SEPA
NATIONAL MEASURES TECHNICAL APPENDIX
SIGNIFICANT NATIONAL ENVIRONMENTAL JUSTICE CHALLENGES:
MEASURES TECHNICAL INFORMATION

-------

-------
NATIONAL MEASURES TECHNICAL APPENDIX
SIGNIFICANT NATIONAL ENVIRONMENTAL JUSTICE CHALLENGES:
MEASURES TECHNICAL INFORMATION
INTRODUCTION AND OVERVIEW	4
GUIDE TO THE APPENDIX	5
MEASURES TECHNICAL INFORMATION	7
BLOOD LEAD LEVEL DISPARITIES	7
SMALL DRINKING WATER SYSTEMS	10
TRIBAL DRINKING WATER SYSTEMS	13
FINE PARTICLE AIR POLLUTION	16
HAZARDOUS WASTE SITES	19

-------
4 I EJ 2020 ACTION AGENDA APPENDIX
INTRODUCTION AND OVERVIEW
Several types of measures are necessary to help tell the story about how the U.S. Environmental Protection Agency (EPA or
Agency) is making a difference in communities with environmental justice (EJ) concerns. For example, each priority area
of the EJ 2020 Action Agenda (EJ 2020) includes milestones and measures for implementation. One of the most important
cross-cutting concepts raised in public comments and embraced in EJ 2020 is the need to demonstrate national progress
toward achieving environmental outcomes that matter to overburdened communities. This Appendix provides technical
information about the national outcome measures that support the four Significant National Environmental Justice
Challenges discussed in Chapter 10 of EJ 2020 (lead disparities, small and tribal drinking water systems, fine particle air
pollution, and hazardous waste sites).
As a start, EPA has identified five measures of progress that are based on available data and demographic analyses. In the
second phase, we will evaluate progress on achieving our current goals, enhance measures as appropriate, and explore
potential development of additional national environmental justice measures and associated strategies. We anticipate
focusing particular attention on issues of concern to overburdened communities that may warrant attention at the national
level. These issues include pesticide impacts on farmworkers, goods movement (commercial transportation of freight and
supporting infrastructure), water infrastructure, air pollution and climate change, among others. EPA is already under-
taking significant ongoing work in all of these areas. We also anticipate working closely with federal, state, tribal and local
government partners, communities, and other stakeholders through our second phase efforts.
ANNUAL REPORTING
To ensure the public is informed about EPA's progress in areas that matter to overburdened communities, the Agency will
report available national EJ performance data annually on EPA's EJ 2020 website, as well as progress in improving existing
and developing new national EJ measures of progress. While EPA will publish measures and performance data as they are
available, it frequently takes time - often a number of years - to collect and validate performance data, conduct necessary
analyses, develop baselines and targets, and report performance.
INTEGRATION WITH EPA'S PLANNING AND BUDGETING
In consultation with our partners and stakeholders and the Office of Management and Budget, EPA will continue to align
and integrate as appropriate, reporting on national EJ measures in the Agency's FY 2018 Annual Plan and Budget, the
FY 2018-2019 National Program Managers Guidance and Annual Commitment Process, and the FY 2018-2022 Strategic
Plan. Integration into EPA planning and accountability processes will promote attention to EJ issues as part of the way the
Agency does business.

-------
EJ 2 0 2 0 ACTION AGENDA APPENDIX I 5
GUIDE TO THE APPENDIX
This Appendix contains detailed information about each of the five national EJ measures that will be used to assess and
communicate progress in addressing the Significant National Environmental Justice Challenges described in Chapter 10 of
the EJ 2020 Action Agenda. Each measure contains information about the following sections, including, where available,
relevant hyperlinks.
1.	Goal: This section provides an aspiration goal that represents the desired end state that the Agency will strive
to achieve. In some cases, achievement of the goal may be outside of EPA's sphere of control, capability or
capacity, but nevertheless is the Agency's ultimate aim.
2.	Measure: This section is the text of the measure by which the Agency will assess progress. The section includes
information on what is being measured, a target to be achieved (if applicable), a date by which the target is to
be achieved, and information about the baselines or universe that provides context for the magnitude of the EJ
issue being addressed and the significance of the performance target, if applicable. Note that not all measures
described here contain targets and may be referred to as "indicators."
3.	Performance Measure Term Definitions: This section defines each key term used in the performance measure,
including additional background information and/or references about the measure, so readers can better
understand why the measure is important in the context of environmental justice.
4.	Relevance to Environmental Justice: This section describes why the measure is important to communities with
EJ concerns and may include available demographic information that helps characterize potential disparities
in low-income and/or minority populations.
5.	Mission and Organizational Context: This section provides information about where responsibility for achieving
the measure lies with the Agency, including the national program manager (NPM) and sub-offices with manage-
ment responsibility. Information is also provided about how the measure relates to Goals and Objectives of the
Agency's Strategic Plan.
6.	Meta Data: This section provides information about the origin and characteristics of the data EPA uses (or
plans to use) to calculate performance related to the measure. This information helps communicate the repre-
sentativeness and validity of the performance result and the applicability to communities with EJ concerns.
Categories of meta data that may be described include the following:
a)	Original Data Source - Identifies the entity or entities providing the data that EPA uses to calculate
performance.
b)	Source Data Collection - Describes the manner by which source data are collected by all original data
source(s), including citing the quality procedures followed. This section describes the representativeness
and reliability of the source data, and the appropriateness of their use for the EJ performance measure.
This section also includes the geographical extent of and spatial and temporal resolution (frequency
of data collection and reporting) associated with the source data. Specifically, it identifies if the data
are collected and reported at sufficient resolution (granularity) to isolate activities and/or impacts in
communities with EJ concerns /vulnerable/populations (e.g., zip code, census tract, precinct, city,
township, parish, county, etc.).
c)	Source Data Reporting - Provides the form/mechanism by which (1) EPA receives data from the original
data sources and (2) EPA enters the data into an EPA information system, including the timing and
frequency of data transmission.
d)	Information Systems - Describes each EPA information system utilized in the process of collecting,
calculating and/or reporting the results for this measure; identify whether the system contains source
or transformed data; and discuss the extent to which the system meets EPA information system integ-
rity standards.

-------
6 I EJ 2020 ACTION AGENDA APPENDIX
e)	Data Quality Procedures - Describes EPA procedures for the oversight, review and quality assurance of
the performance result and underlying data, from the time the original data source provides the data.
f)	Data Oversight - Identifies by title/position the EPA personnel responsible for overseeing (1) source data
reporting and (2) the information systems utilized in producing the performance result and specifies
the responsibilities of those personnel.
g)	Calculation Methodology - Provides the methodology used by EPA to transform original data into the
EJ performance result to measure, in particular, how impacts on communities with EJ concerns and/
or vulnerable populations are calculated. If appropriate, this includes if and how data are aggregated to
national measures. This section addresses the following necessary elements: decision rules for selecting
data, definitions of variables, explanation of calculations, explanation of assumptions, unit of measure,
timeframe of result, and if applicable, description of changes to methodology.
h)	Oversight and Timing of Results Reporting - Identifies EPA personnel who (will) oversee final reporting
by the National Program Office (NPO). Explains that individual's responsibilities specific to performance
reporting oversight. Specifies the frequency of reporting, if other than annual.
i)	Third-Party Audits - If applicable, includes all relevant independent assessments of any part of the data
flow for this performance measure.

-------
EJ 2 0 2 0 ACTION AGENDA APPENDIX I 7
MEASURES TECHNICAL INFORMATION
BLOOD LEAD LEVEL DISPARITIES
OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION (OSCPP)
1.	Goal: Working toward eliminating disparities in childhood blood lead levels
2.	Measure Text: By 2018, reduce the percent difference in the geometric mean blood lead level in low-income children 1-5
years old as compared to the geometric mean for non-low income children 1-5 years old to 10.0 percent.
Baseline is 28.4 percent difference in the geometric mean blood lead level in low-income children ages 1-5 years old as
compared to the geometric mean for non-low income children 1-5 years old in 2007-2010 sampling period according to
U.S. Center for Disease Control and Prevention's (CDC) National Health and Nutrition Examination Survey (NHANES).
3.	Performance Measure Term Definitions:
•	Geometric mean blood lead level: This term refers to a type of average which indicates the central tendency or
typical value of a set of numbers. As used in this measure, it represents the central tendency of reported blood
lead levels (micrograms of lead per deciliter of blood, or (ig/dL) of children ages 1-5.
•	Low-income children: As used in this measure, this term means children whose families are below the poverty
income ratio (PIR) of 1.0. The poverty income ratio is a measure of income to the poverty threshold.
•	Non-low-income children: Children whose families have a PIR above 1.0.
4.	Relevance to Environmental Justice: This performance measure examines the disparities of blood lead levels in low-income
children compared to non-low-income children so that EPA can track progress toward its long-term goal of eliminating
childhood lead poisoning in harder to reach vulnerable populations. Low-income and minority children tend to live in
areas that still face tremendous risk of lead exposure. Non-Hispanic Black children and children living in families below
the poverty level have significantly higher risk factors for higher blood lead levels.1 Low-income, minority communities
still face aging plumbing infrastructure that could contaminate their drinking water, inhabit older housing that is more
likely to contain lead-based paint, occupy areas near roadways contaminated from previously leaded gasoline and are
more likely to be located near ongoing industrial activity or abandoned facilities.
EPA's Lead-Based Paint Risk Reduction program contributes to the goal of eliminating childhood lead poisoning by: (1)
establishing standards governing lead hazard identification and abatement practices and maintaining a national pool of
professionals trained and certified to implement those standards; (2) providing information to housing occupants so they
can make informed decisions and take actions about lead hazards in their homes; and (3) establishing a national pool of
certified firms and individuals who are trained to carry out renovation repair and painting projects while adhering to the
lead-safe work practice standards and to minimize lead dust hazards created in the course of such projects.
Recent CDC data show significant progress in the continuing effort to eliminate childhood lead poisoning as a public health
concern. The percent of children with elevated BLLs (>5 (ig/dL) has declined substantially (i.e., 86% from the 1999-2002 to
the 2011-2014 NHANES survey cycles; 43% in the most recent survey cycle alone). However, the CDC has stated that no
safe blood lead level in children has been identified. Even low levels of lead in blood have been shown to affect IQ, ability to
pay attention, and academic achievement. Effects of lead exposure cannot be corrected. See the 2012 report of the Advisory
Committee to the Centers for Disease Control on Childhood Lead Poisoning Prevention and the CDC's response here.
1	U.S. Centers for Disease Control and Prevention, 2011. Healthy Homes and Lead Poisoning Prevention Program
(Report No. CS223978-C).

-------
8 I EJ 2 0 2 0 ACTION AGENDA APPENDIX
Lead poisoning has had devastating consequences for the health of children under the age of six. Lead can be found in all
parts of our environment - the air, the soil, the water, and even inside our homes - on walls coated with lead-based paint,
and in everyday consumer products likes toys, cosmetics, ceramics, solders, gasoline, and batteries. The long-term effects
on lead exposure in a child can be severe and may include learning disabilities, decreased growth, behavior problems,
impaired hearing and even brain damage. Lead exposure is not equal for all children.
According to the CDC, there is a 34.0 percent difference in the geometric mean blood lead level in low-income children
ages 1 -5 as compared to the geometric mean for non-low income children of the same age, based on information from 2011
to 2015 and greater than the 27 percent disparity estimated from the 2005-2008 survey cycle. Inner-city neighborhoods
with lower family income levels often have higher rates of child lead poisoning than rural or suburban areas since some of
the principal sources of lead in inner-city environments are chipping and peeling lead-based paint from old houses, past
deposition in soil of lead from auto emissions, and industrial sources.
5. Mission and Organizational Context:
•	National Program Manager - Office of Chemical Safety and Pollution Prevention
•	Managing Office - Office of Pollution Prevention and Toxics
•	Strategic Goal - Ensuring the Safety of Chemicals and Preventing Pollution. Reduce the risk and increase the
safety of chemicals and prevent pollution at the sources.
•	Strategic Objective - Ensure Chemical Safety. Reduce the risk and increase the safety of chemicals that enter our
products, our environment, and our bodies.
•	Strategic Target - By 2018, reduce the percent difference in the geometric mean blood lead level in low-income
children 1-5 years old as compared to the geometric mean for non-low income children 1-5 years old to 10.0
percent.
6. Meta Data:
a)	Original Data Source - The original data source is the CDC National Lfealth and Nutrition Examina-
tion Survey (NLfANES), which is recognized as the primary database in the United States for national
blood lead statistics. NLfANES is a probability sample of the non-institutionalized population of the
United States. The survey examines a nationally representative sample of approximately 5,000 men,
women, and children each year located across the U.S.
b)	Source Data Collection - Data are obtained by analysis of blood and urine samples collected from
survey participants. Lfealth status is assessed by physical examination. Demographic and other survey
data regarding health status, nutrition, and health-related behaviors are collected by personal inter-
view, either by self-reporting or, for children under 16 and some others (such as people with commu-
nications disabilities), as reported by an informant. Detailed interview questions cover areas related
to demographic, socio-economic, dietary, and health-related questions. Lhe survey also includes an
extensive medical and dental examination of participants, physiological measurements, and labora-
tory tests. NLfANES is unique in that it links laboratory-derived biological markers, such as blood and
urine, to questionnaire responses and results of physical exams.
Quality procedures followed (by original data source): According to the CDC, the process of preparing NLfANES
data sets for release is as rigorous as other aspects of the survey. After a CDC contractor performs basic data cleanup,
the CDC NLfANES staff ensure that the data are edited and cleaned prior to release. NLfANES staff devotes at
least a full year after the completion of data collection to careful data preparation. Additionally, NLfANES data are
published in a wide array of peer-reviewed professional journals. Background documentation is available at the
NLfANES website and the analytical guidelines are available at this NLfANES website.
Geographical extent of source data, if relevant: Data are collected to be representative of the U.S. population. Lhe
population data are extrapolated from sample data by the application of standard statistical procedures. Spatial
detail of source data, if relevant: NLfANES sampling procedures provide nationally representative data.

-------
EJ 2020 ACTION AGENDA APPENDIX I 9
c)	Source Data Reporting - EPA monitors the periodic issuance of NHANES reports and other data releases
to obtain the data relevant to this measure.
NHANES is a continuous survey and examines a nationally representative sample of about 5,000 persons each
year. These persons are located in counties across the country 15 of which are visited each year. Files of raw data,
containing measured blood lead levels in NHANES participants, are currently released to the public in two-year
sets. CDC also periodically publishes reports containing summary statistics for lead and more than 200 other
chemicals measured in NHANES.
d)	Information Systems - There are no EPA systems utilized in collecting data for this measure as the
Agency is able to secure the necessary data directly from NHANES reports and data releases.
e)	Data Quality Procedures - EPA does not have any procedures for quality assurance of the underlying
data as this function is performed by the CDC itself. CDC has periodically reviewed and confirmed
EPA's calculation of NHANES summary statistics from the raw data files. The Agency determines the
performance result for this measure by performing standard mathematical operations on reported
NHANES data to derive geometric mean blood lead levels by income group and to estimate the disparity
in those levels between low-income and non-low-income children.
f)	Data Oversight - Chief, Planning and Assessment Branch, Environmental Assistance Division, Office
of Pollution Prevention and Toxics.
g)	Calculation Methodology -
•	EPA simply uses the geometric mean blood lead level values for low-income and non-low-income children that
are generated from NHANES survey data, as described below. EPA however, limits the age of the child to under
six, based on the most sensitive receptor age group noted in Section 401 of the Toxic Substances Control Act of
1976 (TSCA).
•	EPA performs standard mathematical operations on the published NHANES survey data. After calculating geometric
mean blood lead levels by income group from the public use data files, EPA (1) determines the absolute disparity
in blood lead level values between the two groups of children by subtracting the lower value from the higher;
(2) averages the values for the two groups; and (3) divides the absolute disparity (i.e., the result of calculation
(1) by the average of the values (i.e., the result of calculation (2)), to express the disparity as a percent difference
between the blood lead levels of the two groups.
•	The performance result is computed from data released by the CDC in sets covering the particular time period
over which sampling occurs. Thus, the timeframe that applies to the measured result is the same period for which
the NHANES data are released. It is not a simple snapshot at a specific moment in time.
h)	Oversight and Timing of Results Reporting - Planning and Accountability Lead in the Resource Manage-
ment Staff in the Office of Program Management Operations. Reporting semiannually: mid-year and
end-of-year, but subject to a data lag due to the periodic nature of NHANES reporting.
i)	Third-Party Audits - Report of the NHANES Review Panel to the NCHS Board of Scientific Counselors.
• Cover letter
• Report

-------
10 I EJ 2020 ACTION AGENDA APPENDIX
SMALL WATER SYSTEMS
OFFICE OF WATER (OW)
1.	Goal: All people served by community water systems have drinking water that meets applicable health based standards.
In working toward this goal, we will place special emphasis on addressing drinking water challenges in underserved
communities.
2.	Measure: Number and percent of small community water systems and non-transient non-community water systems with
repeat health-based violations of key contaminants.
3.	Performance Measure Term Definitions:
•	. Community water systems - The U.S. Environmental Protection Agency (EPA) defines a community water
system (CWS) as a public water system that serves at least 15 service connections used by year-round residents or
regularly serves at least 25 year-round residents. Since 2012, there have typically been between 825-890 systems
serving populations less than 3,300 persons with repeat health-based violations each year.
•	. Repeat health-based drinking water violations - Repeat violations are defined as repeats of the same combina-
tion of violation (e.g., total coliform rule MCL) and contaminant type (e.g., TCR) for a CWS. If a particular
combination of violation and contaminant type occurs at a particular system more than once in a Fiscal Year,
this constitutes a repeat violation. For the purposes of this analysis, only repeat health-based TCR, Nitrates, and
surface water treatment rule violations were included. The analysis is based on Safe Drinking Water Information
System-Federal (SDWIS-FED) data within the previous 12 months year ending June 30th. Systems must serve
fewer than 3,300 people. The same violation code and contaminant type combination must occur more than
once in the above 12 month period.
4.	Relevance to Environmental Justice: It is EPA's goal that all Americans throughout the nation have access to safe,
reliable drinking water. However, EPA recognizes that small community water systems (i.e., those systems that
serve fewer than 3,300 people) face a number of unique challenges that make universal access to safe drinking water
more challenging. Of the more than 51,500 community water systems nationwide that supply drinking water to
more than 95 percent of the U.S. population, the vast majority (82 percent) serve fewer than 3,300 people. These
small systems are often disproportionately impacted by technical, managerial, and financial capacity challenges. In
addition, many of these small drinking water systems serve disadvantaged communities. An EPA review of county
income figures for the community water systems that had repeat health-based violations for 2012-2014 found that
about 62 percent of those communities have average household incomes less than twice the national poverty level.
EPA continually strives to meet the goal of 100 percent access to clean, safe drinking water for all Americans served by
community water systems. By targeting reductions in repeat health-based violations for small drinking water systems,
the Agency is working to improve public health protection for small, disadvantaged communities.
5.	Mission and Organizational Context:
•	National Program Manager - Office of Water
•	Managing Office - Office of Groundwater and Drinking Water
•	Strategic Goal - Protecting Americas Waters
•	Strategic Objective - Protecting Human Health
•	Strategic Target - By 2020, reduce the number of community water systems serving populations less than 3,300
persons that had repeat health-based drinking water violations during the year by 10 percent from a 2014 baseline.

-------
EJ 2020 ACTION AGENDA APPENDIX I 11
6. Meta Data:
a)	Original Data Source - EPA
b)	Source Data Collection - The EPA Office of Ground Water and Drinking Water (Headquarters) calculates this
measure using data reported in the SDWIS-FED and provides the results to the EPA regional offices.
Data are provided by agencies with primacy (primary enforcement authority) for the Public Water System Super-
vision (PWSS) program. These agencies are either: States, EPA for non-delegated states or territories, and the
Navajo Nation Indian tribe, the only tribe with primacy. Primacy agencies collect the data from the regulated
water systems, determine compliance, and report a subset of the data to EPA (a subset of the inventory data and
summary violations). State certified laboratories report contaminant occurrence to states that, in turn, determine
exceedances of maximum contaminant levels or non-compliance with treatment techniques and report these
violations to EPA. Under the drinking water regulations, water systems must use approved analytical methods for
testing for contaminants.
The States or Primacy Agencies report to EPA using SDWIS, basic information on each water system, as well as
"violation" and enforcement information. This measure includes federally-regulated contaminants of the following
violation types: Maximum Contaminant Level, Maximum Residual Disinfection Limit, and Treatment Technique
violations. It includes any violations from currently open and closed community water systems (CWSs) that overlap
any part of the most recent four quarters.
EPA uses this information to determine if and when it needs to address non-compliant systems, oversee state
drinking water programs, track contaminant levels, respond to public inquiries, and prepare national reports. EPA
also uses this information to evaluate the effectiveness of its programs and regulations, and to determine whether
new regulations are needed to further protect public health.
The development of a drinking water metric intended to improve public health protection for drinking water
consumers in small disadvantaged communities must reconcile limitations in data maintained in EPA's state drinking
water information system (SDWIS). SDWIS is the sole national database containing the historic non-compliance
information for each of the nation's public water systems. SDWIS maintains basic system data including system
size, source water type, treatment, and contact information. Unfortunately, SDWIS does not contain any commu-
nity household income information nor maintains any information identifying a community as disadvantaged.
EPA routinely tracks the number of systems with repeat health-based violations of drinking water regulations as
one of several compliance metrics intended to encourage improvements in system performance and public health
protection for consumers. Systems that have multiple or repeat health-based violations are implied to have chronic/
systemic issues needing increased attention by water systems and technical assistance providers.
c)	Source Data Reporting - Public Water System Supervision (PWSS) Regulation-Specific Reporting Require-
ments Guidance.
System, user, and reporting requirements documents can be found on the EPA website.
d)	Information Systems - SDWIS/STATE, a software information system jointly designed by states and EPA, to
support states as they implement the drinking water program. SDWIS/STATE is an optional data base application
available for use by states and EPA regions to support implementation of their drinking water programs.
U.S. EPA, Office of Ground Water and Drinking Water. Data and Databases. Drinking Water Data & Databases
- SDWIS/STATE, July 2002. Information available on the EPA website. Documentation is also available at the
Association of State Drinking Water Administrators website.
SDWIS/Fed Data Reliability Action Plan [2006 Drinking Water Data Reliability Analysis and Action Plan (DRAP),
EPA-816-R-07-010 March 2008]. The DRAP contains the processes and procedures and major activities to be
employed and undertaken for assuring the data in SDWIS meet required data quality standards. This plan has
three major components: assurance, assessment, and control.

-------
12 I EJ 2020 ACTION AGENDA APPENDIX
Office of Water Quality Management Plan
e)	Data Quality Procedures - The data quality review is based on the recommendations of the Data Quality
Workgroup and on the Drinking Water Strategy for monitoring data. There are quality assurance manuals
for states and Regions, which provide standard operating procedures for conducting routine assess-
ments of the quality of the data, including timely corrective action(s). Reporting requirements can be
found on the EPA website. SDWIS/FED edit checks built into the software to reject erroneous data.
EPA offers the following to reduce reporting and database errors: 1) training to states on data entry, data retrieval,
compliance determination, reporting requirements and error correction, 2) user and system documentation
produced with each software release and maintained on EPA's web site, 3) specific error correction and reconcilia-
tion support through a troubleshooter's guide, 4) a system-generated summary with detailed reports documenting
the results of each data submission, 5) an error code database for states to use when they have questions on how
to enter or correct data, and 6) user support hotline available 5 days a week.
f)	Data Oversight - The Infrastructure Branch Chief is responsible for overseeing source data reporting. The
Associate Director of Drinking Water Protection is responsible for overseeing information systems utilized in
producing performance results.
g)	Calculation Methodology - The EPA Office of Ground Water and Drinking Water (headquarters) calculates this
measure using data reported in the Safe Drinking Water Information System-Federal (SDWIS-FED) and provides
the results to EPA regions. This measure includes federally-regulated contaminants of the following violation
types: Maximum Contaminant Level, Maximum Residual Disinfection Limit, and Treatment Technique viola-
tions. It includes any violations from currently open and closed community water systems (CWSs) that overlap
any part of the most recent four quarters.
h)	Oversight and Timing of Results Reporting - The Director for the Office of Groundwater and Drinking Water
and the Evaluation and Accountability Team Leader for the Office of Water are responsible for coordinating the
reporting of all measures for the Office of Water.

-------
EJ 2020 ACTION AGENDA APPENDIX I 13
TRIBAL DRINKING WATER SYSTEMS
OFFICE OF WATER (0W1
1.	Goal: All people served by community water systems have drinking water that meets applicable health based standards.
In working toward this goal, we will place special emphasis on addressing drinking water challenges in underserved
communities.
2.	Measure: Percent of population in Indian country served by community water systems with drinking water that meets
all applicable health-based drinking water standards.
3.	Performance Measure Term Definitions:
•	The definition of Indian country is that used by the U.S. Department of Justice.
Community water systems - The U.S. Environmental Protection Agency (EPA) defines a community water system
(CWS) as a public water system that serves at least 15 service connections used by year-round residents or regularly
serves at least 25 year-round residents. In FY2011 737 CWSs in Indian country regulated by the EPA and Navajo
Nation provided water to more than 918 thousand persons.
•	Safe drinking water that meets all health-based drinking water standards does not exceed a maximum contami-
nant level (MCL) nor violate a treatment technique.
4.	Relevance to Environmental Justice: It is EPA's goal that all Americans throughout the nation have safe, reliable
drinking water. However, EPA recognizes that many tribal drinking water systems face unique challenges that make
universal safe drinking water more challenging. Tribal water systems are often disproportionately impacted by
technical, managerial, and financial capacity challenges, which affect their ability to achieve and maintain system
sustainability. Additionally, tribal systems can face compliance challenges and may lack the ability to develop long-
term planning efforts due to a number of factors, such as not having a governance structure, lack of full-time certi-
fied operator, high turnover, financial limitations, and/or overall difficulty with accessing technical information.
Such challenges can lead to disproportionate health-based violations in tribal drinking water systems, when
compared to similar small systems outside of Indian country. According to FY2015 data, 5.9 percent of tribal
public water systems serving less than 3,300 received a total coliform MCL violation, compared with 3.8 percent
of the non-tribal systems. Additionally, 87 percent of the tribal community water systems served water with
no health based violation in FY2015, compared with 90 percent of the non-tribal community water systems.
The EPA continually strives to deliver clean, safe drinking water 100 percent of the time for all Americans served by
community water systems by targeting its efforts in Indian country to ensure that tribal drinking water systems provide
drinking water that meets all applicable health-based drinking water standards in an effort to improve public health
protection for tribal communities.
5.	Mission and Organizational Context:
•	National Program Manager - Office of Water
•	Managing Office - Office of Groundwater and Drinking Water
•	Strategic Goal - Protecting Americas Waters
•	Strategic Objective - Protecting Human Health
•	Strategic Target - By 2020, ensure at least 92 percent of the population in Indian country served by
community water systems receive drinking water that meets all applicable health-based drinking water
standards.

-------
14 I EJ 2 0 2 0 ACTION AGENDA APPENDIX
6. Meta Data:
a)	Original Data Source - EPA, except for community water systems serving the Navajo Nation, because the Navajo
Nation has primacy responsibility for implementing the Safe Drinking Water Act.
b)	Source Data Collection - The EPA Office of Ground Water and Drinking Water (Headquarters) calculates
this measure using data reported in the Safe Drinking Water Information System-Federal (SDWIS-FED) and
provides the results to EPA Regions and the Navajo Nation.
This measure includes federally-regulated contaminants of the following violation types: Maximum Contami-
nant Level, Maximum Residual Disinfection Limit, and Treatment Technique violations. It includes any viola-
tions from currently open and closed community water systems (CWSs) that overlap any part of the most
recent four quarters.
c)	Source Data Reporting - Public Water System Supervision (PWSS) Regulation-Specific Reporting Requirements
Guidance. System, user, and reporting requirements documents can be found on the EPA website.
d)	Information Systems - SDWIS/STATE, a software information system jointly designed by states and EPA, to support states
and EPA Regions as they implement the drinking water program. SDWIS/STATE is an optional data base application
available for use by states and EPA regions to support implementation of their drinking water programs. EPA Region
9 utilizes an access database system (DIME) to collect and report on tribal community water systems in Region 9.
SDWIS/FED User and System Guidance Manuals (includes data entry instructions, data On-line Data Element
Dictionary-a database application, Error Code Data Base (ECDB) - a database application, users guide, release notes, etc.).
Specific rule reporting requirements documents are accessed via the regulations, guidance, and policy documents.
SDWIS/Fed does not have a Quality Assurance Project Plan. The SDWIS/FED equivalent is the Data Reliability
Action Plan [2006 Drinking Water Data Reliability Analysis and Action Plan, EPA-816-R-07-010 March 2008]
The DRAP contains the processes and procedures and major activities to be employed and undertaken for
assuring the data in SDWIS meet required data quality standards. This plan has three major components: assur-
ance, assessment, and control.
Office of Water Quality Management Plan
e)	Data Quality Procedures - The Office of Ground Water and Drinking Water is modifying its approach to data
quality review based on the recommendations of the Data Quality Workgroup and on the Drinking Water
Strategy for monitoring data.
There are quality assurance manuals for states and Regions, which provide standard operating procedures for
conducting routine assessments of the quality of the data, including timely corrective action(s).
Reporting requirements can be found on the EPA website.
SDWIS/FED edit checks built into the software to reject erroneous data. EPA offers the following to reduce
reporting and database errors: 1) training to states on data entry, data retrieval, compliance determination, reporting
requirements and error correction, 2) user and system documentation produced with each software release and
maintained on EPA's web site, 3) Specific error correction and reconciliation support through a troubleshooter's
guide, 4) a system-generated summary with detailed reports documenting the results of each data submission,
5) an error code database for states to use when they have questions on how to enter or correct data, and 6) User
support hotline available 5 days a week.
f)Data	Oversight - The Drinking Water Protection Division Director oversees the source data reporting and the
information systems producing the performance result.
g)	Calculation Methodology - SDWIS/STATE, a software information system jointly designed by states and EPA,
to support states as they implement the drinking water program. SDWIS/STATE is an optional data base appli-
cation available for use by states and EPA regions to support implementation of their drinking water programs.

-------
EJ 2020 ACTION AGENDA APPENDIX I 15
U.S. EPA, Office of Ground Water and Drinking Water. Data and Databases. Drinking Water Data & Databases -
SDWIS/STATE, July 2002.
Documentation is also available at the Association of State Drinking Water Administrators website
SDWIS/Fed does not have a Quality Assurance Project Plan. The SDWIS/FED equivalent is the Data Reliability
Action Plan (DRAP) 2006 Drinking Water Data Reliability Analysis and Action Plan, EPA-816-R-07-010 March
2008. The DRAP contains the processes and procedures and major activities to be employed and undertaken for
assuring the data in SDWIS meet required data quality standards. This plan has three major components: assur-
ance, assessment, and control.
Office of Water Quality Management Plan
h) Oversight and Timing of Results Reporting - The Evaluation and Accountability Team Leader is responsible
for overseeing the final reporting for the Office of Water.

-------
16 I EJ 2020 ACTION AGENDA APPENDIX
FINE PARTICLE AIR POLLUTION
OFFICE OF AIR AND RADIATION (OAR)
1.	Goal: Achieve air quality that meets the fine particle pollution national ambient air quality standards (NAAQS) for all
low-income populations as early as practicable and no later than their statutory attainment date (which for most areas
will be 2021 or sooner). Low-income populations are among those most at-risk to adverse health effects from exposure
to fine particle pollution.
2.	Measures:
•	Percentage of low-income people living in counties with monitors measuring concentrations of PM2.5 that meet
the 2012 annual and 2006 24-hour PM2.5 NAAQS.
This measure evaluates each year the percentage of low-income people living in counties with monitors measuring
concentrations of fine particle pollution (PM2.5) that meet the 2006 24-hour and the 2012 annual PM2.5 NAAQS.
The baseline period for the measure will be 2006-2008 (i.e., the 3-year period used for designations for the 2006
24-hour PM2.5 NAAQS). Changes since that time will reflect the effectiveness of strategies designed to reduce
particle pollution. The goal is to increase this percentage over time and to reach 100 percent by 2025. Such a trend
would demonstrate that state efforts to attain and maintain these standards are working and that low-income
populations are benefitting.
•	The average county-level design value for counties with monitors measuring PM2.5 concentrations not meeting
the PM2.5 NAAQS.
This second measure provides information on the improvement in air quality in counties not meeting the PM2.5
NAAQS. It relies on the calculated design value, which is a statistic that describes the air quality status of a given
location relative to the level of the NAAQS.
•	The difference in attainment of the standard between low-income and non-low-income areas.
Based on current (2012-2014) air quality data, among the low-income population that lives in counties with PM2.5
monitors, about 83 percent live in counties that meet the 2012 annual and 2006 24-hour PM2.5 NAAQS. This
compares to about 85 percent of the total population living in counties that meet the PM2.5 NAAQS and reflects
a 40 percent improvement since 2006-2008.
The baseline period for these measures is 2006-2008. Changes since that time reflect the effectiveness of strategies
designed to reduce particle pollution. The measure will be evaluated two ways:
•	Increasing percentages of low-income people living in areas where the air quality meets the fine particle pollution
standards will indicate improvements in air quality for these vulnerable populations; and
•	Percentage of low-income people compared to the general population (total percentage of people living in counties
with monitors measuring PM2.5 concentrations that meet the 2006 24-hour and the 2012 annual standards),
which will allow EPA to see how the rate of change in low-income communities compares to changes in the
broader community.
3.	Performance Measure Term Definitions:
•	Fine particulate matter (PM2.5): Particles with a mass median diameter of 2.5 microns or less.
•	Annual PM2.5 design value: the highest reported site-level annual standard air quality statistic, i.e. the 3-year
average annual mean concentration of PM2.5.
•	24-Hour PM2.5 design value: The highest reported site-level annual standard air quality statistic, i.e. the 3-year
average 98th percentile concentration of PM2.5.
•	County-level design value: The highest site-level design value in a county
•	Particle pollution: Also called particulate matter or PM, is a complex mixture of extremely small particles and

-------
EJ 2020 ACTION AGENDA APPENDIX I 17
liquid droplets in the air. When inhaled, these particles can reach the deepest regions of the lungs. Exposure to
particle pollution is linked to a variety of significant health problems. Particle pollution monitors are placed in
areas where high concentrations are expected.
•	Fine particles: Particles with a diameter equal to or less than 2.5 microns PM2.5 - can be emitted directly into
the atmosphere, such as black carbon emissions from a diesel engine or smoke from a fire, or they can form
from chemical reactions of precursor gases including sulfur dioxide, nitrogen dioxide, certain volatile organic
compounds, and ammonia. Emission sources include power plants, gasoline and diesel engines, wood combustion,
high-temperature industrial processes such as smelters and steel mills, and forest fires. Fine particle pollution
is monitored throughout the country to identify whether an area is meeting EPA's national ambient air quality
standards.
•	Low-Income populations: To assure adequate coverage of the at-risk population in the metrics, we define
low-income as two times the poverty level. Low-income status is associated with low educational attainment or
disadvantageous residential location, and these factors can also contribute to an individual's higher exposure to
air pollution. Low-income populations are among the populations that are at-risk for adverse health effects from
exposure to PM2.5. Low-income people have been generally found to have a higher prevalence of pre-existing
diseases, limited access to medical treatment, and increased nutritional deficiencies, which can increase their
risk of particle pollution-related effects.
•	Counties in included in measure: The current monitored counties with at least one site within them meeting the
2012 NAAQS for PM2.5.
•	National Ambient Air Quality Standards: The Clean Air Act requires EPA to set National Ambient Air Quality
Standards for pollutants considered harmful to public health and the environment. EPA has set National Ambient
Air Quality Standards for six principal pollutants, which are called "criteria" pollutants. Particulate matter (of
which PM2.5 is one form) is one these six pollutants.
4.	Relevance to Environmental Justice: The impacts of fine particulate matter pollution are not evenly shared across all
population groups. Low-income populations are among those most at-risk to adverse health effects from exposure to
PM2.5. They have been generally found to have a higher prevalence of pre-existing diseases, limited access to medical
treatment, and increased nutritional deficiencies, which can increase their risk of particle pollution-related effects. In
addition, low-income populations often suffer from low educational attainment or disadvantageous residential location-
factors that can also contribute to an individual's higher exposure to air pollution.
5.	Mission and Organizational Context:
•	National Program Manager - OAR
•	Managing Office - Office of Air Quality Planning and Standards/Outreach and Information Division
•	Strategic Goal - Addressing Climate Change and Improving Air Quality
•	Strategic Objective - Improve Air Quality
6.	Meta Data:
a)	Original Data Source:
•	State and local agency data are from State and Local Air Monitoring Stations (SLAMS).
•	Population data are from the Census Bureau/Department of Commerce (2010 Census)
b)	Source Data Collection:
•	Ambient air quality data: Field monitoring; survey
•	EPA QA Requirements/Guidance Governing Collection: To ensure quality data, the SLAMS are required
to meet the following: 1) each site must meet network design and site criteria; 2) each site must provide
adequate QA assessment, control, and corrective action functions according to minimum program
requirements; 3) all sampling methods and equipment must meet EPA reference or equivalent require-
ments; 4) acceptable data validation and record keeping procedures must be followed; and 5) data from

-------
18 I EJ 2020 ACTION AGENDA APPENDIX
SLAMS must be summarized and reported annually to EPA. Finally, there are system audits that regularly
review the overall air quality data collection activity for any needed changes or corrections. Further
information is available on the Internet at https://www3.epa.gov/ttn/amtic/quality.html and through
United States EPA's Quality Assurance I Iandbook (EPA-454/R-98-004 Section 15).
•	Geographical Extent of Source Data: National
•	Spatial Detail Covered By the Source Data: 486 counties in the 50 continental States plus D.C.
c)	Source Data Reporting - Agencies submit air quality data to the Air Quality System (AQS) thru the Agency's
Central Data Exchange (CDX). CDX is intended to be the portal through which all environmental data coming
to or leaving the Agency will pass. Additional information can be found here: http://www.exchangenetwork.
net/data- exchange/aqs/
d)	Information Systems:
•	Fhe Air Quality System (AQS) stores ambient air quality data used to evaluate an area's air quality relative
to the National Ambient Air Quality Standards (NAAQS).
•	All annual mean concentration data used in the performance analysis were extracted from the AQS.
e)	Data Quality Procedures:
The Air Quality System (AQS) QA/QC process also involves participation in the EPA's National Performance
Audit Program (NPAP), system audits, and network reviews. Please see www.epa.gov/ttn/amtic/npaplist.html
for more information.
f)	Data Oversight:
•	National Air Data Group (Outreach and Information Division, OAQPS) oversees operations of the Air
Quality System, the database used to store and deliver the source data.
•	Air Quality Monitoring Group (Air Quality Assessment Division (AQAD), OAQPS) oversees the
monitoring and quality assurance of the source data.
•	Air Quality Analysis Group (AQAD, OAQPS) oversees the transformation and data reporting aspects
associated with the calculation of this performance measure.
g)	Calculation Methodology - Low-income populations living in counties with PM2.5 monitoring data showing
attainment of both the 24-hour and annual primary NAAQS divided by the population of low-SES living in
all counties with PM2.5 monitoring data. The percentage resulting from this calculation can be expressed as a
percentage of the low-income population living in areas with ambient concentrations below the 24-hour and
annual PM2.5 NAAQS. As PM2.5 air quality improves, this percentage can be expected to increase.
h)	Oversight and Timing of Results Reporting:
•	Community and Tribal Programs Group, Outreach and Information Division, OAQPS, OAR is directly
responsible for the oversight and timing of this EJ2020 performance measure.
•	Air Quality Analysis Group, Air Quality Assessment Division, OAQPS, OAR is directly responsible for
the calculations associated with this performance measure.
•	Ambient Standards Group, Health and Environmental Impacts Division, OAQPS, OAR is directly
responsible for setting the PM2.5 standards.

-------
EJ 2020 ACTION AGENDA APPENDIX I 19
HAZARDOUS WASTE SITES
OFFICE OF LAND AND EMERGENCY MANAGEMENT (OLEM)
1.	Goal: Reduce human exposure to contamination at hazardous waste sites, with emphasis on minority, low-income and
vulnerable communities.
2.	Measure: Number and percent of Resource Conservation Recovery Act (RCRA) Corrective Action Program facilities
and Superfund Remedial Program contaminated sites in communities where human exposures to contamination are
under control.
3.	Performance Measure Term Definitions:
•	Sites are listed on the National Priorities List upon completion of Hazard Ranking System (HRS) screening, public
solicitation of comments about the proposed site, and final placement of the site on the NPL after all comments
have been addressed. The NPL primarily serves as an information and management tool. It is a part of the
Superfund cleanup process and is updated periodically.
•	Sites are defined as Human Exposure Under Control (HEUC) when assessments for human exposures indicate
there are no unacceptable human exposure pathways and the Region has determined the site is under control for
current conditions site wide. This is also a Government Performance and Results Act (GPRA) performance measure.
•	The criteria for determining the Site-Wide Human Exposure status at a site are found in the Superfund Environ-
mental Indicator Guidance Human Exposure Revisions March 2008.
•	On a biennial basis, EPA will examine each of the 799 baseline facilities and sites where human exposure is not
under control using EJSCREEN.
•	EPA will report on the number of facilities and sites with human exposures under control, the number remaining,
and the percent with human exposures under control in communities with environmental justice concerns as
well as in these communities as a proportion of the totals for all sites and facilities.
4.	Relevance to Environmental Justice: A measure such as the "Human exposure not under control" is important because
the ultimate goal and mission of the Agency is to protect human health and the environment. This measure, along with
the Executive Order 12898, draws attention to the plight of overburdened and underserved communities surrounded
by hazardous waste sites. Because minority and low-income populations are highly concentrated in neighborhoods with
multiple facilities, they continue to be particularly vulnerable to the various negative impacts of hazardous waste facili-
ties. For example, a key finding of the report Toxic Wastes and Race at Twenty 1987- 20071 report found that minority
populations make up the majority of those living in host neighborhoods within 3 kilometers (1.8 miles) of the nation's
hazardous waste facilities. This measure, along with the Executive Order 12898, draws attention to the plight of overbur-
dened and underserved communities surrounded by hazardous waste sites. EPA's goal to ensure that controlling exposure
is important because the ultimate goal and mission of the Agency is to protect human health and the environment.
5.	Mission and Organizational Context:
•	National Program Manager - Office of Land and Emergency Management
•	Managing Office(s) - Office of Superfund Remediation and Technology Innovation (OSRTI) and the Office of
Resource Recovery and (ORCR)
•	Strategic Goal - Cleaning Up Communities and Advancing Sustainable Development
•	Strategic Objective - Restore Land
1	Bullard, Robert D., Mohai, Paul, Saha, Robin, Wright, Beverly. 2007. Toxic Wastes and Race at Twenty: 1987-2007. (Cleveland,
OH: United Church of Christ).

-------
20 I EJ 2020 ACTION AGENDA APPENDIX
•	Strategic Target - By 2018, increase the number of Superfund sites and RCRA facilities where human exposure
and toxins
•	Key Performance Indicator - Advancing Cleanups: Number of sites protective for people [across cleanup programs,
will use superfund, superfund alternative sites that are protective for people/human exposure under control, and
RCRA for national calculation.
6. Meta Data:
a)	Original Data Source - EPA
b)	Source Data Collection - The Office of Land and Emergency Management (OLEM)'s Superfund Program (formally
Office of Solid Waste and Emergency Response) and the Office of Resource Conservation and Recovery (ORCR)
also known as Resource Conservation and Recovery Act (RCRA).
•	Superfund remedial site experts make the Human Exposure determinations and enter the data into
the Superfund Enterprise Management System (SEMS). The determinations are reviewed by (and in
some cases entered by) remedial program managers. Following this, the Superfund Headquarters
Environmental Indicator Data Sponsor reviews the data to assure compliance with applicable guidance
and policy, and to assure that the determinations match environmental conditions on site as they are
reported. Each determination is required to be reviewed in the regional office at least once a year and
any time a change in site conditions would warrant a revision of the measure. The data are able to be
associated with communities with EJ concerns thru analysis of basic geographic information (e.g., zip
code, census tract, precinct, city, township, parish, county, etc.).
•	The RCRA Corrective Action Human Exposures Under Control Environmental Indicator (HHEI) deter-
mination for a facility is made and documented by either a RCRA authorized state program or a RCRA
region. The Human Exposure Under Control Environmental Indicator Form is used to document that
the facility has met the criteria and the form is placed in the facility file, and sent to the Region. When
a determination and documentation is complete, the facility determination is recorded in RCRAInfo,
EPA's national data system for the RCRA subtitle C program.
c)	Source Data Reporting:
•	The Superfund Enterprise Management System (SEMS) is EPA's official database for tracking hazardous
waste sites, cleanup activities, and other programmatic functions conducted by the Superfund Remedial
Program. SEMS provides the Agency and interested members of the public with up-to-date information
about the status of cleanup progress at hazardous waste sites across the nation.
•	EPA regional site experts enter the data into SEMS using a module in the system specific to the human
exposure measure. The module requires the user to provide specific information regarding the exposure
conditions on site; the nature of that information determines which of the several exposure categories
the site is assigned to. The data is transmitted immediately, as authorized users of this SEMS module
have real time access to any change in the module.
•	RCRAInfo data is generated and entered by authorized states and EPA Regions. The HHEI determina-
tion (which is then entered into RCRAInfo) is made by EPA Regions or authorized State programs. The
determination is documented with a form which is then filed in the facility file and sent to the Region.
Data is entered into RCRAInfo two ways:
o Via direct data entry into RCRAInfo via the application; or
o States which have their own data systems or tracking mechanisms, can provide a flat file or xml
download of their data via CDX and the Exchange Network to automatically load into RCRAInfo.
This process is called "Translation."
•	Data is entered directly into RCRAInfo on a daily basis. Translators can provide the data via the trans-
lation process at any interval they desire (daily, weekly, or monthly) but are asked to translate data at a
minimum monthly.

-------
EJ 2020 ACTION AGENDA APPENDIX I 21
d)	Information Systems:
•	The source data is contained within SEMS, which is the official system of record for the Superfund
Program. Data entry is performed in the Site Management module of the SEMS, and reporting is done
from the Reporting Tool module. The system conforms to all Agency standards with respect to security
and data integrity. Business processes and data quality are directly supported by the Superfund Program
Implementation Manual and regional Data Entry Control Plans, which are updated annually.
•	RCRAInfo is EPA's comprehensive information system, providing access to data supporting the Resource
Conservation and Recovery Act (RCRA) of 1976 and the Hazardous and Solid Waste Amendments
(HSWA) of 1984.
•	The RCRAInfo system enables cradle-to-grave waste tracking of many types of information regarding
the regulated universe of RCRA hazardous waste handlers. RCRAInfo characterizes facility status,
regulated activities, and compliance histories in addition to capturing detailed data on the generation
of hazardous waste from large quantity generators and on waste management practices from treatment,
storage, and disposal facilities.
•	Using cutting-edge technology and a simple architecture, RCRAInfo provides a convenient user inter-
face for program staff and managers. The system encourages development of in-house expertise for
controlled cost and sports the ability to use commercial off-the-shelf software to do ad-hoc reporting
directly from database tables.
e)	Data Quality Procedures:
•	Each determination is reviewed by the appropriate remedial program manager. Following this, the
Headquarters Data Sponsor reviews each determination to assure compliance with applicable guidance
and policy, and to assure that the determinations match environmental conditions on site as they are
reported. When the Headquarters Data Sponsor determines that the data provided by the original data
source (in this case, the EPA regional office) meets the criteria listed in the applicable guidance, the site
determination is approved.
•	The RCRA Corrective Action Program started the tracking of the Human Exposure Environmental
Indicator with Environmental Indicator Guidance in 1999, which included a form which is to be
completed to document the determination. The form, if completed by a state authorized program is
sent to the Region.
•	RCRA corrective action program had communicated to regional offices and authorized states that if
a project manager becomes aware of changes to the site which would change the HEEI determination
should be changed to reflect current conditions.
f)	Data Oversight:
•	The person responsible for overseeing national source data reporting for the Human Exposure measure
is the Headquarters Environmental Indicator Data Sponsor. This persons responsibilities are listed above.
The person responsible for overseeing the information systems used in producing the performance
result is the SEMS System Owner. The system owner is responsible for overall project management
responsibilities for SEMS, including budget and schedule. The system owner is ultimately responsible
for the function and security of the system, and assumes responsibility for the system after delivery and
installation, during operation, maintenance, and disposal.
•	The HHEI determinations are conducted by RCRA program project managers and approved by their
supervisors. HHEIs prepared by states are reviewed by EPA Regions. RCRAInfo meets EPA informa-
tion system integrity standards and all data standards for data elements contained in the system. The
RCRAInfo application and translation process has data edit checks and business rule verification to
ensure accurate data is being entered. Oversight of this data is performed by the Regions and HQ and
as part of GPRA tracking.
•	The reporting of the RCRA HHEI data for the EJ measure is prepared by staff and overseen by division
level management.

-------
¦ U.S. Environmental Protection Agency
Office of Environmental Justice
1200 Pennsylvania Ave. NW
Washington, DC 20460
(202) 564-2515
environmental-justice@epa.gov
A |—|^#V United States
Environmental Protection!
tl M % Agency
EPA-300-P-16-001
October 2016

-------