1V ES
Buildina State and Local Proarama
UST program activity has increased substantially in recent years, as reflected by State
legislative and regulatory programs, as well as by State progress in having funding available
for cleanups. The number of States with enabling legislation for regulating USTs has grown
from three in 1980 to 42 in 1988. In addition, hundreds of counties and municipalities have
developed local UST ordinances and programs that often operate independently of the State.
AdditIonally, 54 (of 56) States and Territories have entered Into Cooperative Agreements that
allow them to take advantage of the LUST Trust Fund, which was established by the 1986
SARA amendments to fund cleanups from leaking USTs under certain conditions. States may
use the Trust Fund, which is financed by a 1/10 of a cent per gallon excise tax on motor fuels,
to order cleanups of leaks by owners or operators, conduct cleanups, and to recover costs
of enforcement activttles and cleanups. Overall, EPA expects the current high level of UST
program activity to continue to increase rapidly.
OUST, In its role as franchIser, continues to work closely with the Regions and States
to assist them in developing strong UST programs. Examples of OUST’s efforts to impleme
this approach Include:
• OUST developed a handbook ( State Proaram Aooroval Handbook . OSWER
Directive 9690.8, March 1989) to assist State officials who are building and
implementing State UST programs that will be no less stringent than the Federal
UST requirements and will operate In lieu of the Federal UST program. This
handbook Is designed to Increase the States’ understanding of how EPA intends
to implement the regulations for State program approval that were promulgated last
year. This handbook seeks to encourage State applications by making the
application process as easy and stralghtfoiward as possible; describing dearly
EPA’s expectations and criteria for State program approval; and encouraging a
wide range of State UST programs tailored to meet their specific needs while
provIding for adequate protection of human health and the environment.
• To supplement the State program approval handbook, OUST prepared another
dosansnt, Suggested Procedures for R y$ w of $j e U$ *pplicatfoq. OSWER
DIrs 9650.9, March 1989. ThIs document proposes a set of procedures for
EPA Regional review of Individual State LiST applications. Although OUST does
not expect the first Stat. applications to be submitted to the EPA Regional offices
until next year, It is already directly Involved in assisting States with their
applications. OUST has worked with New Me,dco and Region Vi, for example, to
assist them in resoMng program approval issues.
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38-
• OUST, together with a number of representatives of the regulated community and
States, developed effective outreach materials that States, trade associations, and
suppliers are using to alert owners and operators of the first compliance deadline
for leak detection.
OUST provides States with technical assistance and enforcement backup as necessary,
and supports them in the development of unique approaches and innovative tools for
managing their UST programs. OUST also conducted pilot projects during FY 1989 to assist
several States and counties in establishing expedited enforcement programs. Expedited
enforcement programs have been demonstrated in UST and other environmental programs to
enhance compliance using a minimum of resources. Such programs endeavor to reduce the
number of costly and time-consuming enforcement efforts by employing a process similar to
issuing traffic tickets at the scene of the violation. OUST has developed the tools needed to
build and implement expedited enforcement for dissemination to other Interested States and
localities.
One important role for OUST in a franchise-based program is to serve as a
clearinghouse for transferring technologies and ideas developed by other organizations. In
one project established to assist States in ensuring compliance with leak detection
requirements, OUST studied the methods States and localities have used to achieve
compliance and is providing specific help to three pilot States who will be comprehensively
enforcing the leak detection requirements. Research on the pilot projects demonstrated that
many States and localities are developing innovative approaches to achieving compliance.
OUST employs the principles of continuous improvement In providing technical and
implementation assistance to Regions, States, and local governments. For example:
• OUST staff worked with staff of Region l’s UST program to identify and analyze
ways to Improve the Region’s process for negotiating its LUST Trust Fund
Cooperative Agreements; the newly developed process will result in labor savings
of one full-time employee over a two-year period.
• OUST is working with a number of States to identify obstacles to spending LUST
Trust Fund monies and reporting their actMtles. Next steps will include
improvement projects to overcome these obstacles and to design processes that
are conducive to effective spending and reporting.
• OUST working with States to study and improve the process used for site
investIgatIons. OUST Is seeking to assist States and responsible parties to
conduct site investigations quicker, faster, cheaper, and better.
• In another project OUST is studying how consideration of human and
environmental health effects the dean-up process and what OUST can do to
adequately consider human and environmental health while minimizing disruption
to the dean-up process.
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m. omce also developed a health and safety training program for UST Inspectors,
was presented In all EPA Regions and broadcast via satellite to over 100
addl Ofl8l UST investigators.
EPA Regional Offices continue to work closely with States to enhance their program
development capabilities and performance levels. Again this year, the Regional Offices
awarded UST grantS to the States to assist with program development. OUST has
substantially increased its financial SUPPOrt to the Regions to address State problem areas
through specific Targeted Improvement Projects (TIPS). FY 1989 TIPs Included supporting
Connecticut to analyze its UST workload and project future resource needs; assisting New
Jersey to develop and implement Its UST permitting system; assisting Utah to analyze
proposed financial responsibility legislation and liability Issues; and providIng an UST inspector
training course for fire marshals and building inspectors in Alaska. OUST also prepared a
compendium covering all the TiPs undertaken to make It easier for States and Regions to
exchange Information and program tools.
OUST highlighted Its efforts to foster strong communIcation between States by
sponsoring the second annual All-States Conference, entitled Maldng It Work. The
conference brought together over 250 UST program staff from local, State, RegIonal, and
Federal levels to dIscuss all aspects of UST program management The major focus was to
allow States to share information with each other; most of the sessions at the conference we
moderated by Regional representatives and featured presentations by Stat staff. Dlscw
topics ranged from the technologIes that Influenced technical standards to fln& , .
responsibility requirements to implementation issues such as program costs. Overall, the
conference was a great success, with participants requesting that thls type of information
exchange continue In the future.
LUST Trust Fund Activities
At the end of FY 1969, the Regions had negotiated cooperative agreements with 54 out
of 56 States and Territories. One additional State Is currently working toward a cooperative
agreement and EPA anticipates that It will be awarded during FY 1990. Cooperative
agreements between the States and EPA enable the States to spend trust fund resources for
cleanups and associated program costs. During the fiscal year, the Regions awarded
approximately $42.5 million from the LUST trust fund.
To date, 16,000 cleanups have been Initiated by responsible parties, and nearly
5,700 hav, been completed. In addition, States have begun more than 0 corrective actions
using trust fund nmiliss . State. will continue to encourage owners and operators to conduct
corrective actions, and will take appropriate response and enforcement actions where owners
and operators are unable or unwilling to perform corrective actions.
ThIs year OUST has worked toward Improving the cooperative agreement negotiation
and award process. OUST developed a new process for allocating trust fund money designed
to encourage States to work toward program goals. In addition to the base allocation and
allocations based on need, a third allocation component -readiness to proceed - examines
the State’s ability to implement a program (e.g., conduct State-lead cleanup. and oversee RP-
lead cleanup.). States therefore have an Incentive to develop a strong and active program.
-------
-40-
Several Regions have extended the time frame over which awards are granted to three years,
thereby reducing the level of effort required to process State applications in subsequent years.
In addition, ensuring consistent levels of funding over several years allows States to budget
for long-term cleanups. Currently, OUST is conducting a study to analyze LUST trust fund
spending and reporting patterns in five States in three EPA Regions to help States improve
performance under the trust fund.
Outreach Activities
Because OUST considers ‘advertising,’ or making the regulated community aware, to be
one of the major responsibilities of a franchiser, the Office has developed an outreach strategy
that identifies various potential audiences (e.g., owners and operators, State and local officials,
trade associations, Congress) for UST outreach materials and aggressively provided materials
to these audiences. Consistent with the principle that UST regulatory activities should occur
at the State and local levels, OUST prepares the materials and then, generally, makes them
available to States, trade associations, and other groups who, in turn, deliver the materials to
the audience of concern. In some cases, OUST provides camera-ready copy to States who
can add State-specific Information and then reproduce and distribute the materials.
During FY 1989, OUST continued producing materials to help owners and operators
understand and comply with the new requirements and help specific audiences, such as
inspectors, States, and local officials, to do a better job of implementation. in FY 1969, OUST
developed the following materials about the UST Program:
Brochures :
• Musts for USTs — A simple, easy to understand summary of the technical
requirements for UST.;
• Dollars and Sens! — An easy to understand summary of the financial responsibility
regulations for USTs;
• Commitment To Coooeratlon: Franct ’dslna the UST Prooram - A description of the
UST program franchise approach for State UST tetf and
• Oh P I - A simple, easy to understand summary of how to respond to UST leaks
for ws and operators.
• Tank Closure Without Tears - Depicting proper closure techniques for inspectors;
and
• Dolno It Rlaht — Demonstrating proper tank Installation for installers.
-------
- 41
Handbooks :
• Tank Tour — A guide to the Federal UST program;
• Financial Assurance Procrams — A handbook for State officials;
• UST Work-A-Budget — A worksheet package for State program officials to help in
estimating program costs;
• Petroleum Tank Releases Under Control — a handbook for States and remediatlon
contractors;
• Detectina Leaks — a handbook for State officials on the leak detection methods
allowed In the Federal regulations; and
• Leak Detection Comoliance Tool Kit - a compIlation of short, easy to understand
materials on the Federal leak detection requirements and methods to assist owners
and operators to come into compliance.
Bulletin and Newsletter :
• LUSTUNE - A quarterly bulletin aimed at State officials that discusses the latest
UST issues and developments; produced under a grant by the New England Water
Pollution Control Commission;
• Tank Téchnoloav Uodate - A technical newsletter focusing on technical Information
exchange; prodv”ed under a grant by the University of Wisconsin; and
• Compliance Alliance - enforcement Information for State and Regional staff.
Measurina OUSVs Proaess
This year OUST undertook a project to define the baseline of performance, track the
extent of the leaking UST problem , Identify areas where performance could be Improved, and
measure progress on Implementing OUST5 strategic plan for the next four years. OUST
worked with Regional program managers and workgroup members from seven States to
develop meanlngiU progress measures that minimized costs and dIfficulty of data collection
and to define the measures so that data collection would be consistent across States. Forty-
seven measures weio developed. Data on 26 of the measures wlH be collected through
Regional reporting or State reporting (I.e., notification data, Trust Fund reporting, and grant
reporting). Information on the remainIng 21 measures will be collected through special studies
using data compiled from pilot States and industry. Although data for some of the reporting
measures were collected during FY 1969, formal data collection for fl measures will begin
during F? 1990. Once collected, the data will be compiled into an OUST annual report to
highlight the National UST Program’s progress toward meeting the goals of the OUST strategic
plan.
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STRATEGIC PLAN
FY 1992 - 1995
Office of Solid Waste and Emergency Response
November 30, 1989
UST/PM/PG/89-
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OUST Indicators
discussed previously.
(I) Revise Program Guidance. To facilitate routine reporting of information
already being collected on a project-specific basis, we need to clarify and
revisesomeoftheSuperfund project guidance. This will include improved
documentation of site goals (e.g., volumes to be addressed, concentration-
based standard, population at risk), intenm progress (especially reduced
concentrations), and the achievement of site goals.
(2) InstItutionalize Regional Reporting. After completing the initial
He uartezs-managed data collection, wewill turn over on-going reporting
of the existing measures to the Regions in FY 1991. Much effort will be
required over the next few years to effectively incorporate routine reporting
of the environmental results of site cleanup actions into Regional program
management to ensure that these indicators will be in place for the strategic
planning period.
(3) Investigate Additional Measures. As FY 1990-91 measures are
institutionalized, we will work with OPPE to analyze other environmental
indicators. Two of the eight measures that have not been selected for near-
term implementation (ecotoxicity and biological accumulation) will be
included in this investigation.
The focus of OERR’s efforts up until the strategic planning period will be two
fold: institutionalize the data collection and administrative procedures to ensure
that the current indicators are in place for the strategic planning period, and
investigate additional measures of ecotoaaty and biological accumulation to
determine their applicability and feasibility at Superfund sites. After conducting
extensive research, and contingent upon the results of the study, the program will
be able to definitively commit to the future direction of indicators for OERR.
OFFICE OF UNDERGROUND STORAGE TANKS
The mission of the Office of Underground Storage Tanks (OUST) is to protect human
health and the environment primarily by preserving groundwater for present and future
use The OUST program works to prevent leaks from underground storage tanks and, if
releases occur, acts to dean up contaminated sites and groundwater.
Within the context of the OSWER strategic plan, objectives 2.3,3.2,4.3,4.4,43, and 4.6
outline the steps OUST will undertake to achieve this end. Most of these objectives have
administrative measures of progress built into them. Environmental indicators would seek
53
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En ironmentaI Indicators
to measure the extent to which the OUST program has progressed toward the goals to
prevent releases and to respond to them if they do occur. However, the ultimate
environmental measure of OUST’s effectiveness would be the ability to assess the extent to
which the program reduces groundwater contamination from underground storage tanks.
This alternative, however, is neither feasible nor cost-effective.
Ideal Indicators
Measuring groundwatercontamination is both technically dif ficult and resource
intensive. A comprehensive groundwater monitoring network would include
implementingan earlydetection system to prevent orcontrol leaksanda performance
monitorzngsystem to assess progress duringandaftersitedeanup. Thecompledty
and cost of an Individual hydrogeologic Investigation is such that It would not be
cost-effective vis-a-vis the information it could supply and the amount of resources
it would require. Implementation of a monitoring network would be an excessive
expense, given the current budget of the OUST program.
Surrogate Indicators
In light of the resource constraints and mpracticality, the OUST program will
use a variety of surrogate Indicators which, in a much less resource-intensive way,
provide information on various aspects of the environmental impact of the OUST
program. Whet pieced together, the Information from each of the surrogate
indicators gives a good picture of the resulting environmental benefits. The
indicators measure the three main goals of the program—the extent to which the
program has cleaned up contamination from underground storage tanks, prevented
future releases, and reduced the risk of groundwater contamination.
Cleanup Indicators
o number of sites with conf ed releases
o number of sites with petroleum releases brought under control
o number of site cleanups for petroleum releases completed
Prevention Indicators
o number of UST closures reported
o number of UST systems replaced
o number of USTs upgraded
o number of USTs with release detection
o number of USTs tested for tightness
54
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OSW 1nd cators
Contamination Indicators
o number of sites with groundwater contamination
o number of households and wells affected by releases
These indicators are particularly suited to OUST because as a franchise program,
the core of our work is carried out at the Regional and State levels. The nature of the
indicators and the reporting system in place allow us to aggregate this information
and summarize progress on a national scale.
The measures, while not ideal environmental indicators, are currently being
used in the program, and will continue to be used until fiscal year 1992. OUST does
not plan to develop more truly ideal indicators because of the tremendous resources
it would require.
OFFICE OF SOLID WASTE
Ideal Indicators -
The OSWER Workgroup, with input from OPPE, has defined an ideal
environmental indicator as a measure of environmental quality that describes the
true or ultimate risk. Risks indude those to human health and the environment.
Given this guidance, 06W has developed the following set of potential ideal
indicators
o risks to human health and the environment via air, ground water, soil, and
surface water pathways;
o plume volume contaminated;
o ambient concentration levels for air, ground water, soil, and surface water
o population and community dynamics of native biota
o documented illnesses; and
o well concentrations for maximum contaminant level (MCL) constituents
and other relevant chemicals.
06W is currently unable to use these indicators. Data and resoui e constraints
prohibit using these indicators on a consistent , national basis. The size, complexity,
and diversity of the RCRA-regulated universe, under both Subtitles C and D,
inhibits selection of ideal indicators that can be readily and consistently measured
for all parts of the country.
Although we can strive to move toward these ideal indicators, as a practical
matter, they would require unrealistic resources (that are not currently budgeted
55
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THE STRATEGIC PLAN FOR
THE OFFICE OF UNDERGROUND STORAGE TANKS
SEPTEMBER, 1988
DRAFT
UST/Pfl/PC/88-2
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INTRODUCTION
The purpose of this document is to present the plan that
EPA s Office of Underground Storage Tanks (OUST) will use to
implement the national UST program. The plan identifies OUSTs
mission, and how the mission will be accomplished.
Numerous people contributed to this plan by participating in
inter/jews, meetings, or by providing comment. Contributors
included managers and staff from OUST and other offices in EPA
Headquarters, all EPA Regional Office UST coordinators, four
State offices, and representatives from a trade association and an
environmental group.
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TABLE OF CONTENTS
I. Description of terms used in this document I
II. The Mission of the Office of
Underground Storage Tanks 2
Ill. Program Goals and Objectives 3
IV. Activities for Achieving the Objectives 7
V. Key Strategies for Implementing
the National UST Program 8
V I. Measures of UST Program Improvement 14
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I. DESCRIPTION OF TERMS
PLANNING TERMS
Mission :
The mission is the broadest statement explaining the purpose of the Office of
Underground Storage Tanks (OUST). Since OUST’s approach to fulfilling its mission is
unique from other EPA offices, the statement includes operating principles (in bullets)
that describe in general terms how the mission will be achieved. One important point of
the mission statement is that the national UST program is decentralized from its outset.
This has important implications for EPA’s role to continuously assist States and help them
enhance program performance.
Strategies :
Strategies are general approaches for pursuing goals, objectives, and activities. The
strategies help explain important issues and how OUST has decided to deal with them.
Goals :
Goals are general achievements that need to be accomplished in order to fulfill the
mission. These goals are stated in broad and timeless terms. OUST defined four goals for
achieving its mission.
Objectives :
Objectives are specific achievements that need to be completed to fulfill a particular goal,
often by a certain time. OUST defined three objectives for each goal.
Activities :
Activities are specific projects that EPA will undertake to achieve a particular objective.
Since activities change from year to year, they are not included in this document.
However, activities for FY89 can be found in OUST’s FY89 operating plan.
OTHER TERMS
EPA : -
EPA refers to OUST at EPA headquarters and UST personnel in the Regional Offices.
LUST :
LUST stands for Leaking Underground Storage Tank systems.
State :
The word Stat& as it appears in this document refers to States, territories, and local
governments that are implementing UST programs.
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GOAL i •
GOAL 2
GOAL.;3
OBJECTiVES
OBJECTIVES
OBJECTIVE S
OBJECTIVES
activities
:activsties
activities activities:
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I I. THE MISSION OF ThE OFFICE OF UNDERGROUND STORAGE TANK
The mission of the Office of Underground Storage Tanks is to protect
human health and the environment, primarily by preserving ground water for
present and future use. This mission will be achieved through a national
Underground Storage Tank (UST) Program designed to prevent and clean up
contamination from leaking underground storage tank systems.
Due to diverse local conditions and the large numbers of UST owners and
operators, we recognize that State and local governments are in the most
appropriate position to directly address human health and environmental problems
associated with USTs. In support of our mission, we are committed to:
o Decentralizing the national UST program from the outset and improving it
over time by continuously enhancing State and local program performance;
o Understanding the work performed in the field by developing a
communication network for information exchange, composed of all UST
participants (Federal, State, and local governments and the private sector);
o Responding to the needs of State and local programs by providing
genuinely useful assistance and products;
o Learning from the experiences of other public and private organizations
and building innovative and effective methods to improve program
performance;
o Demonstrating constant and measurable improvements over time;
o Promoting a work environment that enables employees throughout the UST
program to realize their potential both as individuals and as members of a
team.
2
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GOALS FOR ACHIEVING ousrs MISSION
Goal 1: Statesa Develop UST Regulatory Programs
All States will operate continuously improving UST regulatory programs that are no less
stringent and no smaller in scope than EPA’s regulationsb, and most tank systems will be in
compliance.
Goal 2: EPA and States have a system to assure that funding is available for all cleanups.
EPA, together with all States, will establish and improve funding systems to assure that
cleanups are paid for and occur in a timely manner. Owners and operators will have primary
responsibility for financing cleanup through insurance or private funds. When owners and
operators do not pay for cleanups, government funds will be used to assure cleanups take place in
a timely manner and States will actively seek to recover costs from responsible parties.
Goal 3: EPAC Will Ideatify and Develop Methods to Improve Performance
EPA, together with States, local governments, and industry groups will identify more
efficient, less costly, and faster methods of performing tasks in the program areas of release
prevention, release detection, cleanup, program management, and program measurement. This
will be done to improve the performance of all program participants, to promote the efficient use
of limited resources, and to protect ground water and human health.
Goal 4: EPA Establishes a Communicatioa Network
EPA will establish a communication network that will continuously improve over time.
Through the communication network, EPA will identify program needs, innovatively transfer
new technology, tools and information to program participants, and promote information
exchange between EPA, States, local governments, the regulated community, and other interested
groups.
a State rders to States, temiones, and local governments that are unplementing UST programs.
b Regulations come from both the UST Prevention Program and LUST Cleanup Program. These regulations are
designed to prevent, detect, and cleanup releases (leaks, spills and oveifills) associated with USTs.
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III. PROGRAM GOALS AND OBJECTIVES
There are four goals for achieving OUST’s mission and three objectives for
achieving each goal. The first two goals deal with developing State UST programs
and the last two goals focus on improving these State programs.
Goal 1: Stat& Develop UST Regulatory Programs
All States will operate continuously improving UST regulatory programs
that are no less stringent and no smaller in scope than EPA’s regulationsb, and most
tank systems will be in compliance.
Objectives:
A. Within 3 years, most States will have regulatory programs with authorizing
legislation and regulations that are no less stringent and no smaller in scope
than EPA ’s regulations and the remaining States will have regulatory
programs within 5 years.
B. Most States will adequately finance and staff their regulatory programs
within 3 years, and the remaining States will do so within 5 years.
C. As EPA’s regulatory requirements are phased in, all States will have
adequate compliance and enforcement programs. Each year a continuously
increasing proportion of owners and operators will comply with program
regulations (technical standards, cleanup and financial responsibility
regulations).
a Stale rders to States, terntories, and local governments that are implen enling UST pioçams.
b Regulations me from both the UST Prevention Pro am and LUST Cleanup Fro am.
These regulations are designed to prevent, detect, and cleanup releases (leaks, spills and
oveifills) associated with USTs.
3
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Goal 2: EPA and States have a system to assure that funding is available for all
cleanups.
EPA. together with all States, will establish and improve funding systems
to assure that cleanups are paid for and occur in a timely manner. Owners and
operators will have primary responsibility for financing cleanup through insurance
or private funds. When owners and operators do not pay for cleanups, government
funds will be used to assure cleanups take place in a timely manner and States will
actively seek to recover costs from responsible parties.
Objectives:
A. A continuously increasing proportion of owners and operators will pay for
cleanups using insurance or private monies, and these cleanups will occur
in a timely manner.
B. Federal or State funds will ensure that all States have some means of
funding cleanups when the responsible party does not pay for cleanups,
and these cleanups will occur in a timely manner.
C. En cases where the responsible party does not pay for cleanup and
government funds must be used, EPA and States will establish and
continuously improve a system to recover costs from the responsible party.
4
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Goal 3: EPAC Will Identify and Develop Methods to Improve Performance
EPA, together with States, local governments, and industry groups will
identify more efficient, less costly, and faster methods of performing tasks in the
program areas of release prevention, release detection, cleanup, program
management, and program measurement. This will be done to improve the
performance of all program participants, to promote the efficient use of limited
resources, and to protect ground water and human health.
Objectives:
A. EPAC will assess current practices in the field, identify areas needing
special assistance, and locate or develop appropriate technologies, tools,
and guidance to improve release prevention, detection, and cleanup
practices.
B. EPA will assess current management systems, identify areas needing special
assistance, and develop appropriate tools and guidance.
C. EPA will implement a system to gather meaningful data and utilize
measures that reflect program impacts on human health and the
environment. This information will be used to assess national program
progress and identify program areas needing special assistance.
C Since EPA will take the lead, only EPA is mentioned here, however. States, local governments.
and industry groups will be asked to assist EPA in lulliuing the objectives [ or Goal 3.
5
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Goal 4: EPA Establishes a Communication Network
EPA will establish a communication network that will continuously
improve over time. Through the communication network, EPA will identify
program needs, innovatively transfer new technology, tools and information to
program participants, and promote information exchange between EPA, States,
local governments, the regulated community, and other interested groups.
Objectives:
A. To determine the needs of key program participants, EPA will
continuously develop more effective, faster, and less costly communication
systems.
B. To distribute new technology, tools, methods, and information to
appropriate program participants, EPA will continuously develop more
effective, faster, less costly, and wider reaching communication systems.
C. To establish UST program credibility, communicate progress, and provide
information, EPA will work to continuously develop more effective, more
frequent, less costly, and wider reaching systems for communicating with
Congress, other governmental offices, industry and trade associations,
environmental organizations, universities, the general public, and other
interested groups.
6
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IV. ACTIVITIES FOR ACHIEVING OBJECTIVES
There are two basic typesof activities. One type consists of projects that
are undertaken to achieve a specific objective. The other type involves a variety
of administrative tasks that can apply to several objectives. Since activities are
planned for the short—mn and vary from year to year, they are not included in this
document.
Projects
There are usually several projects undertaken in a given year for each
objective. The ability to change projects from year to year gives the program
flexibility to adapt to different situations. Projects are carried out by EPA,
grantees or contractors. A list of projects is located in OUST’s operating plan for
the current fiscal year.
Administrative tasks
Administrative tasks ensure both the smooth operation of the program and
continued progress towards fulfilling the mission. These administrative tasks are
not goals in themselves, but are necessary, on—going, and often routine tasks that
affect all levels of the program.
EPA will perform administrative tasks to manage program resources such
as OUST’s budget, contracts, personnel, and staff development. OUST will also
coordinate with other EPA programs in headquarters.
7
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V. KEY STRATEGEES FOR IMPLEMENTING
THE NATIONAL UST PROGRAM
In this Section ten issues that may affect the UST program are presented
along with an explanation of EPA’s strategy for dealing with the issues. These
strategies affected the choice of goals, objectives, and activities in the previous
sect ions.
SIZE OF REGULATED COMMUNITY AND UNIVERSE OF USTS
Issue :
The extremely large size of the regulated community and universe of USTs
makes it impractical for EPA to monitor each UST. Furthermore, local
conditions (geological, hydrological and social) vary from site to site
making a uniform and traditional Federal approach to implementing the
program ineffective.
Strategy :
EPA has developed a non—traditional program, modeled after existing
franchise operations. EPA as franchise( will provide useful tools, advice
and direction, and States as franchisees’ will implement State UST
programs. State UST programs seeking EPA approval will be allowed
flexibility in demonstrating how their program requirements are no less
stringent than the corresponding Federal requirements. This flexibility will
allow all the States to develop UST programs that respond to a variety of
specific needs and characteristics.
Adopting a franchise approach has several implications for the roles of
EPA and States, including: 1) EPA will continue to be committed to
helping State UST programs succeed and to providing services that are
needed by the States; 2) Substantial efforts will be put into building trust
between EPA, States, and other program participants; 3) States will be
informed, have input, be listened to, and receive recognition for their
contributions.
8
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2. LIMITED FEDERAL FUNDS TO OFFER STATES
Issue :
EPA seeks to encourage State UST regulatory program development but has
limited Federal funds to offer States for operating their regulatory
programs. Many States have developed their own funding mechanisms. In
some States, however, UST programs have lower priority than other State
programs. Consequently, some State UST programs do not receive
adequate funding.
Strategy :
EPA will provide States with information about available funding
mechanisms from the outset and will encourage States to develop their own
funding mechanisms. EPA will look for ways to minimize the cost of
operating ate programs and will share training materials, information on
successful state program approaches, and other non—financial tools with
State agencies and legislatures.
3. PRESSURE FOR EPA TO ASSUME STATE ROLES
Issue :
States will need time to develop smoothly operating UST regulatory
programs. Meanwhile, there may be pressure from Congress. States,
public interest groups and others for EPA to fill State program voids.
General Strateav for All States :
EPA will inform program participants about their roles and responsibilities.
EPA will publicize State program successes, provide assistance to States,
and allow States time to develop their own UST programs. EPA will
identify key technical and operational obstacles to general program
development and will assist States in developing strategies to deal with
these hurdles.
Specific Strate v for Selected States :
EPA will develop State specific strategies for those States that have special
difficulties developing and implementing a program. In select cases, EPA
will conduct strategic enforcement actions.
9
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4. PROGRAM PARTICIPANTS ARE NOT FULLY AWARE OF ThEIR
ROLES AND RESPONSIBILITIES
Issue :
Many fire marshals, owners and operators of USTs, and other program
participants are not fully aware of their roles and responsibilities under the
regulations. For the program to function well, EPA will have to ensure
that these groups are provided with the information and training they need
to improve their performance.
Strategy :
EPA will work with the States to identify program participants that have a
critical need for assistance. EPA and States will target outreach and
training efforts to these groups.
5. EPA AND STATES NEED TO UNDERSTAND WORK PERFORMED Thi
ThE FIELD
Issue :
To determine present levels of performance, methods to improve
performance, and how advanced levels of performance can be maintained.
EPA, States, and local governments have to know and understand the tasks
that different participants perform.
Strategy :
In order to improve performance at all levels of the program, EPA will
aggressively examine the tasks that program participants perform. EPA
will help States develop quality assurance mechanisms for program
procedures such as installation, tank closure, and cleanup.
10
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6. LACK OF COMPLIANCE DUE TO HIGH COST
Issue :
The regulated community may be reluctant to comply with regulations that
may decrease short—term profits by requiring large one—time expenditures.
Strategy :
EPA will demonstrate the long—term financial benefits oi omplying with
UST regulations by.
o communicating potential liability due to LUSTs;
o comparing clean—up costs with the costs of complying with the
regulations; and
o publicizing the growing trend for environmental audits to
accompany real estate transactions.
7. OWNERS AND OPERATORS MAY NOT BE ABLE TO MEET
FINANCIAL ASSURANCE REQUIREMENTS
Issue :
Some owners and operators will not be able to meet the financial assurance
requirements in the Federal regulations due to the limited availability and
high cost of insurance.
Strategy :
EPA will foster the development of mechanisms to fund corrective action
and for compensating third parties for bodily injury and property damage
by:
o helping the insurance industry assess the risks associated with
different types of tank systems and facilitating their provision of
UST insurance;
o assisting States that want to develop alternative funding mechanisms
to pay for corrective action and third party claims; and
o monitoring the availability of financial assurance mechanisms and
developing suspension of enforcement procedures for financial
assurance, if requirements cannot be met.
11
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8. CHANGES N TECHNOLOGY
Issue :
There will be technological developments that affect tank systems.
Information about current technology used in tank systems, new fuel
mixtures, and the development of new technology could make EPA’s
current regulations and guidance outdated.
Strategy :
EPA will keep abreast of changes in technology, analyze its effectiveness,
and communicate important developments to appropriate program
participants. EPA will modify the regulations and guidance, as necessary.
9. LARGE NUMBERS OF NEW STAFF
Issue :
There is significant staff turnover and growth at many levels of the Federal
and State UST programs. New staff will need to quickly and thoroughly
understand the program, their roles and responsibilities.
Strategy
EPA will design a program that can function well with a high percentage
of new staff. To accomplish this, EPA will develop tools and guidance for
State employees that they can easily understand and use. EPA will also
work to give its employees the training and equipment they need to
perform well, recognize employees that perform well, and find perks to
enhance work.
12
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10. VARIED EXPECTATIONS ABOUT NUMBER, TIMING, AND
QUALITY OF CLEANUPS
Issue :
EPA will strive to make the UST program continuously improve over time.
In the early stages of program development, Congress, environmental
groups, trade associations, and the public may have unrealistic expectations
for the UST program, especially with regard to the number, timing, and
quality of cleanups.
Strategy :
EPA will work to maintain candid and productive relationships with
Congress, the Office of Management and Budget (0MB), environmental
groups, trade associations, and other interested groups. These relationships
will be used to build realistic expectations of the national UST program,
establish credibility, and share information. EPA will be prepared to
demonstrate that the franchise approach is a viable means for controlling
LUSTs and will strive to show continuing UST program improvements
from a baseline of data.
13
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MEASURES OF UST PROGRAM IMPROVEMENTS
(SECTION IN PROGRESS)
14
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United States Office of
Environmental Protection Solid Waste and
Agency Emergency Response
&EPA DIRECTIVE NUMBER: 9610.5-1
TITLE: iRANSITION TASKS LIST
APPROVAL DATE: January 30, 1989
EFFECTIVE DATE: January 30, 1989
ORIGINATING OFFICE: OUST
( FINAL
o DRAFT
STATUS:
REFERENCE (other documents): osw ir ti
9610.5 - “FY 1989 - F? 1990 Transition Strategy for
the UST Program.”
OLS WER?.LOSWER OSWER
DIRECTIVE DIRECTIVE D I
UST/Ptl/PC/89-1
-------
United States Environmental Protection Agency
Washington. DC 20460
&EPA OSWER Directive Initiation Request
-
1. Direcirve Number
9610.5-1
2. OrigInator Information
Name of Contact Person Ma Code lOffice 1 Telephone Code
Josh Baylson OS-420 OUST 475-9725
3. Title
Transition Tasks List
4. Summary of Directive (include bnel statement of purpose)
The Transition Tasks List supplements the Transition Strategy for the UST Program and
is a guide for negotiating agreements with the States to implement the final UST
regulations during the transition period.
-
5. Keywords
UST regulations, transition period, implementing agency
6a. Does This Directive Supersede Previous Dsrective s)? [ ] o Yes What directive (number. tide) Draft 9610.5—:
DRAFF Transition Tasks List
b. Does It Supplement Previous Directive(s)? [ ] No [ ] Yes What directive 1 number tide’ 9610.5
FY1989 - Y199’0 transition
SI r FPgy for t)i f 1ST Prngrim
7. Draft Levd
L A - Signed by ft.AjDU [ ] B - Signed by Oece Director C - For Review & Cosvvnent [ ]o - In Dev opment-
I Document to be distributed to States by Headquarters? fl Yes No
ThIs Request Meets OSWER Directives System Format Standards.
9. Signature of I d Office es Coor nator
Beverly ivesQordinator, OUST
Date -
I
10. Name and Title
on Brand, D ctor, Office of Underground Storage Tanks
Date
/
EPA Form 1315 -17 (Rev. 5-87) Previous editions are obsolete.
0
VE
S
WER OSWER OSWER 0
DIRECTIVE DIRECTIVE DIRECTIVE
-
- -U.
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S1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
______ WASHINGTON, D.C. 20460
I
4 L PRO1 ’
JAN 30 989 OcEICEOF
SOLID WASTE AND EMERGENCY RESPONSE
I ’ 40P .ANDTJN OSWER DIRECTIVE 9610.5-1
SUBJECT: Final Transition Tasks List
FROM: Ron Brand, Director ,&_ ..t_-
Off ice of Underground Storage Tanks
TO: Waste Management Division Directors,
Regions 1-111, V-IX
Water Management Division Directors,
Regions IV and X
The enclosed Transition Tasks List identifies the
universe of tasks specified in the final underground storage tank
regulations (40 CFR Part 280) that are a responsibility of the
implementing agency. This list is designed to .aid the Regions in
negotiating agreements with the States to conduct these tasks.
EPA’s goal is to have the States conduct most of these tasks
during the transition period before State program approval. All
tasks that States agree to conduct as the implementing agency or
on behalf of EPA must be included in formal transition
agreements. This includes both tasks identified in the following
pages as specified and optional.
This document is an updated and final version of the
September 29, 1988, Draft Transition Tasks List (Draft OSWER
Directive 9610.5—1). Minor changes were made to Part 1 of the
document (technical standards and corrective action
requirements). Part 2 was substantially revised and reordered to
reflect the provisions of the final financial responsibility rule
(dated October 26, 1988).
We hope this list facilitates the development of transition
agreements with the States. These agreements will play a seminal
role in implementation of the UST regulations during the
transition period. For additional information or clarification,
please contact Josh Baylson (FTS 475—9725), of my staff.
Attachment r-
cc: UST Regional Program Managers
UST Program Regional Attorneys
Kirsten Engel, 0CC
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2
TR7 NSITION TASKS LIST
The Transition Tasks List supplements the “FY 1989 — FY 1990
Transition Strategy for the UST Program” (OSWER Directive 9610.5)
and revises the Draft Transition Tasks List (Draft OSWER
Directive 9610.5—1). The tasks list identifies the universe of
tasks specified in the final underground storage tank (UST)
regulations that are a responsibility of the implementing agency.
Since the UST regulations regulate owners and operators (0/0) of
UST systems, and not implementing agencies (e.g., States), there
are few tasks for the implementing agency specified in the
regulations.
Part 1 identifies tasks associated with Subparts A through G
of the final rule (dated September 23, 1988). Part 2 identifies
tasks associated with the final financial responsibility (FR),
Subpart H, fequirements (dated October 26, 1988 and corrections
dated December 21, 1988). The appendices provide more
comprehensive listings of tasks, including optional tasks and
options for carrying out the specified tasks.
CONTENTS
Part 1:
List of Specified Tasks (Subparts A-G)
Appendix 1: List of Specified and Optional Tasks (Subparts
A-G)
Compliance Monitoring and Enforcement Tasks
Part 2:
List of Specified Tasks (Subpart H)
Appendix 2: List of Specified and Optional Tasks (Subpart H)
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OStJER DIRECTIVE 9610.5—1
3
Transition Tasks List - Part 1
Technical Standards and Corrective Action Requirements
40 CFR Part 280: Subparts A - G
The definition of implementing agency in the UST technical
standards and corrective action requirements has been written to
allow the State to be the implementing agency during the
transition period for those tasks that they agree to perform.
Thus, the concept of implementing agency is divisible, with the
State considered the implementing agency for those tasks they
agree to conduct, and EPA remaining the implementing agency for
the balance of specified tasks.
Subparts A through G of the UST technical standards and
corrective action requirements specify only 9 tasks as
responsibilities of the implementing agency. EP A’s goal is to
have States assume and conduct all 9 of these tasks during the
transition period. States with UST program grants and LUST Trust
Fund cooperative agreements already are performing many of these
tasks.
LIST OF SPECIFIED TASKS (Subparts A — C )
1. Receive notifications F 280.221 and certifications of
installation F 280.20(e)1 of new UST systems .
All States will continue to receive notifications as
required in the final regulations [ @280.22(a)]. This is a
regulatory requirement and need not be included in
transition agreements.
/ 2. Answer calls reporting releases, including suspected
releases 1 280.501. spills and overfills r 28o.531. and
confirmed releases F 280.52 & 28O.611 .
/ 3. Receive re rts of corrective actions taken or Dianned.
including initial abatement measures r 28o.62(b)1 .
j 4. Receive initial site characterization re rts I@280.631 .
.- 5. Receive free product removal re rts and determine the
practicable extent for free product removal 1 28O.641 .
6. Under certain conditions. reauest and receive reports of
investigations of the maanitude and extent of soil and
ground—water contamination 280. 651 .
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4
7. Receive, review, and evaluate required and voluntarily
submitted corrective action Plans and reports pf the results
of implementing the glans [ @280.661. For each corrective
action Plan required. provide notice to the public of the
release and the corrective action Plan 1@280.671. Oversee
implementation of corrective action plans .
Tasks 2 — 7 refer to the corrective action requirements
and will occur only after a release is suspected or
confirmed. Many States are currently conducting these, or
similar, activities as part of their LUST Trust Fund
cooperative agreements. States should be asked to continue
to conduct these activities related to releases of petroleum
from UST systems as part of their Trust Fund cooperative
agreement work plans. In addition, States should be asked
to conduct tasks 2 - 7 related to releases of hazardous
substances from UST systems as part of their program grant
work plans.
8. Receive notifications prior to Permanent closure or change-
in—service [ @280.711 .
9. Receive records of excavation zone assessments at closure if -
the records cannot be kePt at the site or an alternate site
for 3 years [ @280.741 .
States now are receiving new tank notifications (Task
1) and likely will want to receive notices of intent to
close or change—in-service (Task 8). Task 9 viii occur only
if the records cannot be kept at the site or an alternate
site. States should be asked to perform tasks 8 and 9 as
part of their program grant work plans.
In addition, both States and Regions will need to be
prepared to respond to Freedom of Information Act (FOIA) requests
and to follow regulatory requirements for public participation in
the program.
In summary, most of the 9 tasks are based on receiving
reports or notices: tasks 1 and 8 are related to management of
States’ notification data, an activity most States currently are
conducting; tasks 2 through 7 relate to the corrective action
regulations and will occur only when an owner or operator reports
a suspected or confirmed release; and task 9 will occur only in a
limited number of cases. -
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U wIJ U 7UL J. L
5
APPENDIX 1: LIST OF SPECIFIED AND OPTIONAL TASKS (SUBPARTS A - G )
The following is a more complete listing of tasks for the
implementing agency. The tasks are identified as either:
S = SPECIFIED : explicitly described in the UST regulations as a
responsibility of the implementing agency or implied to be a
responsibility of the implementing agency based on a
requirement placed on owners arid operators; or
O = OPTIONAL : carried out at the discretion of the implementing
agency.
The specified tasks are a repetition of the previous list.
Guidance for implementation of the specified tasks is indicated
below each task as options for State or Regional implementation
during the transition period. The tasks identified as optional
indicate program areas for the Regions to work with States to
enhance capability.
* * * * * * * * * * * *
SUBPART A - PROGRAM SCOPE AND INTERIM PROHIBITION
O Pursue violations of the Interim Prohibition for deferred
UST systems (@280.11].
- SUBPART B - UST SYSTEMS: DESIGN. CONSTRUCTION.
INSTALLATION & NOTIFICATION
O Determine if proposed alternatives for
construction, and corrosion protection
protective [ @280.20(a) (5)1.
O Determine if proposed alternatives for
construction, and corrosion protection
protective (@280.20(b)(4)].
o Determine if proposed alternatives for spill and overfill
prevention equipment areno less protective [ @280.20
‘ ‘:i
‘ r i t’ •
O Certify or; license insta11ers [ @280.20(e)(2)]. -
1. “- - ,
tank design,
are no less
piping design,
are no less
— —‘fl — -1
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6
O Inspect and approve installations [ @280.20(e)(4)].
o Determine if proposed alternative installation methods are
no less protective [ @280.20(e)(6)].
o Determine if proposed alternative methods for assessing
tanks for corrosion holes are no less protective
[ @280.21(b) (2) (v)].
S Receive notifications [ @280.22] and certifications of
installation (@280.20(e)] of new UST systems.
[ All States will continue to receive notifications as
required in the final regulations (@280.22(a)]. This is a
regulatory requirement and need not be included in formal
transition agreements. I
O Follow-up on notification forms to enhance compliance, e.g.,
forms that are incomplete, contain information indicative of
a violation, or have not been submitted by the 0/0
[ @280.22].
o Update notification data base.
SUBPART C - GENERAL OPERATING REOUIREMENTS
o Estalilish alternative time frame for testing of cathodic
protection systems (@280.31(b) (1)].
O Determine that alternative post-repair test method is no
less protective [ @280.33(d)].
SUBPART D - RELEASE DETECTION
O Approve use of proposed alternative release detection
methods for hazardous substance UST systems
[ @280.42(b) (5) (iii)].
O Approve use of proposed alternative release detection
methods (petroleum tanks) and set conditions for their use
(@280.43(h) (ii)].
SUBPART E - RELEASE REPORTING. INVESTIGATION
AND CONFIRMATION
Some States currently are operating clean-up programs that
include reporting requirements that differ from the federal
requirements. It is not EPA’S intent to place an-unreasonable
burden on owners and operators in those States. Therefore, if
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OSWER DIRECTIVE 9610.5—1
7
State requirements are entirely duplicative of the federal
requirements, the submission of a separate federal report is not
necessary if the State has agreed to conduct the related task(s)
as part of a transition agreement. However, before State program
approval, any federally required reports that are not duplicated
by State reporting requirements must be submitted by owners and
operators to the implementing agency.
Regions should ask States to receive reports required under
Subparts E and F for petroleum releases as part of their LUST
Trust Fund cooperative agreement work plans and for hazardous
substance releases as part of their program grant work plans.
S Answer calls reporting releases, including suspected
releases (@280.50], spills and overf ills [ @280.53], and
confirmed releases (@280.52 & @280.61].
Option 1: State agrees to answer calls as part of Trust Fund
cooperative agreement and/or program grant work plans.
Region refers calls it receives to the State.
Option 2: Region receives and maintains a log of calls.
Region will continue to work with the State to conduct this
task.
O Require 0/0 to determine if the UST system is the source of
off—site impacts (@280.51].
O Establish alternative time frame for 0/0 to investigate and
confirm suspected releases (@280.52].
O Establish alternative time frame for 0/0 to report suspected
releases, spills and overf ills, and confirmed releases
[ @280.53(a)].
o Establish alternative amount for petroleum spills and
overf ills that 0/0 must contain and immediately clean up
(@280.53(b)].
SUBPART F - RELF SE RESPONSE AND CORRECTIVE ACTION
O Follow up on reports of confirmed releases, e.g., site
visits.
O Establish alternative period of time after a release is
confirmed within which 0/0 must perform initial response
actions (@280.61] -
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8
S Receive reports of corrective actions taken or planned,
including initial abatement measures (@280.62(b)].
Option 1: State agrees to receive reports as part of Trust
Fund cooperative agreement and/or program grant work plans
Option 2: Region receives reports and keeps them until the
State agrees to conduct this task. Owners and operators may
proceed with corrective actions without a response from the
implementing agency. RP—lead corrective actions occur with
limited direct supervision from the Region or the State.
Region will continue to work with the State to conduct this
task. -
O Follow up on reports of corrective actions taken or planned,
e.g., site visits.
S Receive initial site characterization reports (@280.63].
Option 1: State agrees to receive reports as part of Trust
Fund cooperative agreement and/or program grant work plans.
Option 2: Region receives reports and keeps them until the
State agrees to conduct this task. RP-lead corrective
actions occur with limited direct supervision from the
Region or the State. Region will continue to work with the -
State to conduct this task.
O Follow up on initial site characterization reports.
S Receive free product removal reports and determine the
practicable extent for free product removal (@28O.64 .
Option 1: State agrees to receive reports as part of Trust
Fund cooperative agreement and/or program grant work plans.
Option 2: Region receives reports and keeps them until the
State agrees to conduct this task. RP—lead corrective
actions occur with limited direct supervision from the
Region or the State. Region will continue to work with the
State to conduct this task.
O Follow up on free product removal reports.
S Under certain conditions, request and receive reports of
investigations of the magnitude and extent of soil and
ground—water contamination [ @280.65].
Option 1: State agrees to request and receive reports as
part of Trust Fund cooperative agreement and/or program
grant work plans.
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OSWER DIRECTIVE 9610.5—I
Option 2: Region requests and receives reports and keeps
them until the State agrees to conduct this task. RP-lead
corrective actions occur with limited direct supervision
from the Region or the State. Region will continue to work
with the State to conduct this task.
0 Follow up on reports of investigation of soil and ground-
water contamination.
S Receive, review, and evaluate required and voluntarily
submitted corrective action plans (CAPs) and reports of the
results of implementing the plans (@280.66]. For each
corrective action plan required, provide notice to the -
public of the release and the corrective action plan
[ @280.67]. Oversee implementation of corrective action
plans.
Option 1: State agrees to receive, review, evaluate, and
provide notice of CAPs as part of Trust Fund cooperative
agreement and/or program grant work plans.
Option 2: Region receives, reviews, evaluates, and provides
public notice of CAPs until the State agrees to conduct this
task. RP-lead corrective actions occur with limited direct
supervision from the Region or the State. Region will
continue to work with the State to conduct this task.
SUBPART C - OUT-OF-SERVICE UST SYSTEMS AND CLOSURE
o Grant extensions of the 12—month temporary closure period
[ @280.70(c)].
S Receive notifications prior to permanent closure or change—
in—service [ @280.71].
Option 1: State agrees to receive reports as part of program
grant work plan.
Option 2: Region receives reports and keeps them until the
State agrees to conduct this task. Region will continue to
work with the state to conduct this task.
o Review excavation zone assessments.
o Direct 0/0 of UST systems closed before December 22, 1988,
to assess the excavation zone and properly close the UST
system (@280.73].
S Receive records of excavation zone assessments if the
records cannot be kept at the site or an alternate site for
3 years [ @280.74].
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OSWER DIF(LLILVL iOiU. —i
10
Option 1: State agrees to receive records as part of program
grant work plan.
Option 2: Region receives records and keeps them until the
State agrees to conduct this task. Region will continue to
work with the State to conduct this task.
Reports of releases discovered at closure trigger the tasks
associated with the corrective action regulations (Subpart F).
COMPLIANCE MONITORING AND ENFORCEMENT TASKS
O Conduct outreach and compliance assistance activities to
promote compliance.
O Conduct site inspections (e.g., random, targeted, new tank
installations, or closures). Review 0/0 records, including
records regarding repairs, corrosion protection, and release
detection.
O Conduct enforcement activities related to the LUST Trust
Fund.
O Use formal enforcement actions to pursue violations of
Subparts A through H.
O Pursue Interim Prohibition violations. -
* * * * * * * * * * * *
In addition, both States and Regions will need to be
prepared to respond to Freedom of Information Act (FOIA) requests
and to follow regulatory requirements for public participation in
the program.
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OSWER DIRECTIVE 9610.5—1
11
Transition Tasks List — Part 2
Financial Responsibility Requirements
40 CFR Part 280: Subpart H
The definition of implementing agency in the financial
responsibility (FR) rule differs from that in Subparts A-G.
Under the FR rule, the State formally cannot be the implementing
agency during the transition period, although it may act on
behalf of EPA. The State may, for example, receive reports and
make recommendations on appropriate actions, but EPA retains
decision-making authority. Thus, some FR tasks may be included
in transition agreements as State responsibilities, others may
not.
Subpart H of the final UST technical standards and
corrective action requirements (excluding the suspension of
enforcement provisions) specifies 10 tasks as responsibilities of
the implementing agency. Subpart H phases in the financial
responsibility requirements for owners and operators over 21
months. 7 .s the requirements become effective during the
transition period, EPA’S goal is to have the States conduct 5 of
these 10 tasks as part of State program grant work plans.
LIST OF SPECIFIED TASKS (Subpart H )
10. Receive State Attorney General’s certification that
guarantees and/or surety bonds are leciallv valid and
enforceable obligations in that State 1 280.94(b)1 .
11. Receive notices that owners or oPerators no lonaer meet the
- financial test of self insurance r 28o.95(g)1 .
12. . Receive description, evaluate, determine acceptability of
use, and notify States of determination for State trust
funds and other State (including State—reauired) assurance
mechanisms F@280.100 & 280.l011 . Within 60 days of
approval, the State must provide to each owner or operator
for which the State is assuming financial responsibility a
letter or certificate to that effect [ @280.101(d)].
13. Instruct the trustees of trust funds to release excess funds
to owners or operators F 280.l021 . This refers to owners’
or operators’ trust funds, not standby trust funds or State
trust funds.
14. Instruct the trustees to refund balances of standby trust
funds to providers (cluarantors) after all costs and claims
have been settled F@280.103(c)1 .
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12
15. Receive notificata - f cancellation or non-renewal of
coverage 1@280.105(b, .
16. Receive copies of the financial responsibility mechanism
from owners and operators in the event of a release
[ @280.1061 or in the event of failure to obtain alternate
coverage within 30 days of notice of incapacity by provider
of financial assurance [ @280.106 & @280.1101 .
17. Direct guarantors. sureties. and institutions (letters of
credit) to deposit money into standby trust funds
[ @280.108(a)1 . -
18. Effect the drawdown of standby trust funds I @280.108(b)I .
19. Receive notices from owners or oPerators of the commencement
of bankruptcy oroceedinas and copies of financial assurance
instruments documenting current financial res nsibility
[ @280. 1101 .
Tasks 10, 14, 17, and 18 are necessary only for those owners
or operators who choose to use guarantees, surety bonds, or
letters of credit to meet all or part of their financial
responsibilities. These instruments require the creation of a
standby trust fund. Tasks 14, 17, and 18 will occur only after
the reporting of a confirmed release.
States should be asked to conduct tasks 10. 11. 15. 16. and
j as part of their program grant work plans. Task 10 likely
will occur once per State. Task 11 will occur only a very
limited number of times. States that are receiving new tank
notifications and/or notifications of closures very likely will
want to conduct tasks 15, 16, and 19.
Tasks 12. 13. 14. 17. and 18 must be oerformed by EPA
(Regional Administrator) during the transition period. States,
however, are required by the final regulations to provide the
letter or certificate to owners/operators related to Task 12.
This list does not include tasks associated with suspension
of enforcement of the financial responsibility requirements. The
following appendix includes other tasks related to the financial
responsibility requirements in the final rule, including optional
tasks, and a discussion of suspension of enforcement.
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U3Wt.t Uiz t.I,rLvC. UiV.J—L
13
APPENDIX 2: LIST OF SPECIFIED AND OPTIONAL ThSKS (SUBPART H )
The following is a more complete listing of tasks for the
implementing agency. The tasks are identified as either:
S = SPECIFIED : explicitly described in the UST regulations as a
responsibility of the implementing agency or implied to be a
responsibility of the implementing agency based on a
requirement placed on owners and operators; or
O = OPTIONAL : carried out at the discretion of the implementing
agency.
The specified tasks are a repetition of the previous list.
Guidance for implementation of the specified tasks is indicated
below each task as options for State or Regional implementation
during the transition period. The tasks identified as optional
indicate program areas for the Regions to work with States to
enhance capability.
* * * * * * * * * *
SUBPART H - FINANCIAL RESPONSIBILITY
S Receive State Attorney General’s certification that
guarantees and/or surety bonds are legally valid and
• enforceable obligations in that State (@280.94(b)].
Option 1: State agrees to request and receive certification
as part of program grant work plan.
Option 2: Region will continue to work with the State to
conduct this task.
o Request and receive reports of financial condition at any
time [ @280.95(f)] (self insurance only).
S Receive notices that 0/0 no longer meets the financial test
of self insurance [ @280.95(g)].
Option 1: state agrees to receive notices as part of program
grant work plan.
Option 2: Region receives notices and keeps them until the
- State agrees to assume this task. Region will continue to
work with the State to conduct this task.
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rl k.fl LA S (S —
14
O Notify guarantor that he no longer meets the requirements of
the financial test of self insurance (@280.96(b)].
O To promote compliance, follow-up on notices that 0/0 and
guarantors no longer meet the requirements of the financial
test of self insurance.
S Receive description, evaluate, determine acceptability of
use, and notify States of determination for State trust
funds and other State (including State-required) assurance
mechanisms L@280.lOO & @280.1011. Within 60 days of EPA
approval, provide to each 0/0 for which the State is
assuming financial responsibility a letter or certificate to
that effect (@280.101(d)].
[ This task must be performed by the EPA Regional
Administrator. It may not be delegated to or conducted by
States during the transition period or after State program
approval. The final regulations require that States provide
the letter or certificate to o/o.]
S Instruct the trustees of trust funds to release excess funds
to 0/0 [ @280.102]. (This refers to an 0/0’s trust fund, not
standby trust funds or State trust funds.)
[ This task must be performed by the EPA Regional
Administrator prior to State program approval.]
S Instruct trustees to refund balances of standby trust fundsi
to providers (guarantors) after all costs and claims have
been settled [ @280.103(c)].
(This task must be performed by the EPA Regional
Administrator prior to State program approval.]
S Receive notifications of cancellation or non—renewal of
coverage [ @280.105(b)].
Option 1: State agrees to receive notices as part of program
grant work plan.
Option 2: Region receives notices and keeps them until the
State agrees to assume this task. Region continues to work
with the State to conduct this task.
0 - To promote compliance, follow-up on notifications of
cancellation or non-renewal of coverage.
S Receive copies of the financial responsibility mechanism
from owners and operators in the event of a release
(@280.106] or in the event of failure to obtain alternate
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15
coverage within 30 days of notice of incapacity by provider
of financial assurance [ @280.106 & @280.110].
Option 1: State agrees to receive copies of the mechanisms
as part of program grant work plan.
Option 2: Region receives copies of the mechanisms and keeps
them until the State agrees to assume this task. Region
will continue to work with the State to conduct this task.
0 Request and receive evidence of financial assurance or other
information from 0/0 at any time [ @280.106(c)].
S Direct guarantors, sureties, and institutions (letters of
credit) to deposit money into standby trust funds
[ @280.108(a)].
[ This task must be performed by the EPA Regional
Administrator prior to State program approval.]
S Effect the drawdown of standby trust funds (@280.108(b)].
[ This task must be performed by the EPA Regional
Administrator prior to State program approval.]
S Receive notices from owners or operators of the commencement
of bankruptcy proceedings and copies of financial assurance
instruments documenting current financial responsibility
(@280.110].
Option 1: State agrees to receive bankruptcy notices as part
of program grant work plan. States receiving notifications
or closure notices likely will want to receive notices of
bankruptcy or incapacity.
Option 2: Region receives bankruptcy notices and keeps them
until the State agrees to assume this task. The Region will
continue to work with the State to conduct this task.
Suspension of Enforcement
The April 1987 proposed rule contained relatively detailed
procedures for suspension of enforcement of the-financial
responsibility requirements. Based on comments and the
uncertainty over the number of suspension applications likely to
be received, EPA has deferred promulgation of procedures for -
suspension of enforcement.
The final regulations phase in the financial responsibility
requirements over 21 months. EPA recognizes that the
availability of financial assurance mechanisms (particularly
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OSWER DIRECTIVE 9610.5—1
16
State funds) may change dramatically over time. In the meantime,
some States may receive State program approval. Thus, there is
significant uncertainty over whether, and to what extent,
suspension of enforcement will be necessary in the future. As
the necessity is demonstrated, EPA will adopt procedures for
suspension of enforcement. Until such time, however, EPA does
not intend to exercise its discretionary suspension authority.
Therefore, tasks associated with suspension of enforcement of the
financial responsibility requirements have not been included in
this document.
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0/
r”
United Stales Office of rY ‘ .
Environmental Protection Solid Waste arid -
Agency Emergency ResDons.
&EPA DIRECTIvENUMBER: 9610.5
TITLE: FY 1989 — FY 1990 Transition Strategy For the
Underground Storage Tank Program
APPR OVAL DATE: April 13, 1988
EFFECTIVE DATE: April 1, 1988
ORIGINATING OFFICE: Office of Underground Storage
JFINAL Tanks
‘ APR I 8 1988 0 DRAFT
‘CRA Management Branch STATUS:
REFERENCE (other documents):
OSWER Directive 9650.6 UGuidelines for LUST Trust
Fund Cooperative Agreements”
“Supplemental Guidelines for FY 89 LUST Trust Fund
Cooperative Agreements
“FY 89 State UST Program Grant Guidance”
OSWER OSWER OSWER
DIRECTIVE_DiRECTIVE IJ
UST/PM/PG/88-1
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I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
_____ WASHINGTON, D.C. 20460
4 L D o t
APR 13
CFF CE F
SO.’D W. SE NO €MEQGE C aES c jS
OSWER DIRECTIVE 9610.5
MEMORANDUM
SUBJECT: 1989 — FY 1990 Transition Strategy for the
1nderg ot nd torage Tank Program
I • ,(, /
/ ‘ -
FROM: . Winstbn rorter
,Assistant A ininistrator
TO: Regional Administrators
The final Subtitle I regulations are expected to be issued
in July and to take effect in October, at the beginning of FY
1989. At that time, the focus of EPA’s UST program will shift
from developing regulations to facilitating state implementation
of the national UST program. The next few years will be an
important time in the development of a national UST program. Th
implementation approach adopted for the UST regulations focuses
on the development and enhancement of state programs both during
the transition period (between the effective date of the
regulations and the time state programs are authorized), and
after state programs are authorized.
The attached “FY 1989 - FY 1990 Transition Strategy for the
Underground Storage Tank Program” is policy guidance for the
Regions and States and identifies appropriate activities for each
to undertake during the transition period. Its thesis is that
from the start, and to the extent possible, the states will be
the implementing agencies. Therefore, federal activities should
focus on assisting and encouraging the development and
enhancement of state programs. As indicated in the strategy,
the Regions should not carry out direct federal implementation of
the UST regulations in those states with nascent programs except
in rare circumstances.
This approach differs from the approach EPA has followed in
other programs. Many of you have expressed concern that we might
be criticized because of a perceived lack of a visible, federal
presence in the states and our reliance on the states to
implement the federal UST regulations. However, given the large
size of the regulated universe, the diverse nature of the
regulated community, and the limits on federal resources, great
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environmental benefits will be realized over the long term by
focusing federal resources on building state programs during the
transition period. It is the norm for new EPA programs that
comprehensive nation-wide program implementation is achieved in
the long term, and not immediately after the effective date of
the regulations. The UST program is no exception, and a
comprehensive nation—wide UST program will be realized gradually,
through the building of state and local UST programs.
The Transition Strategy has been written in response to
questions raised by Division Directors in Regions III and VII.
It is designed to be used in conjunction with the UST program
guidances on LUST Trust Fund Cooperative Agreements and State
Program Grants for FY 1989 and FY 1990. In FY 1990, OUST will
develop an updated implementation strategy which takes into
account the status of state program applications and approvals.
cc: Ron Brand, OUST
Waste Management Division Directors, Regions I-Ill, V-IX
Water Division Directors, Regions IV, X
UST Regional Coordinators
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o1O.
F? 1989 - FT 1990 TRANSITION STRATEGY FOR
THE UNDERGROUND STORAGE TANK PROGRAM
March 31, 1988
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9o O. s
Table of Contents
I. Abstract
II. Problem Statement
III. Transition Strategy
A. Summary of Basic Strategy
B. Scope of Strategy
IV. Implementation Plan for the Transition Strategy
A. Clean-up Program: LUST Trust Fund Activities
B. Regulatory Program: State Program Grant Activities
C. Promoting Compliance with the Regulations
]J. Legal Mechanism
E. Hazardous Substance UST Systems
V. Future Work
2
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9. ‘_o. -
I. bstract
This document presents EPA’S policy for implementation of
the UST program during FY 1989 and FY 1990. The problem to be
solved is described, and a transition strategy and implementation
plan are presented.
II. Problem Statement
The focus of the federal tJST program is on state
implementation. When the federal UST regulations become
effective in early FY 1989, most states will be in the process of
developing state regulations and beginning to assemble
applications for program approval. Headquarters, regions, and
states need policy guidance to identify appropriate activities
for eacri to undertake during the transition period between the
effective date of the federal regulations and the dates state
programs are authorized by EPA to operate in lieu of the federal
program. These may be interim or final state program approvals.
Al]. state programs will not be approved on the same date; hence,
the length of the transition period will vary by state, ranging
from a few months to two years or more.
III. Transition Strate v
The goal of EPA’s technical requirements is that all tank
systems wi].]. be upgraded or replaced within 10 years so that they
are protected from corrosion and have spill and overfill
protection, approved release detection systems, and continuous
monitoring on pressurized lines. The emphasis of EPA’S program
implementation is on the long term. The transition period,
therefore, will be characterized by the continuing growth of a
national UST program realized through the building of state and
local programs.
Comprehensive federal or state UST programs for petroleum
and hazardous substance UST systems will not be in operation
nationwide on the day the federal regulations become effective.
However, many states will have their own regulatory and clean-up
programs in operation. EPA’s goal is to build on these state
programs and to focus federal resources and efforts on improving
existing programs and facilitating the development of new state
programs. The “national” program will be a summation of state
and local programs. The work of -building_this comprehensi_ve
national program has already begun, and will continue during and
after the transition period. Over time, the program’s focus will
shift from building state capability and approving state programs
to working with the states to continually improve the performance
of state and local, programs. -
3
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96 LU. 5
A. Summary of Basic Strate v
During the transition period, EPA’s basic strategy is for
the states to implement as much of the federal UST program as
possible. Many of the specific actions states will be asked to
conduct to begin implementation of the federal UST program are
not much different from those they now are doing on their own or
for EPA under program grant agreements and LUST Trust Fund
cooperative agreements. States that operate clean-up programs
(funded with state and/or federal monies) and receive EPA program
grants have resources sufficient to fund the level of activities
necessary to begin implementation of the federal regulations
during the transition period. States will need to develop
independent funding sources to assure effective long—term program
implementation, as federal support is unlikely to ever be able to
fully support comprehensive state—run programs nationwide.
In the long term, EPA’s resources will have the greatest
impact when used to foster state implementation, rather than
being stretched thin trying to conduct a federal program in each
state. For example, EPA has the authority to conduct enforcement
activities, but conducting direct federal enforcement and
compliance monitoring activities is not the best use of
resources, given the limits on these resources and EPA’s goal of
building state programs. The transition period is an opportunity
to help states build programs and develop the technical and
enforcement expertise necessary to foster effective long—term
program implementation.
B. Score of Strate v
This strategy addresses those states that have clean-up
programs (funded with state and/or federal monies) and are
receiving federal program grants. For those states without
clean—up programs or federal grant monies, of which there are
only a few, state—specific strategies will be developed in FY
1988 and FY 1989.
This strategy pertains to UST systems containing petroleum
and/or hazardous substances.
IV. Implementation Plan for the Transition Strate v
A. Clean-liD Proaram: LUST Tru stFund Activities .
States with LUST Trust Fund cooperative agreements will be
asked to carry out activities to begin implementation of the
federal corrective action regulations during the transition
period. The scope, level, and speci f Ic set of clean-up program
activities that occur in each state will vary. In the first few
4
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* LO.5
years of the national UST program, all states will not be
conducting every activity to the same degree of thoroughness.
For example, states will be asked to receive corrective action
progress reports from owners and operators. As a follow-up, some
states will choose to use these reports as a primary part of
their oversight of responsible—party cleanups, while other states
will use other approaches to oversight.
The specific activities that will occur in each state will
be determined by state priorities, resources, and the stage of
program development, and will be defined during negotiations
with the regions about LUST Trust Fund cooperative agreements for
FY 1989 and FY 1990. These activities are allowable costs for
states to incur using LUST Trust Fund monies.
After promulgation of the final regulations, use of Trust
Fund monies for cleanups is limited to actions to protect human
health and the environment and to occasions when one or more of
the following situations exists: no responsible party can be
found, immediate action is needed, corrective action costs exceed
financial responsibility requirements, or the owner/operator is
recalcitrant (Subtitle I, Section 9003(h] [ 2]).
Section 9003(h)(1) describes activities eligible for funding
under the LUST Trust Fund. These activities are further defined
in OSWER Directive 9650.6, “Guidelines for LUST Trust Fund
Cooperative Agreements” and in the “Supplemental Guidelines for
FY 89 LUST Trust Fund Cooperative Agreements.” Trust Fund monies
may be used for enforcement, site response, and administration
and management activities associated with UST systems containing
petroleum. The following list provides examples of eligible
activities.
Enforcement Activities, including:
development, issuance, and oversight of enforcement actions
directed to responsible owners and operators; and recovery
of costs from liable tank owners or operators;
Site Responses Activities, including:
site investigations; investigations of suspected leaks and
source identification until such time as a leak is
determined to come from an unregulated source; emergency
response and initial site hazard mitigation; exposure
assessments to determine potential health effects of a leak;
the establishment of corrective action priorities;
- corrective action, including the clean up of releases;
- provision of alternative temporary or permanent waier:
supplies; and temporary or permanent relocation of
residents;
Administration and Management Activities, including:
reasonable and necessary administrative and planning
expenses directly related to the above—mentioned activities.
5
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9 ,LO. 5
Trust Fund monies, therefore, may be utilized by states to
conduct enforcement and site response activities related to
suspected or confirmed releases of petroleum from UST systems,
such as to: receive leak reports, initial corrective action
progress reports, free product removal reports, and site/soil
reports; review and approve or disapprove corrective action
plans; and provide opportunity for appropriate public
participation.
B. Regulatory Program: State Proaram Grant Activities
Following promulgation of the federal technical
requirements, states receiving program grants will be asked to
carry out activities to begin implementation of these regulations
during the transition period. The scope, level, and specific set
of regulatory program activities that occur in each state during
the transition period will vary. In the first few years of the
national UST program, all states will not be conducting every
activity to the same degree of thoroughness. For example, states
will be asked to receive advance notices of UST system closures
from owners and operators. As a follow—up, some states will
choose to use these reports as a method of targeting inspections,
while other states will use other approaches to conduct
compliance monitoring and enforcement activities.
The specific activities that will occur in each state will
be determined by state priorities, resources, and the stage of
program development, and will be defined during negotiations with
the regions about program grant agreements for FY 1989 and FY
1990. The costs of conducting these activities are allowable
costs for states to incur using program grants. According to the
FY 1989 state program grant guidance, the four major tasks
eligible for funding, listed in priority order, are:
1. State Program Development,
2. Program Approval Application,
3. Outreach Efforts to Promote Compliance, and
4. Compliance Monitoring and Enforcement.
As in the case of clean-up programs, the transition period
will be characterized by the continued growth of a national
regulatory program realized through the development and
enhancement of state and local regulatory programs.
C. Promotina Compliance with the Reauiation
A primary goal of the federal UST program is to encourage
compliance with the regulations. Promoting voluntary compliance
is an integral part of an overall enforcement strategy. In their
program grant agreements, states will be asked to conduct
6
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9610.5
outreach and compliance assistance activities to provide
technical assistance and inform owners and operators of their
responsibilities. The regions will assist states in these
endeavors.
Many states now have functioning compliance and enforcement
programs which will continue to operate during the transition
period. These programs reflect a variety of approaches and
priorities that states have developed to promote compliance. For
example, some states rely on permitting processes to ensure
compliance, while other states use random inspections or
tightness test results to identify violations. Other states are
developing similar approaches, and an important part of EPA’s
job, for both headquarters and the regions, is to work with state
and local governments to develop effective methods of promoting
and monitoring Compliance, and to share them with other states.
Examples of innovative methods include issuing on—site citations,
utilizing jobbers to promote registration and identify non—
registered tanks, and developing targeted inspection procedures.
OUST is finalizing and will publish a “Handbook on State
Compliance Programs” that provides detailed information on the
utilization of various techniques to promote compliance.
States also will be asked in their program grant agreements
to conduct formal enforcement actions to the extent of their
authorities and resources. If a state lacks the necessary
authority, federal authority may be utilized in response to a
state request. An example of this is responding to information
on the improper installation of new tanks. In general, regions
will refer initial complaints to the states, and the states will
respond and conduct appropriate compliance and enforcement
activities to the extent possible under state law. If the state
lacks the necessary enforcement authority, EPA may back up the
state using federal authority in response to a state request if
resources permit and other priorities are being met. Thus,
during the transition period, most formal enforcement actions
will be conducted by the states.
D. Leaal Mechanism
The legal mechanism for states to implement the federal UST
regulations during the transition period will be by formal
agreement negotiated between the regions and states. These
agreements need not be extensive or complex, and may be: separate
Memoranda of Agreement (MOAs) , MOAs attache4_ o_LUST_Tr st_J jfld ..
cooperative agreements and/or state program grant agreements, or
be included in the texts of LUST Trust Fund.. cooperative -
agreements and/or state program grant agreements. The regions
will determine the appropriate mechanism on a state-by-state
basis.
7
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96L3. 5
These agreements will allow EPA to build on existing state
program resources and legal authorities during the transition
period. However small the existing base of state activities, EP
will try to build on it. The lack of a comprehensive petroleum
and/or hazardous substance liST program does not negate the
opportunity to negotiate a limited agreement that reflects
existing state authorities. The state will be considered the
“implementing agency” for only those activities that fall within
the scope of the formal agreement. As a minimum, the states
should agree to be the “implementing agency” for the purpose of
receiving reports from owners and operators.
E. Hazardous Substance liST Systems
Based on notifications, an estimated 52,000 UST systems
contain hazardous substances nationwide, almost one-third of
which are in California. Hazardous substance UST systems
constitute less than 3% of the regulated universe.
Unlike petroleum releases, releases of hazardous substances
from liST systems are not eligible for LUST Trust Fund financed
corrective action activities. State clean—up programs for
hazardous substance tanks, therefore, are not eligible for LUST
Trust Fund financial support. In addition, some states may apply
for approval of a partial program (only covering UST systems
containing petroleum). Thus hazardous substance UST systems
constitute a unique case that must be addressed separat Ly from
UST systems containing petroleum.
At least 24 states and territories have legislative
authority, in place for devel ig approvable UST programs that
address requirements for tan sign, maintenance, and corrective.
action for hazardous substance tanks. Comprehensive
implementation of a national hazardous substance UST regulatory
program on the date the federal regulations become effective
cannot occur. This is a reality we start with, and as in the
parallel case of regulatory and clean-up programs for UST systems
containing petroleum, the transition period will be characterized
by the continued development and building of state capability to
operate regulatory and clean-up programs for UST systems
containing hazardous substances.
An analysis of the proposed regulations indicates that the
same basic set of activities are required of owners and
operators, and therefore of the implementing agency, of UST
systems containing hazardous substances as foE. UST systems
containing petroleum. As in the case of UST systems containing
petroleum, most formal enforcement actions....wilLJe conducted by
the states. When a state lacks the necessary authority and
refers a significant violation to EPA, EPA may. take an
enforcement action if resources permit and other priorities are
being met.
8
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Under certain circumstances, releases of hazardous
substances from UST systems qualify for immediate removal action
cleanups under Superfund. According to the National Oil and
Hazardous Substances Contingency Plan (40 CFR Part 300), an
immediate removal action will be carried out when a determination
is made that such action “will prevent or mitigate immediate and
significant risk of harm to human life or health or to the
environment from such situations as: (1) human, animal or food
chain exposure to acutely toxic substances; (2) contamination of
a drinking water supply; (3) fire and/or explosion; or (4)
similarly acute situations.” OUST will work with the Office of
Emergency and Remedial Response (Superfund) to clarify the
criteria and circumstances under which releases of hazardous
substances from UST systems qualify for immediate removal action
cleanups.
V. Future Work
This strategy addresses implementation of the UST program
during FY 1989 and FY 1990, the first two years the federal
regulations will be effective. A “Transition Tasks” document
will be completed soon. This document will provide
clarification about the activities required of the implementing
agency by the federal UST regulations, and will identify ways in.
which they can be carried out during the transition period. The
document will also outline tasks that are implied, conditional.
and optional for the implementing agency, based on requirement.s
placed on owners and operators.
During FY 1988 and continuing into FY 1989, state-specific
program implementation strategies will be developed for those few
states without clean—up programs or federal grant monies. In
addition, in FY 1990, OUST will develop an updated implementation
strategy for the UST program for FY 1991 which takes into account
the status of state program applications and approvals, state
funding sources, and state compliance monitoring and enforcement
activities.
9
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INDWIDUAL
ABILiTY TO PAY
GUIDANCE
Prepared for
U.S. Environmental Protection Agency
Region VII
UST Program
726 Minnesota Avenue
Kansas City, Kansas 66101
and
Iowa Department of Natural Resources
UST Section
Heniy A. Wallace Building
900 E. Grand
Des Moines, Iowa 50319
Prepared by:
Industrial Economics, Incorporated
2067 Massachusetts Avenue
Cambridge, Massachusetts 02140
19 June 1992
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TABLE OF CONTENTS
Ir(rRoDuc’rIoN . . . •.. ...... CILA.PTERI
BACKGROUND . 1-1
DEFINING ABIL1TY TO PAY’ 1.2
ORGANIZATION OF THIS MANUAL 1-2
OVERVIEW OF THE ABILITY TO PAY ANALYSIS CHAPTER 2
BACICGROIJ?4D 21
GOALS 2-1
APPROACH AND METHODOLOGY 2.2
Phase I: Income Test 2.3
Phase II: Indepch Ability to Pay Analysis 2-4
Income Determination and Categorization 2-4
Available Cash Flow Calculation 2-4
NetWorthandDcbtCapacityAsses sment 2-S
Review Process 2-7
KEY ANALYTICAL DECISIONS 2-7
STRUCTURE OF GUIDANCE 2-9
FIlING rHE LO4OEZ . . . . . . . . . . . . . , , . . . . . . . . . . . . . . . . . . • • • • CIIAPrER 3
THE PHASE I - IO4OEZ ANALYSIS 3-I
Geaeral lnfbrmation 3 .1
FinancialEvaluation. 3—2
THE PHASE II- IO4OEZ ANALYSIS 3-3
SectionI—Incom 3.3
Section l l-NetCasbFlow 34
Sectionm-Net Worth 35
Phase II Summary
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TABLE OF CONTENTS
(couthiued)
AppLIc tr1’r FILII’JG ‘rilE 1040A . . . . . . . . . . . . . . . . . . . . . . . . . . C11A.P’rER 4
THE PHASE I ANALYSIS .
General Information 44
Financial Evaluation 4-2
Wage lncome 4-2
Non-wage Income 4-3
The Phase II- 1040A Analysis 4-3
Section l-Income 4-3
Section II- Net Cash Flow 4-5
Section III- Net Worth 4-7
Summary 4-9
pp1.IC rrr F1I.INGIHE 1040 • •II lIe SIllS •SSSISSSS•IS 11151 I I I . . . .. . CIIAI’I’ERS
THE PHASE I - 1040 ANALYSIS 5-1
General Information S-I
Financial Evaluation 5-2
Wage Income 5-2
Non-Wage Income 5-3
THE PHASE 111040- ANALYSIS 5-3
Section I - Income 5-3
Scctionll-NetCashF low 5-8
Sectionil l-Net Worth 5-10
surnm ry 5.12
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INTRODUCTION CHAFrER 1
BACKGROUND
This manual is designed to provide guidance to the Iowa Department of Natural Resources
(IDNR), Underground Storage Tank (UST) Section. on determining an indMdual’s ability to pay for
site cc tment or remediation of UST releases. The manual presents a simple, step-by-step process
for calculating the funds that an individual may have available. This project was funded by the U.S.
Environmental Protection Agency (EPA), Region VIL
The State has found that individuals, with or without an active business (sole proprietorship),
constitute a large number of inability to pay claim A sole proprietorship is a business that is not
incorporated. The operator of a sole proprietorship is personally responsible for all liabilities that
the business incws.’ Frequently, the assets of the sole proprietorship and the owner are closely
related or shared.
IDNR requested that an analytical procedure be developed that would help the staff assess
the ability of individuals, with or without sole proprietorships, to pay UST ass,Mment and remediation
costs. Our goals in developing the guidance were that the approachi
• Be grounded in sound financial analysis techniques and theory;
• Be simple to admiithter
• Employ IDNR staff time efficiently;
• Offer fledbility in terms of the ability to pay criteria;
‘In an incorp-”ned siness, the owners, or shareholders, arc not personally liable for the acts
of the corporation.
1-1
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• Minimi’e data production burdens on claimants, and the need for assistance
from accountants or lawyers; and
• Produce clear, concise evaluations.
The ability to pay analysis consists of two stages. Phase I screens from further assessment
those individuals who are clearly unable to pay. This analysis is based on the individual’s most recent
tax return. Phase I lls a detailed analysis of those individuals who are not eliminated by the Phase
I screen, and evaluates three financial characteristics: (1) total income, (2) cash flow, and (3) net
worth. The Phase I I analysis is based on the individual’s most recent tax return and additional data
supplied by the applicant on a Financial Data Request form.
DEFINING ‘ABILiTY TO PAT
Although this manual is designed to provide users with a methodology for calculating an
individual’s financial capability, there are a variety of measures of ‘ability to pay.’ The strictest
definition is know as ‘solvency.’ An individual is insolvent when his or her liabilities exceed his or
her assets. In this situation, the individual could declare bankruptcy and have the court assist in the
disposition of the liabilities. Even if individuals are solvent, however, they may have a limited ability
to pay for UST assessment or remediation costs. For example, an applicant may have a total annual
income at poverty levels, minimal assets and no liabilities. In this case, assets are greater than
liabilities, but the applicant has minimal income, and on that basis must be judged unable to pay. In
addition, an individual’s ability to pay for site investigation or remcdiation depends on the financial
burden IDNR chooses to place on individuals. For example, we suggest that IDNR incorporate
factors such as age and the number of dependents when determining ability to pay.
ORGANIZATION OF THIS MANUAL
Chapter 2 of this manual outlines the ability to pay evaluation process, from information
collection through final aw”m nt , and discusses the methodology and criteria in detaiL Chapters
3,4 and 5 review the Phase I and Phase II analyses for individuals filing a 1O4OEZ, 1040A and 1040
federal income tax return, respectively. Chapter 6 discusses how to use and evaluate the analyses.
Appendix A contains the FmHA Income Tables that we use to make income comparisons. In
Appendix B we provide information about the IO4OEZ, 1040A and 1040 federal income tax returns.
Appendix C contains blank worksheets. Appendix D contains blank data forms that can be
photocopied for use with caset Appendix E contains Consumer Price Index Guidelines on the
relative importance of household expenditures.
1-2
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OVERVIEW OF THE ABILiTY TO PAY ANALYSIS CHAPTER 2
BACKGROUND
The ability to pay process explained in this manual was developed for the Iowa Department
of Natural Resource’s (IDNR) Underground Storage Tank (UST) Section. The State of Iowa’s UST
program requested that the U.S. EPA provide guidance in evaluating the financial condition of
individuals who have told the State that they may not be able topsy for aia ssments or removal and
cleanup of underground Lanka. Iowa’s UST program would like to have a consistent, reasonabLe
process and set of criteria for evaluating the financial position of these individuals.
The Iowa UST program must review a large number of inability to pay applications Many
of these applications come from individuals who are not currently operating a businest These
individuals may have operated a business in the past (for example, a gasoline station) and, as a result,
still own property with an UST. Or they may have inherited or purchased property with an UST.
In the past, the State has analyzed the applicant’s tax returns and a personal net worth statement
using the EPA’s ABEL model and a model developed by Dr. Carpenter for Nebraska. 2 One of the
problems with this approach, however, is that ABEL is designed to evaluate the financial health of
corporations, and thus is not well suited to the majority of Iowa UST applicants, which arc
indMduals. In evaluating applications, the State found that it needed an analytical tool geared
towards sole proprietorships and individuals without an operating businest
GOALS
The goal of this guidance is to provide a consistent and theoretically sound method for
evaluating ability to pay in involving individuals and sole proprietorships. In particular. we want
to set up an analytic framework that provides a clear and concise record of each individual’s case, and
produces results that can be used in conjunction with environmental h vd priorities to make
remediacon decisions at UST sitcs throughout the state.
2 Jon R. Carpenter, PhD. 4’çtj . for Detr j i Solvency of Tlnderaround Storage lanka .
September 4, 1990.
2-l
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The process presented in this manual applies financial analysis techniques commonly used to
evaluate an individual’s fln ncial position. Using basic financial information, worksheets, and a set
of criteria we have developed, IDNR staff can quickly make an assessment of an individual’s financial
condition. While the basic analytical framework is uniform for all applicants, the analysis is flexible
in termi of the ability to pay criteria. For example, IDNR can choose from among three income
levels when specifying their ‘minimum income’ criteria. Also, IDNR has the opportunity to balance
the ability to pay estimate against other factors that the applicant chooses to provide information on
(e.g., health, anticipated expenditures, etc).
Another goal in creating this framework is that it be simple to dmini ter and employ IDNR
staff time efficiently. The worksheets used in the analysis will help staff to quickly and easily calculate
an applicant’s cash flow and available assets. Computations and the use of financial ratios are kept
to a minimum. In a similar fashion, we attempt to minimi7e the data production burdens placed on
applicants. The Financial Data Request forms are simple and straightforward, such that most
applicants should be able to complete them without assistance from an accountant or lawyer. In
addition, because of the Phase I screening process, fewer applicants will be required to go through
this step.
We want to note that this analytical method will not produce a final ability to pay assessment
in all cases. Our objective is to provide assistance on the vast majority of cases , particularly for those
applicants with a straightforward financial situation. Cases involving applicants with sophisticated
investments (e.g., trusts, partnerships, Subchapter S corporations) may require evaluation by a
financial analyst.
Finally, one of our objectives is to establish a uniform process for reviewing individual ability
to pay cases that may have wider applicability. As such, the analytical method we develop for the
Iowa UST program will serve as a pilot study for UST programs throughout the countly, or for other
EPA programs requiring an individual ability to pay analysis.
APPROACH AND METHODOLOGY
We developed this guidance using standard financial principles and analytical techniques. Our
method is similar in some respects to the process that banks and other financial institutions use to
make loan determinations. Using information supplied by the applicant, we first assess an individual’s
cash flow. Cash flow is measured for a time period, such as a month or year, b ’ subtracting all
expenditures from revenues (e.g. salasy, interest, dividends, Social Security) received. Next we ’
networth,thatls ,thevaleofallautsafterdeducthgliabilitiesordcbL We thencompare an
applicant’s cash flow and net worth to standards or ratios based on that individual’s income leveL age,
county of residence, and household size. The degree to which an applicant’s cash flow and net worth
are above or below a specified ratio determines their ability to pay.
Note that ‘cash flow” differs from “taxable income.’ First, tmble income does not include all
sources of revenue for an individual For example, some retirement or investment income may be
tax-exempt, and excluded on the tax return. Second, some expenses are not fully reflected on a tax
return because they are not entirely dethctible (e.g medical costs and consumer loan interest).
Lastly, some tax-deductible expenses do not represet ui actual cash payment (e.g. depreciation).
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Phase 1: Income Test
The ability to pay assessment process is conducted in two stages. Phase I screens all
applicants based on an initial income evaluation. 4 In Phase I, IDNR will determine whether an
individual has resources in excess of a chosen “minimum income” standard. IDNR can “close” those
cases in which a Phase I analysis indicates that an individual does not have sufficient resources to
fund UST site costs. If, however, the analysis indicates resources in excess of the income cut-oft a
Phase II analysis should be conducted.
We recommend that IDNR use the Farmers Home Insurance Agency (FmHA) and the
Department of Housing and Urban Development (HUD) as a basis for income comparisons. 3 Every
12 to 18 months, these agencies update Census Bureau income data on a county-by-county basis (see
Appendix A). They provide the results to their state offices as a guideline in distributing housing
assistance grants and loans. The FmHA income tables specify “very low ” (50% of median household
income, or “MII I”), “low” (80% of MIII) , and “moderate” (approalmately equal to MIII) income
levels for each county in Iowa by family size. This range of income levels gives IDNR several options
when selecting a “minimum income” guideline appropriate for UST ability to pay cases.
Although these income tables were developed specifically for FmHA and HUD programs,
they are available to other government offices. IDNR can obtain updated versions from the Des
Moines FmHA office. We choose to use this data because it:
• IsbasedonCensusdata
• Is regularly updated according to a consistent methodology;
• Establishes several levels of income guidelines; and
• Is used by other government agencies.
IDNR has the option of using other data sources in creating its income criteria as well. For
example, the Census Bureau generates state median income and national poverty figures annually.
IDNR could usc a value representing national or state income figures ii it determines that an income
breakdown by household size and county is not necessary. Overall, we believe that the Census data
is less preferable because it is not as timely and detailed as the FmHA dat&
that “income” as used in tls text refers tc. total cash inflows to the applicant.
5 1f other states chose t inojy U me oIo imjlar data rL’ uld be available specific to the
state.
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Phase if: Indeuth Ability to Pay Analysis
The Phase II analysis provides a more thorough assessment of an applicant’s financial
condition. This analysis is based on the data in the applicant’s most recent federal tax return and data
the applicant supplies on the Financial Data Request form. The analysis has three components: (1)
an income determination and categorization; (2) an available cash flow calculation; and (3) a net
worth and debt capacity assessment. These are each discussed in more detail below.
Income DeterminMion and Categorization
This step identifies and quantifies all sources of the applicant’s income. Note that this figure
will be different than the income figured on the tax return. This difference is because the tax return
identifies only that income that can be taxed , and because some adjustments do not reflect any actual
cash outlay. Our goal is to account for all sources of income, whether or not they are taxable.
The income figure is used for two purposes. First, it categorizes the applicant’s income
relative to an average household of the same size in the same Iowa county as the applicant. In
particular, we have established three categories:
• Less than 75% of median household income;
• 75% to 125% of median household income: and,
• Greater than 125% of median household income.
This classification is then used in establishing suitable ratios for evaluating the applicant’s cash flow
and net worth. The income figure is also used in the cash flow calculation, which is discussed in the
following section.
Available Cash Flow Calculation
Next, we determine what amount, if any, of e, ess money the applicant may have available
during a year to pay for UST costs, after paying all other living expenses. This determination is based
on the income figure already calculated, and expenses the applicant provides in the Financial Data
Request form. As part of this calculation, we allow applicants a contingency allowance, to take into
account emergencies or unexpected needs.’ This contingency allowance is based on the income
criteria into which the applicant falls (established above). The greater the applicant’s income. the
lower the contingency allowance. The allowance is shown in Exhibit 21.
6 This allowance assum that all living costs identified by the individual arc reasonable and not
inflated. The user may.choose not to grant any contingency allowance if there is reason to believe
that the living expenses axe inflated, or if the user does not wish to provide such an allowance.
2-4
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Exhibit 2-I
INCOME CRITERI4 IiL4TRIX
Gross Income as a Percentage of
Median Household Income
Measures
Less than
75%
75 to 125%
Greater than
125%
Net Cash Flow
Contingency
A11owan
15%
10%
5%
For example, if the applicant’s income was less than 75% of median household income, the
contingency allowance would be 15%. Thus, in calculating cash flow the applicant’s expenses will be
increased by 15% before subtracting them from income and calculating available cash flow.
Note that the contingency allowance falls as the applicant’s income increases. This inverse
relationship keeps the dollar amount of the contingency relatively constant over income categories,
but still allows some adjustment for the applicant’s actual expenses. The user can adjust both the
schedule and percentage of the contingency allowance as he or she wishes.
Net Worth and Debt Capacity Assessment
The next step is to determine the applicant’s net worth and capacity to assume additional
debt. These calculations help us understand whether the applicant night be able to pay for UST
costs through assuming more debt or selling some assets.
Net worth is measured by subtracting liabilities from assets. If the applicant’s liabilities are
greater than the assets, then net worth is negative and the applicant is insolvent. ’ The net worth
calculation is based on the information provided by the applicant on the Financial Data Request
form. After computing the amount of assets and liabilities, we calculate the ratio of liabilities to
assets: a ratio less than one (1.0) indicates that the applicant is solvent.
Most bankers, however, will build a margin of safety into an assessment of the amount of debt
that a person or business can carry. For example, for the purchase of a house, many lenders require
a minimum down payment, which represents the amount of equity that the lender wants the owner
to have in the property. If the owner makes a twenty-percent down payment, then the liability to
asset ratio is .80 or 80% (.80 • 1.00). This result indicates that the loan is eighty percent of the
value of the asset
We apply this approach in assessing the debt capacity of applicants. Using the income
classifications determined at the beginning of Phase 11. we compare the applicant’s liabilities-to-assets
ratio to a value in ExhIbit 2-2. The ratios are dependent on the applic’ut’s employment status.
‘In this case, we cannot expect the applicant to supply IJST I 2s ft his assets, either through
sale or assuming more debt.
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ExhIbit 2-2
NET WORTH CRITERIA MATRIX
Gross Incense an a Percentage of
Median Household Incense
Measures
Less tha i
75%
75 to 125%
Grester than
125%
Liabilities/Assets Ratio
• Category k Applicant retired,
neanng retirement, or
unemployed
• Category B: Other
.5
.60
.55
.70
—
.60
.80
This matrix allows the ability to pay analysis to accommodate several important factors:
(1) Lower income individuals should have a larger margin of safety than higher
income individuals because they have less financial flexibility.
(2) The closer the applicant is to retirement, the larger the margin of safety
should be to allow for retirement and increased medical costs. It may also be
appropriate to provide a larger margin of safety for an unemployed applicant.
(3) Employed individuals have a greater capacity to support debt than those
lacking a steady income.
The ratios in Exhibit 2-2 reflect our best judgement of an appropriate range for these values.
Normally, businesses with liability-to-asset ratios less than .50 are considered to be in good shape.
This is the lowest value we suggest here.
An applicant’s ability to assume debt or sell assets is also constrained by his or her ability to
make debt payments. The strictest criteria used by mortgage lenders is that all debt payments
(mortgage and related payments, credit cards and other loans) should not exceed 36% of income.
Therefore, as part of the analysis, we calculate this ratio and compare it to the 36% guideline.
Applicants directing more than 36% of their gross income to debt payments may have serious
difficulty assuming more debt to pay for UST costs, even if their asset to liability ratio is strong. They
may, however, be able to sell some assets in this situation. Applicants who fall below this criteria and
who have a strong liability-to-asset ratio, may be able to finance UST costs through additional debt.
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Review Process
Theabilitytopayprocesscanbesummarizedinslxsteps. Toauistuse wehaep j
a case tracking sheet that can serve as a checldist’ of activities performed when processing a case.
The six steps are:
SteD I : Send tax data request and General Information form to the
applicant. We suggest that you note the date of the request
on the Tracking form. This form can serve as a record for
each applicant
Stec 2 Complete the Phase I analysis using the Phase I Worksheet
that matches the applicants federal income tax return form.
Note the date and disposition of the applicant’s Phase I
analysis on the Tracking form.
Step 3 : If applicant does have available resources, no further
analysis is required. Notify the applicant, if appropriate. If
the Phase I analysis indicates that funds may be available,
request that the applicant complete the Financial Data
Request form and return it to IDNR. Note the date of
request on the Tracking form.
Step 4 : After receiving applicant’s tax return and Financial Data
Request form, complete the Phase 11 analysis using the
appropriate Phase II analysis Worksheet Note available cash
flow and excess assets on Worksheet and Tracking form.
Stem, 5 : Assess additional information provided by applicant (see
Chapter 6). If appropriate adjust Phase U analysis.
Categorize applicant’s financial situation using the Phase II
Analysis Outcomes Matrix.
Step 6 : Make final determination of applicant’s ability to pay. Note
disposition on Tracking form and notify applicant as
appropriate.
These steps are summarized its Exhibit 2-3.
KEY ANALYTICAL DECISIONS
This section briefly identifies some of the most important assumptions that are made n the
design of this ability to pay analysts. In general, of course, the analysis is based on data supplied by
the applicant on either the federal tax return or the Financial Data Request J ,rm. If these data are
incorrect or not fully reflective of the applicant’s financial situatiop, they ufting analy ; may be
flawed.
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C
Exhibit 2-3
SUM1 4ARY OF INDIVIDUAL ABILITY TO PAY ANALYSIS
Applicant claims
inability to pay
I
)
Request tax data
from applicant
1
Conduct Phase I
analysis
I
Potential resources;
Phase 11 analysis
1
Request JFDRF
from applicant
I
Conduct Phase LI
analysis
I
Categok ap, cant
using Outcomes Iatrix
Final
determination
24
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Both the Phase I and Phase II analyses are based on the applicant’s income We assume that
persons with low income generally have fewer assets and a more limited ability to pay. In a few cases ,
however, reported income may not be an accurate reflection of an applicant’s financial situation. For
example, a low-income applicant that fails the Phase I screen might hold a major, non-income
producing asset that would allow the applicant to contribute to LIST costs. We believe that such
cases are rare, and that the general benefits and accuracy of the Phase I screening process outweigh
the risk of eliminating such a person.
The Phase II income analysis is more detailed, particularly for applicants filing the Form 1040.
Those applicants may have a very complicated financial situation, including income from sale of stock
or property, rental income, farm income, estate or trust income, and income from business entities
(partnerships, S-Corporations, and real estate management investment corporations). Many times
these investments serve as “tax shelters,” producing current lr which can reduce the taxpayer’s
overall taxable income, but quite possibly generating an economic gain in the long tim. The
calculations that these values are based on are complicated.
We believe that the vast majority of applicants will not have financial situations involving this
type of income, or that the effect of these investments will not substantially affect the results of the
analysis. This guidance will correctly calculate the net cash flow from rental properties, sole
proprietorships and farming activities, which are most lil ely to be the business activities in which
applicants may be engaged in. In addition, we ask the user to calculate the proportions of income
generated-by busineisca or investments. If this value is significant (i.e., reduces or increases income
by at least 20 percent), and the analysis indicates that the applicant cannot pay for all the LIST
cleanup, we recommend that you consult a financial analyst.
STRUCTURE OF GUIDANCE
The analytical process described in this manual is organized around the three different
individual tax forms an applicant may 111e the IO4OEZ, the 1040A, and the 1040. We devote one
chapter to each type of return. We have structured our explanations around the tax return forms for
two reasons. The first involves the complexity of the financial material presented. Those individuals
with a more involved income situation (who receive, for example, business income or significant
investment income) will file a form designed to detail these income sources. An analysis of these
income sources is mast clearly Illustrated through discussions and examples that follow a sample tax
return through the Phase I and Phase II analysis. Second, the format of tax return farms suggest that
we structure our discussions around them. As we make calculations, we refer to specific lines on the
return. In order to provide as much guidance as possible, we go through each form separately and
note the source line for the required information.
1 1n some instances you may review an applicant who has not filed a tax return. Under certain
circumstances (e.g., very low income) individuals arc not required to file. See the “Do I have to
File? section of the individual tax form instruction booklets for more information on this topic. In
most instances, mdlvi .uals who do not file tax returns will not be able to pay UST costs. fowcvcr,
you should r ’ ’irsr r. t the applicant complete an Individual Financial Data Req!u 1 Fo i so that
you can determine w ther he or she has available assets.
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In each chapter, we demonstrate the analysis by working through a sample case. In the final
chapter, we discuss how to use and follow-up on the analyses. This final chapter also discusses how
IDNR might evaluate more complex tax returns.
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APPLICANT FILING THE IO4OEZ CHAI ’I 3
In this chapter, we describe the ability to pay analysis for applicants filing the IO4OEZ Federal
Income Tax return. The 1O4OEZ is the simplest of all individual tax forms. Only single filers who
do not claim dependents, whose income is less than $50,000 and who do not itemize deductions can
use this form. 9 As a general matter, applicants filing the IO4OEZ are likely to have the least financial
resources of all applicants, because their resources are limited to wage and salasy income and a
relatively small amount of interest income. These applicants will nOt have any income from stock,
capital gains, a business, a farm, and so forth.
THE PHASE I. 1O4OEZ ANALYSIS
The Phase I analysis is designed to ellminnte quickly from further consideration those
individuals who clearly lack the funds to pay for site investigation or remediauon. This analysis is
based on data from the applicant’s IO4OEZ form and initial application form.
We have prepared a Phase I - IO4OEZ analysis of a hypothetical applicant, to demonstrate
the Phase I- 1O4OEZ evaluation. The completed worksheets and data forms for this example can
be found at the end of this chapter. Below we discuss each item on the worksheet using this
example.
Generat Info matlou
• AppIfr t’s Name. On Line 1 enter the applicant’s name. Note that the case
name for our example is AJ Leaks.
• County. On Line 2 note the applicant’s county of residence. As explained
in Chapter 1, county of residence is important to the evaluation of the
applicant’s income. In our example, Al Leaks lives hi Wright County.
9 Sce Appendix B for a detailed Ja don of Fedcr I Income Tax return forms 1O4OEZ . U’ A
and 1040.
3-1
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• Sits location. On Line 3 identify the specific location of the UST requiring
investigation or remediation. Our case example site is Clarion, Wright
County.
• Estimated Investigation or cleanup costs. If known, note on Line 4 the
estimated cost of cleanup or investigation. In our example, the (JST in
Clarion requires an investigation that is expected to cost $4,000.
• Other parties Involved. On Line 5, list names of other parties involved in this
site. Is the property jointly owned? In our example, Al Leaks is the sole
responsible party.
Financial Evaluation
This section of the Phase I - IO4OEZ Worksheet is used to evaluate the applicant’s income
as reported in the IO4OEZ tax return. The applicant’s total adjusted gross income is compared to the
standard for the county of residence found in the FinHA income tables in Appendix A. In our
examples, we will use lowR income category as our criteria for ability to pay.
• Adjusted gross income. Find the applicant’s adjusted gross income on Line
3 of the IO4OEZ form. In our example, Al Leaks ’ income is $22,450. Write
this figure on Line 6 of the Phase l-1O4OEZ Worksheet.
• Minimum income level for households, From the data in Appendix A, we
want to determine the FmHA low income criteria for residents in Wright
County. Since Leaks [ lied a 1O4OEZ, we know that this is a one-person
household. Therefore, on Line 7, enter $17800, the 1ow-income value for
a one-person household in Wright County.
• Incom, in of mInI ua. Subtract Line 7 from Line 6 and enter this
figure in Line & In our example, the difference equals $4,650. This means
that Al Leaks’ income is $4,650 above the “low income” cutoff.
In Section ilL we record the outcome of the Phase I- IO4OEZ analysis. Simply check
whether the income figure in Line 8 is positive or negative. In our example, the amount in Line 8
is positive. Therefore, )VU should request further information from the applicant and conduct Phase
II analysis. If Line 8 is negative, check Line 9. This means that the applicant is unable top , and
further analysis is not recommended.
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THE PHASE II. IO4OEZ ANALYSIS
This section describes the Phase U analysis for the 1O4OEZ Federal Income Tax return. The
Phase LI analysis estimates the resources that applicants passing the Phase I analysis may have to
contribute to site investigation or cleanup. The estimate is based on data from the applicant’s
Financial Data Form and IO4OEZ tax return. The analysis entails three steps: (1) an income analysis,
(2) a cash flow analysis, and (3) a net worth analysis. Al Leak’s completed Financial Data Form can
be found at the end of this chapter.
Section I - Income
The prirnasy purpose of this section isto categorize the applicant in terms of income, so that
we can apply the income criteria in the second and third parts of the analysis. While the Phase I
analysis compared the applicant’s income to a “low-income” minimum, this portion of the analysis
compares the applicant’s income to the country median household income. We will continue to use
data from Al Leaks as our case example.
• Applicant’s name. Al Leaks.
• Adjusted gross Income. On Line 1 of the Worksheet, enter the applicant’s
adjusted gross income. This is the same value entered on Line 6 of the Phase
I - IO4OEZ Worksheet. Leaks ’ income in 1991 was $22,450.
• Median Income. The FmHA data tables provide us with a “60% of median
income” figure. We will use this to determine the median household income
figure. To find this value, look up the applicant’s county and then find the
appropriate household size column. The last row of data lists 60% of median
income. In the case of A l Leaks, 60% of median income for a Wright
County one-person household is $13,350. Divide this amount by 0.6 and enter
the result on Line 2. Median income in Wright County is $22,250
($13,35 0j0.6).
• Ina)nm rode. We next want to determine the applicants income category on
the income criteria matrix (see Echibit 2-1 in Chapter 2). To find this
percentage, we simply divide the applicant’s income by median income. The
result will show whether the applicant’s income is above or below average,
and by what percent. To determine the result for Al Leaks, divide Line 1
($22,450) by Line 2 ($“ 250). The result is 1.01 or 101%. This means that
Le k ’ income is 1 percent above the county median. Leaks ’ income
therefore falls into the 75% to 125% category, or middle range, on the
income criteria matrix. Enter this amount on Line 3.
3-3
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Section II. Net Cash Flow
The next step in the Phase II analysis involves determining the applicant’s cash flow. A
simple way to think of cash flow is as the income left over after paying all cash expenses during a
period. In computing cash flow, we use data from the Current Living Expenses section of the
Financial Data Form (Part II).
I Total annual living expenses. Go to Part II of the applicant’s Financial Data
Request Form. Space for converting data to annual values is provided in the
“For Agency Use Only” column in the Current Living Expenses Section (Part
II). For weekly expenses, multiply the given amount by 52 and put the total
in the “For Agency Use Only” column. For monthly expenses multiply by 12;
and for quarterly expenses multiply by 4. (Al Leaks’ expenses are converted
to annual figures as shown in the Financial Data Request form at the end of
this chapter. Sum this column of figures and enter the total on Line 4 of the
Phase II Worksheet. Al Leaks’ total annual living expenses are $17,735.
• Total annual debt payment. On Line 5 we enter the applicant’s total annual
debt expenses. An applicant’s current debt expenses are important to
determining the applicant’s ability to• acquire additional debt for site
assessment or cleanup costs. Total Lines 8.1 through B.4 on the Current
Living Expenses Form and enter this amount on Line 35 of the worksheet.
leaks spends $3,120 a year on debt payments.
• Cash Flow. Subtract Line 4 from Line 1. Leaks ’ Net Cash Flow is $4,715.
Enter this amount on Line 6.
• Cash Flow contingency allowance percentage Consult the income criteria
matrix to determine the appropriate cash flow contingency allowance. Leaks’
income level of 101% falls into the “75% to 125% category”, and indicates a
contingency allowance of 10 percent. Enter this percentage on Line 7.
• Cash flow contingency amount. We now calculate the amount of contingency
expenses we will allow Leaks based on the contingency percentage and
predicted annual expenses. Multiply total expenses (Line 4) by the
contingency p utage (Line 7) and enter this figure on Line 8. Ten percent
of Leaks’ total espenses equals $1,774. ($17,735 x 0.10) In calculating
available cash (low we set this amount aside to allow for unibraeea expenses
or emergencies.
• A,aII hle cash flow. Subtract Line 8 from Line 6 and record this figure on
Line 9. Leaks ’ annual cash flow, after subtracting out expenses and a
contingency allowance, equal $2,941.
3-4
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• P utags of debt cost relative to income. Here we consider what portion
of an applicant’s income is directed towards debt repayment. The level of
current debt will determine how much additional debt an applicant may be
able to assume for the payment of UST site costs. Applicants who are
currently paying more than 36 percent of their income for debt payment will
probably not have the capacity to acquire additional debt. In fact, they may
be denied funds by a lending institution. To calculate an applicant’s
percentage debt expense, simply divide their annual debt expense (Line 5) by
their total income (Line 1) and record this figure on Line 10 (3,120f22,450 =
.139). Enter 14% for Leaks.
At the end of Section II of the Worksheet, note the Cash Flow Disposition. In the case of
Al Leaks, we check Line 11 - applicant has available cash resources.
Section III - Net Worth
The last section of the Phase 11 analysis evaluates the applicant’s net worth. Here we assess
an applicant’s total assets and liabilities. The data for this analysis comes from the Net Worth Section
(Part III) of the Financial Data Form. Note that the For Agency Use Only’ space on the data forms
can be used to total the amounts on Questions 1 through 13.
On Line 13 through 20 of the IO4OEZ worksheet, we enter subtotals for assets.
• Bank Accounts. Enter the subtotal from Question 1 on Line 13 of the
worksheet Leaks has a total of $1,731 in checking and savings accounts.
• Investments. On Line 14 of the worksheet, enter the subtotal for the
applicant’s investments. Leaks has $185 in investments.
Retirement funds and accounts. Enter the subtotal from this question on
Line 15. Leaks has 0 in retirement funds and accounts.
• LUb insurance policies. Enter the subtotal from Question 4 on Line 16. The
cash value of Leaks life insurance policy equals $500.
• Vehicles. Enter the applicant’s estimate of the value of his vehicles on Line
17. Leaks has entered $13,500 for this question.
• Personal praperty. On Line 18 of the worksheet, enter the value of the
applicant’s personal property. For Leaks this total is $850.
• Real estate. On Line 19 of the worksheet, enter the subtotal for the value
of all real estate. Leaks does not hold any real estate, soenterO.
3.5
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• Other assets. On Line 8, the applicant totals the value of all other assets.
Leaks has listed carpentry tools for this question, at a value of $1,100.
• Total assets. Md Lines 13 through 20 on the worksheet and enter this
amount on Line 21. The total value of all of Leaks’ assets is $17,866.
We next total Leaks’ liabilities as detailed in Questions 9 through 13 on the Financial Data Request
form.
• Credit cards and lines of credit. On Line 22 of the worksheet, enter the
subtotal of all credit card and lines of credit debt. Leaks is carrying $840 in
credit card debt.
• Vehide loajis. Enter the subtotal for all vehicle loans on Line 23 of the
worksheet Leaks owes $11,570 on his vehicles.
• Furniture and household goods loans. On Line 24 of the worksheet enter
any debt on household goods and furniture. leaks enters 0.
• Mortgjji and real estate loans. Enter the subtotal for all loans on real
estateonLine2S. Leaksenters0.
• Other debt On Line 26, enter the total for applicant’s additional debt.
Leaks has listed 0 for this question.
• Total liabilities. Add Lines 22 through 26 on the worksheet and enter this
figure on Line 27. Leaks has a total of $12,410 in liabilities.
• Net Worth. Subtract Line 27 from Line 21 to determine the applicant’s net
worth. (Keep in mind that this çg be a negative number. Negative net worth
simply means that an applicant’s debt is greater than his or her assets.) Leaks’
net worth equals $5,456 and is entered on Line 28 of the Worksheet.
• Applicant’s age. On Part I of the Financial Data Request form, find the
applicant’s age and enter it on Line 29 of the worksheet. Leaks was 31 when
he completed this form.
• Appllcant!s employment status. On Line 30, note whether the applicant is
employed, unemployed or retired. leak’s is employed.
3-6
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• Target Net Worth. We next want to determine the applicant’s target net
worth ratio. Recall that Leak’s income put him in the 15% to 125%
category. Checking under this column on the net worth criteria matrix, we
see that the target liability to asset ratio for Category A (applicant retired or
unemployed) is 0.55, while the ratio for Category B (Other) is 0.70. Leaks
falli into Category B, and his target ratio is 0.70. Enter this figure on Line
31.
• Target Assets. We next want to determine the necessary assets for this
applicant, based on his or her target net worth. To determine this dollar
amount, divide Line 27 by Line 31 (liabilities divided by target net worth).
Leaks’ liabilities equal $12,410. If we divide this by 0.70 we get a dollar figure
of $17,729, which represents the amount of assets Leaks should maintain.
Enter this amount on Line 32.
• Available assets. We next want to determine Leaks ’ available assets, that is,
the value of his assets that may be available for UST site costs. We find this
value by subtracting the applicant’s target assets from his total assets. For
Leaks, subtract Line 32 ($17,729) from Line 21 (17,886). The result is $137
indicating that Leaks has a small portion of available assets.
At the end of this section summarize the applicant’s Net Worth disposition. AJ Leaks has
available assets, and we check Line 34- applicant has available assets.
Phase II Summary
At the end of the Phase II Worksheet, summarize the results from the cash flow analysis and
the net worth analysis. On Line 36, note whether applicant has available cash resources. If so, enter
the amount. We found that Al Leaks ’ had $2,941 excess annual cash flow. On Line 37, enter the
applicant’s available assets. We found that Leaks has S137 of exiess assets. On Line 38, enter the
applicants percentage of annual debt payment to annual incomc On Line 10 of the worksheet, we
see that this figure is 14% for Leaks.
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INDIVIDUAL ABILITY TO PAY CLAIM
General Inforrnauon Form
Case Name: ‘JOJt rL A - 4i
We are requesting if ‘ ciaj infQrmauon to help us evaluate your ability to contribute funds for
riveauaauon or remediation of the petroleum release at the above-mentioned site. Please (ill out this
form and submit a signed. conmiete copy oc your most recent federal income tax return. The Iowa
Department of Natural Resources may request documentation supporting the iniormauoa you
provide on this form or in your tax return.
Name: 4 - i A
Spouse’s Name:
Addrc
Z’ ( ti r-
c wiian,
Phone Number: Home ( J5) €U-32.I I Work ( I5)( 4 S
Count, of R.’ nc O C.4tA U)r
Does the information provided on your federal income tax return accurately redect
your current if n uvc al sicuauon? Please deicnbe below a’ 4 ditional information that
you would like us to consider in evaluating your case (for example. anticipated major
expenditures or changes in income). Use additional sheets if necesiaiv.
Are you currently participating in any type of federal or state assistance program (for
APDC. SSL food s’ ’ HUD or FmHA housing assistance , home heating
assisanee. M hc L or towas mP iIy needy program)? Please describe below.
Attach additional pages if nec ary .
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INDIVIDUAL ABIIIIY TO PAY TRACKING FORM
Iowa Department of Natural Resources
Applicant’s Name
f
Md
I
County:
Case Analyst
PHASE I ANALYSIS
I -h’1vr TS. L ) S 1.
(2 L M-lt
Pr\lasv’- Ay I S# 1
Date Individual was first contacte± I
Date Phase I Request Letter MaiI d I
Date Tax Forms are Returned to IDNR I
Y of Tax Return: I
Type of Form: ( i.e.. IO4OEZ. 1040A. 1040 )
Schedules Attached to Tax Fcrm I
Phase I Disposition (check one) I
I I
14
Applicant has no resources.
Analysis dis ntinued.
[ Date Analysis Complr &
Mditional Comments:
‘
Phase II anaMis performed.
I /I’; /q2 I
l itiqz. I
I ( 9 I7 _ o)qz .
I ( ° i 1
I (04O Z _ I
I l\j v . 1
I I
a
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PHASE U ANALYSIS
Date Maiysis Completed:
Additional Commenu
Date Phase II Packet Mailed I
Date Phase I I Data Forms arc Returned to IDNR: I
Phase U Disposition
Available Cash Flow
HcP Asseu
Final Determination
I
rIIo ’L
I IIic1z.
1
I
Z,C?.1I
Ic
1
I
•1
I
I
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INDIVIDUAL ABILITY TO PAY CLAIM
Financial Data Request Form
This rorm requests information regarding your tinancial status. The data wiil be used to
vaiuate your ability to pay for environmental clean-up or penalties. If there s not enoualt
space :or your answers, please use additional sheets oi paper. Note that we may request
further documentation of any of your responses. We welcome any other information you
wish to provide supporting your case. particularly if you feel your situation is not adequately
described through the information requested here.
Certification
[ declare that this statement o assets, liabilities, and other information is true, correct, and
.omDlete o the best of my knowiedge and belief.
- Signature Date
( Tt.f14 u . LLa.JLi Il11I 2 .
Name: i44 ( 1.
Spouse’s t Iame I
Address: bt’iP 1 ‘ -
CIwt.’on , A
County ot Residence: ujri rft’ C wp..t .-
—
I
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PART L BACKGROUND INFORMATION
I. MEMBERS OF EOUSEUOLD (List the head of the household and U persons living with yoo
Name
Age
Relauonstup to Head
of Household
Cunenijy
EmoIove ?
r .L a S
S1
iJt&L
\/f
,
Name
Pv-W ir (2età .s
2. EMPLOYM (T (list .11 job. held by p sans in hnusahnI )
Employer
i IC c ruc,f,cvi 1 :c nc..
Length of
Employment
Annual
(
— — w I —
Z2,L1t 1
2
-------
PART IL CURRENT LiVING EXPENSES
Please list personal living expenses which were typical dunng the last year and indicate if any of these
values are likely to change significantly in the current year. Please do not include business experies. If
iou are the owner of an operating business, please attachment any available financial statements.
E peni.
l 1od of Payment (cbedr one
For A eucy LYee Only
Vi•
MOn$hI
Qw rI
Ye.rI
A LMn Lx eases
1.Rent
L O
1
48O
. Home_maintenance
3. Auto fuel maint/othertransp.
15()
.1
cO
3. Lrtw
a. Fuel (gas.oal.wood.propane)
5
.1
b.Electnc
10
“
.12.0
c. Water/sewer
d. Thiephone
I $.Food
i)
.1
‘ (oO
‘5
v’
2. O
6. Clothiur. personal care
5
.J
C , 00
7. Medical costs
5
J
ç p
B. Debt Payments
I._Mortgage payments
2. Car payments
J
P Q
3. Credit card payments
‘.J
____
ZL(0
4._Educational_loan_payments
C. Insurance
1. Household insurance
2. Life insurance
L4’
J
3. Automobile insurance
O
I
O
4. Medical insurance
D. Taxes
1. Pmperw taxes
2. Federal incense taxes
3. State income taxes
“
,. /
2,
% pçt4
4. FICA
£4 I2_
./
u .
a Other Expenses
1. Childesre
2. Current School 1uit1onI pensa
—.
3. Legal or professional services
.
4. Other (itemize on separate pane)
ibtal Current Expenses
t1 3
3
-------
PART ILL NE WORTH
Please provide the following information to the best of your ability. Data should be as current
as possible. Estimates are acceptable; if you wish note such items with an “E”.
If you are the sole propnetor of a business, please lists business assets and liabilities, in addition
to personal assets and liabilities. Please mark these entries with a “B” to identify them as
business assets and liabilities.
Name of Bank or Credit Union
(irnt.Ar vittIn,14 Tirijc
(‘ iJLii’ v fltuiy s
-J
1 ’pe of A uaz
- j Ji(iCi S
C1 if t
1. BAtIK A COUN T (cb —’ l NOW Sa’uiiw, MOneT Market, etc)
.
ZTh eel).
1 A J
a,.—- IIIW Wir,.fUu —
%P__a_ I L .....J_. — _._.___ ( ‘ i v .
For A &p Lie. On!,- ‘ ‘ — —
LU IEU — —
w sOnenI
O’IQ. u.S. r € u I?cfl L (i
c’fr ftc. 1Yr I jAV A OfvL (i ‘ i
.‘
3.
Number of Shares or Linus
2
Current 92I Il
-: sp
c
‘I ’
R IZ L 1 1 J’T .S
For Agency Use On1 . 1b LOirreas Mattel ‘d Ine of fnvcsuaams
Current Market %tlue
2 5
(oc j
IRc
J’UI4DSAND A OUPflS (IRA , , 4O1(k) oai .,I.& I If piy—
—
. — - — -r
Desauptuon of A unt
Esdmated Marker Ius
For Aganq Us. OnLT- 1b 1 Estimated Market Wiuc fRethemesz Fon
and unts
. .1.
4-
-------
4. LIFE INSURANCE POLIC1 -
Policy Holder
Isswng Contpanv
Policy 1ue
Cash lv Iue
A 3 (1&L(h
Mu.+ I k C.o.
2O,oo C
For Agency Use Only - ibtal Value of Life Insurance Policies
—
5. VEHI (Cars Thac , M tub 1 Ja., ReaeidaaVehlder, Motor ffomes, Baste, Afrplanes, e
Model
Year
Estimated Market Value
I N coii irdcJ
5c b
1 q g tv i’ Mo 4 (j
For Agency (.Tse Only. iblal Estimated Market Value of Wh4d
i? S oO
6 PERSONAL PROPERlY uP ” Goods and Fiwu*Iw’ Jcir.lr Ar An’qv ., CeUeetlo.
Prado...s M.t.lv e _Only list lti 1 .e with a ‘sins pastes_than S O.OO)
Type of Property
Estimated Market Value
5 i Ai
cj
For Agency (Jse Only. ibtal Estimated Market Value of raonai Property
Pro
7. REAL STATE (Ti 4, 3gfl h.g bad with Bojidhip)
Locetlon
Deaaiptlon of Property
For AgencP Use Only. ibtal Estimated Market Value of Real Estate
P ’1
Estimated Market Value
S
-------
8. Onir. ASS ’ 3
9. cREDrr CARDS AIW Wf or CREDIT
— - —
Credn CazdlUnc of Credit (l ipe)
M(t’,ir,,y,ziv,L
y tht, th iD \(icA
4ni ç ( .t’icvc f .
d
P /pc of_
A.l iP A+y ¶1 \ C4W Thfr I1,l W. wuc..c
(‘
(WA
-J
For Agency J5c.Oufr. 1b I Other Msc
Owed lb
G+ibc-
\ tk’I v (_
A. , vç
For Agency Us. Cal ,- tbtaL 8aIan Due on Credit Caz and Un of
Credit
Estimated Market ‘#tluc
i tcx
92I2Iw Dun
‘4 o
L O
c ()
1o
10. VEHICLE LOANS (Cars Me4u...,d.s Rweado. WMrlti , Mot ffe Born, A1rp
etc)
Ve iclg (Model and Year)
Owed lb
Ra1an Due
IcIc3 1 \j’S a,fl rvit t
Crcd 1 i Ctv .
I O , 2 2)0
4a.yt,.r&, wc e..
Nhi ryi 1 icei .t I sM r
I L Q
For Agency (Is. Only. lb L Balan Due on Vehlclc Lnrn
L Si’O
6
-------
U. FURNITURE AND BOUSEROW GOODS LOANSs
Liat Item
Owed To
Balarnz Due
For Agency Use Only - lbtai Ralant r Due on Furnaure and House ot4
Goo Loan
12. MORTGAG AND REAL TATE LOANS
T ipe of Loan
Owed lb
Property Secured
Against
Balan Due
For Agency Use Only- ibini B.’. Due on Mortgages and Real Escare Loans
‘
13. Q j j DEE? (Amounes due to IadMdaals, FkuI obUgatloea, 1 s Owed, Overdue Allmo.y or ( IId
Support, etc.)
l ,pe of Debt
Owed lb
Balan Due
For Agency Use Only - lbtM 3alin Due on Other Debt
7
-------
PART W ADDITIONAL INFORMATION
Please respond to the following questions. For any question that you answer “Yes,” please
provide additional information on separate pages or at the bottom of this page.
QUESTION
YES
NO
1. Do you have any reason to believe that your financial situation
will change during the next year?
2. Are you currently selling or purchasing any real estate?
.
‘
3. Is anyone (or any entity) holding real or personal property on
your behalf (e.g. a trust)?
)
4._Areyouapartyinanypendinglawsuis?
S. Have any of your belongings been repossessed in the lass three
years?
6. Are you a Thissee, Executor, or Mrnñiirntor?
)C
7. Are you a participant or beneficiary of an estate or profit sharing
plan?
‘ i
8. Have you declared bankruptcy in the last seven years?
$
9. Do you receive any type of federal aid or public assistance?
)(
8
-------
dt Tvu .,—4aar.M L. £.-u...
income li x Rsthm for
1O4OEZ SIl s Alum With No Oegsndun ( 1991
Name &
address
use the I R S lahul (use ps 10). If you don’t have one, plea.. print.
I .
A
S
I
I .
fr- r L .eiJ(5
1% L eb& .a+s4 ‘
O Ms 15460575
Pleas. print your nu bera like thia
876Sti32 10
Your social securzty nueibsr
H . — 1 uIf M. a P0. . — Lb —
U C . ou — W p— a — — iL.
Pies.. l tl s os th. Ale.,... he
Fores 1040 bo. ’ t
Pt—---’--- ’-’ VI i Cospsign (us. page 11) 1a.
——‘U.,—..
Do you w.nt $1 to ge to this fund? _____
your 1 TotaL wagee, salaries, and ups. This should be shown in
income Son 10 of your W.2 forus(ai. your W.2 formic,) 1
2 Tunh ’ interest mmoi , of $400 or Lees. If the total is more
than $400. you “ —i use Form IO4OEZ . . 2
Altzc
Copy S ot
Formier
w.2 a.,..
Attacs ian
payus..t Os
iopcf
Fermi ii W.2.
3 Add lii . land line 2. This is your adjusted grass inooms. 3
4 Can yow parouss (or else) dane you on their ions’s?
Notes YOU D You. 0 . . . rkâuue on bech entor amount aim lie. E here.
nineS ch.ch r ’rr.. Enter 5.550.00. This is the total of your
es O J s’ •’d deducoon and peruonal ezeuspuon. 4
S Sub e4fgomli s3.I(liae4islargsrthaalin .3,
enter 0. This is your
Figure
your
tax
6
Eater your Federal 1n, i m. taz withheld aim Box 9 of
.. W.2 for . .. ,.
6
7
Tan.Usethsanoe.tonUnslt .Sndyour,axinthetaz
tabl. on pgme 1645 c i the booklet. Enter the ten from the
tsbl eo nihj slin e.
7
Refund
amount
OU
ow.
I
Iflius6islergthaaline7,sub sstLjn .7fromlins5.
is yo ..A...d.
8
9
tfthe7 Is. thli& .i is-jthu4ai . .Ia . .7.Tblsistta
s-_ $ you psy I fell paysbis is ibs
‘Tataimi ,ua._ . .._. Writs poor sane. .dd ou nea l y
ri . deyne. p ios .“ set 199t Form LO4O on ii.
Sign
you,
return
Kasp a on ;,
f this form
ror your
F
22,4O 1
4(g,
22,4’ O I
5,550
pi
3,3(o
L 2 ,531 I
LZ
I
I
Report
I has’. ,s.d this return. Under penalties of perjuiy, I declare
that toth. b of my haswladgs and belief . tb. rwI ii
n sais L and -
For Pitoasy Ass aa4 11—. - ‘, _ k. W ’ t4M1e. 4 In ih. b ’
Cm.$s. ISSISV Fore ‘iO L91L
-------
UIDIVIDUAL ABUZ Y TO PAY ANALYSE
PHASE I - 1O4O WORKSHEET (1991)
L General L 1 fiti ...atin, ,
1. Applicant’s name
2.
Countyapplieantliveain [
Site locadon
Estimated cleanup cost
Other parties involved f
3.
4.
5.
f çv-WtU( 1-. L.t .M LR )
I ‘ Mh
Cic ricx’, M ’ 4
44,000
if. Fn’”isl Evalua
6. Adjusted
gross income
(Line 3
on tax
form)
I
7. Mhthnum
income level
for
one person household
in county
(see Appendk
A)
& Income in xc ii f iiiiiuwium
(subtract Line 7
from
Line 6)
S Z2,L450
S 11,8oo
S 4, o
p.
,.
-.
a Phase Ds L . cj e oiie) I
-
9. Line 8 is negative or zero. Applicant has no resources; further
analysis is not recommended.
r I 10. tine 8 is positive. Phase U analysis recommended
ft
Analyst
I ’
2
I3
1$ L
I I
a
Date _______
-------
INDiVIDUAL ABILr1’Y TO PAY ANALYSE
PHASE II- IO4OFZ WORKSH
Appli— .. . L& ’U(_ p -)
IL c ome I
I
1
1. Total income
(Line 6 on Phase I. 1O4OEZ Worksheet)
2. Median income for one person household in county
(use data in Appendia A)
* S
$ 2Z 5o
3. Income rat io
(divide Line 1. by Line 2; multiply by 100)
IL Net Cash Flow
$ 2 .z,25o
I
tO
%
I
4. Total annual living penses
(convert all espenses from Part II of F nci l Data
Request form to annual values and sum)
5. Total annual debt payment ___
(Part U of Individual Financial Data Request form , sum
entries in section “B. Debt Paymenta ’)
& C ’h flow
(subtract Line 4 from Line 1)
1 -q., :;. 35 -
!L..
s
3,I2.o
7. C ’h flow contingency allowance percentage
(see income criteria matr )
Is ‘4 .J5
& Cash flow contingency amount
(multiply Line 4by Line 7)
L 16
f *.; ____
9. Av ilable cash flow (net of contingency)
(subtract Line 8 from Line 6)
10
%
Ist,1’ H
i:
I
I
“a’
%J
10. % annual debt payment to annual income
(divide Line 5by Line 1; multiply by 100)
-------
13. Bank accounts
(Part 1 11 of Individual Fm nd 1 Data Request form,
total of 111.1)
14. Investments
(Part Ill of Individual Financial Data Request form.
total of 111.2)
15. Retirement funds and accounts
(Part UI of Individual Financial Data Request form,
total of 111.3)
16. Life insurance policies
(Part III of Individual Financial Data Request form,
total of 111.4)
17. Vehicles
(Part I II of Individual Financial Data Request form.
total of 111.5)
18. Personal property
(Part 111 of Individual Financial Data Request form,
total of 1116)
19. Real estate
(Part III of Individual Financial Data Request form,
total of 1117)
20. Other assets
(Part 111 of Individual Financial Data Request form,
total of 111.8)
21. Total assets
(add LAnes 13 through 20)
Cash Flaw )is thkin (check ona)
I ‘ 1 LAne 9 is positive. Applicant has available cash flow.
12. Linc9is negative orzero. Applicant
does not have available cash flow.
(
flLNetWorth I
Is
I 1’3
IS(
I
Isø
t
Iscoo
I
$
13,500
J
IS 6O
I
I$
I
[ s
1,100
I
[ S
,1 .,ec,(,
j
I is
116
117
18
119
I 21
-------
22. Credit cards and 1in of a dJt
(Part III of Individual Financial Data Request form,
total of 111.9)
23. Vehicle loans
(Part III of Individual Financial Data Request form,
total of 1O)
24. Furniture and household goods loans
(Part ill of Individual Financial Data Request form,
total of 111.11)
25. Mortgages and real estate loans
(Part UI of Individual Financial Data Request form,
total of 111.12)
26. Other debt
.
(Part III of Individual Finanefal
Data Request form,
total of 111.13)
27. Total liabilitins
(addlin thrnugh26)
...
- ____ ___ - i_i _
___________________________________________________________________________ ______
—
.3 -
_____ L __
t ..
:4
___I_
r —
. - —
2& Net worth
(subtract Line 27 from Line 21)
32. Target assets
(divide line 27 by line 31)
: Assets available
(subtract Line 32 from Line 21)
Ii
I
25
27
$ 4,1F,(,
28
—
29. Applicant’s age
(Part I of Individual F nnncial Data Request form)
30. Applicant’s employment status
(Part I of Individual Finanial Data Request form)
31. Target net worth
(see Net Worth Cxiteria Matrix)
7, ‘ 7: ’ i
_____! L 2
‘
-------
34. The applicant has available assets.
(if Line 33 is greater than 0)
- applicant does not have available assets.
(if Line 33 is less than or equal to 0)
36. Applicant has e er is annual cash flow in the amount of:
(line 9)
37. Applicant has available assets in the amount of:
(Line 33)
% annual debt payment to annual income
(Line 10)
N. Phase II Stmm. iy
3&
“4’
Date
Anal
-------
APPLICANT FILING THE 1040A CHAPTER 4
This chapter provides guidance for applicants using the 1040A Federal Income Tax return.
The IO4OAis moedetailedthan the lO40EZbutlessdetailedthan the 1040. Itcanbeusedby
individuals filing joint or separate returns whose income is less than 550,000, and who do not itemize
deductions.’ 0 In contrast to the 1O4OEZ, the 1040A allows the individual to claim more than one
exemption and to claim income from non-wage sources such as pensions, annuities, social security
benefits, IRA distributions and unemployment compensation.
THE PHASE I ANALYSIS
The Phase I analysis for the 1040A applicant is very similar to the IO4OEZ discussed in
Chapter 3. The main difference is that household size may be greater than one for a 1040A
applicant. Data from the applicant’s 1040A form and initial application form serve as the basis for
this portion of the analysis.
As in the previous chapter, we demonstrate the Phase I - 1040A analysis using a sample case.
The complete sample case can be found at the end of this chapter.
General Information
• Applicant’s Name. On Line 1 enter the applicant’s name. Note that the case
flame for our ‘ample is OL Slick.
• County. On Line 2 note the applicant’s county of residence. As explained
in Chapter 1, county of residence is important to the evaluation of the
applicant’s income. In our mmple, OL Slick lives in Jasper County.
• Sits location. On Line 3 identify the specific location of the UST requiring
investigation or remediation. Our case example site is Reasnor, Jasper
County.
‘°Sec Appendix B for a etailed explanation of Federal Income Tax return forms IO4OEZ.
1040A and 1040.
4-1
-------
• Estimated Investigation or cleanup costs. If known, note on Line 4 the
estimated cost of cleanup or investigation. In our example, the estimated
cleanup cost is not available at the time of analysis.
• Other parties Involved. On Line 5, list names of other parties involved in this
site. Is the property jointly owned? In our example, Slick is the sole
responsible party.
Financial Evaluation
Section II of the Phase I - 1040A Worksheet evaluates the applicant’s income as reported in
the most recent 1040A tax return. In the 1040A return, income may include: wages, dividends,
interest, pension or IRA distributions, unemployment compensation and social security. We compare
the applicant’s total adjusted gross income to the standard for the county of residence found in the.
FmHA income tables in Appendix A. In this example. we will use the low’ income category as our
income criteria.
Wage Income
• Adjusted glues Income. Find the applicant’s adjusted gxues income on Line
16 of the 1040A form. Itt our example. Slick’s income is $30,410. Write this
value on Line 6 of the Phase l-1040A Worksheet.
• Number of people Ii household. On Line 7 record the number of people in
the househoLd. On Slick’s tax return, he claims two exemptions. On Line 6a
he claims himself, on Line 6b he claims his wife (they are filing a joint
return); the total is shown in 6e.
• Minimum Income level for households. From the data in Appendix A, we
want to determine the FmHA ‘low’ income crnena for residents in Jasper
County. On Line 8, enter the low income’ figure for a 2-person household
in the specified county. The low-income’ value for a 2-person household in
Jasper County is $22,800.
• Income In , r- ’i of inlaI um. Subtract Line 8 from Line 6 and enter this
figure in Line 9. In our example. the difference equals $7,610. This means
that Slick’s income Li $7,610 above the low income’ cutoff.
4-2
-------
Non-wags Income
Next we check the tax return to see if non-wage income has been earned. Lines Wa and lOb
of the Worksheet ask if income greater than $400 has been claimed in Lines 8a or 8b (interest
income), or Line 9 (dividends). This would indicate that the applicant has substantial investment
assets. If this is the case, you must proceed with a Phase II analysis. On OL Slick’s tax return, we
see that he has claimed income greater than S400 on Line Sa, therefore we check the respective line
on the worksheet.
To summarize, we note the Phase I disposition for this applicant. Recall that Slick had an
income in excess of the minimum, he had interest and dividend income greater than $400.
Therefore, we check Line 12- a Phase II analysis is recommended.
The Phase II. 1040A Analysis
This section describes the Phase II analysis for the 1040A Federal Income Tax return. The
Phase II analysis assesses the amount of resources that applicants passing the Phase I analysis may
have to contribute to site investigation or cleanup. It is based on data from the applicant’s Financial
Data Form and 1040A tax return. This analysis entails three steps: (1) an income analysis, (2) a cash
flow analysis, and (3) a net worth analysis. Slick’s completed Financial Data Form can be found at
the end of this chapter.
We begin with Section I of the Phase II Worksheet, the income analysis. We will continue
to use data from CL Slick as our case example.
Section I - Income
In this section, we first compute the applicant’s income, and determine how the income
criteria matrix should be applied. Note that the income calculation is more detailed than for the
IO4OEZ. This is because the applicant may have certain income which is not ta hlc, but that we
want to include for the purposes of this analysis. Recall that in the Phase I analysis, we compared
applicant’s income to a low’ income minimum. In this section of the worksheet, we perform a similar
calculation. Now, however, we compare the applicant’s income to the county median household
income, rather than the low’ income standard.
• Applicont’s name. OL Slick.
• Wags Income. On Line I of the Worksheet, enter the applicant’s wage
income as reported on Line 7 of the 1040A tax return form. Slick’s wage
income in 1991 was $13,100. We note right away that this figure does not
match Slick s adjusted gross income from his tax return. This indicates that
he receives income from non-wage sources.
4-3
-------
• Taxable interest income. From Line 8a on the 1040A return, note if the
applicant has claimed taxable interest income. Examples of taxable interest
income include interest from checking and savings accounts and interest from
bonds and treasury bills. (See the 1040A Instruction booklet for a full
explanation of each line entry.) In our example, Slick has claimed $600 in
taxable interest for the year. Enter this on Line 2 of the Worksheet.
• Tax exempt interest income. From Line Sb on the 1040A return, note if the
applicant has claimed tax exempt interest income. An example of tax-exempt
interest is the interest earned on a municipal bond. Slick has not claimed any
interest in this category, so enter 0 on Line 3.
• Dividend income. On Line 4 of the Worksheet, enter any dividend income
reported in Line 9 of the tax return. Enter 0 for Slick since he did not repqrt
this type of income.
• Total IRA distributions. On Line 5 of the Worksheet, enter any distributions
from IRAfunds reported in Line 10 of the tax return. If an enuyis made in
both Line IOa (total value) and Line lOb (taxable portion), enter the amount
from Line lOa. However, if the IRA distribution is fullyt ble an entry will
only be made in Line lOb. If this is the case, enter the amount from Line
lOb. Enter0forSlicksince hedid not report this type of income.
• Total pensions and annuities. On Line 6 of the Worksheet, enter any
pension and annuity income reported in Line 11 of the tax return. lEan entry
is made in both Line ha (total value) and Line hib (taxable portion), enter
the amount from Line ha. However, if the IRA distribution is fully taxable
an entry will be made in Line lib only. If this is the case, enter the amount
from Line lOb. In our example Slick is retired, and has claimed an $18,000
(fully taxable) pension.
• Total Social security. On Line 7 of the Worksheet, enter any social security
income reported in Line 13a of the tax return. Be careful to enter the value
on 13a (the total) and not the value to the far right in Line 13b. The value
in Line 13b represents o j the taxable social security; here we want to
a unt for social security income. In our mple, Slick has claimed
$7440 in social security benefits for the year.
On Line 8 of the worksheet, we sum all of the applicant’s wage and non-wage income ( Lin
1 through 7). Slick’s total income for the year was $39,140. To conclude the analysis of income, we
compare the applicant’s income to the median income for the same size household in the applicant’s
county.
44
-------
• Household size. Enter the number of exemptions claimed on the applicant’s
tax return on Line 9 of the Worksheet. Total exemptions can be found on
Line 6e of the 1040A form. This defines the size of the Slick household.
(Alternatively, check the entry you made on Line 7 of the Phase I worksheet)
Slick claimed a total of two exemptions in 1991.
• Median Income for household size and county. The FmHA data tables
provide us with a “60% of median income” figure. We use this to determine
the median household income. To find this value, look up the applicants
county and then find the appropriate household size column. The last row of
data lists 60% of median income. In the case of OL Slick, 60% of median
income for a Jasper County 2-person household is $17,100. Divide this
amount by 0.6 and enter the result on Line 10 of the worksheet. We now
know that median household income in Jasper County for a 2-person
household is $28,500 (S 17,10010.6).
• Income ratio. We next want to determine the applicant’s income category on
the income criteria matrix. To find this percentage, we simply divide the
applicant’s income by median income. The result will show whether the
applicant’s income is above or below average, and by what percent To
determine the result for Slick, divide Line 8 ($39,140) by Line 10(528,500).
The result is 1.37 or 137%. This means that Slick’s income is 37 percent
above the county median. Enter this value on Line 11. Slick therefore falls
into the “greater than 125%’ income category on the income criteria matrix.
SectIon 11. Net Cash Flow
In this portion of the Phase II analysis we determine the applicant’s cash flow. A simple way
to think of cash flow is the income left over after paying all cash expenses during a year. In
calculating expenses, we usc data from the Current Living Expenses section of the Financial Data
Form (Part II).
• Total annual living expenses. Go to Part II of the applicant’s Financial Data
Form. Space for converting data to annual values is provided in the “For
Agency Use Only column in the Current Living Expenses Section (Part [ I).
Forweeklyexpenses , multiply each expense by 52 and put the total in the
‘For Agency Use Only column. For monthly expenses multiply by 12; and for
quarterly expenses multiply by 4. (CL Slick’s expenses are converted to
annual figures as shown in Section II of the Financial Data Request sample
form at the end of this chapter. Sum this column of figures and enter the
total on Line 12 of the Phase II Worksheet OL Slick’s total annual living
expenses are $31,312.
4 -5
-------
• Total annual debt payment. Enter the applicant’s total annual debt expenses.
An applicant’s current debt expenses are important to determining the
applicant’s ability to acquire additional debt for site assessment or cleanup
costs. Total Lines 3.1 through B.4 on the Current Living Expenses Form and
enter this amount on Line 13 of the worksheet. Slick spends $5,000 a year
on debt payments.
Once we have totalled income and expenses, we can calculate the applicant’s cash flow for
the year. A simple way to think of cash flow is the income left over after paying all expenses. As
explained in Chapter 1, we will set aside a portion of this cash flow as a “contingency allowance’ for
unexpected expenses.
• Cash flow. Subtract Line 12 from Line 8. Slick’s Net Cash Flow is $7,828,
so we enter this amount on Line 14.
• Cash flow contingency allowance percentage. Consult the income criteria
matrix to determine the appropriate cash flow contingency allowance. Slick’s
income level of 137% falls into the “greater than 125% category”, and
indicates a contingency allowance of 5 percent. Enter this percentage on Line
15.
• Cask flaw contingency amount. We now calculate the amount of contingency
expenses we will allow Slick based on the contingency percentage and
predicted annual expenses. Multiply total expenses (Line 12) by the
contingency percentage (Line 15) and enter this figure on Line 16. Five
percent of Slick’s total expenses equals $1,566 ($31,312x 0.05). In calculating
available cash flow we set this amount aside to allow for unforseen expenses
or emergencies.
• Available cask flow. Subtract Line 16 from Line 14 and record this figure on
Line 17. Slick’s annual cash flow, after subtracting expenses and a
contingency allowance, equals $6,262 .
• Pe. .tage debt to Income. Here we consider what portion of an applicant’s
income is directed towards debt repayment. The level of current debt will
determine how much additional debt an applicant may be able to assume for
the payment of UST site costs. Applicants who are currently paying more
than 36 percent of their income for debt repayment, will probably not have
the capacity to acquire additional debt. In fact, they may be denied funds by
a lending institution. To calculate an applie nt’s percentage debt expense.
simply divide their annual debt expense (Line 13) by their total income (Line
8) and record this figure on Line 18. Enter 13% for Slick ( ,000I39,
• 140=0.128).
4-6
-------
At the end of Section III of the Worksheet, note the Cash Flow Disposition. In the case of
Slick, we check Line 19 - applicant has excess annual cash available to pay for cleanup.
Section lfl - Net Worth
This final portion of the Phase II analysis evaluates the applicant’s net worth. Here we asir ’
an applicant’s total assets and liabilities. The data for this analysis comes from the Net Worth Section
(Part III) of the Financial Data Form. We continue our example with CL Slick below.
On Lines 13 through 20 of the IO4OEZ worksheet, we enter subtotals for assets.
• Bank Accounts. Enter the subtotal from Question I on Line 21 of the
worksheet Slick has a total of $1,500 in checking and savings accOunts.
• Investments. On Line 22 of the worksheet, enter the subtotal for the
applicant’s investments. Slick has S 1,500 in a certificate of deposit
• Retirement fhnds and accounts. Enter the subtotal from this question on
Line 23. Slick has $7,000 in investments.
• Life Insurance policies. Enter the subtotal from Question 4 on Line 24. The
value of Slick and his wife’s life insurance policies equals $5,500.
• Vehicles. Enter the applicant’s estimate of the value of his vehicles on Line
25. Slick has entered $7,000 for this question.
• Personal property. On Line 26 of the worksheet, enter the value of the
applicant’s personal property. For Slick this total is $9,500.
• Real estate. On Line 27 of the worksheet, enter the subtotal for the value
of all real estate. Slick estimates this value to be $52,500.
• Otherassets. In Question8, the applicant totals thevaluc of all other assets.
Slick has not listed anything for this question.
• Total assets. Md Lines 21 through 28 on the worksheet and enter this
amountonLine29. ThetotajvalucofallofSlick’saue*sis$84,500.
• Credit cerds and lines of credit On Line 30, enter applicant’s credit debt.
Slick’s total here is $210.
• Vehicle Iq u.s . Sum the total of all vehicle loans and enter this amount on
Line 31. Slick’s debt for vehicles is $3,800.
• * Furniture aus 1 Household Goods. On Line 32, enter the total of all debt for
these t ins. ick has entered 0.
4-7
-------
• Mortgages and real estate. On Line 33, enter outstanding mortgage and real
estate loans. Slick owes $9,888 on his house.
• Other debt. Enter on Line 34 any other debt the applicant has. Enter 0 for
Slick.
• Total liabilities. Add Lines 30 through 34 on the Worksheet and enter the
amount in Line 35. Slick’s total liabilities are $13,898.
• Net Worth. Subtract Line 35 from Line 29 to determine the applicant’s net
worth. (Keep in mind that this ç be a negative number. Negative net worth
simply means that an applicant’s debt is greater than his or her assets.) Slick’s
net worth equals $70,602 and is entered on Line 36 of the Worksheet.
• Age. On Part I of the Financial Data Request form, find the applicant’s age
and enter it on Line 37. Slick has noted that he is 67.
• Applicant’s employment status. On Line 38, note whether applicant is
employed, unemployed or retired. Slick is retired.
• Target Net Worth. We nest want to determine the applicant’s target net
worth ratio. Recall that Slick’s income put him in the “greater than 125%”
category. Checking under this column on the net worth criteria matrix, we
see that the target asset to liability ratio for Category A (applicant retired or
unemployed) is 0.6, while the ratio for Category B (other) is 0.80. Slick is
retired, and he therefore falls into Category A, with a target ratio of 0.6.
Enter this figure on Line 39.
• Target Assets. We next want to determine the necessazy assets for this
applicant, based on his or her target net worth. To determine this dolLar
amount, divide Line 35 (Total Liabilities) by Line 39 (Target Net Worth).
Slick’s liabilities equal $13,898. If we divide this by 0.6 we get a dollar figure
of $23,166, which represents the amount of assets Slick should maintain.
Enter this figure on Line 40.
• Av.II ble Assets We next want to determine SlicWs available assets, that is
thevaLueofhisassctstbatmaybeavailableforUSTsitecosts. Weflndthis
value by subtracting the applicant’s target assets from his actual assets. For
Slick, subtract Line 40 ($23,166) from Line 29 ($84,500). The result is
S61,33
At the end of this section note the Net Worth disposition. Our calculations indicate that Slick
has available assets in the amount of $61,334. Therefore, we check Line 42. applicant has available
assets to support UST investigation or cleanup.
4 -8
-------
Summary
At the end of the Phase II analysis we summarize the cash flow and net vrth assessments.
In Line 44, note the applicant’s cash resources. Looking back to Line 17, we see that Slick has cash
resources in the amount of $6,262. On Line 45, note the applicant’s available assets. On Line 46
note the portion of annual income that goes to debt payment. Thirteen percent of Slick’s income
goes toward debt. This value is less than 36%, indicating that the applicant should not have trouble
obtaining additional debt financing. It appears that he also may be able to pay costs through
borrowing against existing assets. Alternatively, he could sell some assets without seriously
jeopardizing his financial position.
4-9
-------
INDiVIDUAL ABILiTY TO PAY CLAIM
General Information Form
Case Name Ja 1- 4 - rj
We are requesting fin2nciai information to help us evaluate your ability to contribute funds for
investigation or remediauon of the petroleum release at the above-mentioned site. Please fill out t
form and submit a signed. conmiete copy of your most recent federal income lax return. The Iowa
Department of Natural Resources may request documentation supporting the information you
provide on th form or in your tax return.
Name: O..s€t L c 4C
Spouse’s Name aJ( 9. C. 9.J C.4
Mdr 2 J ...
Q Lc’ noc, P
Phone Number Home ( S) ‘-g, Work(gç) j3 .jq
Cøunty of Residence 3 p
Does the informision provided on your federal income iax return accurately reflect
your current flnaneial situation? Please describe below additional information that
you vuld like us to consider in evaluating your case (for mple. anticipated major
expenditures or changes in income). Use additional sheets if necflaary .
fr ujk PIci i1s t t, - - - .tX-
0 - (iJtJVS ,r .i.dtgC., oJo ‘ a-
Arc you currently participating in any type of federal or state assistance program (for
mple, AFDC SSI, food scamçis, HUD or FmHA housing asintance, home heating
ssw nc , Me 4- id . or Iowa’s inedkaUy needy program)? Please v4. Tibc below.
Attach additional pages if ne ’y .
-------
INDIVIDUAL ABILITY TO PAY CLAIM
Financial Data Request Form
This form requests information regarding your tinancial status. The data will be used to
evaluate your ability to pay for environmental clean.up or penalties. If there is not enough
space for your answers, please use additional sheets of paper. Note that we may request
further documentation of any of your responses. We welcome any other information you
wish to provide supporting your case, particularly if you feel your situation is not adequately
described through the information requested here.
Certification
I declare that this statement of assets, liabilities, and other information is true. correct, and
complete to the best of my knowledge and belief.
Signature Date
Name: Olwut. L. - tL
Spouse’s Name: C...
Address:
i5( e 00 4 .
Pb
County of Residence: pee
1
-------
PART L BACKGROUND INFORMATION
1. MEMBERS OF KOUSEROLU ( list the heed ot tbs hnm ho ’ end all p ues Ihint With yoo
Name
Age
Relationship to Head
of Household
Currently
Employed?
01.
l-i€04.
o
c,O
wi
2. LOYM ff (the all jobs held b p. In he-s.hnIAV
Name
Employer
Length of
Employment
Mnual
Sal.r
(f( d .l
gç ” o.I
2 ’s
I ,iDO
2
-------
PART IL CURRENT LiVING EXPENSES
Please list personal living expenses which were typical during the last year and üidicatc if any of these
alues are likely to change significantly in the current year. Please do not include busincsg apenses. If
-,u are the owner of an operating business, please attachment any available ffi ancial statements,
Eq s • SW
c . AM.,t
1o4 htk e. -’
‘
Jbr As e fri
?= •
Y- t
Q Ir
11
A. Living Expera
_______
.___
I. Rent
2. Home maintenanra
ec
I 2A
3. Auto fuel maintjother tramp.
Lt 0
‘J
— Z08
4. UW1U
a. Fuel (gaLoil.wood.propsnc)
.
b.9m tric
(coo
c ter/sewer
(gO
/
4DC
d. iblephone
.ç
./
gpo .
5
,
/
.
&Cothnt.pcoual ra
p
,
2LI a
7. Medi 1 costs
21
“
2 1
B, Debt Nymesa ‘
“
S..
‘
..
S
I. Mortgage
,Ø•
2. Car p ents
02.
l’
SS
3. CrmlIt rd payments
00
“
“
4. Edu ciona1 loan payments
C. lnsuran
‘
-
-
S
L. Hotochold insuranen
Z O
/
2. Life insuranco
3 ’O
..‘.
5 S
3. Automobile Insuranen
,
4. M di’ ’ nsuranen
I
./
f
D. Thx
‘
1. Property t
‘2 4 S’
./
2. ‘4
2. Federal income tame
J3 (
‘
B (
3. State income taam
I (o(o I
wr
( fr S
4.FICA
BthkO
___
,,
E. Other ELpensm
I. ( iLl rS
—
L Cun ent School tuiUon#mpensea
.
—. —
3. Legal_or protmatonal servicra
4. Other (itemize on separate page)
1btaLCurT nTFxDensra
,l,3IZ.
3
-------
PART lB. NE WORTH
Please provide the following information to the best of your ability. Data should be as current
as possible. Estimates are acceptable; if you wish note such items with an ‘E”.
If you are the sole proprietor of a business, please lists business assets and liabilities, in addition
to personal assets and liabilities. Please mark these entries with a “B” to identify them as
busineu assets and liabilities.
1. BANK MenepMsr ete )•
1. VLIW D e JV%
—-
— — S _i — S 5 a. — — -
csan e nt
CID iic v’ 4 L
Number of Sharen or Units
For Agency Us. Only. lbtsLOment. Market. Wineof Invensmenm- .
3. REr1P W(rTUNDI AND ACCOUNtS (IRA,401(k)j aen , t.d Intent In enmpsuy
rd d,cte ).
Deta pdoa of uui
E.sdmated Market ½lue
iwL L riAl. .O ’jc1.sPtA’
l4fSOO
t,wA ( oL pc r)
Z OO
For Agency Us. Only - lbtnl Esthizated Market Wine of RstL .eai Rink
and # unIs
Name of Bank or Credit Union
1)p. of A unt
Current
(,oa.e
t& c4 r La t.
t XILC4
utr
4O
& C
For AgencyiJse Only i. lbtal Qiriant Balsnentn Bank A unis
— I ff00
2.
vg pZeedI Mnlt d -” !
(R T ,e ).
I ’Lavd’——-
Current Market Wine
i,5ao
f ffc b
Is
-------
4 LIFE INSURANCE POUCER
Polky Hover
rIIIrA
— •‘ ;i
()
Issuing Company
Mi,ttiaA ô Ov tcJ —
Mu t O Qw &-
For Agency Use Only - ThtaL’vtli of Life Insunnen POildea
Polk Value
I 0 o c •o
ir .d
Cash Wiuc
4,u v
ccm
5 . ca
5. vEmais
“ . .— -— - M5 -
u—---— r
£I....L. —
For Agency LIse Only. lbtM E tc Mar11eL Wins of Wh
Modd
fvlcreIlrA PJ ttVPAIil
U
C v t
o
Year
I
I %- .
Esthnated Market Wiuc
I59 j
I ., oo
1I’000
I __ - -
•I!#ps of Property
$JVPlflI4 II a -
- I I I •W
7, cf à oUav c Lcc nc cie*c 1
V !\1(r7 .NOAt .. 4c cAeO I V ,1 .. \
‘
. r —ivw
d i PERSONAL PROP IT( . Mt Andqu ., fli,
M al.,st Oui, lid “— t ulns nslar thaw$5OS.N)
For Agency UseOnly..” ’
Estimated Market Wins
(atôCQ
•3 ,S OD
q,s.cb
7• D ’A I —-i r __ a
IAL ( , —--- -j wu
tn
J 4 n ,srkmk . (2i id
Den of Property
)Li I hauc
For Agency tTss Only. ibtal Esthnatet Market Wine of Real Estate
Estimated Market Wins
2 L; ot
S
-------
8 . G [ II A gIT
9. CREDIT C&RDS AIID LUI OF CEED-
Credit Card/Line of Credit (T pe)
cr ,. .fV%V” Ca.m ‘.J ’,C’- .
Tjpc of Asset
For AeLT5y—1b I.Oth Mse5-
Owedib
AL r I &M (Cv &v ..iL
For Agency Use Only- lbtal Rs1aut Due on Credit Cards and LLn of
Credit
E umace4 Market Iue
Balance Due
2 IO
2 1 10
to. VEfflQ.E LOANS (Can M ituI .,Jes, Ei i’ 1 ’u WhIcI. , Meter Row, Beam, AIrp’—L
etc)
Vehicle (Model and Yeafl
Owed lb
Due
M’ ujv’ M WqLAI
(Zf L srot ‘Lc &m-
.
For Agency Us. Only- lbtaI B Jan Due on ‘kBlcie f .
l
6
-------
LI. FURN1TUR AND ROus aOLD GOODS WANS*
List Item
Owed lb
Balance Due
For Agency Use Only. lbal Balanru Due on Fuxnituze and Household
Goo I a
12. MO TCAGEBM4D REAL ISTATE LOANS
Type of Loan
Owed lb
Seoued
Against
Balance Due
6iMW ’—
c g
\J d
For Agency Ui Only . ThtaL R ” Due en Morigagen and Real E3ate Eonsa
ee
LI. Oua DEBT ( Awnufla d.e hidMdnsla, Fl d ebilpdulia , s Owed, Owed.. Alimony or ‘ MN
Su,,ort ese)
1’, eotDebt
Owedib
B ’csDue
For Agency U5eOnly .lbtal Balance Dee on Othor Debt
a
7
-------
PART P /. ADDm0NAL INFORMATION
Please respond to the following questions. For any question that you answer ‘Yes.” please
provide additional information on separate pages or at the bottom o this page.
QUESTION
Do you have any reason to believe that your financial situation
will change during the next year?
2.
Are you currently selling or purchasing any real estate?
3.
ts anyone (or any entity) holding real or personal property on
your behalf (e.g. a trust)?
4.
Arc you a party in any pending lawsuit?
5.
Have any of your belongings been reposseutd in the last three
years?
6.
Are you a Trustee, Executor. or 4 &dminiqra or?
7.
Are you a participant or beneficiary of an estate or profit sharing
plan?
8.
Have you declared bankruptcy in the last seven years?
9.
Do you receive any type of federal aid or public assistance?
1.
r . )‘h LO’ -
C ;wLLplc. L Wi1 j —‘• kL4ru
LIE. CALCV (s V’I UJW ( .,tu
-.
8
-------
1040A
Stepi
—‘ oag, &.,
. ‘i. i S
3,’
OI t
ds L__.J.-4.-.
u .s. iniu 1 - I m.
1991
O R 1 L
—
‘
:
T IR . —
OL.iVQJ( L. Siic. .
‘
a , wi,. .. dm
c*Jtt ( , IiC.-
14.,., , , , — .,.i. • It i P0 . — LSi
G C\1(jIoo .. Lc 4.
c, — . i. .. •It iw . s.u, — I&
2.t.. ,vicr, .A
•
I
s _ . • —
Fr 11)
Dsyoiawant$1togotoz sfimd?
If io.nt r —-- - di i s.ui w 51 ta ta this find?
F Pv*, y
aM P k
p--- - _
r’ - r &
r± W’vi
You QNo
11 Y Q No
Step2 ‘
Clack ., 2 L MvTisd i ti ,u t iouly bnd inr-La
flung 3 0 MiniM 1 f pinEs tw. En pouM. .oàg ivh.. , y ‘—‘ a•
‘hick univ ei . , ak,. and ap i . flU be, P________________________________________
4 g d1_ VI$ qua pe L (S pi I L) If th qualifying a
rhiM dapiuu 4 .it 1 this 11’ P
5 0 Qualii&ini wideute, with “ “ C InU (y uinn thud P iS i. (s. p 1$
Step 3 6 . ___LIf,u ,__wr____ • 1 m -
a a I in L 1
w
S •.j— - -. I •w
•UKi . . & — . . I_U
• .
Cr th —
d. a . . —-
— - :
•
-
&-_____
4 If yo chiI di&t Liv. with you b is “4 as y —
d.p—uii.nr nn,l.v a pr . .1985 ap $ , h . . . r
.—I
S Total nuinip .’ of — dous im,d.
S p 4 1 ‘ ‘ . b . S W. This ShOuld be $hO.fl B 10 JOI_ ’
W.26 a sLL tt . . hFoi ’ta aW4.) 7 I3.lO(
Fgurs your
Tanhl ML . ass pap 26). (Wove ’ $400, alas ouplat.
total Iih IJfll* .it..k Sdiedul. 1. Pet L) 8. (oOO
b Tas— 8b I
a DI,i 1 . 1- lit awe’ $400. ala, p 1V and Itsa h tinI I . PITt IL) 9 -
o VS 2 Total IM lOb T— IIflLMnt
ur i (usspwl7). lOb
Urn T I J1_L_..’L li$ T ” i ii
and. :1I u i (om lib I ,OCO -
12 UL ,t u1 . . ’ ã t ) 10694. 12
•øii ‘ ‘ 13a Social .. y ISP Tm . runt
W.Zort09 04. i . 1 .,’140 (as. 3lL 13b 1•I
14 M$ line Tth . IIb ( right uduami. This a i i - —s- P 14 LI 0
Step 2k Your IRA dadn cu â e applioubie worhihost. 15a
es your a Stauds & di+”.” &vm awli bIs wek I
ad luut .0 NoteRpJ4ab, u icnpag,31 iSb Z,000
g r e. a Mdlinel5aandl5kThese, toMLli . ’ 1s. !5c Z,000 I
23 S ..bt - line 15c frum line 14. The ia y idji.tiil 4IU iRL I
ilflne 121.250. ass Earuud inim Ai&” on pa 4L) P 16 4 ID I
I
-------
1991
Form 1040*
17 Enterthe.mountfromlinel6. 17 L4Ir
13. Check J :4. . were 65 or older = Blind Ens.. nonbsr of
if: ‘ pmise wu 65 or oId.r Blind beau. MeEM 18 .
b If your parent ior someo’ , elaei can ctaim you u a dap.Mis c
te re 18b
a If you are mamed filing separately and your spouse files Form
1040 ana ir ma dadu ons. sea oage .37 and check hale 18c D
1.9 Enter the ssandea’d deduction shown below for your filing stansa.
But if you h k.4 any bon on line 18. or b, go to page 37 to
find your standard dednctLon. If you checked box 18., entar .0..
I Single—13,400 I Head of houaeheld—$5,000
.S Married lin jointly or Qualifying
•M srñed lui ,i. - I—
19
1,oo
20
Suine ljne 19 from line 17. (If line 19 ii mote than line 17. en .0..
20
Z3 1 q (0
Mul ply 52.150 by the total nmobor of axempoons li.ued on line 6..
21
9 300
Subua line 21 from line 20. (If line 21 ii mote than line 20. enon’-O-
This is vomi i.wLi -
23 ! pdthstaxoamosone22.Checkiffrom
Tax Table maine 44-49) or Farm d615 (see naae 39)
— — S ‘ .S
23
2, (A
241
b
Credit for child and dependent ze eap us . .
Couples. and a Schedule 2. 24.
Credit far the eldady or she_____
Comp’eta and ’ 9r1 1uI 3. 24b
24.
Z
I
a
Add lines 24. and 24b. These are vow total aedito.
21
Subtra line 24c from line 23. (11 hue 24. ii more than line 23. en .0..)
25
7... i -
I
26
Advanre canted ineome credit payments from Form W.2.
26
i
27
Add lines 25 and 28. This is your total tax. 27
2., q
I
2 6a
Total Federal mourn, sax wnhheld. i If any
tax is from Fvwmss 1099. h k h .v
28.
1991 esumated tax payments and amount
applied from 1990 i tU u.
28b
!
Earned j iis sliL Couplets and
a” Schedule EIC.
28.
I
Add lines 28a. 28b. and 28.. Th.- are vow
t
-
d ... - ?Sd I
StepS 23 Ifline28dis mare thsnline2l, sub a line27 from Iine2Sd. I
Thlaiathea mountyo uo , . . 1 ,aid. ‘9 i3 I
Fgere your -
refund or
30 Amount of line 29 you want re6.nded to you. 30
amount yost
31 Amount afllne 29 you want app 1 1.4 to your I
11 tax. 31
uac check °‘ 32 If Un. 27 Is man, than line 28d. sub acs line 28d from line 27. This is the
reins Otis? On
:o of Formiu smeunt you o thick or money order fbr full “t payable to
W.2. etc.. on the intanial Rm u. otvi& Write your n m adèou,i 4,
niiuk.r. daytime phma number, and ‘1991 Form 1040& on it. 32
33 ,Esnrnated tax penakv ‘see oare 431. 33
Step 9 L inisiauc( pst v. 1 dfiiv thu I hive — -— uua ietwe us a siuyui — — eM iM I Sv Inislisn
ig be4id. ike, .e ui . fiic . an Du .,.tion pnp.ger ‘ouw.r thee the te.,p., . us is aM .efar.M
Sliiii your flU IS’
V .ur uusea Oar.
re.m
K . ’ tCODyfl( -
thu. .tun (or • ii oust return. must ruin’ • Dat a
___________________
Paid 1 D at. uirnv ii..
cfl$ttu, I
prepareri Fr . AIIis
use onty usut’.mossvisi air. b
• ZIP i i . .
1 2
Step 6
Figere your
seno and
tubs.
“ - “a ”
Step 7
FIgure your
tan. credita.
((yes want tha
(35 to f(w,
yOtW ISL 3G3
ths rnu. cnouI
for baa 22 on
pa ., 38.
‘ 22i J
b
C
U LQJ . - -. e . ItaI -
-------
INDWIDUAL ABIL Y TO PAY ANALYSIS
PHASE 1. 1040A WORKSHEET (1991)
Analyst
I’
Iz
[ 3
14
Is
L GneralTJ.... on
I
1. Applicant’s name I, I u L 5 I((,IL. (..pt
2. County applicant lives in i I aco C.ow - j
I 3. Site location 1. 1 ( Asr r 1 Tc s p c i, CccivL’v 1
I 4. Esdmated cleanup Cost I I N. A. 1
I 5. Other parties involved 1 I rw t
[ ii Flnand2I Evaluation 1
IA Wa c ijs - I
6. Adjusted ou income
(Line l6ontaxform) $ O L4 O
7. Number of people in household
(Line 6c on tax form) 2..
& Minimum income level for household size and county
(seeAppend A)
9. Income in c s of minniium
(subtract Line 8 from Line 6) $ ;, o
I B. Non-wa mm i.
Ito. Check the box if appW’ nt meeta condition I
I ‘I I a. Iute t income eater than $400 (Line 8a andlor 8b on tax form) I
I I. ib DMdendincomegreaterthan$400(T -ine9ontaxform)
I Ill. Phase I DL,r.d .’u (chad oise) I
I!
17
18
19
110
I ii
+12
I i:
11. Line 9 is negative or zero and no boxes are checked under Line 10.
Applicant has no resources; further analysis not recommended.
Date
12. Line 9 is positive andlor boxes are checked under Line 10.
Phase II analysis recommended.
-------
INDIVIDUAL ABIL Y TO PAY ANALYSIS
PHASE fl 1040A WORKSI (1991)
a
IL me
1. Wage income
(Line 7 on tax form)
2. Taxable interest income
(Line 8a on tax form)
3. Tax .exempt interest income
(Line 8b on tax form)
4. Dividend income
(Line 9 on tax form)
5. Total IRA distributions
( twin tax form: if Lines lOa and lOb are both eatcr than
zero, enter the amount on lOa; if Line lOa is zero and line
lOb is positive, enter the value on Line lOb)
6. Total pensions and annuities
(from tax form: if Lines ha and lib are both greater than
zero, enter the amount on 1 la; if Line I la is zero and line
1 lb is positive, enter the value on Line I, ib)
AppIi.t ’s
I OLwvt L.5 cAL (OL 1
Is V3,iav I
S
(oQO
$
c
$0
I I
I
S t ,ooo
$ .,u’-4o
Is ’
J 16
10
7. Total social security
(Line 13a on tax form)
& Total
(add Un 1th rough 7)
9. Household size
(Line 6e on tax form)
iO. v’i ilan income for household sizt and a my
(u data in Appendix A)
11. Income ratio
(divide Line 8 by Line 10 multip’y by 100)
S3 J1UO
I
Ta]
[ i 1 ôo ]
I 131.%] Ill
-------
II
ILNeteuhF l ow
12. Total annual living expenses
(convert all expenses from Part II of Financial Data
Request form to annual values and sum)
13. Total annual debt payment
(from Part II of Financial Data Request form,
sum entries in section “B. Debt Payments”)
I $ 3iz
1 112
14. Cash flow
(subtract Line 12 from Line 8)
15. Cash flow contingency allowance percentage
(see income criteria matrix)
16. Cash flow contingency amount
(multiply Line 12 by Line 15)
Is
‘ oo
J .
Ls• z
1.
I
c%J
I$I,s( &
I
17. AvRi1 hle cash flow (net of contingency)
(suotract Line 16 from Line 14)
114
115
116
18. % annual debt payment to annual income
(divide Line l3by Line 8; multiply by 100)
$ ,ZC.2 ..
I %I
Tc Flow
Disposidnn
(check one)
I
I
1
19.
Line
17 is positive. Applicant
has available
cash
I
]
flow.
20.
Line
does
17 is negative or zero.
not have available cash
Applicant
flow.
tilL Net Wonit
21. Bank accounts
(Part III of Individual Financial Data Request form,
total of fiLl)
1 117
118
119
I 20
I 21
122
.1 123
22. Investments
(Part III of Individual Financial Data Rt uest form,
total of 111.2) *
23. Retirement funds and accounts
(Part 111 of Individual Financial Data Request form,
total of 111.3)
Is%,500
I
[ $I, o
I
I s ,OQO
-------
I 30
131
I 33
24. Life insurance policies
(Part III of Individual Financial Data Request form,
total of 111.4)
1s oo
11
$
7OO
j•
Ls
S)500
1.
I 24
125
I 26
I 27
1 28
Is
25. Vehicles
(Part III of Individual Financial Data Request form,
total of 111.5)
26. Personal property
(Part I I I of Individual Financial Data Request form,
total of 111.6)
27. Real estate
(Part III of IndMdual Financial Data Request form,
total of 111.7)
28. Other assets
(Part 111 of Individual Financial Data Request farm.
total of 111.8)
29. Total a eta
(add 1in 21 through 28)
30. Credit cards and lines of credit
(Pan 111 of Individual Financial Data Request form,
total of 111.9)
31. Vehicle Loans
(Part III of Individual Financial Data Request form.
total of 111.10)
32. Furniture and household goods loans
(Part III of Individual Financial Data Request form,
total of IIL11)
33. Mortgages and real estate loans
(Part 111 of Individual Financial Data Request form,
total of 111.12)
34. Other debt
(Part lii of m i iduak Fina al Data Request form,
total of III.13,
35. Total liabilides
(add lin 30 through 34)
I I. 129
Is
z o
Is
Is
I
9 1 % S
I
Is
j
_______________ 134
Is I 135
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36. Net worth
(subtract Line 35 from Line 29)
S o,(p :—
I T j 36
37
—
39. Target Net Worth (See Net Worth Criteria Matrix)
40. Target Assets (divide Line 35 by Line 39)
41. Available Assets
(subtract
Line
40 from Line 29)
r -I- r 4
$ (. ,, 3 1
I 42
I W.PbasdilSnlnmMy I
44. Applicant has cash resources in the amount of:
(Line 17)
45. Applicant has available assets in the amount of:
(Line 41)
46. % annual debt payment to annual income
(Line 18)
37. Applicant’s age
(Part I of Individual Financial Data Request form)
38. Applicant’s Employment Status
(Part I of Individual Financial Data Request)
( 7
38
1
- I
7.’ ,%Co( I 140
Net Worth Diipt ition (check one)
1141
42. The applicant has available assets.
(if Line 41 is greater than 0)
43. The applicant does not have available assets.
(ifLine4 lis lessthanorequaltoO)
.
(S 1 144
$ ( t, 31
:i j45
Analyst t(Li .k
I ‘ 1 146
Date ( t ,I’iZ
-------
APPLICANT FILING THE 1040 CRAFTER S
The ability to pay analysis for applicants using the 1040 Federal Income Tax return is
described in this chapter. The 1040 is the most detailed of all individual tax forms. Those individuals
whose income is greater than S50,000 and who itemize deductions must use the 1040. In addition,
all taxpayers with business, farm, partnership, trust or rental income must file this form. 11
THE PHASE 1- 1040 ANALYSIS
ThePhaselanalysisisthetkststepinourabilitytopayevaluation. Duetohighincomeor
the omplealty of their financial affairs. most applicants filing a 1040 will not be eliminated in this
screening assessment. Nonetheless. we recommend that IDNR staff go through this relatively brief
process in the event that an applicant has filed a 1040 when a simpler form would have been better
suited to his or her financial circumstances. The data used in this phase of the analysis is based on
the applicant’s 1040 form and initial application form.
As in previous chapters, we use an example to illustrate the steps of the Phase I analysis. The
complete sample case can be found at the end of this chapter.
General Information
• Applicant’s Name. On Line I enter the applicant’s name. Note that the case
name for our example is Russ T. Tank.
• County’. On Line 2 note the applicant’s county of residence. As explained
in Chapter 1, county of residence is important to the evaluation of the
applicant’s income. In our example, Russ T. Tank lives in Lyon County.
• Site location. On Line 3 identify the specific location of the UST requiring
investigation or remediation. Our case example site is Alvord, Lyon County.
“See Appendix B nr a di tiled.explai tion of Federal Income Tax return forms 1O4OEZ,
1040A, and 1040.
5-1
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• Estimated Investigation or cleanup costs. If known, note on Line 4 the
estimated cost of cleanup or investigation. In our example, the lIST in
Alvord has an estimated cleanup cost of $80,000.
• Other parties Involved. On Line 5, list names of other parties involved in this
site. Is the property jointly owned? In our example, Tank is the sole
responsible party.
Financial Evaluation
In Section II of the 1040 Worksheet, we evaluate the applicant’s income as reported in the
most recent 1040 tax return. The applicant’s total adjusted gross income is then compazed to the
standard for his county of residence found in the FmHA income tables in Appendix A. In thia
example, we will use the low” income categoty as our income criteria.
Wage Income
• Adjusted gross Income. Find the applicant’s adjusted gross income on Line
31 of the 1040A form. In our example, Tank’s income is $54214. Write this
valueonLine6ofthePhase l. 1040 Worksheet.
• Number of people In household. On Line 7 record the number of people in
the household. On Tank’s tax return, he cl2im five exemptions. On Line 6a
he claims himself, on Line 6b he claims his wife (they are filing a joint return),
and on Line 6c he claims his three children, the total is shown at 6e.
• Minimum Income level for households. From the data in Appendix A, we
want to determine the FmHA low” income criteria for ri’id nts in Lyon
County. On Line 8, enter the low income” figure for a 5-person household
in the specified county. The “low-income” value for a 5-person household in
Lyon County is $27,450.
• Income In . riem of minimum. Subtract Line 8 from Line 6 and enter this
figure in Line 9. In our example, the difference equals $26,764. This means
that Tank’s income is $26,764 above the low income” cutoff.
Non-Wage Income
nth i spovtionoftheanalysi s ,wecheckthetaxreturntoseeifnon.wageincomehasbeen
earned. Lines 10 and 11 of the worksheet ask if income greater than $400 has been claimed in Lines
8a or 8b (interest income), or Line 9 (dividends), and if any income (positive or negative) has been
claimed in Line 12 (business income or loss), Line 13 (capital gain or loss) Line 14 (capital gals.
distributions), Line 15 (other gains or Losses) , Line 18 (rents, royalties, partnerships, estattes, trust,
or Line 19 (farm incc,.:). 1. 1$ would indicate that the applicant has substantial investnic.. and/a
5-2
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non.wage income. If this is the case, a Phase II analysis must be performed. On Russ T. Tank’s tax
return, we see that he has claimed income on Lines 8a, 12, and 18. Therefore, we check the
respective lines on the worksheet.
To summarize, we note the Phase I disposition for this applicant. Recall that Tank had an
income in excess of the minimum, he had interest, business, and rental income. Therefore, we
check Line 12. a Phase II analysis is recommended.
THE PHASE 111040. ANALYSIS
In this section we describe the Phase 11 analysis for the applicants using the 1040 Federal
Income Tax return. The Phase if analysis determines the amount of resources that applicants passing
the Phase I analysis may have to contribute to site investiption or cleanup. The data used to
perform this portion of the analysis is from the applicant’s Financial Data Form and 1040 tax return.
Three steps are involved in this analysis: (1) an income analysis, (2) a cash flow analysis, and (3) a
net worth analysis. Tank’s completed Financial Data Form can be found at the end of this chapter.
We begin with Section 1 of the Phase II Worksheet, the income analysis. We will continue
to use data from Russ T. Tank as our case example.
SectIon 1. Income
In this section, we first categorize the applicant’s income, and determine how to apply the
income criteria. This determination is more complicated than in those cases involving a 1O4OEZ or
1040A because of the variety of the applicant’s income sources. In some instances, the applicant may
have income that is not taxable, but that should be included for the purposes of this analysis. Recall
that in the Phase 1 analysis, we compared applicant’s income to a low’ income minimum. In this
section of the worksheet, we perform a similar calculation. Now, however, we compare applicant’s
income to the county mc di an household income, rather than the low’ income standard.
• Applicant’s name . Russ T. Tank
• Wags Income. On Line I of the Phase II worksheet, enter the applicant’s
wage income as reported on Line 7 of the 1040 tax return form. Tank’s wage
income in 1991 was $11,401. We see right away that this figure does not
mateh Tank’s adjusted ross income of $54,214 on his tax return, indicating
that he receives income from non.wage sources.
• Taxable Int t Income. From Line 8a on the 1040 return, note if the
applicant has cl2imed taxable interest income. Examples of taxable interest
• income include interest from checking and savings accounts and interest from
bonds and treasury bills. (See the 1040 Instruction Booklet for a full
explanation of each line entry.) In our mample, Tank has claimed $2265 in
t irahle interest for the par. .nter this on Line 2 of the Worksheet.
—
5.3
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• Tax-exempt Interest Income. From Line 8b on the 1040 return, note if the
applicant has claimed tax exempt interest income. An example of tax.exempt
interest is the interest earned on a municipal bond. Tank has not made an
entry in this line. Enter 0 on Line 3.
• Dividend Income. On Line 4 of the Worksheet, enter any dividend income
reported in Line 9 of the tax return. Enter 0 for Tank since he did not report
this type of income.
• Alimony received. On Line 5 of the Worksheet, enter alimony reported in
Linellofthetaxreturn. Enter0forTanksincehedidnotreportthistype
of income.
• Total IRA distributions. On Line 6 of the Worksheet, enter any distributions
from lRAfundsreportedinLine l6ofthetaxreturn. Ifanentryismadein
both Line 16a (total value) and Line 16b (taxable portion), enter the amount
from Line 16a. However, if the IRA distribution is fully taxable, an entry will
be made in Line 16b only. If this is the case, enter the amount from Line
16b. Enter 0 for Tank since he did not report this type of income.
S. Total pensions and annuities. On Line 7 of the Worksheet, enter any
pensionandannuityincoine reportedinLine l7ofthetaxreturn. Ifanentry
is made in both Line 17a (total value) and Line 17b (‘amble portion), enter
the amount from Line us. However, if the pension is fully ‘ ble, an entry
will be made in Line llb only. If this is the case, enter the amount from Line
17b. Enter 0 for Tank since he did not report this type of income.
• Total Social security. On Line 8 of the Worksheet, enter any social security
income reported in Line 21a of the tax return. Be careful to enter the value
on 21a (the total) and not the value to the far right Line 21b. The value in
Line 21b represents y the taxable social security; here we want to account
for jj income. Enter 0 for Tank since he did not report this type of income.
On Line 9 of the worksheet, we sum all of the applicant’s wage income (Lines 1 through 8).
Tank’s total wage income for the year was $13,666. We next minc the applicant’s business and
trust income.
• Busluesslncome . From Line I2on the 1040 return, noteif theapplicant has
claimed any business income. If an entry was made on Line 12 of the 1040
form, a Schedule C must accompany the applicant’s 1040 tax return. From
Tank’s return we see that he has claimed $38,208 in busin ’ income. To
• obtain more information about the business, refer to Schedule C Profit or
Loss for Business. On Line A of Schedule C, Tank has noted that he is the
sole proprietor of a gasoline service station.
5.4
-------
• Depletion. On Line 11 of the worksheet, record any depletion that the
applicant has claimed for his business as a positive value. A unting for
depletion is a way to allocate over time the original cost of acquiring and
developing natural resources. For example, a company that operates coal
mines would record depletion expenses every year to account for the coal that
had been mined that year. The mines are now less valuable because they
contain less coaL Recording depletion is a way of capturing this loss.
Although depletion is a true business cost, it does not represent a cash
payment in operating the mines. For that reason, depletion expenses are
added back into a company’s income when computing cash flow. Tank is not
iniolved in extracting or developing natural resources, and hence did not
claim any depletion for his station. Enter 0 on Line 11.
• Depreciation sadler Amortization. On Line 12 of the worksheet, record any
depreciation or amortization that the applicant has claimed for his business.
Depreciation and amortization are similar to depletion in that they allocate
the cost of tangible and intangible assets over a specified number of years.
Some assets become less valuable with use over time (for example, plant
equipment and patents); this loss of value is accounted for under depreciation
and amortization expenses. In addition, allowing the tax payer to ‘write.oft”
the initial cost of assets enables them to save money for future replacement
costs. Like depletion, depreciation and amortization are real business costs,
however, they do not reduce a company’s annual cash income. For that
reason, depreciation and amortization expenses are ad I id back into a
company’s income when computing cash flow. On Line 13 of Tank’s Schedule
C, he claimed $4,115 in depreciation for the year. Enter this figure on Line
12 of the worksheet.
• Total Income from rental or royalty properties. Note on Line 18 on the
1040 tax form that the filer is asked to record income from rents, royalties,
• partnerships, estates and trusts. To get a breakdown of each of these income
sources, we need to consult Schedule E, which details each of these income
sources. If anentryismade in Line 18,aScheduleEmustaccompany the
1040 tax return. Tank has claimed $2,340 in rental income on his Schedule
E. Enter this figure on Line 13 of the worksheet.
• Depreciation or depletion on rental property. Recall from Lines 11 and 12
of this worksheet that in order to calculate an applicant’s net business cash
flow, we added back the depletion and depreciation expenses fl tmed on the
tax form. In a im’hr fashion, we add back depreciation on rental property
tocalculatecash flow&om this asset. NotethatonLine20ofScheduleE,
Tank has claimed a depreciation expense of $680. Enter this amount on Line
14.
5.5
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• Partnership/S corporation Income. Also on Schedule E, applicants must
detail income or loss from Partnerships and S Corporations. The total income
from these sources is recorded on Line 31 of Schedule E. Enter this amount
on Line 15 of the worksheet. Enter 0 for Tank since he did not report this
type of income.
• Estate and trust Income. Also on Schedule E, applicants must detail income
or loss from Estates or Trusts. The total income from these sources is
recorded on Line 36 of Schedule E Enter this amount on Line 16 of the
worksheet. Enter 0 for Tank since he did not report this type of income.
• REMIC Income. Also on Schedule E, applicants must detail income (or loss)
they receive as a holder of a residual interest in a Real Estate Mortgage
Investment Conduit (REMIC). The total income from these sources is
recorded on Line 38 of Schedule E. Enter this amount on Line 17 of the
worksheet. Enter 0 for Tank since he did not report this type of income.
• Farm rental Income. If an applicant has received income from farm property
that he or she is renting to someone else, they must dedare this income on
a Schedule E. Note if income has been recorded on Line 39 of the Schedule
E. If so, enter this amount on Line 18 of the worksheet. Enter 0 for Tank
since he did not report this type of income.
• Depreciation on farm rental Income. Individuals can claim depreciation
expenses on the farm property they rent to others, just as they do on other
rental properties. We add this expense back when calculating cash flow.
Tank does not rent any farm property or claim depreciation, so enter 0 for
this line on the worksheet
• Farm Income . An applicant must submit a Schedule F to report income and
expenses from a farm that he or she operates, or owns and operates. If an
entry was mide in Line 19 of the 1040 return, a Schedule F must accompany
the 1040 return. If income is declared on Line 19 of the 1040 form, enter this
figure on Line 20 of the worksheet. Enter 0 for Tank.
• Depredation on I5rm property. Depreciation on farm property and
equipment is recorded on Line 17 of the Schedule F. As with depreciation
on other types of property, this expense is added back in order to calculate
cash flow. On Line 21 of the worksheet, enter the amount reported on Line
l7of the Schedule F. Enter0fo Tank.
On Line 22, we sum together all of the applicant’s business and trust income entered on lin
10 through 20. Tank’s total for Line 21 is $45,343. Next, we look at the applicant’s extraordinary
income, that is, income earned from the sale or exchange of a capital asset or the sale and exchange
I business property. iTor a f .11 description of Schedule D and its applications, refer to the 1040 —
5.6
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Instruction booklet.) If an applicant has made an entry in Lines 13 or 14 of the 1040 return, he or
she must include a Schedule D detailing short- and long-term capital gains and losses . We record this
information on Lines 23 through 25 of the Worksheet.
• Capital gain (loss). From the 1040 tax form, add Lines 13 and 14 and enter
this total on Line 23 of the worksheet Tank did not claim any capital gains
or losses for the year.
• Other g iu (losses). Enter the amount record on Line 15 of the 1040 tax
form on Line 24 of the worksheet. Tank did not claim any additional gains
or for the year.
• Total exirnordinasy Income. Md Lines 23 and 24 of the worksheet to
determine the applicant’s total extraordinary income. Tank’s entry here is 0.
On Line 26 of the worksheet, we calculate the applicant’s total income by adding together
his or her wage, investment, business and extraordinary income. Sum the amounts in Lines 9,22, and
25 for this total. Tank’s total income in 1991 was $59,009. We next want to determine what portion
of the applicant’s income comes from each of the three categories we’ve inined. To calculate
these percentages, divide each subtotal by total income.
• Percentage wage Investment and retirement Income. Divide Line 9 by total
income recorded in Line 26. Note that 23 pcncru of Tank’s income comes
from wages and investments. Enter this percentage on Line 27.
• Percentage business and trust Income. Divide Line 22 by total income
recorded in Line 26. Tank receives 77 percent of his income from business
and trust sources. Enter this amount on Line 28.
• Percentage extraordinary Income. Divide Line 25 by total income recorded
in Line 26. Tank receives 0 percent of his income from extraordinary sources.
Therefore, enter 0 on Line 29.
In some instances, a large share of an applicant’s income may come from business and
investment activities, or from capital gains. For these applicants, an analysis of cash flow and net
worth may be more complicated. Calculating the portion of income coming from each source draws
our attention to these cases . If extraordinary sources account for more than 20% of total income,
you should consult a financial expert You should also consider consulting an expert if your analysis
indicates that the applicant is unable to pay, but business and trust income are more than 50% of the
appLicant’s total income.
To cohclude the analysis of income, we compare the applicant’s income to the median income
for the same size household in the applicant’s county. -
- f
5.7
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• Household size. Enter the number of exemptions claimed on the applicant’s
tas return on Line 30 of the Worksheet. Total exemptions can be found on
Line 6e of the 1040 form. This figure defines the size of the Tank household.
(Alternatively, check the enuy you made on Line 7 of the Phase I worksheet.)
Tank claimed a total of five exemptions in 1991.
• Median income for household size and county. The FmHA data tables
provideuswtha’60%ofmedianincoine ”flgureinthcdatatablea. Weuse
this to determine the median household income. To find this value look up
the applicant’s county and then find the appropriate household size column.
The last rowof data lists60% of median income. InthecaseofRusaT.
Tank, 60% of median income for a Lyon County 5-person household is
$20,600. Divide this amount by 0.6 and enter the result on Line 31 of the
worksheet. We now know that median household income in Lyon County for
a 5-person household is $34,333 ($20,60010.6).
• Income ratio. We next want to determine the applicant’s income category on
the income criteria matrix. To find this percentage, we simply divide the
applicant’s income by median income. • The result will show whether the
applicant’s income is above or below average, and by what percent. To
determine the result for Tank, divide Line 26 ($59,009) by Line 31 ($34,333)
The result is 1.72 or 172%. This result means that Tank’s income is 72
percent above the county median. Tank therefore falls into the “greater than
125%” income category on the income criteria matrix.
Section II - Net Cash Flow
The next step in the Phase II analysis involves determining the applicant’s cash flow. A
simple way to think of cash flow is as the income Left over after paying all cash expenses during a
period. In calculating expenses, we use data from the Current Living Expenses section of the
Financial Data Request Form (Part II).
• Total annual living expenses. Go to Part II of the applicant’s Financial Data
Form. Space for converting data to annual values is provided in the “For
Agency Usc Only” column in the Current Living Expenses Section (Part II).
Forwecklyexpensex, multiplyby52andputthctotal inthe “ForAgency Use
Only” column. For monthly expenses multiply by 12; and for quarterly
expenses multiply by 4. (Tank’s expenses are converted to annual figures as
shown in P hibit X). Sum this column of figures and enter the total on Line
12 of the Phase U Worksheet. Russ T. Tank’s total annual living expenses
• arc $42,486. Enter this amount on Line 33.
5-8
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• Total annual debt payment. Enter the applicant’s total annual debt expenses.
An applicant’s current debt expenses are important to determining the
applicant’s ability to acquire additional debt for site a iessment or cleanup
costs. Total lines 8.1 through B.4 on the Current Living Expenses Form and
enter this amount on Line 34 of the worksheet. Tank spends $9,769 a year
on debt payments.
Once we have totalled income and expenses, we can calculate the applicant’s cash flow for
the year. A simple way to think of cash flow is the income left over after paying all expenses. As
explained in Chapter 1, we will set aside a portion of this cash flow as a ‘contingency allowanc& for
unexpected expenses or emergencies.
• Cash Flow. Subtract Line 33 from Line 26. Tank’s Net Cash Flow is $16,523.
Enter this amount on Line 35.
• Cash Flow contingency allowance percentage. Consult the income criteria
matrix to determine the appropriate cash flow contingency allowance. Tank’s
income level of 172% falls into the ‘greater than 125% category,’ and
indicates a contingency allowance of 5 percent Enter this percentage on Line
36.
• Cash flow contingency amount We now calculate the amount of contingency
expenses we will allow Tank based on the contingency percentage and
predicted annual expenses. Multiply total expenses (Line 33) by the
contingency percentage (Line 36) and enter this figure on Line 37. Frye
percent of Tank’s total expenses equals $2,124 ($42,486 x 0.05). In calculating
available cash flow we set this amount aside to allow for unforseen expenses
or emergencies.
• Available cash flow. Subtract Line 37 from Line 33 and record this figure on
Line 38. Tank’s annual cash flow, after subtracting expenses and a
contingency allowance, equals $14,399.
• Percentage debt to Income. Here we consider what portion of an applicant’s
income is directed towards debt repayment The level of current debt wili
determine how much additional debt an applicant may be able to assume for
the payment of UST site costs. Applicants who are currently directing more
than 36 percent of their income towards debt repayment will probably not
have the capacity to acquire additional debt. In fact, they may be denied
funds by a lending institution. To calculate an applicant’s percentage debt
expense, simply divide their annual debt expense (Line 34) by their total
•income (Line 26) and record this figure on Line 39. Enter 17% for Tank
(9,769/59,009 = 0.17).
5.9
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At the end of Section II of the Worksheet, note the Cash Flow Disposition. In the case of
Tank, we check Line 40. applicant has excess annual cash to pay for cleanup.
Section lIT . Net Worth
The last section of the Phase II analysis evaluates the applicant’s net worth. Here we
an applicant’s total assets and liabilities. The data for this analysis comes from the Net Worth Section
(Part III) of the Fhinncial Data Form. We continue our example with Russ T. Tank below.
On Lines 42 through 49 of the 1040 worksheet, we enter subtotals for each type of asset.
• Bank accounts. Enter the subtotal from Question I on Line 42 of the
worksheet. Tank has a total of $19,301 in checking and savings accounts.
• lnvestmeiae. On Line 43 of the worksheet, enter the subtotal for the
applicant’s investments. Tank has $20,000 in investments.
• Retirement fUnds and accounts. Enter the subtotal from this question on
Line 44. Tank has 0 in retirement funds.
• Life Insurance policies. Enter the subtotal from Question 4 on Line 45. The
value of Tank’s Life insurance policy equals $7,800.
• Vehicles. Enter the applicant’s estimate of the value of his vehicles. Tank
has entered $24,000 for this question.
• Personal pivperty. On Line 47 of the worksheet, enter the value of the
applicant’s personal property. For Tank this total is $17,000.
• Real estate. On Line 48 of the worbhee enter the subtotal for the value
of all real estate. Tank estimates this value to be S7 000.
• Other assets. In Question 8, the applicant totals the value of all other assets.
Tank has not listed any other assets. Therefore, enter 0 on Line 49.
• Total assets. Md Lines 42 through 49 on the worbh et and enter this
amount on Line 50. The total value of all of Tank’s assets is $166,101.
• Credit cards and lines of credit On Line 51 enter credit debt for the
applicant Tank’s total is $17,021.
• Vehicl, loans. Enter on Line 52 the subtotal for all car loans. Tank owes
$12,560.
• Furniture and household goods I c tus. On Line 53 enter any debt acquired
for household good:. Tar... : e red $3,923.
5-1
-------
• Mortgages and real estate loans. Enter outstanding mortgages or real estate
loans on Line 54. Tank owes $32,760 on his home.
• Other debt. Note whether applicant has listed any other debt. Here Tank
has listed a personal loan in the amount of $19,035. Enter this figure on Line
55.
• Total liabilities. On Line 56, total all of the applicant’s liabilities (Lines 51
through 55). Tank’s total is $85,299.
• Net Worth. Subtract Line 56 from Line 50 to determine the applicant’s net
worth. (Keep in mind that this ç be a negative number. Negative net worth
simply means that an applicant’s debt is greater than his or her assets.) Tank’s
net worth equaLs $80,802 and is entered on Line 57 of the Worl heet.
• Applicant’s age. In Part I of the Financial Data Request form applicants note
their age. Enter Tank’s age (48 years) on Line 58.
• Applicant’s Employment Status. On Line 59, note whether applicant is
employed, unemployed or retired. Tank is self-employed.
• Target Net Worth. We next want to determine the applicant’s target net
worth ratio. Recall that Tank’s income put him in the ‘greater than 125%
category. Checking under this column on the net worth criteria matrix, we
see that the target net worth ratio for Category A (applicant retired or
unemployed) is 0.6, while the ratio for Category B (other) is 0.8. Tank was
employed when he filed this return; he therefore falls into Category B, and
his target ratio is 0.8. Enter this figure on Line 60.
• Target Assets. We next want to determine the nece saiy assets for this
applicant, based on his or her target net worth. To determine this dollar
amount, divide Line 56 (Total Liabilities) by Line 60 (Target Net Worth).
Tank’s liabilities equal $85,299. If we divide this by 0.8 we get a dollar figure
of $106,624, which represents the amount of assets Tank should maintain.
Enter this figure on Line 61.
541
-------
• A, I12hIe A tj. We next want to determine Tank’s available assets, that u,
thevalue of his assets that might be available for USTsite costs. We find this
value by subtracting the applicant’s target assets from his actual assets. For
Tank, subtract Line 61 ($106,624) from Line 50 ($166,101). The result is
$59,477. Enter this amount on Line 62.
At the end of this section we summarize the applicant’s net worth position, checking the line
that matches the applicant’s status. In Tank’s case we check Line 63, because the applicant has
available assets.
Summary
At the end of the Phase II analysis we summarize the cash flow and net worth assessments.
In Line 65, note the applicant’s cash resources. Looking back to Line 38, we see that Tank has cash
resources in the amount of $14,399. On Line 66, note the applicant’s available assets. Looking up
to Line 62, we see that Tank’s cess assets equal $59,477. On Line 67 note the applicant’s percent
annual debt payment as recorded on Line 39. We find that 17 percent of Tank’s income is made up
of debt. This value is less than 36%, indicating that the applicant should not have trouble obt*ining
additional debt financing. This surnrnary section of the Phase II analysis gives us an idea of the
applicant’s available resources. As we discussed in the introduction, however, an applicant’s ability
top may also be affected by past financial problems, anticipated expenditures, pending lawsuits or
pending capital transactions.
5.12
-------
INDIVIDUAL ABILiTY TO PAY CLAIM
General Informat ion Form
Case Name: TT t jI -‘iSl
We are requesting financial information to help us evaluate your aoilicy to contribute iunds for
investigation or remediation of the petroleum release at the above.mencioned site. Please till out this
form aria submit a signed. comof etc copy of your most recent federal income tax return. The Iowa
Department of Natui aL Resources may request documentation supporting the intormanon you
provide on this form or in your tax return.
Name: I uC LII
Spouses Name: L€ . r cL. P ‘C4 L
Address: - -
L
/ çIVCv 4
Phone Number Home ) u u _ - !.) rj Work (Il z) Li Li / —
County of Residencc L t L4r
Does the information proviá d on your federal income tax return accurately retlect
your current financial situation? Please describe below additional information that
you would like us to consider itt evaluating your case (for example. anticipated major
expenditures or changes in income). se additional sheets if rtere3sarv.
CL4 GL4 CL-
y jw VEA — .. .- j + r ( -
•‘i (‘MA ..t.
-
Are you currently participating in any type of federal or state assistance program (for
example, AFDC, SSL food stamps HUD or FmHA housing assistance, home heating
assw n Me&rai& or towns medically needy program)? Please describe below.
Attach additional pages if nee uxy.
-------
INDIVIDUAL ABILITY TO PAY TRACIT4G FORM
Iowa Department of Natural Resources
Applicant’s Name:
j
Address
I
I
County
1
CaseA
I
Date Individual was fint contacted: I
Date Phase I Request Letter Mailed: I
Date Tax Forms are Returned to IDNR: I
Year of Tax Return:
Type of Form: ( i.e.. IO4OEL 1040A. 1040 )
Schedules Attached to Tax Form: I
Phase I Disposition (check one
Applicant has no resources.
Analvth discontinued.
Date Analysis Completesk
Additional CommenIE
PHASE I ANALYSIS
IR 5s , I
r ,-2.. L\1OtS %L r y .
Aivo ct,
IL oA I
I c . c 1 J cfr I
I -fli 1°i2_
I.
I c ( ° - I
I 1 q I
I
I
I ]•
I
Phase U anp performed.
-------
PKASE U ANALYSIS
Date Maiysis Completed:
Additional Comments:
Date Phase U Packet Mailed: I
Date Phase lIDat cRetrncdtolDNR I
Phase II Dkpcsnion
Available Cash Flow
E Aasets
Final Determination
I 1.II Ic -z .
1
ISlLIdl.Z.
1
I t( t3
1
9c
..
I
•I
I
I
-------
INDIVIDUAL ABILITY TO PAY CLAIM
Financial Data Request Form
This rorm requests information regarding your financial status. The uata witl be used to
vaIuaie your ability to pay for environmental clean-up or penaities. If there s not enough
space for your answers, please use additional sheets of paper. Note that we may request
further documentation of any of your responses. We welcome any other information you
wish to provide supporting your case, particularly if you feel your situation is not adequately
described through the information requested here.
Certification
[ declare that this statement of assets. liabilities, and other information is true. correct. and
omplete to the best of my knowledge and belief.
Signature Date
I l 1° ?
L
-------
PART L BACKGROUND INFORMATION
Name
A e
Relationship to Head
of Household
Currenti,
EmploYed?
Lu , L r.
4
h l
‘1
__ c-..... ‘. —r ,
A
j 1
j
2. EMPLOYM IT (Us$ all Jobs heM by persons In heur” )
Name
Employer
Length of
Employment
Annual
Salaiy
-‘
kua- T rc J
A.V CC ) C .)A.LC
%
no 4.s194
&iy
- c P-r 3M.,k..
t o...t
U,
I.
U k 1Oa Lfl
2 ,
‘2. c,eo
I. MEMBERS OF HOUSEHOLD ( List the huad at the household and all persons Il ’tng wIth you
-------
PART IL CURRENT LIVING EXPENSES
Please list personal living expenses wtuch were typical during the last year and indicate if any oi these
values are likely to change significantly in the current year. Please do not include business expenses. LI
1 u are the owner of an operating business, please attachment any available financial stale cn .
Exi,
Amouna
rifiod of Payment (chedconep
For A cncy IJso Only
‘ .bIp
!dossbay
Q -”-”,
Ye Ip
I. Rent
2. Home rne” ” e
t p
.
/
4CC ,
3. Auto fUel inainijother traasp.
4
t/
1
4. UtilitIes
a. Fuel (gas.oaL vod.propane )
‘/
‘g
b.Elec tnc
12.
/
.
c. V. terisewer
2.
v’
2 ça
d. lblephone
32.
v’
4
5. Food
q
‘•72ja
6. Clothint. personal care
4 3
.____
! 1 q7
7. Medical costs
.
v’
7!,
B Debt Payments
1. Mongage payments
b2C
I
C. 2.40
2. Car payments
L J
/
a q
3. Credit card payments
2.6
/
4._Educational loan payments
C. Insuranen
LHousehold thsuranen
4j
J
2. Life insuran
J
3. Automobile insiuanes
v
rv
4. Medical insuranes
‘7
/
‘—
D. Thxes
1.Pmpcrtvtaxcs
3
‘-f’
2.Federalinoomei
v ,2f
/
4g
3. Stare income ta
ig
/
ciic
.$.FTCA
Ø
v
2o
E. Other Expenses
I. Childesre
2. Current School tuition/expenses
4C
/
/
— .
3. Legal or professional er ices
— 4&)
-
4. Other (itemize on separate page)
ibtal Current ExDenses
4 2.. 4’
-------
PART I lL NE ! ’ WORTH
Please provide the following information to the best of your ability. Data should be as current
as possible. Estimates are acceptable: if you wish note such items with an “E”.
if you are the sole proprietor of a business, please lists business assets and liabilities. in addition
to personal assets and liabilities. Please mark these entries with a “B” to identify them as
business assets and liabilities.
Name of Bank or Credit Union
Iv, M
r :,i& Aiv,wl
vZ4 h hJ yd,..
1 ’pe of A uni
aa LI1
f ?A 1 ? iAfii
C,
1. SANE ACCOUNTS ( P M g NOW Savlni Mossy Mar etc)
For Agency LFse Oidy. ibisi Current Balaoa in Bank A unis
2. INVFSTMfl4TS
(Steck, 3c.d M’ uM fn.sd, Oy”i Futerss CD% R Fisase IMv t&
1 ue (
RflT), e )
-—.- —--
Investment
(r tl 2 ’ Alvw s’
C o £
Number of Shares or IJnits
‘
For Agency Use Only. ibtal Current Market Value of Investments
3. REI ’IRD( IT FUNDS AND ACCOUNT! (IRA, 401(11) , Km. . i4 lut...at thenunp.ny
retirement f n& et )
Desaipilon of A unc
Estimated Market Value
Current B2I. .ce
12.. ZI
L 4( 7.
LO
Lr
3o1
Current Market Value
I 0.
i ( .r fl
2.0. c n
—
For Agency Use 01y . ibtal mated Market Value of Retirement Funds
and A unls
4
-------
4. LIFE INSURANCE POLIcIES
Policy Holder
Issuing Company
Policy Value
Cash Value
Y2 .tss ‘ThntêC-
i, juo1oLOvr .
I i
LC1 4 4
MU+ 4G(. Qr io.iiy
For AgencY Use Only- 1b l Wine of Life Lnswan Policies
1., 800
5. VEHICLES (Can, Thick, Mo& ,Jei, R istlon V4VI.a Motor ff’ u! . Scst& Airplinne, etc)
Fir Agency Use On1 . Thini Estimated Market Wine of Vehicles.
Model
J11fr.VLL 4X4
L4Y t 1 In..
lEict. j,eAy 4.
Year
o
t t
t
Estimated Market Wine
4,X’
OzrD
i.Mai o
.
‘ERSONAL PRO
PERIY (Hoe -l111IA Goods aM P .l1nn, Jeue& , Ax% AMtIqI 1, Cnhl..1Ic I.,
Pu oos Met&
Only list ‘ lth * vein netes than 3300.00)
I-k- j Ek lk I1Ai4if\i AAP
1 pc of Property
4; L,ct .pTh A JADOIpL,4I C.
For Agency use Only. ibal Ealthw d Market Wine of rsanel Property
Estimated Market Wine
2.,
1 j ri—r
i ,(Y01
7. REAL ESTATE (i .4, 3vl$” Land wIth 3 lWe i) .
Loession
I1,7 \ 1flsk’.. O-
(1
Desatption of Property
1 .r #I
-i-t
Estimated Market Wine
R ( !
— — .1 M#
— -.._
For A eecv Use C 31. ThIal EathnaICt Market Wine of Real Estate
O ’JL
S
-------
l rpe of Asset
Estimated Market Value
8. Ouir.K ASSETS
For Agency Use Only. ibtol Other Asse
9. RED CARDS AND UN OF CREDiT
•1
—- -
—
—3 .— -
Credit Card/Line of Credit (l /pe)
M ior ‘ .‘—
o44 r
i C \ (
c G,k- t4W r J C ‘i
Owed lb
vce 44-’ -
A . .. k
*.kIt(?t ‘ 4—L...
For Agency use Only - lbtal Balance Due on Credit Cards and Un of
Credit
Balance Due
,c oo
‘ e 2Q..
1 q 7
%qI o1-’
10. VEHICLE LOANS (Can, Ducks, Mi*uiiydu , Reawedo. V h1den , Motor flowue, Basis, AIrp&. sL
Vehicle (Modal and Yea,p
Owed lb
Balance Due
4 PX4
4. a w -
Q ’ (, CO
A.’-
- tc .o, . . .
6
(0
For Agcn y Use Only. lbisl Balance Due on Vehicle Loa
I 2., %O
6
-------
List Item
Liia’rri I -i’—’i . i(y t1(#..
J-
• OwedTo
Udw r ti4t rL.
BaIan Due
q2. J
Li. FURNITURE AND HOUSEHOLD GOODS LOANSi
----
“-.
-
,r
For Agency Use Only - ibtal Balance Due on Furunuro and Household
000th aue
3 1 q 2.
12. MOI TGAGEH AND REAL STATE LOANS
‘T rpe of Loan
4a
3 )
Owed lb
e .4.M ,4 £ 4.L.
opo f i
Against
12..’ta s J1i,
— n__ _ -
3.
Balance Due
7
n.a a
Only. lbtal Balance Due on Mortgagor and Real Estate Loans
32, 5O
U Or a DEn’ ( Amsnnte due to lndMdnsla, EI d obllgudoa., Thans Owsd, Orordus Alimony or Child
Support, etc.)
l ’po of Debt
Owed lb
Balance Due
V,i r L s
M riei This k4
&4
For Agency Use Only. ibial Balance Due on OthcDcbs
1,IO c
7
-------
PART IV . ADDITIONAL INFORMATION
Please respond to the following questions. For any question that you answer “Yes.” please
provide additional information on separate pages or at the bottom or this page.
QUESTION
YES
NO
1. Do you have any reason to believe that your financial situation
will change during the next year?
2. Are you currently selling or purchasing any real estate?
.
)(
3. Is anyone (or any entity) holding real or personal property on
your behalf (e.g. a trust)?
x’
4. Are you a party in arty pending lawsuit?
X’
5. Have any of your belongings been repossessed in the last three
years?
)(
6. Are you a Thistee, Executor, or Mmmiitrator?
X’
7. Are you a participant or beneficiary of an estate or profit sharing
plan?
X’
8. Have you declared ban uptcy iii the Last seven years?
X
9. Do you receive any type of federal aid or public assistance?
N’
‘ ‘ u 1.- e.r ___ e.3A.
( vi ir - -v
v’ \ - p a.L ci —
8
-------
4 II a 0 m i.vis. (8 4 i
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Label ‘
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if you, wousi warn Si to c i to tois tuna? V i i
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bCFoi ,n4 t3S. . . . . .
Aoamse54Irsijge5IThsisarevaistotitsa in..lSs .
,,
•
Refund or
Amount •
You Owe
;lseIOs iomomaiuma$3 .$ommo52fvomvisi0. Thasmew’sau)ma OV AIQ. .
Mnshne5Ito0sR1 JNOYOYOU
MimaioI ii6ImU$13TINA11lTAl
if Ins 53 1$ more ._. ‘a ’s $0. uueaics sits 80 from ins 13 TPIt ii me ANflIJIT YOU O
AiteitI ails V monuy ores ior flai amiss Dayses to h... .. . Rss.ia Osracu . ae g
nant. m cv iii . some ssmamm, mattes,. o m. onons maims. ins 9191 Feumi t04 on a.
Et ’ .. .a tax srormy sos aims am. Nim on ‘at. 14. ‘ I I I
si
I II i
lug )I I
65 --. __
• a osimy. icious ma’ ‘ama e.r Irnu ,rijm, ama . 4 imasuss ma ._ . ma us ms mo . .I ___ . . NI
tgn :aw. ii as cama. ate .. . Ooo. ’ a . . w mat ama i a DO am as . flli.... . a — ma em
Hers ma iqasus oars Ym, s—--.an
—eso$ccov _____________________________________________ _______
seIum k Samars a iq ’iiw ‘it ian’ ‘lulL iOT “mu 5,’p , _____
.ecoras.
Paid ma I — •••• • $• 4 ,
• aasa—= —
riujiumusi a IL Ni .
Use Only
ic a rus • ZIP coos
Tax
ComDu•
tatlon
‘CU Nan?
i I S t
• ‘ure Our
ass cage
£4.
Credits
es cage
15. 1
‘ Si
‘am —
-------
SCHEDULES MB I Schedule A—4temizea Deductions
Ferns 10401
.
‘ m av a’éi
Mdical CIUUIE Uo nor inauae exoenses eImous5eq or caig v owery.
and I Meaicai ana aentai ezoenses. See oage 38.1 OZ —
Dental 2 er amount trom iorm 1040. line 32 2 LL4 4 4
Ezpsnues 3 .iuwoiv iune 2 aoove ov 7 !% iO75 3 4, C(o —
otract Ire .3 prom line Enter me ‘esuit. if sea iran zero. e’iiee • .- • 4
‘Taxes You 5 3cat. ana ocai income taxes
Pitd 6 eei estate taxes
:tne taxes. iL st—”c1uCe oeraoiiai crooerw taxei.i P
:age 381 .
8 aa tines mrougn 7 Enter ire totat
S c i ome mortqaçu interest aito coinre reoartea to you on form ‘093
Plome mortgage imsrest not recanea to you on Form 1Q98. (If
:aia to a n inaiviauaa. snow mat 05130113 name ana aaareu.i P
10 tnta rot eoortea O you :sa. ee
n$ouCUQ 3 tar soecial ltJlI$.4
11 •nv ji ji interest I auacn Form 4952 if recuireat. (See
age40.).
12 ÂØØ Iiries9atrirouaji 11. Eriterifletotsi. .
Causeis if you meos a chanm e Canmøuean anor
recalvsa a benefit in esun. see page 40.
C nmbuoons oy cain or cnecx . .
tMr titan cain or cmecii. (You MUST attacn F ri?t 8283
lover S500..
Carryover from onot year.
.dd lines 13 tflrOuon 15. Enter me totai.
13
14
Is
is
5
a
7.
a
9b
10 I
11 I
. P p
I
I
I
13
14’
is
.——- .‘1l
P•
I
J
: .isp . I!45.0074
‘Sclieeuls S is on oac
P AltecS to Form 1040. P See In irmons for $cfteeules A arm B (Foriri 10401. — eetai s , o. 07
‘ow sO NSIIt
‘1
Z.? 4
Pie
Casually anu
Theft Losses 17
Casuaitvor treft oseesi (anacn Form 46841 ‘See oaae 40.1. P 17
Moving
Exoenses ‘8
.iavena exoenses ‘aitacn F’ rre 3903 or 2903F ’
. ..nr,,mour$ea emoioyee exainses—co :raVQ. JiIOfl
. aD Ezoiniss 19
and Mo Other
Mlsesfiuuslas
QedutaslU 20
auss. ci eoucauen. etc. (You MUST attacn Form 2106
I reawteo. See imsmicoarsj P
Cirter exounses linvestrrent. ax crecareuon. safe
See
aqe**1Or
ezo.Jl$eS e,
:eeuctnsIs.I 21
20
20
24
aecost OQa. 110.1. LaSt type ama amount P
.
AddlineslSana2O . . . . I .
ntur wmwe trom Form 1010. line 32. fl• l
Multalyline22ov.oya%L02t 231
SubtrW bne 23 ftom lIne 21. Enter me resist. it less man is v. enter
Outer dram list 41 of u coansi. is type and an Ount P
. Lfl t
. P123’
‘4
Other a5
MIusllansous
OsducUses
28
TOtP
Itemized
I ‘1 me amour n Ferns 1040. line 32. is St00.000 or less 550.000 or
li ii Ii fTtII ‘ihng sioarateiy,. aca ,nej4. a. 2. 6. 17. 8. 24. ama
25. Enter me taa flee.
DeductIons
For P .,m R
• If tie amount . in Ferns 1040. line 32. i i more tram 5100.000 more man
550.000 ii mamea filing separste.y,. see gag. 42 Icr me amount to enteI
C flre Be si#e a saw an Fonrr 1040. lane 34. the LARGER of me
amount on sine 21 aoove or your etanwa aeotjceon.
,o—ea ces NoS. . see Form 1040 es 5sicsore,. C ii. Ns.1a110 SCIISSIS
A (Foes 1045 1551
S
•imsii wawn ci’ ‘orm Q1Q
Int•rsat
You Peid
See
zags .39.1
. 5 . 5 ;
Iteresi ‘5
-o ionqer
:saucvole.
Giftato
(See
oaqi 40.1
-------
fO ilII MG ‘ — -
•111 1 mown c ’ p- ’— . C -:‘ re ’ -aie ic i .a. soc::. • .:r • C :r :
:- - O ’.a i 2
ur lociw S .ci ny n,mi
Schedule 6—4nterest and Dividend Income
?art i you recan,ig mars inert $400 in azaci. interest income. or you are claiming in. SICiU$ion o untsfw ft’oni
• sines £2 U.S. savings oonas issues after 1989 is.. caqi 43). you muss corniness Patti. Lit AU. n ,erest r.cii e
ri Putt L I I you received more u , ti , taut income, you must aiso ccmor.t. Pun ill, it you rsce, so .
icome ‘ iiy tisiongs to anouisr person. or you receivea or card accrues interest on sscwiuee
trinst bstwcan interust naymens dates. see nags 4$.
- - erest income
. 0 -3
Note: it ‘ou
•cei eo a iCr .
:99-tNT Farm
• 99-OiO. or
:uasiriute
raisnTleflt. rom
i crowerecs rim,.
Si TI ’S rim, s
- arne as ire
:aver ma emit
-e ‘otat ‘merest
:owr’ on ai
: n
I Interest •rtCOtT le. L3t r tre ci :avsr—’ any interest r me s m
Sefler1inanCea mortgages. tee instrtjczona a s i a ‘ii i mis inten.sl tir 5t.t
4iov c -
2 me ugj n line 1
3 Enter me exciucacie savings cena interest. it any. rrom Form 8815. ‘ne i.
Attacrt Porn, 8815 to Form 1040
4 Subuaci tine 3 from rune 2. Enter ire resuit here asia on Form t040. I.ne as.
I
3
4 2.71t
Pert II If you rs. .mr.iu titers thin $400 Ii es C -.Jends soWer other disthbusons on stocit. you muss ou stp.
Olvidend IlL if you ru . r,1d, ass num.nso. dn , .dinJI that semolly belong to snout., person, is cage 43 .
Income 3iv,aena income
5 Oivuøena “come. Lit name of oayv—nciuas on this liflI caaital gain
:age. IS OlSUIOuVOfll. flOfltaxaOll aISmDUtiOtIs. 5IC.3 P ________________
r a 4.3
Not.’ it vO
cuiveo a i rrn - _____________________
: g -oiv : ‘ .. .. . ... 3
. .:siitute
‘r:m
a :ronereoe
• ‘ i i .st tt ’e
rmsnameas
, caver ma
7i tSf tfli 10111 ____________________
:vainas
i iOWfl on Inst
:rm S AddtiulSarnOuiU$oflkfl,5 5 ____________
7 t’ 1 smmaon., Emit riere asia on Sctiecuie 0’ ‘
S NCiItoItetS ;. “injolte . See ins inst. tar Form I040 line 9.). •
9 A4d 1.’sslana8 . . . . . 9 I
10 Sub 1ctbne9f,omIln,6.Entermeresu Ith,tsandaflFotTn1040.hne9 . . 101
‘If you recmves eap ara gain assrnbuuons cur an not neea Scnecwe 0 to ‘soon any amer gins “losses,
see tire instructions for Fonrr 1040. lines 13 ann 14
Pan Ill If you ruosvs4 m thin $400 of interest or dividends . OR if you lead $ lorerga account or weiss I ‘, 5 No
F of. or a t.anat.eer to. a foreign oust. you must both questions in sn Ill .
ACCui Uflt$ iia ...,y time. iring 1991. cr0 you nave an interest in or a uigrature or amer aumcnw Over a rinarrcraI
and account in foreign country tsucn as a oars account. securities account. cr ::ner —
Fo i si n ac fl?J? f . oage 4$ for excsoaons aria filing reauuemente for Form TD F 90-22.’ I _______
b If Ves. ems me name of thi foreign countrY
See 12 Were you vie grantor of. or transferor to. a foreign trust mat caruso outing 1991. vnetnsr or ai
cage you nave any oenenctai interest in f Yes, you may nave to ne Form 3520. 2520-a or 926
For PS..&. - .15 A ’ i Act us Porn. 1040 Insvvciasst. i — ScItSliiS S (FOrnI 1040 , 1551
-------
SCHEDULE C i Profit or Loss From Business :“e No
1 Forns 1040) (Sole Preun.eo,vvm ©91
, ain ov r I t?a avnsnf
ParUie.V. a jamt venUtrus. etc.. must fill Form 1085.
- a .‘iva ci 0 Atfecj to Form 1040 or Form 1041. See Insanaclonu ic r Scftedi e C (Penn 1040). 09
.ame ot orie er Sociu ..._
r.
ousinses or profession. unciucina prOCUCI Ot service ‘see iflStFUCtlOflSi 8 Enter cnnczoai ousiness ccce
. e.. itrOnt oaqs lP .i 55 3
C u 5lfless nan e 0 t c 10 manser INSt SSN)
I •
E
usiness aaaress iinctuainq suits or roam no.j s .. . C 9 4A iri.
C.tv. town or cost dud. stats. ana ZIP coos M V’ (’C
F .lcccuminq memoa (1) L.. Cain (Z’Accn al (3)U OtIWIsa .cif ii
G MetitOdill usea to — of cost Other attacn — 0cm not aooiy if
aiue ciosinq invemary (1) L Cost (Z M or meritsi (3) ezoestavoni (4) U cnec*ea. SkID tine Pt) I V I II No
H dial mere any cnanqe in determining quainmas. costa. or valuanons ti1thi ooeninq ana closing uivssnorp? (II •Vet actacit exciananont .
I Cid you malsnauy a stoats in me ogersuan of thiS surmise curing (If ,
J I ms is me itrat S eaw. C tHea for mis Dusinou. cneca he’S
I TU Incom.
I Gross recetots or saiss. Causiosie i i?,!,! income w ru otteO ro ‘ e cu an Farm W.2 and tie
!tanjrarv emc,ayse cc i on mar fann wee see rite ,nsmiceerts one aiou netet Z,2 40 .22.!,
2 etums ana allowances . . . . 2
3 Subtract tine 2 from line’ . . . 3 L 1 .UO .ZZ
4 C stotgooassolaIfromuine4OonoaqsZ :
5 SubtraCt line 4 from bite 3 ins enter me grass icM rote. 5 ‘ ( t q
S Outer income. incftiomg Federsi ma state gasomns or fuet tax crecit Cr refund see sissuctores. ‘
I
7 Add lines S aria 6. ThIs us yasir gives . ‘ y j Ll 2, 5 I
•t m l. Expenses lCaution: Enter expenses for business use of your home on line 30.1
• Advertising L±. — 21 Re awu 1W metmeresice. . 21 I . I’2.S
9 Bddeemfvumsalssor I . I Suo04nnstmcluced lnPvtlIl). I IU5IS ’
see cisuucuonsl. . — ss tiaSs IN hansel 23 I 2
10 Car ana tnj exoemes see
I 24 TraveL meals, and smsrtsttment I
ristructt ons—eisO anacit
Form sea. . . .JL 27-’ a Travet 2411 4 I(OI I
11 Commissions aria fees. Lii_ I i
bMs uiws I
12 Ceotetion. . .J!. I
t3 eorectauon ma section I 9 I
oenseae aucuonInotunc luaeain — I CE1 l Iu,ZO%ltIS
:3n till isee 13 q, i ‘ : I
ues
14 motovee consul grograms • d SuOtract hi ’s 24c trom urns 240
tester man on line 19).
IS tnsuJw s lester V 1 neaivu) 15 ‘ g, oq 21 IJtjhtJIS
. .... . :
a Mortgage toast to sees. SIC.) . 141) ala outer saneness iset ttee aol I..mml)
b Other j ) Z2..1 ’1 J
17 Legal ane arofausIN seviess . I L , %1 & I I
18 Offlceexoense Ii (. 1 2.g
19 ‘ension aria orolltlnannq . ::::::::::::::::::::::
J
20 Rent or ease SN untru onsa: I I
a VelliUl!. mamess. ate eennes
o Other cusinesl ..
- -
25 . ia asraunne in cdIuflV ’ is for lines 8 Imougil 2Th . These are ‘tour tetsi ue neu oilers exoenses for £. U, !.,U3
.lSlflS$$ Ull Of your non ,.
29 ‘ntauv. atoM dossi. Subtract line 28 from ,in i - as i . 2.C9
30 erlses for øusuicsa use of vow name laftacO Poem - . i as i
31 1 grills or (10511 $uOT?lct tine 30 from line 39. If a orofe. enter’ item 1W on Form 1040. bite 12. Also
ser me net cram on Schsøuue SE. kite 2 (sta tory employees. see inssu000ns$ ii a iou, you MUST I
on to ne 32 Utduciwes. see insstJcSefl$ 5 I 31 I
32 ,ounaveaio ss.youMUSTc l ’ecN t i tebOxmltde$Cn aesyourinvestm sntil lmilaC t iv%tvI SeIiflsrn lCVOnSI - • l32.a Al aatnix
f yOU C! ’ SCKSO 321. Sitter Ills 1013 on Form 1040. lIne 12. ins Schedule 55. line 3 (stxsooiv I 3 L Soils . .wu o An it flu
mouovees. see iflsstictzonsl. it you citecase 320. you MUST autaci Form eias.
.
For Ploerweis Redurtlori Act NuU s . see PeniS 1040 Nssotsteons.
C* N 113319
ScIieSls C (Farm 1O 0 ) 1981
-------
:eoui. C F fM C40 1 ‘ 9t
:.. 2
Agncuiturai Services,
Foresuy, Fishing
• 390 Ae”si w ’cst oulur uuss
33 Cr ossivices
3 Fame ‘aw 6
:stvcss
248 Fjnin . c mneu ia
- ::e F rest,v s csG1 OQ nQ
• :2 l-,mc* rn,s 6 anascaotnq
- .69 l . ninq 6 uruoDung
376 L.sslocsg..l .q
538 L q9nq
‘56 ie’enieatu torsuss. irmuoma outs
Finance. Insurance. &
Related Services
4084 Broululs 4 a... . sm.mus
4080 C. av ’ .av canitacts ororuti &
O slL M .WflY 4
5148 CrieS itootmoito a Mat19191
5703 tnutj ius
57M Im.touius .us —
comi . . .. - -
5130 lm. . . .....I* ut . a . . .. s
571? 00w il ...
Manufac n1iiq, Inc luding
P,l. 1 1*ng 8 PublIshing
77’,
2879 Aoosul & oeesr tuseos otesicus
• 13 Escoc 4 smiusvuse 6155
073 soncatse miss asmucu
:638 Foie c’oSiCts 6 o. cuqu
8 10 Futnuiuts & luidii$
I S I S I.U0W . .UI ... . iou. I “
63 1 Lumow&oDmV OeO ’eoucu
C99 Mi...t.. , 4 msmewou woos
877 °sor 4 aiIeS arosicus
337 .imrr msqaj i i
IS? ‘ ?Wt9 4 OuOieWq
32 Stems. c av. 4 q’cu oto cou
683 T•stis mis otos
583 cm. mwusacs5q nm ess
Suululnq. 6 G .8un 3i i
£416 Buiidino massus. c. .u,s
.1457 iiarawu,. status
1473 Nursinsi 4 9410il1 JO0IY starU
£432 Pam quasi. 6 — v siorus
I FoeS a
2612 9aucsn . siuuweq
3088 Caismnq soumcss
3095 Onruiweq ouasu icuti. tavittli.
:Jos. saioems. stc.i
!079 Eatueo o’acsi. meos a sn ss
2 0 Grocers stores ‘q.wut isto,
...51 L uOr 5tO,s5
.236 Soecuaiizsa ‘000 stares imuit
.:oauci callow resim lao s. lc u
F,gnmro a Gonuss Meicasusus
3988 Comaurni a s..s.. stat ,.
3970 F•jrninjrs status
£317 4am, lunhiunqssta,esudnln 5.
float cov,v atss.
.1119 I.4sissi se loosuics stems
4333 Mucic 4 nose slams
3996 1V aucia a statuS
3715 Vanity stons
3731 OIlier geitoru status
• r::- --....ou sos $Mr ,s
.1312 Boat a.
5017 Boos states. escejoni IWu .i1U 10 5
i 53 Cam , s a wow susmy states
I 3271 Dtt stone
5058 Fa nc 4 ne s stones
1655 orists
I 5090 Fuil ouow isicuos qasatuns’
1639 Gift. nowsity 6 sauvw WOOS
.533 Il000v toy a gin ’s woos
137? .0wy state S
• 1895 LuOqags 4 4W1at qooos status
1074 MOat’s r ’at”S diajull
879 Cotcat goom. stems
1837 Soamung gooo. 6 oic ts woos
‘5033 Staiiatwv states
I .1314 USeS 4 v u status
sicus motor .siiei gaitsi
5864 0015 r ,t sos ,.
Tilde. Wha lssal—SellInq
Goods to Other Iussaews. etc.
aesss Oo — Iei ismq ISSji. . . . . ,
I iwuos. WOOS. use.
2834 Agem at o0w IVITIS —
mow mu, 90% W
O il C0...” ’
2818 Ssiweq ‘or ,ous
Nu, coSM ir Wosag Food.
Flaw. cmsiisc a
2815 Agent at om. ton ovw firms.—
—one ti ’ 50% us gross uiss
omcommlsao ’
2659 Ssuw’q ion c m ’ accaunt
flansportaVofl Services
8619 Ar soamu t
6312 Bus 6 naua1 ’ s wenwoitat,o ,,
8381 qnss, OOassiw I’.-. . iatus
.e drans’sS sirscsi
6111 Taacass
• 6833 T’ vsi ogorits 4 aesrators
6338 T cuueq s.csct iraum colluctiam
655? What ,ransoon at ’
6650 Ott ’. uir ’soattaoat ’ wvcis
MM Linuow la cia&e
i iiuiIi Cost of Goods Sold (See ansrnjcrzcns.
33 r.vsntoiv at oegirtninq of year. ill d 1 ff . tram ass years ciosing invemorv. attacri
34 .jrcrase eu cost of items wonarawn tot ersonai use. . . . .
35 : st of labor, tOo not menace saiavv oa ’a to vourself.l
35 suooues
37 C her costs .
33 -aa iunes 33 tftrougn 37.
39 inventory at end at yew. .
£0 Cost of goods sold. Subtract ire 39 from me 38 E’.ter trio resuut riere aria r , :aae 1
exoias,avon,
re 4
33
34
-‘ ‘C O
I (n 3O
33
38
22 010
Z 2 ”
3 i
39 I
2, I4 , C r
(.4 Q ’L,tci D
so
41,
• j a j Y Ptinci aI Business or Professional ACtIVItY Codes
.. cate me ma or category tnai ossi aescroes your activity Wminurt ins major cateqory. sated iris activiiv coca mat most cicssuv uaenuhtes trie
2uSlflSSS 0? orotesalo’s 11111 II Vie onticu SCItCs Of VOUV saiis Or recowus. Enter d os 4 ’dlgut cods on oaqs I • ins & For ezamos. isa esorie
jqen t is uncor me major carsgavy of ‘Rs £state. aria ins coae is 5520. - tNotus d your anncscai source at income is rmm Ta int ing acavives. you
:ioujo fits Schsauls F (Farm 1040k Profit or L . o33 From
1582 Od&gas 7260 PuDh riiiti 5
11719 Quwflirq 4 naluflhluIc niiwiq 6 UdtcWstUIatising
5730 Teaenmnq or tutoring
Heal Estat. 8510 Trwi simiU am ’ oumu
5538 Oos,uta ii & lessats of ouloalge. 6592 UtilitIes icumos. wa . .c .o.. . . .
nesting nssaeemms , . . clu .wIq .
5553 Oosstors 6 ‘essats of omsr nest 7500 OIlier ousuisu services
ore . .iv I 6882 01115 oursatlu swvcis
5520 Pea estate agelts 4 0 ,05515 _____
5579 Pist sst ts . JO1 W meniguls I St IS & 0 11w LoQgm9 Places
5710 Sucemicow 6 oi. ucsts . 4 5CM. I 7231 Camos a caim.nq cuss
7096 HOtues. motos 6 lounsl Fames
4155 rI !. salvos 011,081 7211 Pooming 6 aoa,oriq reuses
Ljig & CI aq 5...... .
7450 Cirost 4 uoitollsiv cisuong
7119. Coui-ecsiulsu lamonis 4 Orf
c ’s — mo
_______ 7435 FuiI-s wicS Iaurorv. cry cmsuimq. i
& qanvicu winos
7476 Jaretoms 4 rescue
Dm iq . natas. 4 . . .
£ Hsaui
9374 CI1 .w. 1U..
_____ 9233 Osnsc’s allIes or cisc
______ 9317 Oocters tPA.0) olIves or curse
____________ 9456 MoseS & Isis- i.0 . ..w . .
9472 laasrq & eatw cars taceouss
9290 0 ..wai.uieu
9238 OsteceaUlis aIviousm 4 suiqism
9241 PoøiOSM
9415 Raq4Ia..u 4 oracocs nurses
9431 Oncus a csimos of amer meant
WL .u . __ .
1110Ie 55. l Oi s - I 0WO-04J4t5
3888 01 11w fleeS? ssivcss
MiucuNsluous meow. l
Cots-mow
9019 AuS ’ s smesmeni a TV ‘sow
______ 9035 Cows - a eauaornere
stow & TV
_______ 9080 F ,rmmai ‘sow & im . . .
2881 001w urns-nile now
_____________________ Services: Personal.
Consvuctton Professional, & Business
1I C:ereows Ouuioufs itat own Services
accasiti • Ms-unities & AsowabseeS $an....s
Gealdsg 7MM Co..VSLL . . . . IieSiq 9670 Sos-eq centers
9688 Mason o’ow. 4 ties ainusition
______ ____ I & uiisSsomlc s S
0411 Caio....... 5 4 NO.... , I Mass? as-a, 4 vials ____
iS5 Corecruis woels _____
0213 C . .uiicl wale I oucsae U ’ sat . _________
0299 Mawv . aty weS. stars. & fits 6557 noises tows.
3237 Puituig 6 ChOW flai t • 9698 P’ute..-,n sas. 4 receig.
3232 P’unes?g. nsoseq. & ill cori#Il ., resting . . . s a managem
0430 Pooling. tiøirig 9811 fli . _____
0865 0 0 w aulwng its. . .. wre a us . otuoucem & ninatso ______
elcavstlon. qiaca5. stcj
Cells - CesiVuCIele 19813 Vs-S tiCS vu’s-
075 M.Otiwsv 4 sliest CatisoiJCssii I37 01115 iillt ilSfTIifIt 6 recteitlvMi ______
:059 NOrrSsIO* IIIS oumlalnq I S s iV cS 5
:334 s- I Sass-es
• 359 C:mer “sew COIlStlIIes-I 0i 5 9813 AulinoOve venus or iewig.
lying. onoge consmacoote eic.Il eiusa anew
6153 Autatiloave now.. gesu &
8039 Penning. sicest vs.
8898 00 ’ . agornoave winces waste.
I to __ __
______ I
I 7655 *ccosiwq & ban riq
I 7718 Ad..-.., . sacues owes
7662 Itatisseors W i v es. ___________
_____ 8318 esow was ion ouwn
____________ 8110 Busmy woe tat s—’ ”e flsds. Retail—Seeing
____ 8114 C ’S ’S Goods to Individuals &
_____ 6818 Cwonumcatiw wivess _______
7072 Counuut . .iu.. . ...q. Households
ohs iscuowi 4
ins-S wvces 3035 C mel aew
cati ’ uo . s-er, & 3013 SeIimg sew’s seat. ev L.-Ru’s
0? ostii or troll . mouse is’s
______ ____ 3053 yenatig 1e..... . es-eq
Corisia” . meos . . .....-g a FVSIII 3b.. .O 5ISII . 5 1 1 1w.
_____ • 3I.rf services otis., FMd
Cons-wig 1 . —sr 11555?
o veemamuiu l A. el&P 1aS
__ CaaorowaQs o o uv.y 3921
_____ ______ CillatelliTIss sqwoius 4 utl iers tat ws?i5l ?
o.. _ ..... , sisooty 3939 ctcStilq. tor .r
____ I, .n..nrq ass-iS 3772 CiOming. mane 4 oo,t
Eauion ’em rents & leasing 3913 Crameig. women 5
I i es comas. on autamotivet I sj os s..
15533 Cus- 5 WiCSS 4 crerniisi’us - 3334 OU iw soowa 4 L—’ ’V stamsu
• I 7833 Its-ni atuasuis- a Sits .
‘914 Inveucqwe 4 onoluCtis’s sees-is _____
7811 Lags sews-S Or ‘hWWfl 3553 Gisasis somcs . .. . . . .i’I
‘7358 Ms-iq. ,uorasacflal. cuinm.soms$ 3319 P4 5w car ass. ifruosesuit
art, 4 3333 Trig. . -‘- - -— uL LouIs
I U5OS Cat
‘243 Ma. . ,.... u lI sews. I 3517 0111w as-is-us owes
I 5771 as-ins I i.ii.. __ atss . ....
5334 PIiu ,j, , .. . ( . s?UsoS I v55at satj I
Mining & Mineral Extraction
‘537 Cam ‘swig
I I I Yuisneiwig
.us. I eII4 .aus. ’?m
-------
Who Must File Schedule SE
You must file Scheøule SE if:
• Your net earnings (mm self-emoloymenr (mm other man churcn empio ye. income dine 4 of Short Schedule SE c
line ‘ I C of Long Schecule SE) were $400 or more: OR
• You nac church employee income (as defined in the instn.icvonsj of $108.28 or more:
ANO
• Your wages (and tips) subiect to social security AND Medicare tax (or railroad retirement tax were less than
5125.000.
Exception: If your only self-employment income was from earnings as a minister. member of a religious order. or
Christian Science practitioner. AND you filed Form 4311 and received IRS aoproval not to be taxed on
those earnings, 00 NOT file Schedule SE. Instead. wnte ‘Exempt—Form 438V on Form 1040, line 47.
Note: Most people can use Short Schedule SE on this page. But you may have to use Long Schedule SE on the back.
Who MUST Us. Long Schedule SE (Section B)
You must us. Long Schedule SE if ANY of the following apply
• You received wages or tips and the total of all of your wages (and tips) Sub;eCt to social security. Medicare. or
railroad retirement tax plus your net earnings from self-employment is more than 553.400:
• You use either op1lonal method to figure your net earnings from self-employment (see Section 8. Part II. aria
the instructions);
• You are a minister. member of a religious order. or Christian Science practitioner and you received IRS approvat
(by filing Form 4381) not to be taxed on your earnings from these sources, but you owe seif-emoloyment tax on
other earnings;
• You had church employee income of $108.28 or more that was reported to you on Form W-2: OR
• You received tips sub;ect to social security, Medicare. or railroad retirement tax, but you did not report
those tips to your employer.
Section A—Short Schedul. SE (Read above to see if you must use Long Schedule SE on me back (Section 8).
I ‘4et farm profit or (iosai from Schedule F (Form 1040). line 37. aiio farm parmuarnos. Sctteauie
(.1 Form 1065%. line I 5a. . . . . . .
2 Net profit or (loss) from Scliedule C (Form 10401. line 31. and Schedule i(.I (Form 1065). us
ISa (other than farming ). See inamictians for other income to report
3 Ccrnbires lines I and 2
4 Net e.m... from seif-s..,.1 1 rnent . Multiply line 3 Dy .9235. If less tiwi $400. do not file
this scriedulr you do not owe self-employment tax, Caudon: If you re d wi ot uPS, and
Uie total of our w r t 3) start no social s.ciail$ Ms te, or . &bvad iewurnent tax
plus the amount on line 4 is more than $53,400. you caiv t use Short Schedule SE In ”+4
use Long Sch ciale SE on me ba r
5 Self.i.mpieylt at teL If the anotatt on line 4 a:
• , x, multiply line 4 tiy 15.3% ( t’t%remJlL
• Mo tnan t400. but less in i ’23 mumply the am nt in e eu of $53,400 by
2.9% (.029) id $8,170.20 to the result S enter the total.
• 5125.000 or iore, enter 510.248.60.
Mso enter mis amount on Form 1040. lIne 47
Note: Also enter one f ‘ elf of rh amount from line 5 on Farm 1040. Lèlr. 25 .
SCHEDULE SE
(Form 1040)
w
01
SelfEmployment Tax
P See Inseticlons for Schedule U (For ,, 10401
P AtfaplitoForot 1040.
iame or carson with it iu i.. 1 uusis income as snown on Form I 04( i Socisi seoumv numoer or cemon i
with ssd-&..,luyn* income .
j MS No.
Si No 17
I
2l Z
4 .2 S
: 5 1
For PlU&.....1I Peo’ ’vi Act Nailos . so Fomi 1010 lesthacOcew.
C N il3SIZ
Scflee. 51 (Yarn i04 111
-------
ci es s SE Fomi IC4O 1991 ttacrni . . ecu.nce Fiio 17
i nie or oerson wiin 51 t-4.u ..,,m... 1 income as siiown On 10f!TT 10401 Sociat secunrv ilumoer 07 oerson
Huh satt-smotoWnent income
Section B—&.ong Schsdul SE (Before completing, see if you can use Short Schecuie SE on ne omer s,ae
(Section Afl
A If you are a minister. memoer of a religious oroer or Chnsvan Science practitioner. ANO you filea Form 4381. but you
ac 5400 or more of other nez earnings from seif-emotoyment. cr ecic nere aria continue with Plrt I. P
B If “our criiv income suoject to soif-emotoyment tax is criurcn emooyee income ana you are not a minister or a member
or a reuigious oroer, skiD hnes 1 throuqn 4b. Enter -0- on iine 4c aria go to line a.
. m.i Sefl-Emolovm.nt Tax
Net farm oront or ilossi from Scheauie F (Form 10401. line 37. and faiTh parmersntos. Sctiecuge
K-I IForm 1065). line 15a. tNo Skip this line if you use the farm optional merrioa. See
reQuirements in Pefl II below and in rho inso’ucvcnsj
Net Pratt or tioss) from Scheaule C (Form 10401. line 31. aria Scheaule K-i (Form 1065). line
1 5a (other man farming). See insmicuons for other income to report. (Note: 5kb this line if you
use rile noniamv optional method. See repuiremenrs in Pair II below and in tire insa’ cvans
Comoine lines 1 aria 2
If line 3 is mote than zero. multiply line 3 by .9235. Otherwise. enter the amount from line 3 here
If you euectea one or born of the optional mernoos, enter me total of lines 17 and 19 here
Comaine uriS 40 Orid 4b. If tess than $400. do not file 1hu screaule: you do not owe SeIf-etnoloyment
ax. iEx .ouare If less man $400 ana you r’aa churcn emoioyee income, enter -0- ana continue., P
Enter your criurtin emouoyee income trom Fon’n W-2. Caudom See
na instructions i cr aennman oi cnwcn employee income . . . . ‘ I
Multi iy line Sa by .9235. (II less man $100. enter -0-.) Sb I
Nes earnaigs from us$f-smp*oyin.nt . Add lines 40 and 5b .
Maximum amount of combined wages and se f-emoIoymsnt earnings subject to social security
tax or ins 6.2% portion or the 7.65% railroad retirement (tier 1) tax for 1991.
Total social security wages and tips (from Form(s) W-2) and railroad
retirement (liar I) compensation
Unreported tips subject to social security tax (front Form 4137.
line 9) or railroad retirement (tier 1) tax
Add lines So and 8b.
Subtract line Sc from line 7. If zero or tess, enter -0- here arid on line 10 and go to line 12a P
Multiply the smallsr of line 6 or tine 9 by 12.4% (.124)
Maximum amount of comotned wages and sod-employment earnings subject to Medicare tax
or me 1.45% portion of me 7.65% raiiroaa retirement ttier 1) tax for 1991. . .
Total Mecicare wages aria tips ifrtim Formisj W-2) and railroad
etirement (tier I) comoensatiori. . 12i
(Jrlreoortea tips suo ecr to Medicare tax ufrom Form 4137. line 141 or
ailroaa retirement mar ip tax 12b 1
Add lines l2aana 12b .
Subtract line 12c from line 11. If zero or lees, enter 0- here and on line 14 otto go to line 15
Multiply me small of line 6 at hne 13 by 2.9% (.0291
Sslf-.mpkWm.1* teL Add lines 10 ar Id 14. Enter me result here and on Form 1040. line 47
Note Also enter one-half of the amount from line 15 on Fomr 1 11 1w .
: .. 2
I
2
31
I
441
I
•
4b1
l
7 I
:
1801
—
191
ilol
. I
J ____
13
.
14
:
15 ’
- Optian Methods To Fgw. Net Earnings (See “ Who Can File Schedule Sr and “Optional Methoas” in
the instiucttansj
Farm. Op onal Method. u may uss the farm optianai method only if (a) ‘vbur gtoss farm tncomo was not more man 52,400 or
(b) Your gross farm inlOlll& wee mote thai 52.400 and you net faint wu u4il$ ’ Wail less thai Si .733.
16 Maximum incorneforopspn lmu p Jie I s:. ooI ‘
17 Enter me smaller of: two-miros ½) of gross farm income or 51.600. Ales include titis amount
on line 4b above . . 17 I I
Nonharm Optional Methoc You may use true nanfarm optional method only if (a) Your net nonfarm profits were uses iran 51.733
aria ajsoiess lnasi 72.189’ ofyauossnonfa,m,ncoffle’afl (b)’rbuhadnuISEeamIflg5ofatleaStSdOOfl2oltheCrTCr3
years. Cautioni n.. may L ‘the 110111 epeori. ’ method no mars than five times.
18 Subtrzci me amount line 17, f any. from’ ii 16 arid enter the result 118 I
19 Enter ire smaller of: va-muds ) of gras.. nonfam’i income’ or the amount on line 1& Also I
neluce iris amount on line 4b acove . . i 19
From cI1e ijie F iForm 10401. tillS It a sia Sclieauls K.l (FOrni 1065 ). lire 150. ‘From Scflsatius C (Form 10401. one 31. ass S isouis ‘i mm ‘0651. InS 15a.
From Scilsoije F iFonn 10401. lire 37 ass $cJleSijIs .I Form t0651. line I Sa. ‘From Sdiesuat C Fcrm 10401. lire?. isle Scfleaujo u’i iFou ‘0651 line 15c .
1
2
3
4.
b
C
5a
b
6
7
80
b
C
9
10
11
12a
b
C
13
14
IS
•i & ,•i’Ga$5,IsI
-------
SCHEDULE E
Form 1040)
- i.,i. IvuI aarvcei 3 )
•.aM ii StlOwfl On
Supplemental Income and Loss
(From rums, royui ss. parv.erunms, s.tatic VUIII, MEMIC. e;c.j
Al el, Form 1040 or Farm lOSI.
6 1e lnsvucuuis for 5dIsdl s S (Form i04 .
••‘lI ’io 1 .4O74
I ___
: m_meNO . 13
dOW IS
t ,smau Income or Loss From p i yaltas 4ts , eoo,y ram, ‘ enter income Or ‘ CU rrcm corn, 4435 on oaee a . . ‘l J3•
I I Show in. inc asia ocaoon or aacn rental otooeri 2 For eacn remas orocertv .steo cr1 YSS, NO
Al ne 1 oi you or your raimv use
t f OQf5Ofl l ourooses ; r rore A
:nan me greater or cavs or
SI 0% of me aavs rentea at
‘air rental value outing ire !ax
C: veer? (See instrucvQn5j
c
______ Proparuis
Rental and Royalty tncorns A S c & . n. c. .
3 Rents received. . 3 I , 2 7 I 3
4 Rovalbesreceiy40 I 4
Remal and Royalty Expenust
5 Aavertising
8 3 ut0 asia travei
7 Ceaning asia maunenenee.
8 Comnvaaions
9 Ins jr rice .
10 Legal asia amer plafeUlOnul fe
11 Mortgage interest paia to banKs.
etc. (See insoucoorag .
12 Other int st . -
13 Pagan .
14 Sugoties.
IS Taxes.
IS LjtiliOeu
17 Wages aria sa avmes
15 amer (list) P
Deo,eaauon exoenesor drl$.lioq
(S5 nUUCUOItaI
21 Totil ezoenees Add lInes 19 and 20
22 income or !osu from rental or
roya y grocerese. SubDam ins 21
from line 3 Irenta) Cr line 4
rayaltleSI. It Ills luilit is I (bilL
us insoucoana find am if ycu•
must file Form 6195
19
20
- ao lines tnrotqm 15
3 ;
6 I
it
.
1
9
.
.
‘10
I
11
‘ I I a
I I I
.11 I I
. L Z5 •‘
i
I
151 i I
L I a
It I
151
L.I 2
I:’
A 2 . 4 0 I. I I
I I I
23i( hf If
23 Deductible rental bass. Cautirs
‘oui ren ter icss on tans 22 may as
•.miree. See in rjccons to find out
lyoumuszti l eFomi8W .
24 Income. Add rental eria royalty ‘ • ante from line 22. I’nor me mota income Piers
23 Louse. *00 royalty lilsi. fm.. ’ ‘e 22 aria renter cues from line 23. Enter me ‘otal losses liars
26 otal rentas asia royalty sicante or ui. Corroine lines 23 asia 25. E!ner the result here. It Parti II.
III. IV. ana line 39 on page 2 øø: it analy to you. enter me amount frcm line 26 an Form 1040.
‘ne 18. Otherwise. include me ati ouni from line 26 in me rots) on line 40 on cage 2
Ill I
///
/
•111
IrA .
19’
Ii
Scnseui.IlFom , ¶04011951
-------
: o’
acri’r” 4OL&Ce a,’, 3 to, 2
im.I, wow ” or jii Co rot iriv wo ccai ntjIrO ’ , wawn on otn iu c ei
ur IOCIS lIic4Ily raai
o,l you recoiv amoun rrem ‘aninna or nWmo on Scheains E yOU must enter scur arass inCOffiI U flP e acrivtr’es an tr 4
Income or Loss From Parmmrs1u i. and S Carpoii ons
iou reocry a loss erom an at-risk acvvitv. you MUST cheat eimer coiumn (el or (I) of line 2’ : cescrice your r,e ne y ire tree
Jvitv. tr “ truct ons. If VOIj cnecx coiumn (f’, you muse aetacre Form $198.
b u P ‘or ‘ tee Citam if ci €motovsr ii._
2 , laiN ., ,. :v o twinwS I :ejiie ticji ii sme .
t S CC ai.OAi - .r? Or .. - - 5
A
3’
C:
0l
E
Pessive lncem* slid
Nonoualve Income aria Loss
5) Pussy. Cu 115145 N p q -
iimm Fonn 18sl a ‘cums tmj t
(4 u) Sicusi ua.ns. , ,
‘am -l .. ur. : ‘n s i .i
A . i
!
at .
I
C:
DI I .
.
L_
281 Totais
bibtais
9 Add columns III) aria (Ii) f line 26a. Enter me total inCOffil lIStS 29
30 AØØ coiumns iqj, ci) . anu (j) of line 28b. Enter tile total here. . 30
31 Totai oarmersnio aria S coroorasan income or lo u ,. Comoane lines 29 aria 30. Enter me resuit
Mrs ann inctune in tee eatS an tine 40 tow . 31
1531 1 5111 Incum. or Loss From Estates and mists
14
: .. .-,.. ma
Al
II
C:
Pau. Income and Loss
Nono.uive Income ann Loss
( P or eu (8 Pius.. nwnu
ausm Foam Msl C’ssiweu . w’ , $sissm. a — I
IS Oec - or cu ill Oils “am
5c 1 ,.sm. a — i Scneu. a -i
Al
3
C:
333 Totais
bTota l s I
34 Add columns 10) and lfl of tine Enter ens total income rests 34 I
35 Add cotumna (C) and 1$ at tine 33b. Enter tree toesa tees. . I
38 Total ast.t aria ve ,ncwiie or COjDIJUDS snes 34 ann 35. Enter lee resuat nets and include I
in ti le CO rilinedO below . 3$ i
I53l PI Income or Loss From Mi 8 .551 . Maflgaes InvesSnent Conduits (REMICs Re duaI $o d1r
w anhisoler _ (5 T 1 15 1 Cu I (us ii i5 .am 15 Q
• — m $usQ .iire eu ,,
38 Comøire columns (01 ann Is) onty. Enter me risuit hers inn include in me total on brie 40 below 33 I
•5311W3 Summary
3$ list tame rental income or llou, from Form *t ’. (Aisn ‘omelets line 41 belOw.). .
40 TOTAL recome or Io u ,. Coniaine iines 26.31... 38. a 39. Enter ens reswt leers aria on Form
1040.l ,neI S . . _________________
41 Rec ncsliation of Faiiu.nq and FIsNnq In umL Erie. your juu i
‘arming ann fisleing income ‘eOorled in Part3 II 5110 III at . 1 , on line 391
eee IflSttUCtOflSI 41
____—
—
•g $ ‘,s’.ias•,si
-------
INDIViDUAL ABIIXFY TO PAY ANALYSTS
PHASE 1- 1040 WORXSH 1’ (1991)
L General
- 1. Applicant’s name I I ‘ ‘ I
2. County applicant lives in I icv s C v1+1
3. Site location I I rWord L_
- 4. Estimated cleanup cost I I i 1
5. Other parties involved L I - 1
U. Finairil Evaluation 1
A.Wagemcome I
6. Adjusted gross income
(Line 31 on tax form)
$ ç Lt 4
7. Number of people in household
(Line 6e on tax form)
ç
& Minimum income level for household size and county
(see Appendix A)
s 17, i
9. Income in excess of mminium
(subtractLine8fromLine6)
$ zco 1 7c 0 4
I B. Non-wage income
10. Check the box if applicant meets condition I
I’
12
13
14
Ls
[ 6
17
L8
L9
14
I I
IA
I I
I I
TI
14
I I
I a.Interestincomegreaterthan$400(Line8aand/or8bontaxform) I
I b. Dividend income greater than $400 (Line 9 on tax form) I
I c. Business income not zero (Line 12 on tax form) I
I d. Capital gain notzero (Line 13 on taxform) I
e. Capital gain distributions cit zero (Line 14 on tax form) I
I f. Other gains not zt ó Di 5 on tax ftsrm )
g. Rents, royalties, parthersLp , estates, trusts not zero (Line 18 on tax
form)
h. Farm income not zero (Line 19 on tax form)
-------
I
fiL 7base I
Dispoiinon chcc one)
j
10. — 11
T12
I
I
‘
__ ._4’
ii.
Line9isnegativeorzeroandnoboxesarecheckedunderLine
Applicant has no resources; further analysis not recommended.
12.
Line 9 is positive and/or boxes are checked under Line 10.
Phase II analysis recommended.
Date _________
-------
INDiVIDUAL ABaIrrY TO PAY ANALYSIS
PHASE II- 1040 WORKSHE F (1991)
Appli nt s fl2nI r [ t i —re
IL
1. Wage income
(Line 7 on tax form)
2. Taxable interest income
(Line 8a on tax form)
3. Tax-exempt interest income
(Line 8b on tax form)
4. Dividend income
(Line 9 on tax form)
S. Alimony received
(Line 11 on tax form)
6. Total ffiA distributions
(from tax form: if Lines 16a and 16b are both greater
than zero, enter the amount on 16a; if Line 16a is zero
and line 16b is positive, enter the value on Line 16b)
7. Total pensions and annuities
(from tax form: if Lines ha and 17b are both greater
than zero, enter the amount on 17a; if Line 17a is zero
and line hlb is positive, enter the value on Line llb)
& Total social security
(Line 21a on tax form)
9. Total war, in e.tment and retirement income
(addlincslthrougk8)
10. Business income or (loss)
(Line 12 on tax form)
11. Depletion
(Schedule C of tax form, Line 12)
12. Depreciation and/or amortization - .
(Schedule C of tax form, Line 13)
13. Total income or (loss) from rental properties or
royalties (Schedule E of tax form, Line 22)
I__s t’)4°1
$
2.,2-c C, I 12
Is
1
Is
•
1.
Is
çs
Is
I
Is
I
Is$
I
Is
I’ ,(c CoC ,
I
Is
Is
I
Is
4,ii
J
Is
l 4O
I
I ii
112
113
-------
J$Co o ii
I
S
I
I
S
1 .
s
1•
S
s 1
i4. Depreciation or aepieuon on rental property
(Schedule E of tax form, Line 20 total all properties)
15. Partnership/S corporation income or (loss)
(Schedule E of tax form, Line 31)
16. Estate and trust income or (loss)
(Schedule E of tax form, Line 36)
17. REMIC income or (loss)
(Schedule E of tax form, Line 38)
18. Farm rental income or (loss)
(Schedule E of tax form, Line 39)
19. Depreciation on farm rental property
(Form 4835, Line 13)
20. Farm income or (loss)
(Line 19 on tax form)
21. Depreciation on farm property
(Schedule F of tax form, Line 17)
fl. Total b’ .- ” and utjt income
(add Lines 10 through 21)
23. Capital gain or (loss)
(Lines 13 plus 14 on tax form)
24. Other gains or (losses)
(Line 15 on tax form)
25. Total_______ income
(add Un 23 and 24)
26. Total incnme
(add I Jn 9,22 and 25)
27. % wage, investment and retirement
income (divide Line 9 by Line 26;
multiply by 100)
28. % business and trust income
(divide Line 22 by Line 26;
multiply by 100)
29. i xtraordinary income
(db ide Line 25 by Line 26;
multiply by 100)
I
s I
S 44 ,M
. ! Ti p I I
122
123
I 24
125
I 26
I 27
128
I 29
ISç
I
Is
I
Is
I
Is )ccA
I
I
13
%I
I.
7 7!!J
I
%j
C-
-------
I Cash Flaw D sp . - tinn ( dcck one)
______ 40. Line 38 is positive. Applicant has awi1 ble cash
flow.
______ 41. Line 38 is negauve or zero. Applicant do • not
have available cash flow.
II
30.
Household size
(Line 6e on tax form)
31.
Median income for household
(use data in Appendix A)
size
and county
32.
Income ratio
(divide Line 26 by Line 31;
multiply
by 100)
IL Net Cash Fl ow
I
Is
]_
I
t72.
33. Total annual living expenses
(convert all expenses from Part II of Financial Data
Request form to annual values and sum)
34. Total annual debt payment
(Part II of Individual Financial Data Request form,
sum entries in section “B. Debt Payments”)
Is 4Z 4%(O
35. Cash flow
(subtract Line 33 from Line 26)
I
36. Cash flow
contingency
allowance percentage
(see income criteria
matrix)
37. Cash flow
(multiply
contingency
Line 33by
amount
Line 36)
30
31
I 32
1 33
I 34
1 35
I 36
137
138
I 39
14°
1 41
38. Available cash
flow (net of contingency)
(subtract
Line
37 from Line 35)
Is
1
Is
‘(., z3
I
I
‘
%I
I $
2,12.1
1.
Is
t4 °i
I
I
7
%I
39. % annual debt payment
(divide Line 34by Line
to annual
26; multiply
income
by 100)
I I.
I . .1
-------
I flLNetWorth I
42. Bank accounts
(Part III of Individual Financial
form, total from fiLl)
Data Request
43. Investments
(Part II I of Individual Financial
form, total from 111.2)
Data Request
44. Retirement funds and accounts
(Part III of Individual Financial
Data Request
form, total from 111.3)
45. Life insurance policies
(Part III of Individual Financial
Data Request
form, total from 111.4)
46. Vehicles
(Part III of Individual Financial
Data Request
form, total from 111.5)
47. Personal property
(Part III of Individual Financial
Data Request
form, total from 111.6)
48. Real estate
(Part III of Individual Financial
Data Request
form, total from 111.7)
49. Other assets
(Part ill of Individual Financial
Data Request
form, total from I lLS)
50. Total assets
•
(add Un ’ 42 through 49)
51. Credit cards and lines of credit
(Part III of Individual Financial
Data Request
form, total from 111.9)
52. Vehicle loans
(Part III of Individual Financial Data Request
form, total from 111.10)
[ 2.4 ,000
$
t7
Is
7 ccC
j
Is
I
Is
I
I S
7 2.i
I
Ls i’i,,oi 1 142
Z°cCO
Is . I
Is
148
I 49
I 50
I 51
[ 2
Is I
-------
11156
II
[ S 3,c z;
53. Furniture and household goods loans
(Part III of Individual Financial Data Request
form, total from 111.11)
54. Mortgages and real estate loans
(Part III of Individual Financial Data Request
form, total from 111.12)
55. Other debt
(Part III of Individual Financial Data Request
form, total from 111.13)
5& Total liabilities
(add 51 through 55)
57. Net worth
(subtract Line 56 from Line 50)
58. Applicant’s age
(Part I of Individual Financial Data Request form)
[ S 3Z 7c e,
$ IS..
Is
[ s o, oz
59. Employment Status
(Part I of Individual Financial Data Request Form)
I
4 yrL
60. Target Net Worth Ratio
(See Net Worth Criteria Matrix)
k 4-t ç o jcdI
I
I
58
L 6 0
161
62
61. Target Assets
(Divide Line 56 by Line 60)
62. Available Assets F
(subtract Line 61 from Line SO).
I
a _______
-------
II
Net Worth Dispc ition ( eh k one)
65. Applicant has cash resources in the amount of:
(Line 38)
66. Applicant has available assets in the amount oft
(Line 62)
IH
63. The applicant has available assets.
(if Line 62 is greater than 0)
64. The applicant does not have available assets.
(if Line 62 is less than or equal to 0)
W. Phase II Si.mmmy
63
164
165
166
67. % annual debt payment to annual income
(Line 39)
S t4 3
Is
j
‘7 %J
V
Date _______
Analyst
-------
APPLICA110N OF PHASE II RESULTS CRAF ER 6
The analyses using tax data performed in Chapters 3,4, and 5 produce estimates of an
applicant’s ability to pay, given their resources, age, household size and county of residence. At this
point in the analytical process, an analyst must determine how to use these results to make a final
determination concerning an applicant’s ability to pay. In this chapter, we summarize how users can
use the Phase U results, how to review applicant data and how IDNR might handle unusual or special
cases.
UNDERSTANDING THE PHASE U RESULTS
At the conclusion of the Phase II analysis, the user will have assessed the applicant’s cash
(low, and debt capacity. The set of potential outcomes is shown in Exhibit 6-1.
Exhibit 64
PHASE II ANALYSIS OUTCOMES
Available
Cash Flow Available
Yes
No
Yes
1
2
No
3
4
6-1
-------
The response to each outcome is discussed below.
Outcome Ii The applicant has available cash flow and available assets. Therefore,
the applicant can afford to contribute to UST coats. The user should,
however, examine the debt payment ratio to determine whether more
debt can be assumed. If the applicant’s debt payment ratio is less than
36%, then the applicant could pay LJST coat through additional debt.
Outcome 2: The applicant has insufficient cash flow but available assets. The
applicant may be able to contribute to UST costs through the sale of
assets, but not Out of annual income or additional debt.
Outcome 3: The applicant has available cash flow but does not have available
assets. Therefore, the applicant should be able to contribute to US?
costs through annual income, but not by sale of assets or assuming
more debt. The amount of annual payments can be estimated by
looking at the Phase II worksheet.’ 2
Outcome 4: The applicant has insufficient cash flow and does not have available
assets. This applicant is unable to pay any UST coats.
GOING BEYOND PHASE II RESULTS
Verification of Exoenses Assets and LIabIlIties
IDNR can be fairly certain that the income figures used in the Phase I and Phase II analyses
are accurate, given that they arc based on an applicant’s tax returns.’ 3 In general, however, the user
may be concerned that expenses and the value of assets and liabilities are not reported accurately.
We assume here that IDNR will not attempt to verify information reported on each applicant’s
Financial Data Request form. However, additional research may be warranted in instances in which
reported figures seem inappropriate. If adjustments to the data are made, the Phase II analysis can
be redone.
‘ 2 Linc 9 on the-Phase U 1O4OEZ worksheet, Line 17 on the Phase II 1040A worksheet and Line
38 on the Phase II 1O’ ) worksheet.
‘ With thc. ..xcep ius discus in C ipter 1.
6.2
-------
Part II of the Financial Data Request form asks applicants to detail their current living
expenses. In cases in which an applicant’s expenses are greater than or very close to his or her
income, a closer examination of these expenses may be appropriate. Appendix E contains the
Consumer Price Index measure of the average relative importance of typical urban household
expenses as of March, 1992.” Although we recognize that this index will not exactly mirror the
breakdown 0 f expenses in an average Iowa household, the measures may be helpful as rough
approximations. Note, for example, that the index allocates 17.7 percent of all household expenses
to “FOOd and Beverages”. A household with annual expenses of $17,735 (like AJ Leaks’) might
therefore be expected to spend about $3,139 each year on food and beverages.
Obviously this index will not match expenses noted in each ability to pay case that IDNR
reviews. However, it might help to highlight those expense claims that are significantly different from
the norm. In general, we recommend that IDNR review more closely the expenses of those cases
in which an applicant’s Phase II analysis shows very low available cash flow (Outcomes 2 and 4).
Assets and LiabliltIes
Applicants may also understate the estimated value of their assets on the Financial Data
Request form. Again, such instances may be difficult for staff to detect and evaluate. In general, we
recommend that IDNR take a closer look at those applicants who have a very low or negative net
worth (Outcomes 3 and 4). IDNR may want to compare the listed value of the applicant’s major
assets (e.g., their home, vehicles) against average values in the area. Contact the local or county
assessor s office for verification of property valucs or check newspaper listings for homes in the area.
Car values are also readily available from car dealerships or industry “blue books.’
Extenuatini Financial Circumstances
Section IV of the Financial Data Request form, and the General Information form ask that
applicants explain any renuating circumstances affecting their financial position. This information
must be considered in reaching a final determination on an applicant’s ability to pay. In completing
a Phase II analysis, note first whether the applicant has answered ‘yes’ to any of the nine questions
in Section IV of the Financial Data Request form. If all answers are negative, there is not a problem.
If one or more responses are “yes,’ check to see what additional information is provided. Use this
information to evaluate the analysis and outcome produced in the Phase II worksheet.
‘ The CPI detail report is published monthly and is available in the business section of moss
libraries. Note that the time period for CPI data may lag the time period for which you have tu
data. This should not have significant effect on its use as a tool to roughly calibrate key family
expens
‘ 5 Noie that younger applicants will generally tend to have fewer available assets than older
applicants. Younger applicants are likely to have greater liabilities (e.g. college loans, car bar’,
mortgages).
6.3
-------
Specifically, note whethec
• The applicant is currently involved in any legal actions or property
transactions. ft may not be possible to determine the applicant’s ability to pay
until a final settlement on these mactars has been reached.
• The applicant can document a legitimate increase in expenditures. For
example, the applicant may be able to identify anticipated medical
expenditures or expenditures for a dependent’s college education. IDNR will
have to judge whether such anticipated expenses should be deducted from an
applicant’s current resources in determining his or her contribution to UST
site COStS,
• The applicant has experienced finAnrial difficulty in the recent past. Has the
applicant declared bankruptcy within the past seven years? If so, perhaps
special attention should be paid to determine whether newly-acquired assets
should be considered as a resource for UST site costs.
• The applicant is currently experiencing financial difficulty. As we noted
earlier, high levels of debt compared to income often indicater that an
applicant is finnncially overextended. Other indicators to look for include
repossession of property or delinquency in payment of bills (e.g., utility or
debt payments). These applicants will experience difficulty in obtaining a loan
to cover UST site costs, and will probably have to pay a higher interest rate.
Long-term payment plans featuring small monthly contributions to UST site
costs may be a good alternative for these applicants.
IDNR will have to determine the extent to which these questions affect the applicant’s ability
to pay. In most instances, documentation supporting the individual’s fin*ncial circumstances should
be included with his or her Fin nciaI Data Request form. If this. information is not inclw 4 .i L IDNR
should request that an applicant provide further evidence supporting the claim that he or she is
unable to pay.
Sitnificaut Extraordinary or Ineatmeat Income
O c on lly IDNR may find that an individual has claimed signifle*nt gains or l’ u from
capital trmctlons (e.g., from the sale of stock, property, or other assets) or from investments (e.g.,
stock dMden inseza.s income). As noted in Chapter 1, we recommend that casri involving
extraordinary income gain or loss in eis of 20 percent of total income be reviewed by a
analyst. Capital losses often serve to signiflc ntIy reduce an individual’s mhle income, and for that
reason are sometimes incurred intentionally. Such Losses do not neccssaril r have a negative effect
on cash flow. Applicants cl2iming significant gains or loss should be more closely inspected.
-------
Currently Onerattut Business
The case of Russ T. Tank is one example of an applicant currently operating a sole
proprietorship. Assets and income from a sole proprietorship are often indistinguishable from the
assets and income of the applicant. In some cases, applicants may be overstating their business
expenses (as detailed in Schedule C) in order to reduce business income, and hence the income of
the applicant. Such occurrences are sometimes difficult to detect, and when found, can be difficult
to substantiate. In general, special attention is usually warranted if the business has incurred a loss,
or if business income is significantly below the industry standard. In these cas . note whether
business expenses (particularly those related to travel, entertainment, employee benefit programs,
officers’ salaries, pension and profit sharing plans) seem high in comparison to those of similar
businesses. These cases ma require additional evaluation by a finpncial anal it.
CONCLUSION
While we cannot predict circumstances for all IDNR applicants, in this chapter we have tried
to highlight case ’ that may merit closer attention. Some - - may require additional evaluation by
a financial anal t. However, we believe that the vast majority of IDNR’s individual ability to pay
cases can be resolved through the Phase I and Phase II analytical process described in this manuaL
The Phase I and Phase II process will also serve to highlight tho requiring additional
attention, and will lay the groundwork for suMequent analyses.
6.5
-------
Appendix A
FMHA ADJUSTED INCOME LIMITS
By Income level and household size for counties In lowu
(organized by district)
-------
I I* INSIIIUCIION 1944*. IJ$IIBlI C • j I N C 0 N I S. I H I I S - -
P R 0 8 H £ H $ PERSON 3 PERSON 3 PERSON 4 PERSON 5 PERSON I PERSON 7 PERSON I PERSOU•
51*11: IOWA
COUNIY $6 RUINA VISIA
VERY LOW INCOME 11150 12700 14300 $5900 11150 $0450 $9700 21000
SOW INCOME 1600 20350 22800 25410 27450 29500 11850 33600
N tRa1E INCOME 33300 25950 20400 aoeao 32150 35000 37050 31100
39 fl*R 11MM 13350 11210 17110 $1100 ao.oo 22150 23980 25200
oz o MI0I*NIMFN) 3350 11250 $7110 I l$00 20600 22150 23180 25200
C 0W4 1Y IA CHEROKEE
VERY LOW INCOME $0600 $3300 94150 16600 $1950 $1250 20600 21900
ION INCOME 10100 3 5250 23900 26150 20700 30000 33950 35050
50010*11 INCOME 34100 26750 38400 32050 34300 36300 30450 40550
39 7 1* 0 11PM $3150 $1.50 11150 19900 21100 23100 34100 26300
S0 OP N1D *NIM1N) $3950 $5150 11950 11909 30500 23100 34700 26300
COUNIV : IA ClAY
VERY ION INCOME 1S 150 02100 04300 $5900 $7150 $8450 $1700 21000
SOW INCOME $1100 30310 22100 21450 37450 21500 31550 33600
NOOUIV I IN ONE 33300 25050 20400 30950 32150 35000 37050 31100
38 V I I I VEIN $3350 $5280 11150 19100 30600 22150 23650 25200
SOS OP N10I*NINFNI 3350 $1350 11150 11100 20600 22110 23850 25200
COUNIW IA DICKINSON
VERY SOW INCOME $ 1150 12700 $4300 $5100 $1150 $0450 I ISO O 2 10th
LOW INCOME $1100 30350 32100 21450 21450 29500 31850 33 9th
5001 1*11 INCOME 23300 35050 20400 30150 32150 35000 31050 311th
30 VII I VEIN $3350 $5350 . 11050 19100 30600 22150 23650 2520.
60* OP MIDIANIMINI 1350 15150 $1150 $9100 20600 23150 23650 3520.
COUNlv - IA 111*
VERY SOW INCOME 11150 $2100 $4300 05100 11150 $0450 $1100 3100
ION INCOME $1000 20350 33100 25450 21450 31500 31550 33 9o.
I OERA1 INCOME 23300 35050 38400 30950 32150 35000 31050 3910.
39 VIAl 11MM $3350 $5280 17150 $1100 20600 22150 23650 2520
60* Of sIDIANIMVH$ $3350 11210 01010 01000 20600 22150 236 5 3520
COIA IIV : IA LYON
• VERY SOW INCOME $1150 53700 $4300 $5100 17150 10450 09100 2Iot
SOW INCOME 51000 30350 23900 25450 37450 31500 31550 3 . 1 1 W
SODIRAII INCOME 33300 35050 20400 30950 32950 35000 31050 3910
3$ VEAl 11MM 3350 05250 $1150 $1100 2060.0 22150 23 65 o 3520
60* OP MIOI*N INPI$I 03350 05350 $1180 $9100 20100 22150 23850 2520
C OUN IV IA MONONA
VERY SOW INCO’II 00010 2100 $4300 $5900 $7150 $8450 $9700 2100
LOW INCOME 01000 30350 22900 35450 37450 29500 30550 3360
P00 10*11 INCOME 33300 31010 20400 30950 32950 35000 31050 39 U)
30 YEAR 11MM 03350 11350 17150 11100 20600 22150 33650 2520
60* OP isfl$IANSMPNI 03350 05210 $1150 11100 20600 22150 23650 2520
DISTRICT I
-------
INNI INStrnjc,.OM $044-A. ERHISSI C
St*,t IOWA
‘0dUSt15INes , LIl l g
P I 0 0 R A N I PEPSIN 3 PINION I P1 150w 4 POISON S PINION S PINION 7 PERSON S 0 1 1 5DM.
IA 0 IRIEN
vE v SOW INClINE $1110 $2700 14300 $5900 17150 10450 loico 21000
ION INtONE $7000 20310 23100 25410 37410 20500 31550 33800
MOOtRAR INCOME 23300 35550 30400 30950 32910 35000 31050 3 I00
35 YEAR VEIN 13350 15200 $7150 $5100 30000 22150 33650 35300
801 OF NEOIApIINps $ $3350 15250 17110 igl o O 20100 22150 23030 25300
C(1l $P1Iy : IA OSCIDLA
VENT LOW INtONE SI $10 $2700 54200 $1100 $7 I SO $0450 9700 2 $000
LOW INCOME $7100 20350 22100 30410 27430 31100 31510 33800
MODERAtE INCOME 33300 25010 20100 30950 32010 35000 37050 33100
35 TEAR VEIN $3350 $1250 17110 $ 1 100 30000 33110 . 33050 25100
107. OF NIOIAN SNFH 5 $3300 $5210 $7150 U S$00 20500 32150 23050 25200
COIflI IY IA Pt YNOUTII
VERY LOW INCOME I $210 $2010 $4450 $0010 $7310 5000 $9100 21200
LOW INCOME ____ $1000 20110 23100 25700 27750 29000 31150 33100
MODERATE INCOME 23500 31050 25000 31200 33250 35300 37330 39400
30 YEAR TERN $3100 1400 17350 10310 20000 32310 23000 21400
10% OF NIOIANINFNI $3500 15400 17350 11250 20000 22350 23900 25400
COIINIY IA SAC
VINY LOW INCOME 11110 2700 $4300 11100 17150 11450 $1700 21000
LOW INCOME 17100 30350 23900 15410 37450 29500 31550 33100
MODERATE INCOME 23300 25050 25400 30110 33950 35000 37010 31100
30 TEAR VEIN $3310 $5250 $7150 11100 30100 22110 33510 31200
60% OF NEDIANINF$I) $3350 $5250 $7150 $0100 20000 32150 23150 25200
CIflhtI lY : IA SIOU*
VERY LOW INCOME 11110 $2700 4300 11100 $1110 11410 $9700 31000
ION 5NCOW 57000 20310 22000 11410 17410 20500 31110 33000
MODERATE INCOME 33300 35050 20400 30110 32950 35000 37050 39100
35 TEAR 5(IM $3350 11350 11150 $0100 20000 23 550 33110 31200
102 OF NEOIANINVHI $3330 $5250 17150 $0100 20000 23150 23010 25200
NSA Slouls City. IA-NE
VERY LOW INCOME $1700 13310 11090 11700 15090 $9350 20700 22050
W 00 0BURY LOW INCOME 11700 31400 24050 2S7 0 0 30050 31000 33150 31250
MODERATE INCOME 14200 26900 29550 32200 14310 36500 30050 40750
30 TEAR TERN 14010 11050 $1050 30050 31150 23250 24050 30450
50* OF NEOIAN$NFN) $1050 10050 $0050 20020 21130 33250 24010 75430
$3 1 3 -OIl SPECIAL P11
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f194* INSIRUCI IL S14 -I. 11511 117 C
Ira n: IOWA -ADJUSIED INCOME LIMI IS--
P P 0 6 1 A N S PEPSIN I PEPSON $ PIRSON 4 PEPSIN 5 PSISON S PIRSON 7 PIRSON I PER5O 4.
COUNIT : 5* C*LIIOUN
v pv sow iwcoi 51550 52700 54300 55900 $7150 11450 $1700 2 5000
sow INCW 1I 11100 20350 22100 25450 21450 21500 31550 33600
woouav, •Nco.q 23300 25150 2 1400 30150 32950 35000 31050 39500
35 I*I 11PM 13350 $5250 17150 59100 20600 22150 23650 35200
01 OP N1OI*NISU$I$ 13310 55310 1)150 59500 20600 23150 33650 35200
ca lmly a CEllO qpQ
V I I I LOW INCOME $3400 1455,0 S1 150 17700 SSSO O 30550 31950 23350
LOW IlICOMI ____ 15100 22650 25500 26300 30600 35100 37400
1 I*1E 1I ON 35300 25110 35000 23*00 35100 35310 40600 43900
25 yEAS 11PM 14150 $7000 9100 31210 33150 34650 36350 26050
50% 01 MIDUNININI 14S50 $1000 $9100 21210 32950 24550 36350 25050
coil”,
vtiv sow INCOME 11150 53100 54300 15100 $1150 $6450 59700 2 1000
sow INCOME $7600 20350 22100 25450 21450 29500 35550 33500
10015*11 INCOME . 23300 25050 • 25400 30110 32050 35000 37050 39500
35 VIII SCUM $3350 $1260 $1110 $5100 20600 22550 23650 25200
50* DI NIOIANINHII 53350 5350 17110 19100 20600 32150 23650 25100
cosali , !j COAMILIN
vuv sow pirgps $ 5350 $2650 $4450 SS O5 O $7350 $0600 59900 25200
LOW $NCOIII 16000 20150 33100 21700 31150 29000 31610 33900
iloolPall $lxfl q1 33100 26050 26600 31200 33210 31300 31350 39400
35 11*5 11PM 53500 15400 $7250 $5250 20100 23350 23900 35400
603 01 N10I*N IMHI) 13500 55400 51350 $5350 20600 23350 23900 25400
COIJNI! : IA S4*IUIION
viuv sow uico.st 55 550 52700 54300 51900 $7150 10450 19700 25000
• LOW INCOPSI 51000 30350 23100 25450 27150 29500 31550 33500
5190(0111 INCOME 23300 35650 25100 30150 32510 39000 37050 39500
39 VEIl (PM $3350 15350 $7110 15100 20600 32550 23650 35200
60% 01 N(DI*NINVNI 53250 55310 1,110 59500 20600 23150 23610 35300
COIJN IY : 5* II4NCOCI(
V I II SOW INCOME 11150 53200 54*50 $6500 57*00 I I $60 20450 25600
LOW sNCOii ( 56100 31100 33750 35400 25500 30600 32750 34550
10011*11 INCOME 24000 36600 21350 31100 31000 36500 36250 40350
36 V I II 11PM $3010 51510 51500 19000 25400 22950 24550 25550
603 01 M$D$*N INI,II $3.10 $5.10 I7SOO 59500 25400 32950 34550 21150
C O5iN IV : IA HAROIN ____
vipv sow INCOME $ 110 53510 $5350 56550 10300 59650 25000 22350
low INCOME 51000 31100 24400 31100 25300 35150 33550 39000
10011*11 INCOISI 14500 31300 31900 32600 34600 36510 31150 41300
31 VIII 11PM 14310 56310 50300 20350 31990 33600 25300 36550
60% 01 M1Oi*NINflI S 14210 6350 11300 20$50 35950 23100 252 0Q 36550
cournv IA 111190101
viav sow INCOME $1550 52700 $4300 11900 $7150 $5410 $1700
SOW IIICONE 1600 20310 32100 25410 31450 21500 35550 33600
10010111 INCOSIE 33300 25*10 31400 30510 33910 35000 31O5 39100
36 VIII 11PM 2350 $1210 $1110 11100 30600 33150 23550 25100
DIST ICT 60% D I slDuatilwlU 53350 $5250 11150 $5100 20600 22510 23550 25200
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INHI INSIRUCTIIJN 0514-A. FINISh C
-ADJUSTED INCONI LIMITS-.
P N 0 0 N * N I PERSON 2 PERSON tO PERSON 4 PERSON I PERSON S PERSON 7 PERSON N
C(JI NIy IA KOSSLJVII
VERy LOW INCOME 00010 03700 $4300 05500 11 1 10 $S4 0 05700 21000
LOW INCOME 11100 10350 33100 35110 37450 25500 30550 33500
NOOCRITE INCOME 13300 25050 30400 30,50 32550 35000 31050 35000
3o yEas URN 03310 suaso fl hlO 15100 ao loo 3 h50 23 1 5o 35200
80% OF NEDIAN $MfN$ 03350 05250 07050 Ig loo 30100 21150 23150 25200
CO IJHIY IA PALO ALTO
VINY LOW INCOME 00*50 02700 01300 05000 07010 00450 08100 20000
LOW INCOME $1100 20350 32800 31450 21410 15100 31550 33501
NODUIU INCOME *3300 35010 30400 20550 33550. 35000 31050 35000
30 YEAR lISP 03350 05110 S lO b 05000 30100 22050 33550 25300
sox or MEOIINIMIII) 03350 05250 10150 05500 30800 22050 23550 33200
CUIJNIV IA POCAIIINIAS
VENT LOW INCOME 01050 13100 14300 01500 17 1 10 00450 11700 31000
LOW INCOME 51000 20350 23100 31450 37410 35500 30550 33100
NODESIlE INCOME 33300 35050 30400 30150 33550 35000 3 ,050 35000
30 YEAR UN 03350 05250 07050 11100 20100 33150 23850 33200
50% OF NEDIANIMF 105 03350 05230 07050 15100 20800 22050 23150 33200
COUNOY IA WEBSTER
VERY LOW INCOME I 810 03300 15000 $1 110 00000. $5300 20550 22000
LOW INCOME 50850 21300 24000 25850 2S 11 0 30500 33050 35 050
NODIRATE INCOME 31110 38500 35500 32050 14250 38400 30550 40850
30 YEAR 1DM 4000 01000 00000 30000 11800 23300 24000 28350
10% OF MEOI*NINFNI 01000 05000 00000 20000 20100 23200 24000 25350
C OIDIIY : IA WtI*IESAGO
VINY LOW INCOME 11150 52700 $4300 01500 07050 11450 01700 30000
0W INCOME l7S 0 20210 3*100 15410 37110 *5500 3 0550 33500
NOODI1E INCOME 33300 35550 35400 30110 32510 31000 31050 35000
35 1 1*0 lION 03310 1210 17150 15100 20800 33050 33550 21300
101 OF NEOI*W IMFMI 03350 15250 11150 05100 20100 32050 21550 25300
COIJN IV IA WORtH
VINY LOW INCOME 11310 02510 04500 11100 17500 $100 20100 30100
LOW INCOME 11110 30110 23350 31100 31000 *0050 33050 34200
NODIPITE INCOME 33150 25310 30550 31400 33500 35350 31830 35100
35 YEAR 1DM 3500 01150 07500 10410 30000 33350 24000 25550
80% Or NfO *NINFHP 03500 05550 01500 05450 20000 22550 24500 25550
COUN V : 5* W0 10IIT
VERY LOW I1V 0NE 50510 03700 54300 05500 01050 11110 01700 *0000
LOW INCOME 01500 20350 32100 35450 *7450 35500 31550 33100
50010*11 INCOME 13300 25050 *0400 30150 32510 35000 37010 35000
30 YEAR lEON 03350 05350 11150 15100 30000 33050 33550 35300
50% OF MEOI*NINFH) 13350 05250 17130 15100 30100 22150 23530 25200
-------
IAMA INS1IUCIION $944-A. IX$IISSI C
8 1* 1 1: IOWA AOJUS 11 INCOMI LIMItS
P 9 I I o A * N I PIASON a PILlION I PIUSON 4 P1610 11 1 P195011 S PIASON 1 PINSON A PIRSON
COUld! : 1* *LI.*NIICU sow flicoNt. 11110 2100 14300 $8900 SlISO 19450 19700 21000
Sow II ON1 57000 20350 32100 25410 31450 29500 31550 33600
0U*11 INCONI 33300 25150 as 4 00 30 1 1 0 32950 35000 31050 39 ioo
U VIAl 11AM 13350 $1250 $1 550 19100 20100 22150 23650 35200
50* IF NIDIANINHI) $3350 $1350 S i 550 $1100 20600 22150 33650 25300
NSA : W.U.rSoo-C $Sr rass.. IA
VII I LOW INCONI $2010 $3110 $5500 51200 8100 $1950 21350 22100
SOW INCONI 51210 31000 24710 37500 29100 3 5900 34 100 36350
SLACKI IAUK paouA1 INCOIII 34110 37100 20250 33000 35200 31400 39600 41050
5615511 lIAR 11AM 4410 $1100 $ 1600 20450 23300 23950 31600 21250
60*,, N1DS*HIIWISI $4450 58500 $S600 20610 23300 23150 25600 21250
C011 1 1V IA UCISUI*N
VII ! LOW $NCON 55100 52900 54680 16180 11450 $1750 20050 25300
• LOW INCONI $100 20650 23250 21010 21900 39910 32050 34100
• NOOllAIC Iwcoisi 23400 31150 20150 35150 33100 35450 31550 39800
35 VIAl SIAN 13550 11600 $1450 19400 20950 22500 24050 25600
soz or suIoIafflNrNl 53550 55500 $1410 19400 20950 22500 24050 25600
COUNIY : IA SUItOR
WIRY LOW IIICOMI $1110 52100 54300 55900 11S50 $8450 19700 25000
LOW INCIHI $7600 20350 32900 25450 21450 29500 35550 33600
• 60011*11 INCOME *3500 21650 21400 30150 32550 35000 31050 31500
30 71*9 11AM 52210 11250 17150 19100 20600 22180 23650 25200
i0* or M1DI*N(NIH) 53350 55210 $7110 $9100 20600 22150 23650 25200
COUN IY IA CISICKASAW
VIII LOW INCOME 1 1110 S2100 14300 15900 11150 11450 $9100 21000
LOW INCONI 51000 30350 22100 21410 31410 29100 35510 33500
10016*11 INCONI 32100 35610 20100 30950 33910 35000 31050 39100
30 11*6 11AM $3310 $5210 17110 $9100 20600 22150 23650 26200
SOZ OF NIDI*NINVSII 53310 $1210 $1510 $6100 20600 22 15Q 23850 25200
C OUNI! : IA CS.AV ION
WIRY LOW IS I US$10 $3700 4300 55900 .17150 50450 19700 21000
LOW INCONI ____ 51600 30310 23900 31450 21450 29100 31810 3J600
UAtf INCOME 33300 35050 36400 20150 33950 35000 31050 39500
35 VIAl lION 53350 $1310 11150 $9100 20600 23150 23650 23200
601 OF NIDUINIMISI) 51350 $1210 17110 19100 20600 22150 33550 25200
COUNIT : IA OILAWAI I
VIA! LOW INCONL $1510 $2100 $4300 51900 11150 50450 19100 21000
LOW INCONI 17100 20350 22100 25450 27450 39500 31550 33500
• N001S*l1 INcUNI 33100 29650 30400 30550 33950 35000 31050 39500
36 71*9 11AM 3350 15250 $7550 $1100 20600 32150 23650 25200
SO* or NIOSANINHI) $3350 55350 1,110 59500 20 500 22110 33650 25300
DISIRICI Ill
-------
FVH* 111 $ IRUCT$ON 1644-A. rAisiphi C
SlAtE IOW*
I 0 m l U $ 7 1 0 I N C 0 N I L t N V S -
P 6 0 0 6 * N I PERSON 2 PERSoN I PERSON I PERSON S PERSON S hRSON 7 PERSON S PERSI’N.
r.oIpplIv IA FAYEIIE
VERY LOW INCOME 11110 12100 4300 IS Soo 07 150 osno oiioo 21000
LOW INCOME 17100 30310 32100 15110 *7410 25100 31510 33500
MODERATE INCOME 23300 21010 10400 10510 33510 31000 37o so 35100
36 vEal lIEN 13350 .1310 17150 11100 30100 *2110 23110 21300
60% OF MEOI*NIMHI 13350 .3230 17150 11100 20600 22110 23690 33300
COm m IT IA !L0 D
VERY LOW INCOME 11100 3000 14710 11100 07700 15000 20360 ZIS I O
LOW INCOME 00350 30000 33100 25310 21350 30450 32150 34150
MODERAtE INCOME 23050 21500 36000 30710 33650 35510 36010 40110
36 VIAl tEEM 13100 01750 07100 06700 20210 23550 24100 31000
60% OF NEOIANIMIHI 03000 01750 07700 05700 21210 32650 21400 26000
COUNt V • IA 06 1111) ? I
VERY LOW INCOME 02100 3600 01100 $7210 00010 20000 20400 21750
LOW INCOME_____ 5300 33000 21610 27100 21500 32000 34200 36110
MOOERAfl INCOME *4100 37600 30310 33100 35300 37100 31700 41150
31 11*6 IUN 04100 08550 11110 30700 21350 34000 25010 31300
10* or .uEoIaNIMvrn 04100 15550 15650 20700 22350 21000 29550 21300
COUNtY : IA I WAR0
VERY LOW INCOME 00050 12700 14300 11100 07*10 $5450 05700 20000
LOW INCOME 17000 20310 32100 25410 27450 25300 31150 33600
MODERATE INCOME 33300 35850 35400 30150 32510 35000 37050 35100
35 yEAR tERM 03350 06210 17150 01100 30600 22150 23510 31200
50% OF MEOIANIMIN) $3390 15250 17150 1 1100 20600 22130 23550 25200
COhliI IY IA MITCHELL
VERY LOW INCOME 11150 12700 4300 01100 17150 0S450 15700 31000
lOW INCOME 01500 30350 23500 15410 37450 25500 30110 33500
NOOUATE INCOME 23300 *5050 30100 10650 32550 35000 37050 35500
30 VEIR tERM 03350 05300 17150 lOOm) $0100 32010 23550 25200
60* OF NEDIANIMFN) 11350 05230 17150 05000 30600 22030 23650 25200
COI INIT IA WhlAIESIIIEK
VERY LOW INCOME 10150 0*700 1300 $1100 17150 IS ISQ 1 )0 21000
LOW INCOME 17100 20350 33500 31410 27150 21500 30150 13500
NOOERItI INCOME *3300 35050 20400 30630 33050 31000 37050 36100
36 Yf AR $(UN 03350 15210 17110 05000 30000 23I!O 33550 31200
60% 01 NEOIANIMIH) 03330 05350 11190 $6100 10600 22110 21050 25200
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11111 INSIMUCIION C - j j ( I N C 0 N I I I N I U S
P 6 0 0 6 6 N S PESSOM 3 PIllOW 2 P165014 4 PISSON 5 PIStON S PERSON 7 PERSON I PERSON
51*11: IOWA
Cowiiv . Is SINION SOW INCOME S2200 53950 15100 51450 5650 20250 25650 23050
SOW INCOME $1550 32310 25 150 3)600 30150 32400 34600 36650
500(5*11 INCOME $5050 37610 30610 33400 35650 37900 40100 42350
Vial hIM 54550 16710 11150 20110 22600 24300 25150 27630
00$ Of NEDISNININ) 54650 6750 SIlO 30150 33600 24300 35910 2)650
VII ! low INCOME 11150 02400 15050 $6150 11100 19460 20150 22100
LOW INCOMI 10110 25410 34100 26600 25150 31100 33250 35350
50056*11 INCOME 34350 36010 21600 32300 14410 36600 30750 40050
36 vIal $1 .5 $4050 1 1 100 $0100 20100 21100 31300 24900 26550
60* 01 i.10 1*NIMI$II 04050 55500 $0100 30500 20100 33300 24900 26550
COIMIlY 5* I SI1I1lN ______
VINY LOW INCOME 13150 13100 55500 11350 $1150 20S50 21500 22900
LOW INCOME 5410 23200 25000 27710 30000 32200 24400 36650
500161ff INCOISE 24510 27700 30500 33*50 31100 37700 39500 42150
35 V I I I l OIN 54150 06650 11750 20600 33500 34050 25600 27300
60* 0 ! P 1 1 0IIHIMVN ) $4510 56510 ISP IO 20600 23500 24550 25600 31500
MU I A ____
VLR LOW INCOME 52400 14150 $5950 51700 $6500 20550 25950 33330
LOW INCOME 56600 33610 25500 30300 30600 32650 35100 37400
MOOllali INCOME 25300 $0150 3*000 33500 36100 38350 40600 43900
DUBUQUE 35 VIal 1165 $4650 17000 19100 3 5250 32950 24550 25350 26050
60% Of 510 1*14 15114) 14150 07000 $ 1100 25250 22950 34650 36350 23050
CO II4 IY 5* SlIME!
VINy SOW INCOME 50100 13310 $5050 $6700 $6050 59350 20100 22030
SOW IICONI 0100 31400 34050 26700 26050 35000 33150 33350
50015*11 INCOME 34300 36100 39510 32200 34350 36500 36650 40750
36 V l S I 1165 04050 $6010 *0050 20050 21650 23250 34550 36450
• 60% OF M10 10NIIIlN) $4050 $6050 $1050 30050 31050 33260 34050 21450
COIJilIS A lOWS
• VII! LOW INCOME 52300 4050 55000 07550 11950 20350 21750 23550
LOW 05(0556 00650 32410 21250 30000 30350 32550 31000 37050
50016*11 INCOME 31*50 37550 30150 33600 35650 36050 40300 42550
31 V1*I 1165 $4750 $6010 .6150 31050 32150 34450 26000 21500
606 0? NIDIANINIHI 4750 51510 16950 21050 23)50 31450 26100 2)600
CO IiN IY 5* uSd150_N
wily SOW INCOME $1150 52700 54300 55900 $1.50 5450 59700 2 1000
SOW 55(0551 57600 20350 33600 26450 27450 21500 3 33600
5001 5*11 INCOME 33100 25550 26100 30150 32150 35000 37050 39100
o vias • Ilw $3310 $5250 $7150 $9100 20600 33050 23650 35200
60* OP 5iOI*NINIH I 53350 56350 07050 19100 20600 22150 33610 25200
MU Iow* C5S . Ia
VII! SOW INCOME $4550 56550 50200 30200 31000 23450 25050 26630
JOHNSON I” LOW INCOME 23600 25650 21100 32300 34100 31500 40100 43650
• NOOU*UE INCOME 21100 30350 34600 31500 10100 43000 45600 46150
25 VEAl 1165 51110 59400 21100 34250 36200 36500 30050 33000
501 I )! NIDUANINIIII 56930 194 1W) Y IUIWI ssrwi linnA
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FMH* INSIRUcUON 1541-A. 2*90501 C
90*01: IOWA • .•—- 0 ii U S I S N I NC 0 N I I. I N $ 1 S - - -
• o a i a w • . .sow P 1 11011 a pei o •i p11 5011 s ptisasi • PER sON ? PERSON S
CO uNTY Ia jour;
VERY LOW $NCWg 1500 3250 04500 01150 17150 05000 *0500 3550
LOW INCOME 11550 11300 33510 25100 20200 30700 32510 34510
NOOfsafl INCOME 34050 10700 35350 33000 34000 31200 35350 10450
35 ‘1l TERN 03500 15500 17150 15110 11110 13050 24510 2.200
80* OF NIDIANIMFIII 03900 15900 07550 15110 21110 23050 24510 35200
M5A Cc.dar RiupId . IA
VERY LOW INCOME 01400 1 1410 05300 20510 33300 23550 25100 21050
LOW INCOME 23000 25300 25100 32100 15500 $1110 40150 43400
I OlIN 10015112 INCoME 32300 30500 25000 35100 11000 43550 45250 45500
32 VEA l TERN 17310 15750 22300 24510 10110 3SSOO 30000 32530
601 OF MFf1I*M(MFII$ 17250 05110 22300 24810 25550 25500 30600 . 32390
COUNOY : IA LOUISA
VINY LOW INCOME I 0510 03010 01350 07010 5100 11100 1150 23100
LOW INCOME $1100 30000 24150 31300 35410 30510 33250 1I
MODERATE INCOME 24500 21300 30030 33200 14510 37010 31350 40500
35 YEAR tERN $4300 05350 11400 30410 31100 23110 35310 31000
60% OF MEOI ANINflI) 14300 05350 15400 30450 22000 33750 25350 27000
COUNTY : IA MUSCATINE
VINY LOW INCOME 01500 01400 07300 5*10 *0500 22110 2 fl 25400
LOW INCOME 30510 3PU0 37700 $OSO O 33250 33110 40030
MODERAtE INCOME 31010 30050 33200 35300 35110 41350 43700 41150
35 YEAR tERN 11110 US$00 20500 33000 14050 25500 35110 30500
60% 01 NIDIANINFU) 16130 05300 20500 23000 24910 26500 SS30 30900
couurnv - IA POWESHIEN
VINY LOW INCOME 00200 02000 04400 05000 17300 1 1550 11010 20000
LOW INCOME 11100 30100 33010 35500 37110 25700 30710 33000
MODERATE INCOME 23400 15000 35110 11100 33110 35200 31230 35300
35 VI I I tERN 03410 01350 07300 05200 20150 32210 23500 31310
802 OF NEOIAN(N I1) 3450 03150 07300 1 1200 30110 22250 23500 21350
NS A - Dnv.nporl-Rock I.Iuind-MoIIn.. IA-IL
VERY LOW INCOME 03450 5350 07300 05100 *0150 33*10 23500 11310
SCOTT LOW INCOME 20100 24500 *7150 30700 33200 35210 31100 40510
MODERAtE INCOME 27000 30000 33050 31300 35100 40010 43500 41050
35 v IR TERN I I 010 05410 20710 23010 14100 30110 25110 30400
001 01 NEOIIN$NfNP 11150 11450 20750 23010 24500 25130 25530 30400
COU,flv IA lANA
VERY LOW INCOME 00400 03000 04500 5230 11110 15050 20050 *0410
LOU INCOME 0200 20S00 33400 21000 2 1100 301w 32*10 34300
300(5111 INCOME 23700 35300 35500 31100 33000 31010 37710 35500
35 YEAR VEIN 13S50 05000 07150 05100 20010 32500 24300 21110
60* OF MEOIINIMIHP 13S50 03000 07550 15500 20050 32800 24200 25750
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11141 INSIRUCIION $944-A. EXHIBIT C
51*11: IOWA -aejusilo INCOME LIMI IS- -
P 8 0 0 8 £ N I PERSON 2 PERSON a PERSON 4 PERSON I PERSON S PERSON 7 PERSON I PIRSON
COIINJY IA APPANOOSI
VERy lOW INCOME 11150 12700 14300 15900 17150 18450 $9700 21000
ION INCOME 11600 20350 33900 25450 37450 29500 31650 33600
NOOIIAII INCOME 33300 31850 3 5100 30950 32150 35000 37050 39100
25 lEAR hIM 13350 11310 11150 11100 20100 23150 23 510 25200
0$ OP M1D *NIN1HI 3350 15310 17150 11100 20100 32150 33610 25200
COUNIV Ia DAVIS
V I I I SOW INCOME 1 1150 12100 $4300 5900 17110 5450 $9700 21000
LOW INCO 1 17100 30350 33900 25410 31410 29100 31650 33100
NODERA,, INCOME 33300 35810 38400 30950 32910 31000 37050 39100
30 VIAl 11PM 13210 $1210 17150 11100 20800 22110 23650 25200
SO S O MLDIANINIII $3350 $5250 $7150 11100 20500 22150 23550 25200
d IllY IA 01$ NOIMES
• VII I LOW iNCOME 13350 $5350 17110 SIOSO 20550 22100 23600 25150
lOW INCOME ____ 21350 24400 21450 30500 32900 31350 37500 40250
NOOUA1 INCOME 25050 29900 32650 31000 38400 40550 43300 45750
35 15*0 hEll 5000 $ 1300 30510 33110 24700 25500 20350 30200
SO S OF MEOIANINIH$ 16000 $1300 20160 32150 34100 26500 20350 30200
CO IIN IV IA JIFFIRSON
VERY SOW INCOME 1 1150 52700 $4300 $5900 17150 18450 59700 35000
• LOW INCOME 57600 20310 32100 25450 31450 29100 31650 33600
NOOLIATI INCOME 23300 11950 21400 30150 32150 35000 37050 39100
31 V III 11 11 13350 15250 11150 $9100 20600 22150 23650 25200
SOS OP NIDIANININ) 3310 $5250 $1110 $9100 20800 22150 33650 25200
COMMIT 1* 1(01151 VI II lOW INCOME $1150 $2100 $4300 51100 11150 $0450 $9700 2*000
LQW 1NCIPSI ____ 11100 30350 32900 25450 • 21450 39100 31660 3390* )
ERIII iNCI 23300 31810 38400 30950 32950 31000 31050 39100
25 VIII INN 2310 $1350 17150 $9100 20600 22150 33150 21200
SOS OP NIDIININFN ) 3310 5250 $7110 $1100 20500 32150 23850 25200
*0S1$IV IA III
VERY SOW INCOME 12100 14100 1 1400 50350 $9100 21150 22650 24100
LOW INCOME 20410 33350 3S3 00 25200 31510 33650 31200 3I s so
NOOLIAIE INCOME 25110 3IS I O 31100 31700 37010 39350 41700 44050
38 VIII hElM $5350 07500 11100 21600 23650 25400 31 150 20900
SOS OF MIDI*N INIH) $1310 $1500 19100 31900 23650 25400 27110 35900
C $RRIIV IA LUCAS
VIII SOW INCOME $1110 $3100 14300 $5900 $7150 0450 0970 ° 21000
SOW INCOME 11100 30350 32900 25450 27410 21100 3,650 33600
NOOLIAlE INCOME 33300 21550 38400 30110 32110 31000 31O5 39100
30 VIII 11PM 13350 $1310 $1150 19100 20500 32150 23650 25200
SOS OF NEOI*NINN$ 1350 15210 $7150 $5100 20500 32580 23150 25200
DISTRICT V
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MHI INSORUCTION 0944-A. DUIRIT C
,ATr Iowa -
- ADJUSIID INCONI LIMItS.
P I o o A N I P 1 1305 2 P11305 Ptu oM 4 PIlsaw 5 PDSON S P1150W 7 P N pp 5 P1150W.
I(PlINJ IA NAIIASKA
VERY LOW INCOME 11110 12700 11300 15100 17150 11450 19700 30000
LOW INCOME 07000 20350 22500 35410 21410 25100 31510 33600
NODER lIE INCOME 23300 35550 26400 30110 32550 35000 37050 31100
30 V III PLUM 13350 15210 17150 05000 20500 22050 23510 30200
oux or N1OI*NINFIII 13350 .5230 17150 19 100 20100 32150 23550 25200
rrnpNlv IA MONUQE
VERY LOW INCOME 1 1150 12700 01300 05500 17110 11410 I *I IO 20000
LOW INCOMI 07500 20350 $3100 *5150 11450 25100 33600
NUOUaIE INCOME 23300 25510 35400 30150 $2050 31000 ...0SO 35000
30 VIII ID. 13350 05350 17010 05000 30600 22010 31V0 25200
50% OF MIOIAMINflIP 13350 05250 17050 0*000 20100 32130 23650 25300
COUNtY IA VAN RUREN
VINY LOW INCOME 0010 12700 04300 05100 07050 1S410 -11700 20000
LOW INCOMI_____ 07600 30350 22*00 15410 *7450 60100 aisso 33*00
50015*11 INUJME 23300 25510 26400 30150 32510 25000 31050 31000
35 lIAR PlUM 03350 15210 17110 11100 30500 22150 23550 21200
sox or NEOIAN(MFH) 03330 05230 17150 0*100 20500 22130 21650 25200
COUNtY IA WAPELLO
VERY LOW INCOME 11110 03700 14300 05100 07050 05410 01700 20000
LOW INCOME 17100 30310 32 OO 21450 21410 35500 30550 33600
MODIRSIE INCOME 23300 25510 2S400 30950 33*10 35000 37050 35100
35 YEaR tERN 13350 01210 17150 15100 30500 32110 33550 35300
50% OF MEDIANIMF 1 11 13330 05230 11150 19100 20500 23050 23550 25300
COIIUI V : I A WASIIIP 1ON
VINY LOW INCOME 10010 02100 04300 01500 07050 5450 1*700 30000
LOW INCOME 07000 30310 ft lOo 25450 27410 25100 31150 33500
N00 IRIIE INCOME 23300 21510 *5400 30950 32510 33000 37050 36000
35 VI II tERN 03310 01250 07010 0*000 20500 22010 23610 25300
60* OF MIOIAIIINYII) 13350 03250 17130 05000 20600 32010 23630 23200
COUNtY IA WAYNE
VINY LOW INCOME 111 10 02700 01200 0*500 11150 00450 0*700 30000
LOW INCOME 07000 20310 22*00 35410 21450 25300 30*10 33*00
MODERATE INCOME 23300 35510 35400 30150 32530 33000 37030 35000
30 VEA l lION 03350 11250 17110 05000 30600 33050 33650 35300
6011 OF NEDIANIMIN) 13350 053*0 17150 05000 30500 22030 23650 25200
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I A I1a$IRUCIIWI 0944-6. 11111111 C
%$( AOJUSILD INCOME LINI IS-
P A C C A £ N S PERSON 2 P151CM 3 PERSON 4 PERSON 5 PERSON S PERSoN 7 PERSON I PIRSON•
NSA D•s NGSn*$. IA
VLRV LOW INCOME 54210 56300 11300 30350 22000 23600 2 5250 26850
LAN IIICOISI aa.oo 35050 31300 32550 35050 37750 40350 43000
DALLAS 1001 5*11 INCOISE 30300 35550 34000 30010 40650 43250 45550 40500
VOLE 30 91*5 11PM $7500 esoso 32000 34400 36350 21350 30300 32250
OV M1DI*NINIH) 51500 51510 32000 34400 26350 25350 30300 32250
WARREN
0S5flY : A *0*1 1
WIRY 0.0W INCOME 50 510 53100 04300 55900 57550 55450 59700 25000
ION IIICONI ____ 51600 30310 22500 35450 27450 35100 30550 33000
10015*11 INCOME 33300 25050 35400 30110 32150 35000 37050 39500
as voas 11PM 03310 05250 57550 $1100 20600 22550 23650 25200
60* 0? MDI*NIN100 53310 00310 07010 59000 30500 22150 23650 25200
COUNIT IA 100’4
VERY LOW INCOME 55300 03900 54510 $6050 07450 16150 20050 20300
LOW INtONE 56000 $0.10 33210 31650 27100 29950 33050 34000
N00IR*1E INCOME 23600 36050 25150 30350 33400 35450 31550 39600
30 11*9 11AM 53550 51100 51450 59400 20950 33500 34050 25600
•o* or ss lOIANluflI) 53510 05500 51450 19400 20950 22500 24050 25600
COUNII : •‘ C1 *RK1
VERY LOW INCOME 55150 02100 04300 05100 07050 $ 1450 59700 asooo
SOW INCOME 17100 30350 22900 25450 21450 31500 35550 33500
NOOI5*11 INCOME 23300 25150 20400 30110 32150 35000 37050 39000
35 11*5 11AM 03350 05350 11150 $1100 20600 22010 33550 25200
601 01 MIDIANIIUlIl 03350 $0250 $1110 01500 20600 32050 23650 25200
COUNI! : IA OSCAISIR
VI II LOW INCOME $5510 $2100 $4300 51100 07080 $ 1450 $1700 25000
LOW IIICOISI ____ 57600 20350 22100 25410 31450 31500 31880 33600
10OES*I INCOME 23300 25610 30400 30950 32110 31000 31050 39500
IS YEAR IllS 03350 01210 17110 11100 20600 23050 23150 25200
501 0? M10 1*NININI $3350 5310 51510 19100 30600 22010 23650 35300
COUNIV 1* JA$PIR
WIRY LOW INCOME 12450 04250 06000 11100 $9300 20650 22050 23500
LOW INCONI 55950 33500 25650 26100 30150 33050 35300 37600
10010111 INCOME 25410 30300 30010 34000 36300 30550 40000 43500
35 11*0 11AM 04110 57500 0120.0 21310 23050 24500 26500
50* 0? NI0I*NSMIH$ 04910 57500 09300 30350 33050 24500 26100 25200
cousoiv : 5$ MADISON
V II I LOW INC(W1 55650 5 ) 200 S50 00 6650 55000 51300 20650 22000
low INCOME . 11610 35300 24000 25510 25750 30900 33050 31150
50010*11 INCOME 34050 21100 39800 32510 34250 36400 30550 40650
2R YEAR 11AM 04000 01000 $1000 20000 21600 23200 24000 26350
50* 0? NEDI*HINVIII 4000 01000 11000 20000 3 5500 33200 24000 35 3so
DISTRICT VI
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FMH I lP4S1 ucjThu 0544 -5. 11111017 C
StAVI IOWA -*OJU5,1O INCOM e L INI IS-
P 5 0 5 £ N I PEISON I PERSON 3 PERSON 4 PERSON S PERSON S PERSON 7 PERSON I PERSON.
rnhpP1lv I A UnRION
vElY LOW INCOME 13300 13950 00700 17410 11 150 ldUO vISO *3050
LOW INCOME 01550 aa so 30050 *7500 30100 13400 j4600 35550
000USD INCOME 30050 2 aeo 30550 33100 35550 37500 4O 00 12350
35 7155 0560 14550 10750 11 150 20550 33600 34300 35950 11150
sox or IuEolaulInr 1 1 1 01650 icoso 06 550 20950 22600 34300 25550 31630
Ullill V I A MARSHALL ______
WINO LOW INCOME 03000 4500 16750 5600 20000 30600 23050 14550
LOW INCOME 30610 23500 25500 *5710 13150 14100 36100 39300
000USD INCOME 21350 29300 32300 35150 37650 40000 42400 44600
36 Y IR flQN 15100 07650 20000 21300 14000 25900 I 271.. 35410
102 OF NEOIAN INFHI 10600 00550 20000 23300 24000 35900 27 1C,0 39450
COUN IY IA 0014000(0 -
WIRY LOW INC011I 11150 13700 4300 11100 17110 16400 11 ?00 *0000
LOW INCOME ____ 17100 20150 31500 *5450 37450 26500 3.110 33100
00010*01 INCOME 33300 31550 26400 30910 23550 31000 31050 39000
35 7 5*0 lEON 03350 01350 17150 1 5100 20500 33010 33610 25300
10% 0? MEDIAN(MnI) - 03350 09250 17150 19100 30600 22050 23150 25300
C0UN V IA 5 1007
VERY LOW INCOME $2300 $4050 11500 11550 $SI50 20310 30710 33150
SOW INCOME 19150 31450 20250 IS $00 10310 33110 34500 17050
NODIRIlE INCOME 25050- 37550 30100 13500 15550 36050 40100 42550
35 15*5 TERN 04750 15650 15910 21010 33750 24450 26000 17500
602 0? MEDIAMINFH$ 11710 01550 05950 20050 22790 24450 21000 27600
CO uNtY IA UNION
VERY LOW INCOME 11110 13700 $4300 01900 $7110 15410 9700 10000
LOW INCOME 01600 20350 32900 25410 11450 21500 10550 33600
NODERI IE INCOME 33300 25650 26400 30950 32910 35000 37050 35000
35 YEAR TERN 03350 09250 $1150 11100 20100 22050 23150 25200
10* OF N IOIANIMTHI 03330 15300 07050 5000 20600 23030 23150 25200
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S I .
F IA III SIRUCIION 1 S944*. EAHIUII C - -* N C 0 N I I I U I I S -
51*11 IOWA
P a o 0 8 £ N I PERSON 3 PERSON 3 P185011 4 PIRSON S PERSON 6 PERSON 7 P(RSON a PIRSO’.l
CO*JNIV lOANS
• VERY SOW INCOME 11150 12700 $4300 15900 $1150 18450 19100 2*000
sow INCOME siaoo 20350 22900 25450 27450 29500 31550 33600
• 110018*11 INCOME 23300 25850 28400 30950 32950 35000 31050 39100
sa viaa I IRM $3350 15250 11150 59*00 20600 22150 33650 25200
•O pF N(DIANIMIIII 13350 $5250 11150 $9100 30600 22150 23650 35200
IA *110119011
VERY SOW INCOME $1150 (2100 (4300 $5900 *7(50 $84 50 *9700 2(000
LOW INCOME S7 800 20350 32900 25150 21450 39500 31550 33600
110019*11 INCOME 23300 35850 28100 30950 32950 35000 37050 39100
i 39 lIAR 11811 13350 S5250 $7150 19100 20600 22150 23650 25200
602 OF NfO$ANINFNI 13350 $5250 17150 19100 20600 23150 23650 25200
COUNIY : IA CARROLL
VERY LOW INCOME 11500 $3150 $4800 *6450 $7750 (9500 20400 25100
sow INCoME 16400 21050 23700 28300 28400 30550 32650 34150
• 110011*11 INCOME 23900 26550 29200 31100 33900 36050 38150 40250
38 VIA l 11911 $3100 $5800 $1150 $9150 21300 22900 24500 26050
602 OF ISIQIANINV III 53800 $5100 $1150 $9150 21300 23900 24500 26050
COWI,V : IA *S$
VERY LOW INCOME 11110 $2700 $4300 $5900 • 17150 $8450 $9700 2(000
LOW INCOME 1600 30350 22900 25450 21450 28500 31550 33600
110018*11 INCOME 23300 25150 28400 30950 32950 35000 37050 39100
38 lIAR TERN 13350 15210 $7110 $9100 30600 22150 23650 25200
S02 OF MIOIANINIM) 13350 15250 $7190 $9100 30600 22150 23650 25200
COUNIY ‘% CRAWFORD
VERY sow INCOME $150 12700 14300 *5900 11*50 $8450 *9700 21000
LOW INCOME $ 990 20350 23900 25450 21450 29500 31550 33500
900(8*11 INCOME 23300 25950 28400 30950 32950 35000 37050 39*00
38 YEAR tERN $3350 *5210 11150 $9100 30600 32150 23650 25200
• - 002 OF NLOI*NINFII$ 3350 15350 11150 $1100 20000 22150 23650 35200
CO uNtY IA R1N0NI
WIRY lOW INCOME $1150 53100 54300 *5900 $7150 $8450 (9700 2*000
sow $1800 20350 23900 25450 21450 29500 31550 33600
NOO IRA II INCOME 33300 25850 38400 30950 32950 35000 37050 39 *00
38 YEAR tERM $3310 55250 11150 $9100 30600 32*50 23650 25200
002 01 NLOIAHIMES$I $3350 $5350 $1150 11100 20600 22150 23650 25300
cuialiv IA GREENE
WIRY IOU INCOME 11 1513 *2100 $4300 *5100 $7150 18450 19100 2*000
LOW INCOME *7600 20350 32900 25450 27450 29500 31550 33600
MODERAtE INCOME 23300 25850 26100 30950 33950 35000 37050 39*00
39 YEAR 11811 $3350 15250 $1150 $9100 20600 23*50 23650 25200
602 01 NIDIANIMI III ‘ ° 15250 11150 *9*00 20600 22*50 23650 25200
DISIRICT VII
-------
,‘9 $ I1lstRijr jp $q444. rxuini, c
‘lAl I owA
pRI’C PaM
‘till,,, i IA l:IJ,Iip$
CO I IN IV IA IIAPRI5QPI
‘flulpily IA Ufl Is
roI,u ,’ , IA UON$r.OMIRy
tinitil v Ia PA( F
“ cA 0.n. l ’.l. I D E - IA
P i1 TAWATTAIIIE
CO I IN IY IA ShELBY
( (1SI IJV IA IAVIOR
-* 0 d U S I
I PERSON 2 PERSON I PERSoN
£ 1$ I N C 0 W i t. I $
4 P16 5o14 s PERSON S PERSOI1 7 PFP 5ON A
V Y LOW INCOME
LOW INCOME
UDOEPlIE INCOME
35vEA I PM
60% or MIDIAP,JIpIr l,p
1 1150
‘7600
33300
11350
$3350
12700
20350
35650
15250
I”50
14300
32900
25400
17150
$7 150
$5900
25450
30950
19100
19100
17150
21150
32950
20100
70600
11450
39500
35000
22150
‘so
$9700
•3 1S50
31050
23650
23650
21000
33600
39100
25300
3530 o
VERY LOW INCOME
LOW INCOME
MODERATE INCOME
35 YEAR 11PM
60% OE MEOIApflMrIsp
, , I 0
$1100
23300
13350
1313 ’)
$2700
20350
2 5 15o
15250
13390
$4300
22900
25400
17150
I7 5n
IglOo
25450
30950
19100
igloo
17110
21450
32950
20600
20600
11430
29500
35000
23 50
23150
$9700
31550
37050
23650
33Gw
21000
33600
39 100
25300
25300
VERY LOW INCOME
LOW INCOME
MODERATE INCOME
35 tAP TERN
60% OE MEDIANINFUI
$1550
11500
24000
$3.50
$3150
13300
21100
26600
$5150
13550
11550
23150
29350
$7500
17100
11500
26400
31900
$1500
19600
17500
26500
34000
31400
21400
19150
30000
31100
22950
22950
20450
32750
35250
24550
24550
21 100
34550
40350
26150
26150
VERY LOW INCOME
11150
12700
14300
15900
$1150
$1450
19700
21000
LOW INCOME
$7100
20350
22100
25450
27450
29500
31550
33600
NODERAIE INCIIMI
73300
25950
35400
10930
12950
35000
37050
39100
36 YEAh 11PM
$3330
15250
$1150
$9100
20600
22150
23650
25200
5 1 )7L or MEDIANIMFIII
$3350
$5350
11150
$9100
20600
33150
2)650
25200
V(R LOW INCOME
11150
12700
$4300
$1000
17150
$1150
$9700
21000
LOW IIICOMI
17100
30350
33900
25450
27450
29500
31550
33600
MODERATE INCOME
73300
25550
35400
30950
32950
35000
37050
31100
36 YEAR TERN
$3350
$5250
17150
19100
20500
23150
23650
25200
60% OE NEDIANINFII)
13350
$5230
11130
$9100
20600
32130
23050
23200
VERY LOW INCOME
$3600
$5500
$1450
19400
20950
22300
24090
25600
LOW INCOME
21750
24650
27950
31010
33500
30000
35500
40150
MODERATE INCOME
27250
30350
33450
36110
35000
41500
41000
16450
26 YEAR TERN
$6300
$1100
30930
23300
25150
37000
21150
30750
60% or NEDIANINFU)
$6300
$5600
20950
23300
25130
27000
25030
10750
VERY LOW INCOME
LOW INCOME
MODERATE INCOME
35 YEAR TERM
60% or MEOIANINrII)
11150
17100
23300
13350
11350
$2700
20350
35550
15250
$5230
$4300
22900
75400
$1150
17150
$5900
25450
10950
I9t00
$9100
11150
27450
32950
20600
70000
15150
29500
35000
22150
22150
19700
31550
31050
3650
3 1
21000
33500
39100
25200
35200
VERY LOW INCOME
LOW INCOME
MODERATE INCOME
311 YEAR TERM
601. or uFDIIhlIMfhII
11150
$7100
13300
$3150
13150
$2700
20)50
25550
15250
15230
143(X)
7311)0
75400
$7150
17150
15900
25450
30950
19100
19100
1,150
21450
32930
30600
20600
11450
29500
35000
72150
22150
p9700
.1550
11090
23650
23650
31000
33000
39100
33300
25700
-------
Appendix B
GUIDELINES ON USAGE OF INDIVIDUAL
FEDERAL INCOME TAX RETURN
IO4OEZ, 1040A, 1040
-------
A , ..a .S
CUID 14 014 ISACE Of INUS’JIDUAI.
1 AL TAX UETUNN$
ls. 10Z 104 0A.Iss.
fs. The,. are sloe. si letum For l.dMd .ah: For. IOIOEZ. , Fat. IOIDA. sad Poor iota Ye. .sy use Foe. 1010 If you e..t lo but po, .111 ,..,LU saW be K you ret able to Fe,. t0I0 or Foe. INM
us.? IuuIr.4 Iliseove ,. ‘sate p flpIr atul us. Fe.. 10.5 tipIal.d belts.. -m . clott 0. thu. ps ...Ill leip you dedde Ohich feat 10—
stat
of
.- ..-d-..
Torable lieu,.
O.ly beats Is.
luss.s
d t dudbe
‘
Other
Tat s.. b
l040t2 S1a . s.d. , OS s.d
aol blind)
No .o . Ibses.
pes.o.al rs.aptloa
for youn.lf
0.1 , titaNs j., ,.
(lIst 5) c i It. thu.
$30000
- Wa 1 su .dadss. lips
• TauNt .chdsnllps s .d
i efli s . Ips
- tuws.st of $100 or be
NO sdjust...ti to souse
No Ik.. .ta . 1
dndsc IIo.u
No ullel bats
N. sal
tOiflA - SI . le
- Mined fil ls 1 oI.I
- Materd ( ui . 1 repseale
• Head of boateholil
• Qualilytag .‘ide.(cr)
will drpr.dru il raId
All elr.plIo.s 1101
you ste ..lItkd I.
dii.
0.1, huh. lam..
(Ii . , 72) oil..
Is. $50000
•
Wig. ustaib lip.
- huh. .thoiatshps s .d
(stIosuMps
- s w , . ,
- D4J.sL
• P..slo.. 5.5.1115 s.d IRAS
• Us. .,.I. ,_st cu.peusados
- Tush. . .d.I IrnlI s.d
v.111 .4 ,etItorr.t beutliti
Duly die drds.lIus to,
s,th. .us.t.ibutiosi loss
IRA (Iictsdl.g
.. ...L4.r ltifr
ULstious os. IRA)
.
No ILl
&4.oi..
Duly . )..
ni..d l.c .e
audit (AEIC)
,.,....k
Oofj
- Eai .sd l. ...e
c,edil
0.41 1 for . 1 1W
sad dipuadi.l our.
‘*
(Schedule 2)
- 0.4 1 1 (or 11.
eldeely or 11.
ii ’
1010 • Sii, l.
• Mamt -d IiII. jnttt
• Matted llIi.g .rpavil.
• I rid of l,nvwhold
- Quslifyi.g widow(er)
wit ) depe.de.i child
All es.s$uoss 1101
you a ir eutitied to
dii.
Asy satosul of
tatatde Isocuse (list
37)
• Wages oulsilat tips
- Tanbk sc hoistublps s.d
Idl eushlp.
. tuweesi
- Utaldeude
- Tush. serial utterly s.d
ialtrnsd uethe...I brusfib
- U.e.,L, . .. l ms.p .sssllos
- Seli -. usplriyuuc.t
• Rout. aud tn ’shks
- Poudn.a. assuMe.. ..d IRA.
• Tush, state s.d local I.e...
I., rofuads
- Capital p1..
- Cial. leo. She tale of your
ho..
Alii.o.y ... .K J
- All oil., .
All torah 10 Iscv .
- Allatosy pull
- Frailty lie os.Iy
oliWnoul tui ssel.p
. Dsd.cilaa is, resels
coahlbutioss loss IRA
or Keogh pta. (I .cI.dIug
. . ..Jedudibl .
cosidbutless to as IRA)
• DuIscilo. fst sri!-
.$.,d 10.111
I..u,..c.
- Dud.dle. lie .41-
s.ploy. .ul wa
- All oil., sdju.toeul .
All ls.1i.d •
didsetlese (Us.
Schedule A):
- State s.d oral
I.e.. tiai.
- Roil atisi. b
• tuIsesel p.M
- 011w 10 chiulty
- MslIraI s .d
deutil ,iasiu
0.ssIty sad
40140 latiN
- Mailed
- MkrsIl...oou
d l e .
AU .40 ., user •;
- Ale..us emrd
I.e... aud I
(AUC) paywvti
- &i! .. ..j4 qst.4
be
- Tore. qs.I1Ik4
.JL... l p t a . .
(lscI.dl.g IRA.)
• Alseteatlee
sWats. Is
• SnrIiI 1.5111,11
ii. tips sos
. . 5 . .I1J to ynu,
...p lqe .
- IJ u t.Uck4
sinai ....aIIp lou
- es lIps slow ...
ye.e Foe. W 2
- All other laususe
Is ..
All us cvedlh:
• ts,.ed lets..
audit
- 0.4 1(for thU
s.d dipa4c .I cite
.
-0.41 faith.
ciluly or
disabled
- O..seal lad...
audit
• Peutiga Ii cledil
- CisdIl Is p.1st
you .1.1... iou
-0.4111w Fedetal
tiles tush
- Matugag. loi.mi
audit
- All oiler credits
-------
..IO efiI of e F.ea.ujv—. iuvI’li f u•
1 040 u.s. Individua’ Income Tax Return 191 -
me veer jan -Oec t ‘ 9l cr orner ax year oecinn’no
aDeI
I .
A
a
:aae’ I a
‘ S I
.:ei 14
erwise. e
- ease crirn
.:e
‘resloeflha)
Election Camoalga
ise oaoe 1’
1Iing Status
:.-ec oniv
e cox
xemotions
ee oa e ‘2.1
re trai’ Six
acenoents.
:ee cage 13.
ncome
Attach
of your
W-2.
V.2G. aria
995 here.
CU C 0 f 01
.et a V .2 see
:aoe l
. .rtacn c ecx or
oner. orcer on
o ot any
rm5 w-2.
. :.2G. r
S ’dIII0
3 iBNO
Your social security flumes,
Soous. s sociar security num
For Privucy Act and
PaDC,wo,k Reduction
Act Notic.. ce o
inStrUctioni.
‘ 10 I N la f eCNlna f• ! -
or cnanqe you, ax cr
lO I ‘eouce you, ‘e una
1 Single
2 I Mwvied fdung oint return (even If only one fad uncomep
3 ____ Marnea litirq seaa’ste return. Enter seouse $ social security no. acase ana fuit name nais. _______________
at VlO isenold (with auahfying personp. (See cage 12.) lIthe aualifying caesar is a cnii but not your cecence
enter tilts Cnulds name flare. ______________________________________________________________
S Oualifvina wucowten wurn decendertt cflutd iveer 3001151 diea ‘9 (See oaae t2i
6. V u f. It y uJ carent (Or someone e.sep can claim you as a aecarvoent Ofl n ’s ot flu tax
‘etum. co not cnecs box 6a. But be sure to civics ave o cx on me 33b on cage
b
C
I
,
L_. Soess.
.
.
Oegsn asms, 5) C ’icii
(1) iiiii .e i’st — ‘ai a is v rims, . .rter
3111 ace I Cr co
:tcenaem I social ucumv I
- .‘v’oer
iai Olosnoalts iS) lo
ansnsnuo to is • .
“i -
4 ltyCurCitflCOudflt live witnvou OullS cIaimeO asyout osoetcem undera om .i98S .esmais. cnecenere a 0
• Total numoer *1 ex tians cisirnea
7
Si
b
9
10
11
12
13
14
15
us
1 ?u
18
1 8
21
21e
21
23
24.
Adlustments b
to Lncomr 25
See oaqe 191 28
2?
21
29
30
Wages. saianes. tics. etc. tanacsi Formrs W•21 . I
Tezitile interest income vaiso at?acn Scheøul• B if over $400). . . . . ____
Tezusuet merest income ‘see oags (61 DON T incluci an ‘me Oa I Sb I
Olvidena income ‘us c attics? scheoui. a .s over $400) . . . S
Taxwe ‘snubs at state ma macu income tesus. if any. tram wcrivvest on cage 16. 10 I
Alimony recurvec . . . . . . 11 I
3u lme$s income or uaasi pinion Scrsciue C l. . . . . . . I 2
Cacitu gait or tuosu ritracn Scheaule 0) . . . 12 I
Cacasi gain aremouuons not reocneo on line 13 Isis Digs I? ). . . 14
Outs’ quits or losses, tuition Fern ’ 4797). . . . . . ...ILL
TotS IRA bb ait 5, 1 Tiiatts iltOUfli (SN Zi 17 )
Tate I ii i Ilb tixacte amount see cage I? ) 1Thi
Runs. royames. cuimsienucs. estates, trusts. etc. tartary Scheoui E) . . . . .JL!.
Finn un oina s’ ‘c ii i tuition ScfleauI• . 19 I
Unimc(0 i11srt umcmosaoor unsursncei see cage 181 . .
Scuat ssaimy o..atas. 211 1 21b Taxauie amount see gage II ) ..31L1.
Other income (list t s and amount—see cage 19) 25 I
.aa me arireinhs s.-aen in tile P1’ n I? Coumn for lines 7 ‘cuon 22. TM is tour totS Slb5
YowiRAasa iamcn.Iram - -iwani sr tes lonoagelOcrl l
Sacuse $ tRA decuction from acuicale r’sneet on ouge 2Oct21 24b r - .
0ne-riu* t self-simtoyment tax isae cage 211 - 25 I —
eItimSltseQ neaan uminnte oernata& tram omssea on cage a.
‘(eoga retirement otan asta self-emcioyeø SEP deductiOn 2? 1
Periuty on early wimdrawai at savings , : 25 I
_______________ 29
A lines 24a atravon 29. These are your totS admuauna.fls
Ne. a Sues
disuse en Ca
ailS IS
Me. ii your
crnlsiis 51 55
cut
. uesvou —
• SICalilvewits
p si Catts
Ilvins si
s. ..ua use
page 14) —
Me. SI Sissi
r: saIs —
*44 ..i _ .
sass N
liRS5 55i
30
d;usI
Gross
80
Income
31
.
uOViCt line 30 tram line 3. This is your aclusteSI 910.5 .. I? fill &? NIt ‘sill lil a?
527.250 aria a avid Ivsd eset Si. a.. cage 45 to t na Cw if yo cat n its Eumea &i....na i
cntotr on en. a ‘ 31
cat. No ‘ssoav
I
You, tir t name aria initial - ...ast name
It a Qulti re ijm IOOIJSC s nut name anc Initial .1St name
l4ums acer,,, inumOer arc screeti ill you rave a n 0 :oz see oaqu I’ . -at. r’o
C lv tOwi7 or cost on’c.. state arc ZIP COOi ii Cu nave a :oreiqn acoress. see oaqe ii
Do you want St to go to in’s tune?
If i int return ooes your soouse want SI to co to m ’s tuna?
-------
040 119911
iqe 2
32 AmOunt from line 31 (ao;usted gross ‘ncomep -
33a Check ii: 0 You were 65 or older. D 8lind: Spotiss was 65 or older. 0 Blind.
Add the number of boxes cnecked aocve ano amer me total here.
b If your patent (or someone else) can claim you as a dependent. check here 33b 0
If you are mamea filing a secarate return ano your socuse itemizes deductions.
or you are a dual-status alien, see oage 23 ano cnecii nets. . 33c C
Itemized dsductmns itrom Schedule A. line 261. OR
Enter Standai deducton snown aelow for your filing status ). Cautlont it you
me c!ecksa an’s doz on line 33a or ti. go to page 23 to find your standard
largsr aedmjcrion. if you cnecxea Oa t 33c. your sranaam aeaucnon is zero.
• Single—$3.400 I l4ead of housenoid —$5,000
• Marvmea filing jointly or Qualifying wIaowf en—U. 700
• Mamua filing separateiy-$2,850
Subtract line 34 from line 32 . . . .
If line 32 is 375.000 or less, multiply 32.150 by the total numeer of exemptions claim an
inS 6,. If line 32 is over 575.000. see page 24 for the amount to enter
T - -”* ( i pa . Su tract line 38 from line 35. (II tins 36 is more thait Irs 35. enter -0-.).
Enter taim. Check if from a C Tax TabIs. b C Tax Rete Schedules. a 0 Schedule 0.
or d 0 Form8815(seeaags24). (Amount. if any. from Formfs) 8814 S I
Addibanal taxes see page 24). Check if fram a 0 Farm 4970 a 0 Fame 4972
Add line 38 1110 39.
41 Creait for child ana oapa aiu cars expenses lanacsi Form 2441) _______________
42 Credit for tite elderly or tne aiudlea (attach Schedule RI. _______________
43 Foreign tax creait ratracn Form 1116) _________________
44 Other crecits see page 25). Check if from a 0 Form 3800
b 0 Form 8396 a C Form 68010 C Form (specify)
45 Add lines 41 tflrougn 44
46 Subtract line 45 from line 40. (If tine 45 is mars titan ins 40. enter -0-)
Other ‘
Taxes
Payments
Attacn
Forms vV 2. 57
W-2G. ana
l099-R to
front, 59
81
Refund or
Amount 63
You Owe
Sign
Here
I(pep a COCY
of this reiurn
for your
r e CO rØ0,
SeIf-empicyment tax tistacn Schedule S6)
Altamativs minimum Tax (attach Form 6251)
Recipe,, taxes (see page 26). Check if from aD Farm 4255 a C Ftsm 8611 a C Farm 8608.
Sociei secizay arid Ma , t a x on tip wne not r,ponsu to emgio er (attach Farm 4137)
Tax on an IRA or a qualified retiremant pian (attach Farm 5329)
Advance earned income amiss payments from Form VV-2
Add lines 48 throuqit 52. This is yaw toed tax
rdertl income tll itflftltd (if 1il ‘Strom FOrll e(i )1099. citeci
i991 ii ta aayaui lie WTmaIt etmea from i990 rattan.
Earned amo ariaS taftaon Sch. . SQ
Amoujfl paid with Form 4888 (extension request),
security Ms am, are R TA tax ouflftuld taee eage 21).
Other payments (see page 21). Check if frame C Farm 2439
b OFa,m4 138
80 Add lines 54 tivouqit * Thess are your tOtal paymexise
It $m IOn am, mel wie 33 aaron tin. 53 titan irs 60. The .me wv e ys 0v59P4J. .
of tars 81 to as RIRINOID TO YOU. 3.
6Ia*? U1OTOYOUR1I62UT1M*flOTUP I 631 I
If tIes s is mars men Ins 60. sutittect brie 60 frqm line 53. This is the AMOUNT YOU OWl.
Attirl øesøi or monsy orar for full amount payaare to int e rn t a Rewenus Sevvics . ‘mts yams
name, a ss . soa security nurser. aayams pears nurser. and 1991 Form lOW on it.
65 Estimat tax ou’iaity (see cage 26). Also include on line 64. I Ii I
34
35
36
37
33
3.
40
Oats
42
43
44
33’
35
. L
33
—
Al
,
411
I A
47
4$
4.
- -
mi
unoer osriers. ø o iap. i alone inn a non sso’wisa me ‘rum we ia n us we atii......iu . we to see Mat at ‘I lRi1 IidvI nie
O 1M& mnsy ns ma, cwvuo. are of m acn v iQum sent taacasso . ees sri at . 1...... of ncn . J l sty iU10wieUgi .
vow lignaiw, Oat, ‘ Yeiw 5I - ___
I-
;oos., sq’amws iii om ‘sewn eON muse sage
Paid
signature , ‘
Preparer’s AWlS
Use Only f: nsrovsn
Oats
caiota
1Sr*wac L. i
I 8.1. PIe.
r ipe 0 5 .
Pe aiir s scsaai $CW1TY 110,
Tax
Compu-
tation
If ou want
:ne AS to
figure your
cax, see oage
24
C
—I.
‘I
Credits
See cage
25.)
— i I
641
aa_ . rsmeai ‘NI -__
-------
..O4OA
Stp 2.
— ,
— ‘r!,IRS
- ‘I
. ur—
— I 1•. _ . — .n a. I a —
U .S. h l lU luuUi lJUUIW
Taz Retiu a 1991
1Ns i 46Ia
,—
. i i ii. - --
. • .. .a ‘ am. i . a. •. -
;
‘a. •All • It M S —
—
S I•. i ii l . —- — • st a. i.w S lil — — —
_
-
s s
Pr -‘ c F, . i7 )
Yp f i 1
F.e rd,...
N ii . — , &
‘y
Step2 1 . Cc;n j.
C?is iycur 2 C M - - ,
II $tIfl 1 C M!i E MhS! i_,_._ a . — i —
• . on,. a vs a i’,j’j’.i.$ bfl n . P
4 L HaM (wit qãi I tSss p 13) If lbs qu.iifjing p—-- . isa
t.hjld b thiWi ‘ a , .
S Quth widouui wnb —-‘ -- - -‘ child Iys id P19 •. iS is pi 19
Step 3
bC _
em—uII .s
• c..— - ‘a aEa I 14i’UJ. p d
- - -1w_ I • a
• ... ._ . .
.
if . ‘ • —
.
•
•
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i—-u.
I I
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4 fyo l4di ’t l i v , with yuab’ 4 as y
• • P
• Total li. _h-_ ( pIi.iut. l . L
Step 4 7 W 1 . 1 .hr b. a uu m E 10 ol y
Wd sL (P’ ° W-t) —
TM inri-ir - pigs ). (If ouir 9400. aX
i s !di&JulLPIr L) -
b T 8b
Obh’—- lfo, i rS4 u’I. l . LPartU . ) 9 -
0 , TaM IR& 1 b T — .wor
W.i IONS P 27). LOb -
.-
ha TaM ps 13 ._ : w
aM-- (7ft Ub -
. —
— ü Pass) 10194. 12 -
‘ - “ IS a II II1 IS II7 I ia Tmh1 i g I
V.2 or I0S54.
1 .3* I (ii . 31). 13b
14 .Ui 7 I3b r t l 1 gtr, 1 -,otg a, P 14 •. I
Step Lie £(.ir LEA 4a iS wt . av wsiubasi. 15* — —
b Sç iU IR A ‘-‘ ‘- “-—‘ fr app1i M wNk .
a R ,ILR4sb, mo, 31 LSb
girsus a Add Ithas lii aM 15k Th ae ‘ ‘ taul adjr-’- -. - 1 5 0
itI . •&IL& 1$ SlibUilis IX I S o IX 14. Tb ii ycir .. “ uu i -
If lou. ibis t250. as !araM —-- - ae ’ on 41) P 16
C M&
4
-------
: 991. 1040A
d
21
i.3$ Check IYo*w.y,óSoroide, 3lina Ent.rnumbsrof J 1
= wu or 1ina boz 4 th J . A ____
If your ourent ‘or someone eisei can cLSlil you as a aer.i n.t
!b
o If you are ameo ülin seoantew ana your icouss ñlm Form
U4O ana itsi”— aeoucuons. .ee oa e 47 ana cneca ere ‘ t3e —
13 Enter tne standard deduction snown oeiow for your tiling status.
Bus if you rk.ijied any box on line 18* or b. go to page 37 to
ma your s’ ”cIaM deauction. If you checked box 18c. en .0..
31
22
• Singie— 3.4O0 • Head of houaeäold—3&000
• Mamed filing jointly or Qualifying widow’ er,—$5.700
• Married RNii
Suboect line 19 from one 17. hf tins 19 is “— than line 17. ent ’ . ..
.eusrandv-4t 850
Muinniv 32.130 be the inral nimilion’ of azemonons “4 on lice e-
Subti’act line 21 from line 20. lit line 21 is mare than line 20. enus’4s
: .- -
23 Find the tax on th. amount on line 2. Checn if from
____. Tax Tibic rna4us 44-49) or Form 4615 (see ones .39)
e.. ia . . —— —
-- 21
— 23
Total Federsi bosom tax withheld. ‘If any
tax is from Formtsi 1099. check here . 28$
b 1991 estimated tax payments and amount
3 plied from 1990 28b
o Earned inconi . credit. Complete and
attacn &hedul. EtC.
Add Line. 28a. 28b. and ZSc. These are vnnr
((ticS 284 ii than line 27. aui lice 27 em los 28 .
Ns is th,ain.,... .t von seuseald.
- -- — -— -__ ,—.— —_— •‘ ‘ !!d
Stea a .7 Eater tne amount irvin tme 16 .
LI
gur. you,
stailame
educoon.
exesiotion
. ua.
fl Ii,w
— 19
20 — - - ---—--- -.—-. ---__- - 20
Step 7
tail. i.4lts .
L( the
R5 to tiqwe
ow IOL US
:rts inarucuare
:or lion 22 on
,I J&
. I
24a
— SIMS l&v r wuus i &W
Complet, and ‘s 1i &heàl. 2. 24*
24c
I
b
Creditfortbooidar lyarth. k..h1 a4
Complet, and aneck &‘ ‘ui. 3. 24b
a
Add LInus 24* and 24b. Thus vo total crsdi .
25__iubulcthn.24cfrom lion 23. 1W line 24c is more than lion 23.enrai ’4 ..i
25
2$
Advance earned inosm. edat payments from Form W-2.
28
I
27
Addline .25an426 .Thjaiavourtosaltaz. 27
‘
25.
- 29 I
Step S
“u,
ret mdoi
amount
30 Amounz of tic. 20 r c a w ralbadad you 30
31 .oI onwsnsappliedt.,
1999 t ’—— d . 31 1
cia ch.s* or
iionsv orn.r oil
to ot Faron ii
w.2. •
u. I.
32 If 111.2711 use than lii. 23d. suboact Line 284 from lion 27. Thin laths
-— Or OD*7 order far fall i ot , 155 bh
!nL. . Ruom Sum..’ Writi your naii. &LkL, trrinl —-, I
fl’hlflt. d. 1 #L 1 . ph i. numb.’, and ‘1991 Form 1040*’ on IL 32
33 Estimated tax aerraliv ‘us cue 43). 33 1
- — —
sii aus oi , . I on £ save s isis is lam us s— - , ,4 — — on — ‘-——-—-- sa. is in. ass is is, sassisus
alis ioii . ins, us tan.. conss. an. Osmasus is ,... .ja’ei tan on ,... is on au in aisslisS is 515551115 1 1155155
r
a.saCOVVfll
ua mum tar
‘ .nur re uru&
.• -
I
‘ .(sali& t, ‘nuts mists. aUth a.iuus aaonu Date
I
-
prusrsrs
U1 0 1W?
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.II .lIi i sS sss Zip cuss
:o S
— — , - non
-------
frU i- —ji,. ,r g
i 1040 u.s. n iv u i nccmi Thz R*fiir , 1)91
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Label ‘ Y011 0101 0101 i S -a nato - ‘I(V
“
m acns
:‘caq.it
I .
55015*
if $ s tu Aui is a ‘i ii ’s - RIMS —
llttlltS s.stowv m iMSsr
•
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1V0..
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, wa ptot Ill
3 caco iii if !eI iat,i. a l0SJ s . $ f ft 7 I
Filing States
Exemptions
es oaqs I L:
M0 ?S M W ill
O s . Oa S 13.
Income
Coos e of ysiw
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;st a *4. is
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to Incpms
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— Ms uu isis. sr —s 50151101101 Ms. ____________________
I HS I SUUN( i$s.uu 12.3 Ilto. yuig
55* V Ito 5 $ 15501 Ms. ________________________________________
_ . I V iSi s sacs ‘2.1
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—
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- - w u aa aS IlUs. I I O 1403
Ta - mss.lsuwIN IeLoalr1.s..aII I
iAdu .n ..a aIScis S ss 8 d 1
T 5 ( 5 5I55 S 501 . . . . si 4 u . iss — ..- ui- - S5 S iI.
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$ uss i a. . I 215 I ais
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—— — — — —— — — 01 at sa -.;._..__
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ac sa — .. s.. ‘m ’s . ua a sit, 12.
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Fii a say . ..ms a s sss ,gs
21 sat ua.iru 3I ____________
21. This. is tsa
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to. 01_
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to. 01
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at
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s muus 0501 a a. TI u . tOt, —— UVIS -_-_ - ass is as sat
c rIt5 a, to a at as lasa- . ._.
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-— . .‘o i s ’
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-3 -mo at* worn un. I IaGIUILSQ gross inccvuii
33$ C uciiui.C Yosaws.4loroscv.i 3 itic r-.tw ’ s4 oros 0ui 3lino.
-cc vts mgnssr at oaus a’iscssa cove Inc entv iris tots riro. ___
3 it yCit Os icr s mu, io s CIA CI aUn you as a CISIA nil. i’ 33b C
• iou am mimic ttIw lq a seosais rei rn inc your socuss uernuzis cecuccons.
:r you me oiiaa.stas aiuun. see cage .3 ins cneca nile • 3.31
Iteqsu aeteJosons itrom Scneoui A ins 21. . CR
34 ! tv ir- .i usncwn aesow icr vci httnq statitel. U’ I! you
:ecxso an, ocr on ‘ins 33a a, a. go to aaqs 23 to yaw sranas
1 -esjcac, . you cnecreo cot J3c. asjr 3raA aeouccon is zero.
• Snqis-43.400 •M 5 ’ s 1 r iousenom-45.000
• Mini ’ s sing taint,, or Ouaiiymq v ..o inirt-48.7O0
• Msvieo f tq sIo. -; — 2.$5O
13 ..cwici ins 34 tic ,. ‘ins 32
35 Ins 32 is 175.000 or ins. mussy 12.150 y ate tots riurnoer of I4.. . . ctaanss on
ins 64. Ii tins 32 1$ ovr $75 . . s’s ‘sge as for ate inisas to enter
3? 1’— - 5s ucr 5,536 Itim cis 35. flf Sic 3$ S mers Sin ins 35. amer 0 .. .
3$ ies c 4f,sIIs ... 1aiTabic. iC TuRatsSdissaIus.oC ScIssauO.
6 C Fcrn ’ iSlS ties sags au. (ArtiStS. ii sit. I rmo FQsiniiJ $$14 i’• ________
3$ .acc tanu.is.s sgs24IC1Ieca ficm. C Fom ,4$10 b C Fcmtm$fl
40 .ooims.3lane3I. . .
41 uesw ass sic 4.UIIS tsI 110115. . 51551 Fins 1449
4 l , $c ’ s 42 I
43 C , jw lIlf . . .
44 CSer .aw..isisoiqsasLa ’eca4fioma i...i Fcm.3500 ‘
CF c r m s t s seCFonnM01cCFaimuiis , 4’ ’
4$ AØ 5SicsaImmugsa4
4$ Si asawts 45 (tom iww 40. df tins 45 mi’s mes us 40. enter .0.
1 .0
3’’
37 1
I
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.
41 I
I
other
.
axes
IS
50
SI
52
53
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Mi.. . . s jm urnS, w ’ usui
, nt.S SSI,. 1 1521.CIUIU4SSI ISCFOIII ,I35$bCFI II IIS IISCFIYmI 5 0S.
SacS susan, sic r .,... im ones tim ti iue su * Fern’ 4I31 .
•ii Si IA iRA or a auauu$uc cmx maims, Foci s s
A n s IsIISS JlG Jfl cietet OSifti.... 1 1am Fern W4
4 4’ 53 5yØ 5
47 I
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.
I
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,
syments
-Itac l i
mis W.2.
4 gu1
rom.
54
55
SI
57
SI
5$
c.as i nC O lUeim.4 1P 1 5 1 511511 I50(Umx ,
391 i....... 15 OLUU 51551511 51 -_.. 950 I Jul.
causs . _tu. ai m.su , Schssas E)
M1541 ass wan Form ‘MS .. .
bimi tesa mant i—. am 507* is. 2fl.
Otter os ....... . is’s sags lfl. c1 ’ es .. C Form assi
bCF cm ,413 1
. — as a — —— — — —
I 64 I I
$ I
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• • — , ...—_ . . . . .
—
SI uI1150sss, wls5jus s. 50 .Ttu ismssrmal su0VWMS. U 1 I —
Relund or A , .S11of IItO ’ sI L I YOU , liii
Amount Auss ss, 5011TUIE)1IIlUTU*1t1TM I I I I
You Owe asicI Smamas.ws mx5.IO*s .ss531I IeIs IT UO .
A dies, C I .. *m siesas irs....g ( lstssm Sssss . IIs s
ns a .. iecS susan, ic155. suits macv. sic 9151 Fsm IOS ins. ____________________
SI Ea -..,..4 St OInMV ties seas am. ASS i15115 5 in ins 64. I I I UP ’ ” ’
._._ te osew . i ow i -_ — -.. ._ ow use ,,, us . ... __ ...ie —— _ us muid lilt •._— -_— 5 5
sgn ——. — — — — —— c _ . ____ . ,.. . ....... _ ... . . — - _
Hers Ycxiq lmsa
i(ee a cccv - - .: 1 1 ____________________
ot m ’s retwa _______
‘ cryow 5csesus.siui,sesue 1.Q11I11umiqs . I • _____ -.
— _______
Paid ‘ I cm.. —
I I.et-. _ -i
Preparir’s tLtte .
Use Only )
Tax
Com u-
: tJ NIflT
-e ‘.S o
; .ars yOur
: . see cage
: 4
35’
Credits
3..oaqs
— 5 ’
‘ I II
-------
SCHECUU5 MB I
or1, , 1040$
,o
•• P 4 lji uI Ce t
Schedule A .—’temizea Deauctions
,Sclteauis B is on oacsh
‘Aitecn to Foreii 1040. See In uons for SCIIIOUfS$ A 4115 5 (For, 10401.
dO. I 45 .Q 74
©91
SMG. 07
,anlev w.a n Ø per, • ow soc .ssi i•-
CaI loL nor :na g ucenses resmour e or :aw cv 0117 5t5.
i ‘Aeocalanaaen ,aiexo., es .Se.oag. . I
:zasnses : .t ito y iire 2 aoove ov 7 iOT5 3
4 Otraci tire 3 from ne I !r er tre ‘esuit. if ess ran zero. enter .• -
Taxes You State icoaj income taxes I
PIIØ 6 esi estate aices 6
Zter taxes. iLst— ’cIuoe oersanai or ce w axes.i •1
:aqs 36.1 7
3 . dd tines 5 rnmuan 7 —ter me otai • 8 I
IntSN$t 9$ rome morqage mum ano oainm reoonse to you it form 1096 —
You P aid Momemonqagevíta,s notre eøovowiFom, I098.(If
:aio to an unoivicue. snow mat oatson s nams anu aoaress.i
:aqe .19.1
:
9b
i 1Ot%1I 0 ints riot reoon,a o .ou on FQIm C30. See
Tifestus
- ‘anger nsm cto,m for sosais naies.
:auctiote. 11 ,rP flan, lnt l5 5 fl Form 4952 1 reaijrsw. See u
C$5s40.) . . . . I 11 I
12 A05hnss9ammu iI1.Ent.m,e,ai. —
Gifts to CauDum sf y a maos a cnris e co,wssixn ana
Chanty 11c .J a 0Ilhi 6t maim ass oiqe 40.
13 Con uvortsoycasnorcnecat 13
:aq. 40.1 Cute man caw or ateoc. (tbu MUST macn Form 6203 . :
•toveS500. 1. 1141
IS Carryoverfvomanoryear. . . II I
1 5 jØ lines 13 rwouan 15. E ,terme oat. S ¶5 I
Casually ass
Theft Losses t i Caauanv or me tO$atesl minion Farm 684$. See oag, 40.1. ‘17’
Moving
Exosnus ‘a ‘.‘—
j • 11 Jnr,mours$Q sin yps eaoenus—oo cravat. nuon
ass M0 Othse ouus. ao eo’-’ -- .-’u . etc. tmu MUST anion Form 2105
Mlsesllansaus 1 ‘lemma. Se. msmaciOnsj
Osduclisos Ø 001 eassitum (irivss iisnt. ax creoa,a cn. sai
0 — -’ Sni. St04. Liit type mo amoum
geaifer at
IaCaticSS 10 .....
:eouctnsmj 21 umiaao L !J
* au waIO4IIas32.
23 Fi 5upIutefl o ,oy2%(.02t
2$_Si sa tIns 23 from line 21. Sitter me vssiAt . I? lees nm 51 15. enter .0-
am.,
Mlsosilansa us
Tot
Itsm sxed
Oeducttons
25 Oømmtusanaage41 O$ aitiL List psenaensan P
--
p •
24
211
—: 2l v it me amnown on Foist 1040. , . iz. s 5100.000 or ‘ess sdo.000.cr 1 ! -
leI$utmanlatu$ngus.r’vsy .;. 0lines4.8. 12.1117. t8.24.ara
23.E ittemstoiat ei.. . - p 21 I
• W itte amman on Form 1040. line 4. ii mere 111111 5100.000 (mom nan
550000 1 mimes muting s.oamazei t. se oas 42 for me amawn to emr
-‘vru 8. amme roomer i F mt 1040. Iut 34. the LARGER of in
______ anuses on ens 21 sso s or vow stalIiJ&U ceoriceon. -
p —
z / / /
z
/
For P.,&,...m Attirlri Aet see Foist lOSS
C . miaaio
5cSedi s A p.m, 104 1151
-------
1 1 WO*fl 0 - . .. • . . ,: :. . .. . .: .1 i C.4 $Iai numour
Schedule B—4nterest and Dividend Income Q8
art i you rsc,, ou more iran 5400 in Iaugu iniere i income, or you are ciaimmq ins ezcius on ci mutest Iteill
•inss €8 U.S. savings aenas iuu.o after 1989 (see oage 431. yøu must comoteus Pan i. L .st AU. . ,ieresu raceivea
ri Punt. If you , ce i.ea more iran 400 in asag*s interest income, you must asso comousue Pan iii. it you r.ceiveo.
icome s a noliwu. .. interest was acu adv oseongs to anomir onion. or you receives or oaua accrues interest on uecuruoss
‘rall$*Srrua DetWeen irnereut Daymem oases. see aaqe 43.
:ei ‘esi ir: re -mount —
- I fltSfe 5 rcome. Lit rams ot aver—l any m,,erssi rcome s ‘-:m
seuusr.unancea mortgages. see ,nstrucuons arc ‘st zr’s interest fiiit.i
“IOtei iT:Ou
• ‘eevea a ‘ “
‘ :99- t NT. ;‘•
‘99 -0I0. Cr
l ijD siflUt.
::auurnem. :m
FOklf0i nrm
i i me t.
-arne U ire .
ivet are
-e icisi in’e.eei
“:wn on ‘au
- ‘ S
2 Aoo ins amounts on ins 1
3 Enter me exciuaaais savings aorta interest , It any. from F rite 8815. ne ‘
At t Form 8815 to Fern ’ 1040
_4 St bua t iriS .3 from line 2. Enter ire resuit nets ana on Form 1040, line 8a .
3
.1
Pert U 1 ysi. 5 ,.d lusts man $400 ‘ gious _ IU ,. anwor OiuSr ll htUon* on steeL you mull II4& Puite
OMdsnd ii aM ( IL If you . .. .&...4. ass nommo . , tIJ Je that acWat Ditanq to mother DillOn. S OS 0095 4&
Incom. • ivioena income
S os 5 Olvicinu incotute. name of aaysr—nauae on tries ins clonat gasi
:40n ‘8 OiWi uoons, nomaitacis Ol5tflOuU lis. 010.1 ‘
inn 431 ______________
901st if v
,csiv.o a , mi - ____________________
13-OIV.
smUul
: ‘atimem. ?cm
i orceeress __________________
. . list me
‘rm s namsa$
‘-5 O$VW WO
tntur ne iotai
sr%Owfl øfl inst
m. S AdOthSwiaunisariltneS . , I
7 Cusonguiaonstisto,es.GitwnsreanaonScnsotmO
• mIuSsSU1eouLtorFo,m104&Ime9J.u 3 I -
• MS uus7an 8 9 I
10 Sub ectbne9?mmNnstEnts,ute,esutpesmuitaanFonnI04O.liflS9 1101 1
f , g g , S i tø teo 1 an, Outer qOnS or {JIUL
see ins insusj n fur F mr 1O4O i ,,,e 13 ana 14
Pert III If ITi Ots ._ $400 of U%I or $b4S4iJS, OR If you laM C f lU.95 I000ult I I’ WillS y Ne
Forsiqn of. are v t ts, a tutu.,.. vuus. you moot aa...r oaM ue- .s ii Pert IlL _______
ACCOUntS Ill At any urns awing 19 L 0 ye ’ live an intetsst in Cr a 5i tstuJe Ct CUter IUUIOVWI cveri TuflaflC ’l
and acrnuws in a fom i coünuy ..icn as a cans account. SICWIVS3 3C Wfl. Ct Outi T;n s tIC
reign nteifl? (See aigs 43 far sx aouons inn hung reatanumems tar Form TO F 90 .22. ’.)
b if s. enter me name of tie foreign COUIIOY 5’ -
I S a . 12 WSv VoIt Ills of. or Ustes$1 1 ,r to. a oust was e uiu curing 1991. wnume’ or no
. 195 ‘ I OU flCVS In, O4J1 . fh.. i..t..r5. in it? If . s.’ you may nave to fits Form 3520. 520-A. or 920 .
For Ii. is P511111019 -j ____ Pouq ion— dathitiS (Fepin iOOU 1W
-------
SCHEDULE C Profit or Loss From Business
Form 1040) So Prosn a s ann.gs
Peruis,-.n.u. solas vimure. ito.. roust nh Farm iO$5 i
•- . •..iii iv
AIIICI, to Form i040 or Form 1041. Sse inacucucsii toy ScJIsøuis C tFo.,w 1040). I .aiiwe rio. 09
a, :r cr1etof Sos . swamp airmer
—eioai ness or ororasslan. rc...ainq crccuct :r service see insrnjc:; nsi 3 E er crincriai ausinsss C aS
cmoacs .
C name 3 Emui....., 10 isaas tios MIS
.jsInsss acaresi unciuaamq Suits or room
C.tv. mown or cost ofOce. state. me ZIP coos
-ccournmnq meuio (1) L . Caso (3) L Accrual (3) L Cuier ISoSQM
‘.llUIostsi t $l0 tO — Low at cast — CtI er aoson — 0 1$ not aociy ut
iaius closing mventsty (1) L at (3) or mumist (3) L examasom (4) L :necxea. simo ins p, I YMI No
14 .111 Ulifi M V CflZSIQS II cijwwas. CDsti. Cf V IstR Ouiww . 1IO1isI Ill. CCst IFmSSV? lit “es. macn exo,sgizocn.i
i you matenijip oar . in me oegatcn at V II I ClOmsis awmq 1991111? 110. see TO? uiiu Iiuans on toi$asj I
j ‘rm,s is me tint Scrisesas C Ides mis taxais.. oneos iiu,e • L.
IRT II Incam.
3ra (si. 1$ 0 1 saiss. Cau s. if fO.i dh.....l w iU Oj J tO you t Fov,,r WI Inc — I
?afurstv ereeiovse b oa an mar term was cru,.... . as m mwucverst one am o s
2 stunms aria iiiousti . . . 2
S i0Vi i r iS 2 tram Unit . . . 1
4 Cost at qOOOS SO lO ifi m tins lOon apse 2) . .
5 SuOVICI ios 4 from me 3 aria ester m gross prone Phi. . . . . . .
I Outer .. ...s. unciuos Ftoaru ma soss or I us tax croon or resist as asma. I I
7 A hiss S moO. This. you gross .w..iin . 7 I
I iI Ez wu. sCaia on: &rter exoenses ic r Cus,neu use of vow name on line 30.1
—
I 04 1,.iV..9 . j .. 21 asast . t. &. 1 3 I —
9 EsO deOfi from ass or j 2$ Sunuiss Inst .. LiI.I S Put nfl. I —
SiP4 li5SW5VU RI 9 — 2$ TâjiIi1Sk .,. . . . I I —
10 Car ma utic ilolim... isi s 2$ Tras. teas. ito isiwm .
Fostu 4562). . . . 1 .......... a Term. . . 240 I —
11 aria fuss. . Iii — I
‘2 19 I
• 3 2 tOr-ws -— ans se on t 1 I — ‘ . I
*aeflhi aecvcaan ins sousa in C
:3n rn (US ifl 5 fl$ 13 I -
I - _lw
14
to i 5rv 1asonimslII. . L i i I dSu ISish 1524 6ff 0mUn 524 1 -
15 insiosios toOl.? V l S I alarm). L — 2$ ust s II
. .
a Mopsa s to iUI ito.) i . VS 06111 -— (I lips 556 MIsUSE
bO I I h r I ’ I—
17 L 1q ito Oiwl w I iii, . .2. I
t S OMOS 4. . 15 . . .._.IZ .....
19 P4IIIm IISISCIOMIMl.9pMI. ,I i I__.J
2$ Ru5 tuslsS..W’—-- I —
a vatiau,. , .um- — .
6 o I 2Th Tct sOlar IMIrihIS.
2$ o amoiaw in casilvis
use t ys i tome
2$ omfr lam
39 5I$ 5 5 tar sias i 5
31 MiS profit as (loss). $rbvUS
antis me nit orate on
go on to me 32 Ifl$st s.
32 .1 you nave a loss. you 11(1ST
I you rwtaa 323. anti,
umasonass. i.e easosari.
for m i s I 6vou i 5Th. These ar toW 1
SuOlas line 25 lion, ale 7 .
at l I Fasuis a . .
me JO from me 29.1? a arms, enter ions moan Fanin 1040. brie II. Also
Sonasas SE. line 2 (saseoiy 1a ..is.s . see irosuosasos. It a sue. you MUST
see amxaons
cllest os eas as iis.. your auu . .iwI.is ii m l stavep (us . .am.arl.s .
me mason Fømi 1040. IM ie ‘3, 59. ligle 3 f 5I55p y
I? vasi .—--—‘ 3 . you MUST anosm Fasuus 611$.
I -
A. — —
La ..’ —
3$ I —
I
‘21 I
3211 A’ IS his.
I 3 L SUS $ IS O flst
—
C l It3$IP
Satisisis C (Fsw ions test
-------
: ... l
I 73 U1 .ost o Goocs So’o t e
: entorv at ceoinnirta of veer. ut ciTtefem Tam ‘ass veer S G:csina nvefltOrv. at aCfl cxc
24 jrOf $ ‘isa coat of gems wimatawn tar ceisGilaI use.
:s S1 Ot accr. ‘Do not incittos !aiari asia to iourSef I
:5 :enais arc st cciiee
:7 2:rer costs
:3 - :c lIr e5 : rcuan 3
9 IVSA(O(V at ena of veer.
0st of aoaas sold. Suctract re i9 “em r, 8 E e, ‘i’e ‘ su’i e’e a a C :ace
ariation
a
3
‘
35
6
7
:a
:9
•O
r JYI P,inct aI Businses or Professional Actyity CoQsi
• :ate me maicr cateacry iiist ciii ciscrass vow aCIMlY dvitflin ire major CaIeOON se ’ect te 3CINIIV coce mat moss c:cseiv G1flUIISS UlS
.sSifliSS Of O1OTIS3 1Cn mu 15 fl 5 QflflC!O2J SO%UCS Of vow au or riceicts. Enter tICS a.csqit COOS on sags I. ins 5. Fcr e.samee. ie
:ent is unoer me rnaior category or aR. Es es via ins coos a S2O. - Nofat it vow cnrvow scw’ce or income 3 rmm ran?uig ac3bi . YOU
c ’wa tile Sch uas F (Fom, IO4OL P’avvror tass iron? arvmriq.i
Agncultura$ Servscss. ‘552 Oil & oii 5O P OIIC fill_v
I 719 Oi anw’q & J’-.-.——l — iVIIW £535 PUiiC WUilICSI 1IIC ____
Fc’vsUy, Fishing ______________________ --os S , s,wiq wv_v
_____ 3730 te w at IU
R..i Es ts e l l a ham- - u_vaes ewes
30 Anii”li ur ’cn. cow ________
5535 Ccata e & issuers at o.es I eelS UIIIIiSS 1S4_v. &iQ..w... .p ______
33 Coo wv_v ?SISISIOS 01 5 SIC .I
• 2 cairn ‘acer a ms. .. . 553 OOOiwi é ISSW 5 at OUIV flU I Oilier rn_v
:r osslv 6551 Cmsr o .. i us
v”o. :320 . . si_v mg_v a atsu..
::e ‘w.v sicw ‘OO 4S S_v , w.flV majia _ v I4S S £ OICW . Psi _ v
— n’cwcws a &nascisiv 7’O Su . iO l _ v 5 £ — — SICUIC I 237 Ciii S acW 0 5 5$
—•iMIi O 4 tacoma - ! -fl. . . — •95 sni g. maiss a :ciJ.sI - uS _____
L mS_CU - 33 :s aolu of cuI a aosmoia -o’.aca
•:s i.:;mq ____ L, aCSs I C Iq5..- a —
9 ‘i. ’emmr. 11 1WP5 . . , _ Smrvscss Personal. • a wv cissws
Construction Pvofssasonal. & Business ie Con-assEss usgiansu
___________ c
o e Cosmos. ogeasi liar own Sirv,css r AØ-o._v iso_v. W V —., . I
— a £ Pa .. -. . a ian . .. . i
e. sag T .ss Cwivmuaam . ._sas, 19510 io.. 7475 jarn . a IS_v v. 16
SS_v )IIS Ma_s sEas & miss iajsi, aj _ viq . moos. a
oaia c& -- , a . .... . _v _vesè si_s _____
_______ _____ - p
:.&55 Ccn_ss ss I ——- - - iI S 51 .
0273 Et. ‘ei macas, 5174 Oi......... .
:zii Ma1S_ . civ W a. ITWU, & us ‘_s - —_ ,s s o. s cities at o.’at ________
____ SISI P ••• ••U• WSIIC £ rnerq. 9217 Coowi u.ai ones or a_s
0233 P’um rn_v. & - I _v o . a oems — . . - .
2130 R0WU . sEsig & .. I11 ThUS_CI v.. I C.-— . si NIVU & s . ass . .-—- —
0553 Otiw s_v mass su.... . . . i agssi. s_vcs, a muss ____
• ‘925$ Ottu,jkM P_s_v a sw_s. ______
Gins. CaJW ...de ‘9813 VCSS I_s filE 92u c ea_v
• 75 i4 .onw a sow ccnuu_vcn ‘037 Cmi i PICieSIIUII & ‘UWUSSIS R . a _____ _____
:o 59 0% IS_15 9431 Offices a Es S_IF (IS_s
:034 RS_asIIa WoEs 5 . 1 . . .IU S _ I 3 . .r — —
:!ae O:Nsr ‘mow cOniV1 _si IOns 3 3 I at ISEsIS. P UCII O u -
vmq. areas catiweacil. .ic.II . ,_v s, 4 J
4953 A._. ...* ms_v. j... .Jsa iSIS cm ii il_si I ____
Finance. Insurance. & r- _ . esso.. Ijris
Rslate Services ails over . . — ____
a _ v. . t_s . _va 3Q11 -— s_vs_v I1V as _______
. . cin. .. -. wsi&i a i s’— a F _ . . _ .s s& _ ticucs a _ v
____ ______ _______ I . a iv
s _ sos 8 . -.—y a: _v a i . . , .I. ...4
7715 As ..... .. .4 atsE ___________________________
Gill Ce _ s u _ s _ v a . - — 2151 00w us_s_v m
_____ liii. less_v er
5153 mewuues es _ v at Uua. . 511 5 er ‘ T _dL RatslI .—SslIIng
5248 S_lEES — - .-— — i 0114 Cf ES - _____ I Good. Individuals & _____
us _ sag. . — _ vs SITS C_vow -— ____ ___ __
6130 iip. _ —.. _ . _ v & i in . . — — - -, . H iiuhokls
5Th OVES I...... — I a
- i_v — 300$ ‘ -e at
at_v_v areas rn_v_s
M a4II 1c c_v _v. .._ . __ a 30’s 51M5 ill R _v IC __ J1UIU ______
P i..i ig a Put ’-’duig CII — 3Q51 v_v
‘7715 Cats _ v a ,_s 5$ _ _ v , $ _v, ______
0671 Ao l_s 8 es. s_vs sesias I . em. . zss t3 _ v-v
• i ES _ sc a Sia U _ v IS_sIUS 0751 Ccia _ vat :
• 073 F....... n _ v arcs _ s ______________ auiu. a — ______
253$ coos oics_s a 0 _ si _ v COOw at — r- Oa.U’ , 3W • a — £
$1O Fijmisws & h*NUS I Crc xi _ v 1.,.. I — I . . _______________________
6IS Lasser h... iI . - SIC I - , el, CTOIV 1! i_v.
:335 Lmoer&ouw efSs_s 51 1 - - - - — 3m C_vIq.mUI& • f—---. __ L . .i4aJl q 5
• SS maw —.. . a nuaaw. EECI - . T73 (s_s_v_v a 4M1 15 3513 Ce_v. . .1
:eri .orr. mass eros_s _s at 1 14W 1 1.00lE9 3755 5 I l_S _______
• ° — • I p , _v a 315$ 0_s aos i - - ‘-3’ , _________
:359 -.nuwig a at ’e I i i_s . ___________________ _____
• 032 StOIIS. c *v. a g arcs_s 9j4 £ i . . usi
3553 Tuas II I 7017 sjgs suisces er a_v 3355 G Il_U i_vS ______
053 0_s _ssaissi S_EsSS I 3319 Miii W 0_si
an. a 3333 rn. - — & 055 ________
Mining & MIflirli X 55 55 ________ I 3 3
•243 is _ . _ .. —. I 3S97 COW 5 _ — ________________________________
S37 C i a AUw m l u - ___ 8 . a _ . . ‘ i.. ______ . _ v .
• Ill U_s wivat 33 p, ., ,,. . _ v — — I v __ _ v — illS 15 _ v IC
Bi_vq. s& aG_v li_v
.I8 Gui_sq mats_v ousus
.&&57 Warcw.,_ssi
473 Nurserisu a qvasu sass ass
433 Pii . gi a — -—‘ — ass
c_v a
0612 Gaii.usu.uuuu’q s_v
cas Cat_sq seven
3033 Or_sq si_v SEC_vU.
:ucs. il_vU. 115.1
079 Ematis cesus. mues a wo.
.. 0 Giaasv stein iv— ’U sE
.2 !’ La.ert_vs
:335 Sa moos sm_s imsu
•-cc ’ a. railer. n_v ‘cci. stc.i
F1_so.S £ 0 _ vs &I.......
: us Camsiw a uii . u_vs
3970 Futints sEs
4317 MOms S_si CUE.
oar c sv . ..Jis.
4119 I45 1CI S_si
.4333 P. 1_v & mccis _v
31 W.a &. _v
3711 Va_v _v _______
3731 O0wq_v — ._
- - -- .S _ v less
.1513 50s au _ s .
5017 locasu.— —
‘455$ Camsi £ at_v S_lU S_Is
3217 OruS S_si
- SC s i Pa_va .— - ‘s
- U i co _ v __
3010 Pus Oil _ S I_sS_
4620 Gilt. n_vV a_vs woes
,-33$ MCCIV. l ay, £ _vU WIll
411 .teesiv I_v
- aus ‘ r a _ s w go_v asus
5074 Mocas es_s i _ v
.119 Co_v qx ass
• . 16 51 Sossug go _ s £ OOsiS _v
! St v _ v
1814 U • — I_vS_ I C
‘i_v_v_v usts
‘555$ Cow_v S_Is
TrUs. WlsIsms* — (IW$!
I Goa $ I I O If kuuuu. sic.
asusI. - - — lit. ,... .
I w_v _v
253$ Aquuu er_sw u_v s_s-
ea. _v 5005 u —
ci ,
511$ 1 u ‘ _v —
— Vis&
. at.otL —
I 2515 Aquu at — er user....
5 0% at miss
C I — -- — - -
250$ S_sq er _v
—— —
($15 A ... —________
5312 Itie £ 155CI5
U I Il. •i
i_v _ v N_v
6114 l1Tt ______
TriEs_vs £ Sr —JS
533$ Tn _ sq ie _ sui owl , w ’TU
5551 WIlIF . ———.
5.0$ C _ sw — us _ vs -
-------
SCHEDULED Capital Gains and Losses . 10 No. t $. C14
Form 10401 (And ReconcUia on at Forms 1099.6 for Bartenng Transacoors,,
iiismicocms tar Sd1em s 0 Form ioa !I91
-e e .ius_ r uc i 1 F r mom U&—ijjij ’ for wise ii n 81. got 3ctsøu s 0.1 (Farms 1048.1 OI*ICS NI. I 2A
3msm WOW!, Oil u fm 10.10
auoon: ‘ aa tt e ‘cucwr q amounts e cno to you rat ‘991 on iorm ,099-8 ai’a r099.S ‘or :ri suasonzra sws i , rrcnr
nsacuans InV OMnO stOcJts. ocnar. as i’ a s g gt otoceecs rmm roe esram rranzaccro not rooatrsa on anatiw tanrr or
• : ?eouse II 1”! t t3I aces nor ectiaj at B a. gn i uci. anao a sc narmv excsaisiinq n e cifl,.
I 1Th1 - Lo am-_Assets
1) O 1IUU ( I Oato aesasem (Cs Cams em I (4) Si s I lfl (033 0MM
iammss. 100 s 1% I
auwo ffosms,oss, , I U4)snwsem,ui
:,,u,,so a, M s .. c iv. vr.i Ms.. c i v. YTJ I isis i u I uasis m •uoes is mm is
L Short.Tentv CaD,ta* Gains and
Pl.Id One Year or Less
a SIOOMs. Soiiøs . Other Ssa,m... a i lS R.th Catais. kr Fons 1091.8 and 1091.8 Trvua.cemms. S.. m .m
b_ nswam a1oeaO-l_ ,romoai iBcmeaO .fl ___________
i To1tho1MSa Pi4csAmeuuiss.
d SC0nan nId1attines1aaflS1b • ‘I to
I 0 Other Tram jw.a i0o NOT Ineftjds rs a is from E wwia 10094 oii this Ims. Rooort them an i. Ia. )
I
• I • I .
I
I
I I
I
2 Shmtorm .i from sais or excrsigs at yew nouns horn Fame 2119. ins 10 or I4C
3 Shan-uum, gain from inotaiknam uz from Fame 8292. hn• 22cr 30. -
4 Not unon.fime gum or (loisi from $ W!IM s. ano fe Itrtanse. 1 • I______________
S Shait4wme eaMal loss carryover from 1990 Satlsthis 0. tIns 29 . . . I S I
S 1d0bneula.1b.1d.ano2tP1rouga5.uico*a1vmsiflanaIg). . . . t I ‘I C I
7 Mel steovt.usnue - —“-1.1 gum or iIo Ccn s calijnns ill ano uap of line 6 7 I
i 1Th’. Lonq.Tirm Caaits$ Gains Lcss,e...A.a.a Held Move Than One Yes
S c Stocus. BonOs. Other Seemess. inS Real Es is. auj Form 1091.8 ann 1091.8 Tras’uacuon. ,. See unuvuceons.
I I
I
I I I
I
I
I
I
I
I
:
ss. i -is from Fonsis 1009-Ion Seth 811. nspsn mum at I S IS 554
Bb ,%msns non 81iusao 0.1. tie iti ,
as ToeIMlelusPHmsMusuimi,
Ad 5ColIdlOfttiIesI*ailSIb. • Is
Id Other T , ...C ‘- (Os NOT es cfo
r i. ,t,
I
I
I I
I I . i I
• Loêq mm’ gain from ass or s.ut.n . at yew none from Fame 2119. lIne $001140
10 Lanq. ’m.cer i ai ns1auImebLsalss . orn Farm 5252. line 22 cr30.
tet Ionqtenn y 1 or 1 10am from oomisom $ u auons. area ttOuciansa
12 Cians gain c ia ..amons .
‘3 Gain from Farm 797. tIns 7 or 9
14 LGt .t Ian Callyovur from 1990 Scriumas 0. ins .36. I
¶5 A4ullnssoab.ed.and9tcuga14.incoIu1, Iflanaug ) . - 15 II ii
19 Plot be-term cse55l gem or desk Ccnmmms coarse sfl ann igj of butts IS • . 19
.__________ _____
“// / /; //
11
For Pa &.....is lesuenon at r— _ . es Fern, 1040 msuvceo.
N _________
‘ El __
a.Ns. 113354
$081011.0 (Foils 10481951
-------
.eou is , •I 4Ol • :crse—’ .i
ZA
‘..
2
rn& nç n or -‘ C40. Co rot ent name am wc.ai s *a,Iv r j .oam in :own on •- m s’ce.
. ,. ,
I m a iulI Summary of Parts I and II
17 Comorne tines 7 asia 16 asia enter tne net gasn or tosm nene. it me result is a gain. aiso enter me Cain
orni 1040. Iris 13. Nose it tcet tines 16 arIa 17 are gains, see Pert iv :esow,
‘8 :urie iT satsos elnsrne c ,anaasaIcsalonporm 1040. ne i3. :re smallolor
‘I
.
a The 110551 on ‘ins I?: or
b iS3.000l or. it mtene Sling a seoecs:s rettulTi. 51,5001
Nets: vVnen nawinq wnemer line 18* or 18b is smMsv. trsar ooui numcen 45 OOSIDVS.
‘
2 .rnoiete i v ’t V i? ne uo on line il ;s moc, man me uoss Ori ins IL OR if Far,,, 1040. line 37 s zero.
ith1 asL!I Tax Computsdon Using Maximum Cap,ts$ Gains nate
USE THIS PART TO FIGURE YOUR TAX ONLY IF 30Th UNES is ANO 17 ARE GAINL ANO.
ou cns es Fern 1040, You .r:=ee
Fone 1040,
illnq stese oos: AND Ins 37.11 omit Siq stem asit AND
Ins 37.11 Omit
543.300 3
341.075
Zor C 382.150 4
70.4S0
ii msamo iaslmmFonn lOaO ,Ig ie3T . . . . . .
20 .iter iris .... ot line 16 or urns IT. .
21 Subvsci ins 20 from urns i9 . .
19
20 I
21
22 £ite a 120.350 ii you ne’ an fdinq sens: ooz 1: b 134.000 it you cnscssa tiling 31* 54 oos 2 or 5:
c SI? 000 if you cr’sensn tiling stane aet 3: or 0 527.300 ii you cnecae@ filing 51*54 005 4
23 Enter ins at urns 21 or line 3.
24 S 0ira iune23tramirns19 . . . . . . .
25 Figig. ins sean ais ensias on me 23. Lias in. Tas Table or rax Rate ScTie ’ wnicflsvsr ano”ss
26 Mi .doulyWte24byaa%1.28 .
2? 500 Ilnei 25 and 26. Eitsr hers uto on Fern 1040. line 33. and ctiscM ins box for ScIteause 0
22
23
24
25 I
2? I
iRiiwa Cagitsi Loss Carryovers from 1991 to 1992
icflon &-Canyovsr Umle
231
251
- l
.
23 Enter m ainsias from Ftern 1040, line 35. If I loll. ecluole Iris WIOUll in o .w aies
25 Gitsvom bIEmI5sssgaodvsanieaIr
30 Ccs2Sasia26.Ifasor1*se .stmi0 .
31 Enter via ..alI of line 29 or ‘ne 30
Iaolthn t—Elmit .T.mi Cassse Loss Can . to 1992 ( Com u s ni otvv y
ri lines F asia 13.1
33
34
33
35
. .
EnerIrteqw.itatIV.fromirne l 5.
. . .
Enter ins encia’s from tine 31
I
Add lines 33 asia 34
Shon4eim .nts lose asn to 1992. Subiriat ins 35 from ins 32.1? :ers or tees, enter -0-
33
I
35
I
Sacs
on C.—4.onq.TelTh Caase Lass Canyovsr tO 1992 Comoisis oils sscvon omv it triec, us a a
as on
oom lines
16 aria 18.1
4
,
.
33 Enter me gem. if ant. fnen irns? I I
35 Ent.,m..mia ’ stromms3l 35 I
40 EntelvisaniornLufe ly.framlme32. 1401
41 Si aubned0frteiis3tifzursorte .s.wmi-O. 141 I
42 i 33I 4$
I
...
43 L 4ern loasab , .rts1US.th bol trn.42 frornims37. If nesorme. situ ’4- —
. L!1I .1 ‘ s Method (Comptat. tI te pan oiiiy if you eIsa c ‘ul 1Ileflt
m 1Iod sild JuØ.dt a nota or thir okKq .’.orI at less than full face vaIue.
44 C?t I Pius if i l 01$ of the J....i* ....III4
45 Eneromboewam5ncCr00mi u’- ,.1 .
4$ Enter ins of vasumion of ins note or aver . . .
Ij ’I AII RiconCillS Ofl of Font ’s 1099.8 for Swsnnq Tnunusadons . .I’°
(CompIsts thta pant if YOU received on, or mo FQm1S 1099.8, or suOstituts ‘ ‘, , , .. ...
statements rioortiflq bana g Ifl UW44. an torn, or saneous
omi 1040.1*1022 . . . I
as .Scyussjs C. 0.2. or F (Fern 104 , I 4$ I
49 COw fern or scnss e4J1IaM (If . —.it_j-- .i JL-Ll rs sicr i—at 1 *Cfl aaaioets moms if
‘Si
50 1 ’ toI *00 1 1 115$ 47 ttvneqi 49, Thlo ulicias mass es vie sonis as ale tone baiI&.9 u oine on ii
corme I0994 1110 .. .... m a tar u — [ lK-.I . i 50 I
I
Ca
.u & iisi au.,rT
-------
Who Must File Schedule SE
‘cii must :i e Scheaute SE f:
• Your i er earnings rrom sed-emcicvmenr from cuier triaiT ctuurcri emczovee ,nc:rne lime d Short Scheaule SE or
ne 4C or Long Scheaule Se were £400 or more: OR
• you nac cnurcn em ioyee income as oeftnea in me insuuctlcnei of $108.28 or more:
AND
• Your waces land tipap sub;ect to social security ANO Medicare tax ior raliroac retirement taxi were ess man
3125.000.
Ezc.aoa, it your ont . seif-emotoymem income was from earnings as a mintstei memoer of a rei,qious oroai or
CM uan Science pracaboner. ANO you filed Form 4381 aria receivea IRS aocrovai not to be ‘ axea on
moss earnings . 00 NOT fIT. Scheaut SE. InsteaU . write Ex6ln.4- arTn 4361” on Form 1040. brie 47.
Note: Most ceocle can us. si, n SCh.diJ SE an üus cage. But you may have ma use Lang Scheaut. SE an ins cacx.
Who MUST Us. Loiig Sch.dut. SE (Section B)
‘ou must use Long Scheauts SE if ANY at the following agpiy
• You receivea wages or tics and the total of all of your wages land tIPSI suoiect to sociai security. Medicare. or
raiuoaa eti. najit tas pius your net earnings from s.f-emøiz,iment re more man 553.400:
• You use either opuonai methoa” to figure your net eainiigs from self . emulu,imem (see Section 8. Part II. aria
me mnsmicucn*
• You are a m t.,. member of a religious order, or Ch rISIIafl ScIn practitioner and you received IRS acproval
(by filing Form 4381) not to be taxed on your . wwlgs from these so*aces. but you aw se (f e .’U*O inuIfl tax on
other earnings ;
• You had church employee income of $108.28 or more that was reported to you on Form W-2: OR
• You received tips suplect to social seourity, Medicare. or tSIlIOad retirement tax. bUt VOU did not report
moss tips to your emoloyec
Section A—Short Schedids SE (Reaa above to see if you must use Long Sch ule SE on me bacic (Section EU
I ‘let t 51y11 r fit 0? 110551 (rOn’ Scrisai s F iFoim 10401. ni 37. ano farm £cheauis
<-I ;Form 1065). lins i Sa. . -
2 Net woflt or (lass from Sdiseias C (Fan’ 1040). lmns 31. and Sd’ieaills K-i (FOfITI 1065). lifii
i Sa lom.’ man ( .Jw. .. .q . Ses masuasons far ams’ income io reowL . . .
3 C iino..Nnss1wd2
4 liSt . ,...ji lets sul-arum i mag& MIlleoly urIs 3 by .9 5. If 1 5151 5400. do not fits
INS 5CI1StIll you do ‘ ose soJL.... 1 k, m ,n.itts. ‘5 ’i you , u U 1 w 55 a’ ac and
the root of yo( 5 ’ sscra5 Mi 1 J. L W1UU&á . .&.IJ11’J
pjr 5 — 4 553.400. you ,, ,o ( us. Sf55, Sdisdi SE. In’
us Long Schectlls SE an ins cact
5u. .S.111 --- 4
• 153.400 or lets. mutely sins 4 b itZ% (.15 : ‘0 sns the rum L
• More trIm 153.400. b,jt t sits $‘ ly 515 51555fl il l r-CIU Of 153.400 by
2.9% (.029). Add $8.170.20 to vie muilli ai sir vie toot.
• 1125.000 or mars. eniar 110.240.60.
Also emit mm. amman on Form 1040, line 47
Motel Also s’, on l o , ins snoia r ftmn ens S on Font i Ihnt
WHEDULE SE
Farm 1040)
Self-Employment Tax
P’ Sno wm.vurrg tar Sctesot U (Form 1040).
‘8N0 i:. G &
MmmueFenaI0lO.
.ame or cetsen w fl sot - i. mcom i sa snowim on iom
O O
Sociar ssoimv umas ’ or cerson,
.viUi IIlf-411 1W41V1155 11 ncorne
‘91
— 1 7
2
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—
4
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For F ....i P”t Aet Feint lOSS leotvot .
c iim.as
_______ s. iron. ios isor
-------
:
• ‘.r
:r—’ . .e ’ei
7 : ,
iie or erson . ‘rn 3rnT-.mo.. n1Irn irc: e ‘as snown cn - - -.
:ai sac.r’i .:r : icri
in sest ..moIeYmsnT .fc: -e ‘
5ec on 6—Long 5ct .aut. SE t etore comoteting. see ii you casi use snorT c eau:e E cn tr.e amer sice
ecvcr1 i
cu a e a minisre, rrernoer or a retigious orcer. cr C .r.suan c;ence oracL’!:orer. i-NO you nea Farm 4381. ut you
c or —ore or Other net earnings rrom seir-emouovrnent. c ecit rere a ’ -c ::ritirrue w,tn Fv•t t
3 our :-:v income suocact to sen-ecnoiovmenr tax s c urcn emoovee income aria you are not a minister or a memoer
a re ,a’ js croer. si i “rice i •—rouan 40. Erter -i)- ri ‘ne 4C aria Co O re :a.
is imi Selt -€maioynient Tax - ____________________-
C
9
10
11
2a
b
C
13
14
IS
:er ‘arm :rorit or ossi rrom cheCuie F Form ‘C. 01. ‘ -c 37. asia farm oarmersnuos. Schecuis
Form 065), CS ISa. Nets: Skia mis line it you u • ti l e maim coacnas memoa. See
eauremenrs in Pan ii aes w ano in me ,nsrnjcvonsj I
‘1et cront or tiossi from Scheauin C (Form i0 0 ) , line .31. asia Scneauie k-I Form 1C65) , .rc
!a touier rr an farming ,. See ns ’uctons tar ocier tncame to reoon. Nets: Skso m is sine if you
ss. in. nantvrn cooanas mernoa. 5e reawr.nieus in Parr ii ceiow aria in tire ,nsrrucccns.i 2
Comotneitnesi ana’
if line 3 ii more man zero. muitioiy line 3 by .9235. Otherwise. enter iris amount from ire 3 here d i I
if you etectea one or ooui 0? iriS ooucnar meatoas, enter ins morai or lines 17 aria 19 here lb I
C moine nnee da aria lb. It less man $400. do not ide iris neaute you do not Owe sett-4fi iotOv,nent
E snort if ie man 5400 aria u naa cirurrn emciavee income. enter .0- ana cQnW .a 5’
Er er ‘:our crurcn emotovee income rrom Form W .2. Cauooss Lee
J7 ,nsxrucnana tar amman or cnwai emasoye. income
Muitioiv ins Ia @v .9235. (II less si a n $100. enter .0-.) .
Net earnings from s f-Im Iovrnar*. Ada lines ec aria Sb .
Maximum amount ot comainea wages arid seif-ematoyment earnings SuoliCt tO SOCIal SSCUTIY
tax or me s.2% oomon ot ins 7.65% raiuaaa rewumsut Itier 1) tax tar 1991
Tots eoo seotjrny wages and ti from Fom s) W4) aria railroad
itter I) camoensanon. 6 1
Unrecormea tins suatect to sootal securny tax ifrom Form 4137.
ne 9) or raiireaa retirement met i tax . . . 8 I
Add linea8aar ia8b. . . . (IS I —
SubUact tire 8c from ire 7. It zero or tees. enter -0- hers aria on uris 10 aria go to tine 12a 5’ I —
Munic*ymesmailsrottuneóoriunegby 12.4%(.124) . 10 I
‘.Iaiumum amount at carnamea waqe a r ia ssit .emoioyment earnings suotect to Mearcare tax , - - . - -
t 1115 1 45% rticn Øf 765% ‘ 99 I I ....:. - .01
:tai 3( wades ama rios ifram Fomssp W-2 ) aria rantoaa
ii C mOen 5a ion t2au
urirecortea tics luotect to Medicare tax ifront Form 4 3T. rie or
aiuuaa retirement vet 1 p tax. . 12b I
Addi i nesl2aanal2b . . . . . .
ubiTaCt line 12C from tine 11. If zeio or less, enter .43- here aria on iris 14 aria go 10 tine 15 J II
me smaller of tune 6 or nns 13 by 2.9% (.029) . . . i 14 I I
Self-sm, .layu’uit . AGO lines 10 aria 14. Enter me nesuit here asia on Form 1040. iris 47 15 I
Nets: N3O entlr one-mat of me anrclgnf f m ans 15 on Fonw 10w. thss 25.
O Vona$ MevIwls To Figure Net Earnings (Se ‘Who Can File Scfleaui. SE’ aria “Ouvuris: MUtoas’ in
tile unsuuctlons,)
Firm Oødoiial Method. You nw”q i me tam m.un u oId if ( a Your gross farm n umi’ wee not niorS than $2.400 or
(bi Your gross taiuII . fh. 4F4 wa 5 9) $3 ,4 - y g wss ’)e55 utari *1.733.
i Mamumincom taroaVonulm.UioU3 . . . . 1•1 Si
17 3nt 1 . ne smaller Ott two-minds 1%) of gross farm income or SI .600. AlsO mnctuos uits amount
on,ure4baoove . . I Ill
Nonfarm Oodond Wsllod. You rreay u ins wjif&m ofijy uf (.$ g net n , .1arm mfui& were sian $1733
aria aiso mess man 72.lnP% at a’ gmss.nanfairn • ( y net SE eam.nqs of arleaa $400 in 2-at i tt. grior 3
years. Cauuoit YOU ma’, US. 19W . oniwm a m - ’ca no mosvinw, flv ’. ..DiTTS&
15 SubSaCt ire amount on tint iT. if any, tram Isle .. aria enter tne reluit Is I
iS E.iter ire smaller cit r.vo-irii. ’os l5 of gross norwajm income’ or ins mOurn Oft liflS 18. MaO I
ncluoe iris amount on line 40 acove . . . . 19 I
F item 10401. kite Ii an .; (Fern 1065), lute i5 . ‘From 5 zi.i C Fonii 10401. tIlls 31. SM - 44 (tOnS 10 151. line i Sa.
C.om uiaeee t f Form 10401 ‘ins 37 Scfteeiis 4.) ito,m tori). liiti 15a. ‘From Sdiuees C lFatilt 10401. bIte 1. ailS SOlisis .I IFOMV lOW, line l Ie .
Pirt II
7 I :.; I
2
3
di
b
C
6
IS
-------
SCHEDULE E
Supp ementaI Income and Loss
tFram rena, royatUss. oarmsranms, e iaiu . U JU . REMICi. etcj
P AfltOFO,ts10400,FCI,,11041. ___
P Sis Insoticeons to , $clisslls 4 (FØ t 10441.
•amssI wawn an ‘ aim
i 1 ii Income or From R.nt is ano Royaross NOtal , eocn rann ‘ enrs income a’ s riot,, Fcn *435 or’ sacs . re j .
Show me r’c ana locavon 0 ? eacn renmt amuiny 2 F r eacn re’iiai oroaer v ‘stec on ‘ ‘ ‘
ne 1 cia votj or your yarn ,iv use
for oersonai curooses tot r.or A
-nan me qreater ot • . cave or
0%ormeioia laavsre nteoat
‘air rentai vajue aunnq me tax 81
C: ‘,eer? (See nsu c ons.i
C:
_______ r”uI l&uu . 1.a _s
Rsin a$andRoysgtyIn wns:
3 Rern receives. . I I I 3 I
4 Roviaties receives 4 I
Rental and Royskty Expenses:
Adventsmq.
S Auto aria trays
7.
a
9
10
11
:eanmq aria IIlRILIII .
Co ..
Legal aaii 0015’ CrOfiisonaa fees
Mortgage iiuLaII& Oald to 0an a.
etc. see svucoanss
12 Other .
13 Rapu
14 SuoO’ S.
13 lazes.
is Ut lhO
11 Wages aria saisius .
18 CtMrflistlP’
Deoreciseon ezoirsi or aiulioun
(See W501J000nd
21 tiaexcs eus.MdIk es 19 ana 20
22 Income or (tO (rem ram or
roysny cwoouiuss.3i vscs ln. a l
from line 3 ( r. or hne 4
raysmual. If 915 iusg s a ilose.
see vamacooru 15 Ikid cImiIy I
mum Is sm 6119
II
7 !
.
L’
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.
.
I.
101
.
,
11
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12
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23 Oe ioutu ‘Ses I—
‘aw rents ,am on ans 22 may as
.im,,e . See elwuceors re fti
yvwwn%jg __________________________________________
24 income. AC’. raysty in....,.s from iine . ntv m tots . .. ré. . 24 L
23 lj°-.. A c rayesy ‘ asses tram ins 22 aria rents io s tram irs 23. Enter me total lo ‘I
25 lbtal rent* 3 lOYallY iriCOnti or lo s$. C inum . lines 24 aria 25. Enter tne resuit Puts, if Patti I I.
Ill. IV. aria I .t 3900 oaqs 2 o not spely to ysi. enter 0 e amount from ‘ins 28 on otm 1040.
‘ins 11. OUi .... . incuae me amount from line 26 in me tots on m is 40 on oaqs 2 - 29 L
Forni 1O40
:eoa,oruIw a, r’e
“u ’o r .ivl
•‘er o
-
13
5’
11
Nr*g
, //
/// ,
‘?‘ ‘ /‘;/‘ ‘z < //.‘Y. /7/71/-
.4z,ø; //½ ; / 1
// /1 /7/ ////
/
/
/ ‘ // / / 1 ’
19
20
19
19 I
I
1//
I
/// /
½
i /I¼ ½’/ %1
r 7/
FáP , _ ..re n. ’rt *s eec Vets, 1040
C NØ. i ’31J1
Sd.uuls I IPena 10401 991
-------
“ u’e c . . -
eiII 1flO On ejm C1 etuc , me aria aci. IsQanra flumes, rcwn on trr ice
r soc ai $icw s, nu,
iots: I, •IO (1 ‘1001 ? aIrcum! non, ‘anvr?n’a or nsnina oil . cneawe E :i must eiwervcc r ts inc:r “—— se -s .s
Imiiii Income or t.oss Frvm Permi.. ii ano S Cor orauons
:OU recort a ‘oss rorn an you MUST crecx eimer c:Iumn Ic ) or if) 0 ? “tie :escnce vc r in
::::vuiv ee lns ruc:cn3. If ‘ iou c eci co,umn (fi. you must ar acn Form 6198.
101 ner 0 ‘on Ci if 01 !T’CtO iSV *1 RUin?
2i run’.. 5 I :smmcation ii .o s iifl jams’.
‘‘Sc:rmrsuosii 3(tR 5 1,uO .t ’CSc i3IflI
.
3
I-
0’
ionoau s Income aria Lou
iiioue .J1__In.
mao’. Fo’.n i 4 rssass ‘rc,, -
III cis Sic si ’ .s. .kI raa.. , . .. w
,m Scilsinis #.$ Fe , ’ ., *5l Soiis V —$
Al
31
c:
.
0
—
LL __
ZSa Tota’s
Totaia
21 AdO cotwwia fl, aria 1k) of line 28a. Enter ins tote income nere 29
3D Addcon.imnsig),(i).anafj)ofhne2eb.Emerinetota iner.. . 30
31 tai oarviersnio aria S C ’ .uOfl income doui. Ccmoine meg 29 aria 30. Enter I?! resuit
nero aria inciuce in ins totar on one 40 below 31
ITITIUIII Iflc i or LOSS From E’.titu inof Thas
N_ is (IS tøu
38 (of
Al
B,
C l
Psia, ,.. Income $110 Loss
Nonoasaive Income and Lou
( Piw.s — 155$ — (of Flip.’. .J’...m_
a F ins 14 ‘s’.iss rine Sdiuss v..l
.55 0 ” or 151$ .f 0U ’ .I? ‘ .iiS U_i
om $cass —I SdI_i .i
Al
3.
C:
33a Iota ’s
Totais I
34 AdO Cat%aTmI Id) aria 10 of line 33a. Enter me to ic . . rns tiers . . . I 5
33 AdO COSOTinS (of aria IS) Of line 33b. Enter me toim nets . . . ‘(
35 To stat& uiO M uine or loss). Cornu..e line. 34 aria 35. Enter ne resuat lists aria include
in tile t t$1 on line 40 b$1l , 25 I —
In ma or $.ass rium .Of 3.151.
31 I - UP I 4T CuICuUP I (SI o in. ne.-
33 Conutwie CCOJmnI tol aria el oniv Enter me reinait liere aria inciuce in me total on mine 40 below 39 I
mm.ly
39 ‘zet farm renw ricomec, uossa from Form 4838. (Aito coir jilts one 41 belcw.i. .
40 TAL ncome or lossi. Comoine iines 26. 31. 35. 3& aria. i. Enter me resuil nets aria on Form
040. line iS
Li Reconciliation of Farm.4 and Pahlnq Iricomel Enter y . qrsu I
‘aaminq aria fIiIIIr I9 income reooriud in PartS I I aria Ill aria Ci.. uriC 39) .
tec instrucconu, . .11
Pirt V_
S
__________ _—/
K dIr
.w iine e5$t fl 5. ’S ’
-------
12
10 Potts 1040. Fo,in 1041. or Ponis loll.
13
14
h
19 I
.!LI
17
• ‘4O : .G7
I — iau w it
I duJU S lIO 14
See Insvucoor ‘ sr
$d’sss s F IForm IOSIL
ims 0 ? :orstor
s
es fl 11 1 i53M
.
:. —— :31 cr:—__::
. - rne n en Cf •%Ø woros vail OrrlCCaj C. O Cr ac • iv
Cr ?i c .ren, ai ‘ear
3
! :r i 1 tj1fl r 1CCV’iV
.:eurcn’caØe 4 l •
3
!mao ... ,Om moituNs ,UM
. c: nt!ra e’ ao: fi) L._ aan 23 L.. -3n .iai ____________________________
9 yOU i e an eeciion in a on veot to inciuce Commoonv Cracut Ccrccraoon ‘can oracesos as nccrne in fUn’ = ‘55 ‘ 10
F YOU atenaiiv eanlcioat in inc ooeraoon Of t i llS OUSIINS CUt1I1 n g1’ ‘Ii No. see in$0%UN fit Oil ieil j Yes i._ NO
G Ø iou aect. :r C :0 You 0revIOUSl U L • c ysnn ceouci censm creo’ccu vs cm esOSNesi — i$ l 0t —
ee ‘nsm. ct :ans.u — C0lV — L 90
j Farm Incali*..Cain M.tho pists Pins I ano 1 1Mm . .nss ‘ 11 . Pats ii ace UI. us use 11 c i Put LI
Do not melule 5 5 5 of 5 _ pnk i won, or deep Olir . rUOOfl I -is on Posts 4111.
I dlfl Of ,uvs 1 ins omit oems youjou i tot ‘SINS
I I
.
2 C..stor omit owe ot ins omu nuns re . .wisu an ‘mel 2
3 !ubiraci ems from mel
.1 aiu at ‘v.gsocx Oromice. qiwe. ins omit ommieti you raises
a Tc ai c:ooumiv. cuomeusons uP maip i099 .PATTh I SI I 55 T1?W ’e atT IotliI
a i ancunurai crowam omen... , . uses u 6$ I 60 rauc. amowit
? nmo N C:ees CCc tca’
a ccc :oans reucnss 355 UIWIJCSNN .
b cc: awe ‘ortinsu mi To T e unowic
5 C:o0 unsunaj e crocsi ii ins ce i ouweur cayisienes is is mstsiceons
a M ’ icimt ‘scones i v 1991 LI. Tr imowit
O If ile000n to cut IS 199.us esig , 34 Mlouj’s j asj f’om I 999.
• Custsm ‘Iwo i.. . ‘semi
10 Othit ui . , . & mouomq Fiotu uis snss i.as or fud via or ronuns INS WIIVUCOOVNI
It AdO amowits sims .iqis css vm 5r in 3 5VIu l 10.11 miuwu INoayw. imurns onisu’s from
owo 2. inS 92. Tht m vu m . . . . . . . . .
12
13
I
m
5b
ra p
?e
rr4
95 1
I
34:
9,
I
lot
I
I slid ACcni Method (00 nie unauiv I w.ai it nyu ’s mien ’s sum as sass insurance sosis. ‘ is. an vow non’s I
ill
14
19
ii
iT
1$
19
a
21
32
23
24
. .
:. 3110 ‘3 DU m ’ s 31 P. . 1 .. ito onvonarw
‘sovecci’s—iso iNS Iiiu 4I t oses
:‘ . . V em.
nseivanon eaoui s a vaiscueL il ,..,v. ins swomait
Form 1645 - 5(PJ
C ...uam net, ius .o esi . a Ri 5 SN
:.onseauon ins sicust 119 a
aouiss aeauCSUi 115 - a $101104 .10 woIIisNS 5 . .
,sm n i n ass s i iccm. . 31 s- • • ,
E ,ii s em cun i 32 Twes
omr man an tos a. . . . 32 uom.
eS0 SaCM$SS... - 34 V1 .... .,tess 11J.....&
F - 7 niiz.i ens I.S . 3$ 01W
Ftsqsusvusulq .
3u0 5ie.tuuLsnOol . 0
in m amit man n C
ntsimia 4
Menqaqsioaisrnoemmsu:. I
.
1sltost2Of,ou 3 1 .fl iaisys siu ues. IS
il1SNuesMerdisN,$i5 :ms3 19 ’ suwie II. Ifausue. smiton FimI 1040. tItle 19 . SISWI 34ISUSS
:9, line 1. L I I LOU. tOil MUST S UI N SN 3$ LllOiem UN OIJSIU11IN. lie ISN Oi . •
29 I
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32 I
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all
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3941
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311
V
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—
37
311 iM . JP . .4 . . 001115.
395 CN
Is
—
1 5
I
.
3$ you nave a ease. you MUST cnesi me ose mu m .,.....ts in me see muucooon. }
I you cneacunes 385. u’tit mc lO SS on Fonvi 1040. Ins 19, we Scilesie SE. tIns I.
vI ,j cneexus 380. you MUST aimsi Form Slit
: oatw om OTI r.!suiV I
-, a, i v nt .,
!CHEDULE Profit or Loss From Farmmg
Form 104O
u’ Ri ’i 416 NO FOil’s 1040 Oaieuts.
C&Ne. 1 13455
Schssis F (Fenin iOi 11.1
-------
•—•. . :.... -.
ThIIuI Farm uncom.—.hccruai Metnoa
Oo not inciuae saies of tvessoca fold for aran. ores.inq. soort. r cairy Ourcoses: reoort mess saies on Form
. 79? ana as not inctuas ni livestocK on ins 47 below.
:i :.. s c . siocx. :rcauce. au amer orocuc:s :..:rc ear : 3
- . . ::::e s ,e O.Q 1 I Oi ’ Ob -. . ________________________
.la - : -:... ...ai : -::rai,e :avmen,s ‘see r5tr c::si i -lb - . : a s——.. _______________________
‘2 mmoaity Cceaii Corootmion iCC loans:
. :: cars ‘ecertea unair election ieee nsmceensi _____________________
b C : .ans torfeitea or reoa’a witri c -uft ... es. I 42c . ixao,e amount ____________________
: insurance giocuios _________________________
.stam n—e ‘r ”aaim. wonti income ______________________
- ‘ c:e 0 cueira F ’ arei aria state cuoune or ei ax cectt or ‘e’uria see ‘nsmac:cns, _______________________
.8 - :a amounts in me “ant c umri 0 , “ es 9 tflrouan ..S ___________________
- ento at ‘veslOUl. crocucs. rain1. ana outer oroaucts at :ea ,flnino C?
evev . . ______________
.ss a ’ vestacli. roauc.. ç.ains. i r a amer ctooucto CUSCnUIO aw ing
II I
.1. as aries 47 aria ‘8. . 1 5
50 naiv ot livesloca. ootice. grime. altO 0 0 1e v OreSicto at era of veer 50
51 st at I ’vISlOCL CrOotJS. grim,. ara eeuer $ 50 fr y g i&9 St I
.2 .00101 • -‘ ‘ r a m line i8. Grits, me remat ‘tore aria on osse’ I5I ‘5 ‘ 5 our gross income 32
• au use tfte un’T - ”wSu* OCli .onCl mmroc or me ame.onss meinca t vaiuina inventorY aria trio ammint art irte :i 5 ‘arcer man me amount r
-e.j s.otract oa r05—âarC:’ °enre ,ctai
Prencio Agncthtursl Ac vfty Cod..
eiect 01150? tTC ro50wt-Ig cools ins •1 I ________
:n cage 1 • ne a. t 4stm it your o i sawce of zncOrr ‘ 2
‘om cmvvanq a tcIaMat services suct? U S S c aleVcn S
•‘erinnvv. lamt ‘aooc s ti uftirer. or b a t s or
an a cantisct a p a S1 C file Schedule C Forni 10401.
‘ flt Of i.OSS &001 250
20 Flild eros, e iq ins n , 1 ,ia.a suon as zoo
cotton. ceanum, fees corn. wheit. 1abl©C0 nih _____
_____ 270
V.q.uofes aod melons. garaen-uv veqelaoles aria
itegon,. suat as sweat corn. tomatoes. sauun. etc.
70 Fruit and Pus mati. irauautg graces , comes. ciives. etc.
•8O Ornwuustel fioncuitwe mat nursery products
85 Food crops under cover. including :20
Bswár nia fuselots
Ss#iilldu. e.iceot reeaio
Hogs, sheep. and goats
0
Poumy and oggu, inciuaung cnicuue.ii. aucx*.
auaii. etc.
Ganiiel lIveetocX. not scectiacrig in any one
Animel 5 lb..#V , inctuding fur .cwmq aiwit .
:ets. noises. etc.
Anlind aquaculture. ‘1 sreilfisfl.
?lcIlu5II5. frogs. etc.. :ooucea wiiflifl 0011111150
1c e.
Foro.t pme& is, .zncTuosnq rarest nurse.ies ana
seec’ tfl•. exInIcVCfl at 0111 1 Ouff triO
gau lvingor-ist cr oaUCt S -
300 AonSfldW i iditodO ” . not weaned
‘2a
. 120
I
.13i
4
.
4 5
-------
Appendix C
INDIVIDUAL ABILIV( TO PAY ANALYSIS
WORKSHEETS
-------
INDIVIDUAL ABILITf TO PAY ANALY 1S
PHASE I - 1O4OEZ WORKSHEET (1991)
L General Lnformation
1. Applicant’s name I
[ 2. County applicant lives in
3. Site location I.
4. Estimated cleanup cost
5. Other parties involved I .
I Iii
I 1
I I
IL Fmantiai Evahi tinn
6. Adjusted gross income
(Line 3 on tax form)
7. Mininium income level for one
in county (see Appendix A)
person
household
8. Income in excess of minimum
(subtract Line 7 from Line 6)
(IL Phase I Disposition (check one)
L I
L!
L
J7
18
L9
10
I I
I I
9. Line 8 is
nepuve or zero.
Applicant has no resources; further
analysis is not recommended.
1O Line 8 is positve. Phase II analysis
Date
—t
-------
INDIVIDtj ABILiTy TO PAY ANALYSL
PHASE 11 1O4OEZ WORKSHEET (1991)
.
I
1 L Income
1 Totai income
(Line 6 on Phase I - 1O4OEZ Worksheet)
.
2. Median income for household size and county
(use datainAppendixA)
:•. . ..:
I .
.
.
.
1 : 5 . ... (dmdeLifle lbyLine2multiplybyloo)
ow
4. Total annual living expenses
. .
j :
I
1•
- .
4
.
i __1
.. ... -
‘-S -
— , 7& X • Y.4* .:,.cç
• - S -• . . . ..
S . ..
i. jjL
(convert all expenses from Part if of Financial Data
Request form to annual values and sum)
5 Total annual debt payment
(from Part II of Financial Data Request form,
sum entries in section ‘B. Debt Payments”)
6 Cash flow
(subtract Line 4 from Line 1)
.5 ..
.. : —- .I 7. Cash flow contingency allowance percentage
(see income criteria matrix)
.
8 Cash flow contingency amount
(multiply Line 4 by Line 7)
- .
9 Available cash flow (net of contingency)
(subtract Line 8 from Line 6) -. 5
.
10 % annual debt payment to annual income
(divide Linc5by Line 1; multiply by 100)
.: - ‘ •
.
L
t - S/ 1 A -. v . 5 5 -
.
T [ 6
% % % I1 [ 7
.9.
. .‘
. 5
% %
-------
. . ‘ , — . . .
V
. , - ..
__ .* — ,
I Cash Flow Dispomtion (check onc)
.
4 .
I I [ ii Line 9 is positive Applicant has available cash
,
..
F 12. Line 9 is negative or zero Applicant
L does not have available cash flow
I ilL Net Worth
I i,q I, .i
1. iCCOUfl
(Part Ill of Individual Financial Data Request form,
1 total of IIL1)
14 Investments
(Part II I of Individual Financial Data Request form,
flmd nanda1DRf
16. Life insurance policies
IL (Part 111 of Individual Financial Data Request form,
total of 1114)
i ’•
17 Vehicles
(Part III of Individual Financial Data Request form,
total of 111.5) .
I
‘; — i
. . . . . .
‘
flow ii
* w -
:
:
J P
I :ie ’•
I
ilL. 13
IS 1q14
.. : . v.
/
. t 16
h. •:
h 117
— ø,
x .-.
1: 118 I
I 1 19
...
*
i.ii •1 20 I
H.:L.. . •: :•.- . .:‘: ... . .
,.
21
.
20 Other assets
I . (Part II I of Individual Financial Data Request form,
total of 1118)
.
21 Total assets
(addl ines l3throih2O)
18. Personal property
(Part
III of Individual
Financial D
ata. Request form,
total
of 111.6)
19. Real
estate
(Part
III of Individual Financial Data Request form,
total
of 111.7)
S
-------
22. Credit cards and lines of credit i :.. •. .• :.. ....
(Part 111 of Individual Financial Data Request form,
total of 111.9) . . . .. _____
23 Vehicle loans
(Part LII of Individual Financial Data Request form,
total of 111 10) _______________________ _____
______________________ ts 1 I23
24 Furniture and household goods loans
(Part III of Individual Financial Data Request form,
total of 11 1.11) ___
_______________________________________________________ 1. _____________________ 24
25 Mortgages and real estate loans
(Part LII of Individual Financial Data Request form,
total of 111.12) . : :‘ : ______
1 L2s
2 ther debt
(Part III of Individual Financial Data Request form,
Ls [ z6
“ 27. Total liabilities
(add 1m fl through 26) $ __
—. ‘ . .- ,,,
. . .. “ . ,
28. Net worth ...
(subtract Line 27 from Line 21) $ I L 28
29 Applicant’s age _____________________
(Part I of Individual Financial Data Request form) ..
Yts. .: ___
30 Applicant’s employment status
(Part I of Individual Financial Data Request form) 30
11 ____
... . -.. .
31 Target net worth
(see Net Worth Criteria Matrix) . ‘* ‘l I .: I
: : . . ..1 i4 .iL_31
32. Target assets
(divide line 27 by line 31 ) Fi’ 1_32
33 Assets available -
(subtract Line 32 from Line 21) I 1
-------
I NetWorthDisposition(chcckonc)
I I 34 The applicant has available assets ..
(if Line 33 is greater than 0) .
: xse:v*: ‘ ‘.. . . .:. ..•.i .
-.
. “ ____
35 The applicant does not have available assets.
I (if Line 33 is less than or equal to 0)
I . ‘ A,
IV Phase if Simm2ry
36 Applicant has excess annual cash flow in the amount of $ j . J 36
Line 9 . ‘ ?: ‘ . .f • ... . :
¼ /
37 Applicant has available assets in the amount of ____
(L ine33) ‘ I i 37
38. % annual debt payment to annual income
lI ••. (LinelO) .1 __
i.iat e
-------
LNDIVIDUAL ABILiTY TO PAY ANALYSIS
PHASE 1- 1040A WORKSHEET (1991)
I ii
I i-
I L General Information
I
1. Applicant’s name I I
2. County applicant lives in I I
3. Site location I I j]
4. Estimated cleanup cost I I ii
5. Other parties involved I I 1]
U. Financial Evaluation I
•AWageincome 1
6. Adjusted gross income
(Line 16 on tax form)
7. Number of people in household
(Line 6e on tax form)
8. Minimum income level for household size and county
(see Appendix A)
9. Income in excess of mmiITIum
(subtract Line 8 from Line 6)
(B. Non-wage income I
ho. Cl eck the box if applicant meets condition I
I I I a. Interest income greater than S400 (Line 8a and/or 8b on tax form)
I I I b. Dividend income greater than $400 (Line 9 on tax form) I
I ilL Phase LDL position (checkone) I
Ii
12
‘ 3
[ 4
15
16
‘ 7
18
19
110
I I
Ti
11. Line 9 is negative or zero and no boxes are checked under Line 10.
Applicant has no resources; further analysis not recommended.
12. Line 9 is positive and/or bozes are checked under Line 10.
Phase II analysis recommended.
Date
—t
-------
tNDIVIDUAL BIL1TY TO PAY AL’IALYSIS
PHASE fl 1040A WORKSHEET (1991)
Appff nt’s fl ” I 1
(LIUCOInC I
1. Wage income
(Line 7 on tax form)
2. Taxable interest income _________
(Line Sa on tax form)
3. Tax-exempt interest income
(Line 8b on tax form)
4. Dividend income
(Line 9 on tax form)
5. Total IRA distnbutions
( from tax form: if Lines lOa and lOb are both greater than
zero, enter the amount on 10a if Line lOa is zero and line
lOb is positive, enter the value on Line lOb) _____________
6. Total pensions and annuities
(from tax form: if Lines ha and hib are both greater than
zero, enter the amount on 11a if Line ha is zero and line
1 lb is positive, enter the value on Line 1 ib) _____________
7. Total social security _________
(Line 13a on tax form)
& Total j t n _________
(add Un 1 through 7)
9. Household ‘size ____________
(Line 6c on tax form)
—
10 Median income for household size and county - ____________
use data in Appendix A) -
11. income ratio ____________
(divide Line 8 by Line 10; multiply by 100)
Is
Is
. I.
fs
I.
1
12
13
$
114
Is I.
Is I . ___
Is I . ___
—I.
16
17
[ 8
19
110
I ii
Is .1.
-------
[ 2
IL Net Cash Flow
12. Total annual living expenses
(convert all expenses from Part II of Financial Data
Request form to annual values and sum)
13. Total annual debt payment
(from Part II of Financial Data Request form,
sum entries in section “B Debt Payments’)
14. Cash flow
(subtract Line 12 from Line 8)
15. Cash flow contingency allowance percentage
(see income criteria matrix)
[ S
I
L
1
Is
I.
%i
I
•
I s
IS
Is
I
I
%I
16.
Cash flow contingency amount
(multiply Line 12 by Line 15)
.
17.
Available cash flow (net of contingency)
(subtract Line 16 from Line 14)
18.
% annual debt payment to annual income
(divide Line 13 by Line 8; multiply by 100)
112
113
F 14
I 15
I 17
118
119
C ih Flow Disp tion (check one)
I
19. Line 17 is positive. Applicant has available cash
flow.
I
20. Line 17 is negative or zero. Applicant
does not have available cash flow.
IliLNetWaith
Lzo
21. Bank accounts
(Part III of Individual Financial Data Request form,
total of ff1.1)
22. Investments
(Part 111 of Individual Financial Data Request form.
total of 111.2)
23. Retirement funds and accounts
(Part III of Individual Financial Data Request form.
total of 111.3)
I 21
Is
I
Is
I
J 1231
Is
-------
24. Life insurance policies
(Part III of Individual Financial Data Request form,
total of 111.4)
25. Vehicles
(Part I II of Individual Financial Data Request form,
total of 111.5)
26. Personal property
(Part III of Individual Financial Data Request form,
total of 111.6)
27. Real estate
(Part III of Individual Financial Data Request form,
total of 111.7)
28. Other assets
(Part II I of Individual Financial Data Request form,
total of 111.8)
29. Total aiseti
(add lines 21 through 28)
L
II .
Ls
I
Ls
J
Ls
1.
[ S
I
I.s
1
Is
I
Is
I•
Is
I
ft
I
ft I
Is
1.
I 24
125
I 26
I 27
[ 28
I 29
I 30
I 31
I 32
L33
I 34
I
30. Credit cards and lines of credit
(Part II I of Individual Financial Data Request form,
total of 111.9)
31. Vehicle loans
(Part II I of Individual Financial Data Request form,
total of 111.10)
32. Furniture and household goods loans
(Part III of Individual Financial Data Request form,
total of ULI1)
33. Mortgages and real estate loans
(Part III of Individual Financial Data Request form,
total of 111.12)
4. Other debt
(Part 111 of Individual Financial Data Request form,
total of 111.13)
35. Total liabilities
(add lines 30 through 34)
-------
38. Applicant’s Employment Status
(Part I of Individual Financial Data Request)
Net Worth Dbpoiidon (check one)
42. The applicant has avRilable assets.
(if Line 41 is greater than 0)
43. The app
(if Line
licant does not
41 is less than o
have
r eq
available assets.
ual to 0)
f IV. Phase II Si.nunA I
44. Applicant has cash resources in the amount of:
(Line 17)
45. Applicant has available assets in the amount oft
(Line 41)
46. % annual debt payment to annual income
(Line U ’)
Is
I
I
S
.1
42
% I. 146
36. Net worth
(subtract Line 35 from Line 29)
37. Applicant’s age
(Part I of Individual Financial Data Request form)
Is
yrs.1
136
38
39. Target Net Worth (See Net Worth Criteria Matrix) I
40. Target Assets (divide Line 35 by Line 39) 1
• 41. AvRilable Assets
(subtract Line
40 from Line 29)
$
Date —
-------
ii
I I
I I
I I
I I
I I
I I
I ]
tNDWIDLJAL ABILiTY TO PAY ANALYSTS
PHASE I - 1040 WORKSHEET (1991)
Li
12
13
14
Is
L General Information
1. Applicant’s name I I I
2. County applicant lives in I 1
3. Site location I I -Il
4. Estimated cleanup cost 1 I
5. Ocher parties involved I I 1
IL Fn ncial Evaluation
A. Wage income
6. Adjusted gross income
(Line 31 on tax form)
s
7. Number of people in household
(Line 6e on tax form)
8. Minimum income level for household size and county
(see Appendix A)
9. Income in excess of minimum
(subtract Line 8 from Line 6)
B. Non-wage income
10. Check the box if applicant meets condition
16
17
18
19
Lio
I a. Interest income greater than $400 ( Line 8a and/or 8b on tax form) 1
I b. Dividend income greater than $400 (Line 9 on tax form) I
I c. Business income not zero (Line 12 on tax form) I
I dCapitalgainnotzero(Linel3ontaxform) I
e. Capital g distributions not ±ero (Line 14 on tax form)
I L Other gait not zero (Line l5nn tax form) I
g. Rents, roy cies, parmerships, e caces, trusts not zero (Line 18 on tax
form)
h. Farm income not zero (Line 19 on tax form)
-------
II
I L ii i nase i
Disposition cnec ODC)
10.
12
f
11.
Line 9 is negative or zero and no boxes are
Applicant has no resources; further analysis
checked under Line
not recommended.
12.
Line 9 is positive and/or boxes are checked
Phase if analysis recommended.
under Line 10.
Date
-------
INDWIDTJAL ABILiTY TO PAY ANALYSIS
PHASE U - 1040 WORKSHEEF (1991)
Appli S I
LIncome
1. Wage income
(Line 7 on tax form)
2. Taxable interest income
(Line 8a on tax form)
3. Tax-exempt interest income
(Line 8b on tax form)
4. Dividend income
(Line 9on tax form)
5. Alimony received
(Line 11 on tax form)
6. Total A disthbutions
( from tax form: if Lines 16a and 16b are both eater
than zero, enter the amount on 16a if Line 16a is zero
and line 16b is positive, enter the value on Line 16b)
7. Total pensions and annuities
(from tax form: if Lines 17a and 17b are both greater
than zero, enter the amount on 17a; if Line 17a is zero
and line 17b is positive, enter the value on Line 17b)
& Total social security
(Line 21a on form)
9. Total wa u,eiuiie ’ =m it ina,m
(add Th 1th rougb 8)
10. Business income or (loss)
(Line 12 on tax form )
11. Depletion
(Schedule C of tax form , Line 12)
12. Depredation andlor amortization
(Schedule C of form, Line 13)
13. Total income or (loss) from rental properties or
royalties (Schedule E of tax form, Line 22)
Is
J
[ S
ii
[ S
1;
Is
I.
Is
I
Is
i:
Is
I
Is
I.
Is
I..
Is
I
Is
I
Is
I
Is
I
U-
12
13
I 4
Is
17
Is
19
[ 10
Iii
112
113
-------
i-. .. pre:iauon or aepiecion on rcnt i property
(Schedule E of tax form, Line 20 total all properties)
15. PartnershiplS corporation income or (loss)
(Schedule E of tax form, Line 31)
16. Estate and mist income or (loss)
(Schedule E of tax form, Line 36)
17. REMIC income or (loss)
(Schedule E of tax form, Line 38)
18. Farm rental income or (loss)
(Schedule E of tax form, Line 39)
19. Depreciation on farm rental property
(Form 4835, Line 13)
20. Farm income or (loss)
(Line 19 on tax form)
21. Depreciation on farm property
(Schedule F of tax form, Line 17)
fl Total b.—. .e and tn t in m
(add Lin 10 through 21)
23. Capital gain or (loss)
(Lines 13 plus 14 on tax form)
24. Other gaiz ’ or (losses)
(Line 15 on tax form)
25. Total_______ ____
(add Un and 24)
26. Total income
(add I in 9 , fl and 25)
27. % wage, investment and retirement
income (divide Line 9 by Line 26;
multiply by 100)
28. % business and trust income
(divide Line 22 by Line 26;
multiply by 100)
a-
29. .% e aordinaiy income
(divide Line 25 by Line 26;
multiply by 100)
It r
Js IlL 114
Is J us
1116
Is 11 117
Is 118
Is — 119
Is I 120
h 121
r • T
Is
i;
Is
t..•
Is
I
Is
I.
Is
1.
I
%I
I
‘of
I
%l
122
23
I 24
L25
126
127
128
I 29
-------
I C h Flow Dfsi,csidon ( cheek one) 1
I I
40. Line 38 is positive. Applicant has available cs5 ’
flow.
J30
30. Household size
(Line 6e on tax form)
31. Median income for household size and county
(use data in Appendix A)
I -
32. Income ratio
(divide Line 26 by Line 31; multiply by 100)
IL Net Cash Flow
1 13 ’
33. Total annual living expenses
(convert all expenses from Part II of Financial Data
Request form to annual values and sum)
I
I 32
I 33
I
I 35
136
I 37
I 38
I
%J
Is
I..
Is
I
Is
1.
L
%I
Is
I.
Is
I
I
34. Total annual debt payment
(Part II of Individual Financial Data Request
sum entries in section ‘8. Debt Payments’
form,
35. Cash flow
(subtract Line 33 from Line 26)
36. Cash flow contingency allowance percentage
(see income criteria matr )
37. Cash flow contingency amount
(multiply Line 33 by Line 36)
3& AvRil ble cash flow (net of contingency)
(subtract Line 37 from Line 35)
39. % annual debt payment to annual income
(divide Line 34 by Line 26 multiply by 100)
I I
41. Line 38 is negative or zero. Applicant does not
have av iIahle cash flow.
-------
II
1 152
I m. Net Worth
Is
42. Bank accounts
(Part III of Individual Financial
form, total from 111.1)
Data Request
43. liwestmerns
(Part III of Individual Financial
Data Request
form, total from 111.2)
44. Retirement funds and accounts
(Part III of Individual Financial
Data Request
form, total from 111.3)
45. Life insurance policies
(Part III of Individual Financial
Data Request
form, total from 111.4)
46. Vehicles
(Part III of Individual Financial
Data Request
form, total from liii)
47. Personal property
(Part 111 of Individual Financial
Data Request
form, total from 111.6)
48. Real estate
(Pan 111 of Individual Financial
Data Request
form, total from 111.7)
49. Other assets
(Part 111 of Individual Financial
Data Request
form, total f&uw 111.8)
50. Total a iets
(add tin 42 thiuugh 49)
51. Credit cards and lines of credit
(Part 111 of Individual Financial
Data Request
form, total from 111.9)
•
Is 111
. 1
Is I.
Is I
Is
Is 1
Is I ,
Is I
Is
I
[ 46
I
148
1 4
I so
I si
52. Vehicle loans
(Part III of Individual Financial Data Request
form, total from 111.10)
Is
-------
IF-
L53
•S2
53. Furniture and household goods loans
(Part III of Individual Financial Data Request
form, total from 111.11)
54. Mortgages and real estate loans
(Part III of Individual Financial Data Request
form, total from 111.12)
55. Other debt
(Part 111 of Individual Financial Data Request
form, total from 1IL13)
56. Total liabilities
(add IJn 5 th tiijg 55)
57. Net worth
(subtract Line 56 from Line 50)
58. Applicant’s age
(Part I of Individual Financial Data Request form)
Ls F
Ls
[ s •I•
Is I
I F
I yrL
I I.
I I.
I I
Is TI
59. Employment Status
(Part I of Individual Financial Data Request Form)
60. Target Net Worth Ratio
(See NeL Worth Criteria Matrix)
61. Target Assets
(Divide Line 56 by Line 64
62. Available Assets
(subtract Line 61 from Line 50)
-------
II
Net Worth Dispt ition (check one)
66. Applicant has available assets in the amount of:
(Line 62)
I I
I I.
63. The applicant has available assets.
(if Line 62 is eater than 0)
64. The applicant does not have available assets.
(if Line 62 is less than or equal to 0)
I IV. Phase II Srnnn Ary
65. Applicant has cash resources in the amount ot
(Line 38)
I s
63
L
$ _
$ I E66
_________________ 67
—
67. % annual debt payment to annual income
(Line 39)
I
I
Date
-------
Append D
IN1 LVIDUAL ABILiTY TO PAY DATA FORMS
.
-------
INDIViDUAL ABILiTY TO PAY CLAIM
General Information Form
Case Name:___________________________________
We are reaucsung financial information to help us evaluate your ability to contribute tunds br
nvesclgauon or rcmediauon oi the petroleum release at the aoove.menuoned site. Please till out this
form anu submit a signed. comolete copy ot your most recent tederat income tax return. The Iowa
Department of Natural Resources may request documentation supporting the iritormauon ‘ .ou
provide on this form or in your tax return.
Name
Spouse’s Name
Address:
Phone Number Home (
County of Residence
)
Work (
)
Does the intorinauce provided on your federal income tax return accurately retlect
your current financial situation? Please describe below additional information that
you would like us to consider in evaluating your case (for example. anticipated major
expenditures or changes in incomc . Jse additional sheets if necessary.
Are you currently participating in any type of federal or state assistance program (for
‘ “ple . AFDCI SSL food stamps, MUD or FmHA ho ”tg assistance, home heating
aelitsn’ M& - t or Iowa’s me 4 IIy needy program)? Please d . & ribe below.
Attach additional pages if nec uIy.
-------
Applicants
Name:
Address
Councv
Case Analyst:
INDIVIDUAL ABILiTY TO PAY TRACKING FORM
Iowa De artment oi Nacurai Resources
PHASE I ANALYSIS
Date Individual was tint contacted: I
Date Phase I Request Letter Mailed: I
Date Tax Forms are Returned to LDNR: I
Year of Tax Return: I
Type of Form: (i.e.. IO4OEZ. 1040A. 1040)
Schedules Attached to Tax Form: I
Phsc I Disposition (check ones I
Applicant has no resources.
Analysis discontinued.
Date Analysis Completed:
I
I
I
.
I
I
I
I
I
I
I
I
I
I
I
I
LI
I I
Additional Comments:
Phase LI analysis performed. - I
-------
ENDIVIDUAL ABILITY TO PAY CLAIM
Financial Data Request Form
This :orrn requests information regarding your rinancial status. The Gaza will be used to
vaiuate your ability to pay br environmental clean-up or penalties. If there is not enough
oace or your answers, please use additional sheets or paper. Note that we may request
further dacumemation of any of your responses. We welcome any other information you
wish to provide supporting your case, particularly if you feel your situation is not adequately
descrthed through the information requested here.
Certification
E declare that this statement of assets, liabilities, and other information is true. correct. and
ompiete to the best ot my knowledge and belief.
Signature Date
Namet 1
Spouses Name
Address:
Couut of Residence
—
I
-------
PART II. C i ‘rr LIVING EXPENSES
?!ease : st :ersonai liv n exnenses wnich were vpicai during me iast year anc Inolcate ir any or these
• atues are ukeiv to change si ificarniy in the current year. Please do not include business expenses. If
•ou are the owner o an operating business, please attachment any available tinancial statements.
Expense
Amount
PerIod or Pnvmeni (cheek onet
For A encv Uie Only
“.e Iv
StoasWv
Qwi.flv
ut
A. Livine Exi,enses
Rent
I
.
Home mamienanoo
3 Auto fuel maintdother transo.
. euiui
i._Fuel_(gas.oiLwood.propane)
h.E!ectrtc
.
c. SYatersewer
.1. Teleottone
ood
‘ ._Clothine. personal re
- Medial costs
B. Debt Payments
t._Montage_payments
._Car p ments
3._ retht card payments
Educational loan_payments
C. insuran
L Housenold insumen
Life_rnsuranco
I
3. Automobile imunnoo
I . Medical insuranen
D. Thxes
t. Pmpesiv ta
: Federal incomo imo&
3. State income t 3
.1 FTCA
E .OiherEenensnt
t.Chlldcare
:. Current School tuzuthdexnt Cs
3. Lent or orofessionat servia
—
.L. Other (itemize on seosrate vane)
3
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PART Ill. NET WORN
Please provide the following information to the best at your ability. Data should be as current
as possible. Estimates are acceptable: If you wish note such items with an E”.
If you are the sole proprietor of a business, please lists business assets and liabilities, in addition
to personal assets and liabilities. Please mark these entries with a B” to identif them as
business assets and liabilities.
4sme of Bank or Credit Union
l ipeo( A uni
1. SANK ACCOU?11S (Chr”-q NOW Ss’1n i, Mossy Mar eta)
For Agency (Is o Oal - lbtal Current Balanen in Bank Aunts
e nt
Number of Shares or Units
Current 8alan
2.. v a vaggi w (StXk, Scuds, M —’ Fund,, Opd’ , FuUw.. CD’s, Raul Estass 1w’—
1 uem (REIT), eta)
For Agency Use Only - lbtal Current Market Value of Investments
3. RET1R 1EIIT FUNDS AND ACCOUN1 (TEA. 401(k), lCeou b, .ind bitereal In es.psny
etc)
Dearripuon of unt
Estimated Market Valuc
Current Market Value
For Agency Use Only. ibtal E.u matc( Warket Value of Retirement Funds
and Acenvuts
4
-------
8 OTHrJ( ASSETS
Type ot Asset I E tzmate Market Value
For Agency Use Only - Tbtal Other A e :
9. CRED CAISDS AND LIN OF CR 1T
Credit CardlLine of Credit ( T ipe)
Owed To
Balance Due
For Agency Use Only. ibtal Balan Due oa Credit Cardi and r in of
Credit
LG VEHICLE LOANS (Can, frncb. Mut....,dee. Rwwedou Veb .k Motor Ifoas . Boe .-Aiiplmi .
etc.)
Vehjc ( (Model
Owed To
92I.n Due
For Agency (Jan Only. Ib 1 Ra6ii Due an Vehicle Lom
-------
PART W ADDITIONAL INFORMATION
Please respond to the following questions. For any question that you answer ‘Yes.’ please
provide additional information on separate pages or at the bottom or this page.
QVISTION
YES
NO
1. Do you have any reason to believe that your financial situation
will change during the next year?
2. Are you currently selling or purchasing any real estate?
3. Is anyone (or any entity) holding real or personal property on
vow behalf (e.g. a trust)?
4. Are you a party in any pending lawsuit?
5. Have any of your belongings been repossessed in the last three
years?
6. Are you a Trustee. Executor, or Adrnniisrawr?
7. Are you a participant or beneficiary of an estate or profit sharing
plan?
8. Have you declared bankruptcy in the lass seven years?
9. Do you receive any type of federal aid or public assistance?
8
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Appendix E
CONSUMER PRICE INDEX
MEASURES OF THE RElATiVE IMPORTANCE
OF HOUSEHOLD EXPENDITURES
-------
TI6IS 1. Conmimur Pdms dsz for Al Urbmi Cimusmimu (CPMTh U.S. efty u rsi , by Ixpsndlbui 1o, , mid cmL..la , mid
(10$24 . $00. itiMm .4I ... Mm
G to
U .- .—
-
Ui L4
— us
M 1Mm Mm-
S...i....a, -f—-i
Fib
1991
Fib.IMm
0us.
Jusi
——
Al 1Mm 11957 — lO S).
Food SM b ss
Jm%.us
F
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Food Mm.
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Omypmsmus’
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0m food m Mm.
igm SM oosuu’
s
N JiL. L _
0m Mm
Food us, Mm Mmm l
1 010
‘7 7
1 5 . 007
urn
‘.4 9 5
1010
1954
2 . 3N
344
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6 .095
1. 1 21
41.544
271$’
ION
UN
2.1 9 5
‘UN
‘UN
.131
ON
7127
4.0 17
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112$
UN
UN
1ON
1.154
1.495
Us?
UN
9451
1317
.21S
.1 50
M m
17.01
91131
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4.ON
1.131
131 5
1.531
UN
.7 .
3295
1.450
121•
4112
1211
‘37.5
1*1
141.3
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1*1
1*6
195 . 1
1314
131.3
1110
1312
1*S
146.7
1*1
1452
15 52
1413
1*$
“U
153.7
140.5
1213
133.0
123.5
‘ II .
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01.5
1110
141.2
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105.7
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922
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1010
1510
$10.7
1*3
4172
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137.1
145.7
130.7
1272
161.3
125 2
1322
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111.3
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140.1
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1214
1012
1454
117.3
156.1
156.3
141.0
1214
1325
1315
1113
1053
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111.5
141.7
117.7
1014
121$
1213
133.4
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127.4
‘31$
1 3 7.1
13 1$
1461
141$
1314
1*6
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1*2
111.7
314
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1 403
1121
101.5
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3.3
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1.$
flusmiW corns_______
Rol_
0mm Mm
u _ _ mum £______
Om w i JidSii Mm ______
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U uuwcu SM room.’
SM roi W% ’
SM moor
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0515, uS Old Oi.
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SM .il
his SM lotW &
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05w coors ‘.____
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05w wmu .—.........95... ’
05w iivius . . s —
-
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3
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-------
T.bls 1. Coituwnur P l idsi f r Al Witsi Conuiaiui, (CPIU U.S. city l, 1 11 . by i l1Jl40h 011433 7 i4 u4
M U —
(1552.14 —100. t N . ,Il . .. ..Le i Iu
.
ONoi
Rs
L,
liii
UI f
— d ‘- v- N
M . ig fr
WWI — 0N
F
iwn
M w
3102
MN.1 1 01
F.M 1903
0N.N
JUL
Ju N
F.M
F.M
-.
1MN 191.3 117.3’ is 0. 5 0.1 0.1 0 .5
M . Mcal c I.20S liii ls. 7$ . 5 .5 1.0
WI l 44 1421 111.4 11.4 7. 5 5 7 7 .5
3.213 1715 113.4 5.2 .3 .4 .1 .3
4.357 1407 412 3,3 .4 .1 .4 .4
l IJ4 n,...JlN 1 2.015 1312 1311 3 4 3 3 4
Ei ’ Inhi1sw s ’ 2.330 1307 131.3 43 4 . 0 .7 4
OMNgoo00 M NL . 0.074 173.4 IPS.S 7.1 .2 .3 5 .5
MN . . 1 a . 1 MN01 1.111 2114 13.5 to .0 -.i .2 .0
1.151 131.5 137.9 3.2 3 I .7 3
ToIN 90000 MN WI ....,.I,’ .501 1312 liii 3.3 .3 .1 1.0 .2
CUe 0...... ’ .555 1*2 131.5 2.1 3 .4 5 3
MN — —‘-.1 3121 1115 193.5 7. 1 3 S .5 . 5
SMN osboMN M Nv 243 91.7 is. 5.3 -I .4
3.575 113.4 194.0 5.0 .3 . 5 .1 .5
— . — _ J. _ I.
101309 31.3 1*3 33 .5 .1 .3
44.407 I SiS 135.4 2.1 .5 -3 .4
FedNSba1 .I 17. 1*1 *1 1.0 .3 -4 .3
MIS as 35153 1111 1311 3.4 . 5 -2 .5
MN MN II’i ’ 11.215 1217 1310 3.5 1.1 -12 S
A4WS 153$ 31.7 1313 3.5 3.7 .3 IS
MN MId L.I.SU,... . M al .MI’ — 15 125.4 121.5 23 .3 -LI -3
t—_.I. 10155 117.5 117.1 3.1 .3 .0 .2
— 30513 1301 1301 4.1 .4 .3 2
RuiweIwlufl’’ . 21.213 1155 *3 is .4 .4
LIII 1301 1315 23 -.1 .5 -2
IU%NN 1. 114 1144 50.2 7 . 5 5 .4 -.1
____ 5.413 115.4 117.4 7 .5 .7 .7
— 7.021 111.0 1 11.0 1$ .3 4 5
*INS.ISMNMIO 13115 131.5 1*1 3.5 5 .1 3 .5
A II IWIIS 10 1fl IIIU. 71105 1312 1*2 3.0 .3 -.1 3 S
44 1 _____________ 11317 140.1 140.1 3.0 .5 .1 3 .4
Al NUN MN . ...J J WI 30311 1315 1*5 71 .4 .0 .3 .4
_______________________ 25.410 1311 1300 2.4 .7 -.2 .3 .5
NU17JNIN MIS MN’ 11 . 514 134.5 1303 2.7 1.0 -*0 1 1.0
NonSv00ss MssI 0 0 0 M N55psN’ 12310 121.7 131$ 3.3 .3 -.1 -.1 3
N01031001 1S ... 3130* 111.1 1311 2.3 . 5 -.4 .4 .0
25341 130* 151.1 4.4 .3 -.1 .3 .5
3.vueus MIS 4 11IL WI . ...JNS 10.050 1412 147.1 3.5 .3 .1 .3 3
7.351 iS O 15.1 -. -1 .1.5 -. 5
Al SUN MIS 1CU90 93.12$ 144.0 144.7 3.5 .3 .3 .4 .3
A I NUNM I SMI OU I IIIW 1 3 70.123 1451 115.4 3.1 .5 .3 .4 3
C .. ... ...ai.s MN MId UN ..-. .41... . 24.117 131.0 132.1 3.1 .5 3 .5 3
3.713 115 93.3 .5.1 .3 .5.3 -$ I
u _________ 11.575 154.0 114.7 43 .5 .4 .3 3
PwU . p N Os OIMN
tN S44 —$l00’..___________________ - 1713 1715 -5 .1 -3 -e
1107.11.00 ...________________________ . .24* .240 . - - -
____ - . -
MINIS C I I . C.. 1 153 — 100 N0* h 1001451415001 N I 00 1114 NW _-- - —
Sourer Qpmuiner Puce lnd Detail Reoort . U.S. Department of Labor. Bureau of Labor
Statisti . March 1992. (Published monthly.)
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