ML20197C679
| ML20197C679 | |
| Person / Time | |
|---|---|
| Issue date: | 12/12/1997 |
| From: | Bangart R NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | GENERAL, OHIO, STATE OF, OKLAHOMA, STATE OF, PENNSYLVANIA, COMMONWEALTH OF |
| References | |
| SP-97-085, SP-97-85, NUDOCS 9712240249 | |
| Download: ML20197C679 (15) | |
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2*i UNITED STATES g
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NUCLEAR REGULATORY COMMISSION
'C WASHINoToN, D.C. 20566-0001 December 12, 1997 ALL AGREEMENT STATES OHIO, OKLAHOMA, PENNSYLVANIA TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-97 085)
Your attention is invited to the enclosed correspondence which contains:
INCIDENT AND EVENT INFORMATION..........
PROGRAM MANAGEMENT INFORMATION....XX CRITERIA FOR TRAINING FUNDING ASSISTANCE FOR AGREEMENT STATES TRAINING COURSE INFORMATION...............
TECHNICAL INFORMATION...........................
OTH E R IN FORM ATION..................................
Supplementary Information: The Commission has completed its evaluation of issues associated with NRC funding for training of Agreement State staff. As directed by the Commission in the Staff Requirements Memorandum (SRM) on DSI-4, the staff developed draft criteria for potential NRC assistance for States that demonstrate a hardship due to lack of funding for training and associated travel for their radiation control program staff. The draft staff criteria were sent to the Agreement States for comment on June 9,1997. Comments received were addressed and the revised staff criteria were sent to the Commission on August 7,1M7 (SECY-97-183). On November 19,1997, the Commission issued an SRM on SECY-97-1ba which directed the staff to add an additional criterion to the staff criteria and to adjust the priority for student selection for the training courses. The Commission also approved the staffs proposal for addressing Agreement State requests for technical assistance on a case-by-case basis using existing guidance. The revised criteria reflecting the Commission direction are enclosed.
The SRM on SECY-97-183 indicates the additional criterion is to establish a' limit on the total number of training requests that the NRC will approve for an individual State over a three year period to ensure that States do not rely upon NRC funding as a matter of routine. This number should represent an appropriate fraction of the Agreement State's training needs, and be based on the size of the Agreement State program and the projected training needs of the' individual States so as to provide an equal incentive for all States to seek funding to cover their training needsindependent of the NRC
!I The relative priority for clats admission is as follow; l
i Priority i NRC staff and Agreement State sta# fully funded by their State.
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9712240249 971212 Id..a 4
- SP-97085 2
Priority lli Agreement State staff for whom tuition is funded by the NRC, i.e., space available training at no tuition cost to the State, and the State would be
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paying travel and per diem expenses, Priority lli
. Agreement State staff for whom NRC has funded tuition and travel, in whole or in part.
The NRC staff will begin using the criteria and the selection priorities immediately. Additional
. guidance will be issued in early 1998 specifying the process and methods for paying the tuition expense for NRC courses.
F If you have any questions about this correspondence, please contact me or the individual named below.
CONTACT:
Dennis M. Sollenberger TELEPHONE:
(301) 415-2819 FAX:
(301) 415-3502 INTERNET:
DMS4@NRC. GOV N
fit Ott. At ?,
v Richard L. Bangart, Director
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Office of State Programs
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Enclosure:
As stated m
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e SP-97 085 2
. Priority ll
' Agreement State staff for whom tuition is funded by the NRC, i.e., space -
available training at no tuition cost to the State, and the State would be paying travel and per diem expenses.
Priority ill Agreement State staff for whom NRC has funded tuition and travel, in whole or in part.
~ The NRC staff will begin using the criteria and the selection priorities immediately. Additional guidance will be issued in early 1998 specifying the process and methods for paying the tuition expense for NRC courses.
If you have any questions rhout this correspondence, please contact me or the individual named below.
CONTACT:
Dennie M. Sollenberger TELEPHONE:
(301) 415-2819 FAX:
(301)415 3502 INTERNET:
DMS4@NRC. GOV OriginalSigned By RICHARD L BANGART Richard L. Bangart, Director Office of State Programs
Enclosure:
As stated Distribution:
DIR RF EDO RF (WITS 9700061)
- DCD (SP03)
SDroggitis.
PDR (YES/)-
OSP Staff Agreement State File Training File DOCUMENT NAME: G:\\SP97085.DMS to r
. cor or w. e.e ni, wem a m. not c. ew.4.'/.nenm.nv.nc=,. v. Sopr
.ucem,ne.ncio..i. v. m cu,y OFFICE OSP @ l OSFNDpf/
OSP;D//q y
NAME DMSollenberger:
PHLohdud " I RLBangart *ld DATE 12//l/97-12R/97 12/p/97 OSR FILE CODE: SP-A+
CRITERIA TO EVALUATE AGREEMENT STATE TRAINING AND TRAVEL FUNDING NEEDS
' By Staff Requirements Memorandum (SRM) dated March 19,1997, the Commission directed the staff to develop criteria to determine when Agreement States have demonstrated that State funds are not available or cannot be used for the purposes of training, travel, and technical assistance. The direction was that the criteria should be stringent enough to provide adequate assurance to the Commission that the State has thoroughly explored funding attematives available to the State and a determination by a high ranking State official (e.g., State agency head or chief financial officer) has been made that funds are not available. In such cases,
- States should also explore partial funding of costs. Such an approach must be designed to ensure that such certifications are not " pro forma" and that use of NRC-licensee funds for these purposes is in the public interest. The staffs proposals should provide for funding and should be provided to the Commission in a time frame that would allow implementation of the modified policy beninning in fiscal year 1998. Otherwise, training should be made available on a " space available" basis with Agreement States funding their own travel and per diem costs.
The staff has considered the area of technical assistance (defined for the purpose of NRC funding support as NRC inspection of Agreement State licensees or NRC completing Agreement State licensing actions) to Agreement States in the conduct of their licensing and inspection programs. Since the NRC has not been requested to provide any such direct technical assistance in the last 3 years, the staff has removed any fu-ther discussion of technical assistance from the criteria and will address any such requests on a case-by-case
- basis if they occur in the future. Assistance on other technical matters should be a cooperative effort among regulators and cost reimbursement is not a consideration.
The staff understanding is that, as a minimum, the NRC will make training available to the Agreement States on a space ovallable basis with NRC funding (at least in part) for States that have met the criteria developed by the staff. Students from an Agreement State agreeing to pay tuition for attendance at NRC training courses would be considered the same as an NRC student for purposes of selection, Slots remaining after selection of NRC and Agreement State students in the above category would then be filled by Agreement State staff for whom tuition le funded by NRC and lastly by Agreement State staff for whom NRC has funded tuition and travel, in whole or in part. State staff attending on a " space available" basis would pay all travel and per diem costs, except for students from States with approved training and associated funding support from NRC.
The staff will schedule the training courses to meet NRC training needs and the needs of Agreement States that will pay any tuition, travel, and per diem costs, or will pay travel and per diem costs, or will receive NRC approved funding support for training and associated travel costs contingent on availability of funds. The staff does not plan to schedule additional courses in the future unless the demand would fill the additional courses, 4
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The staffs approach to the development of criteria has focused on four key areas: (1) a State determination of need for training and availability of State funds to meet that need; (2) a State demonstration of need for NRC assistance in funding the State need; (3) the NRC evaluation of the State request against NRC criteria and logic diagram; and (4) the availability of NRC funds to meet tht sum of the State requests. Each area is discussed in further detail below. Each request imm a State would need to includa informatiun identified in items 1 and 2.
To facilitate preparction of a State request, the staff has developed a questionnaire that the
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Sittle will need to complete and submit, along with the statement on availability of funds, to the 3
NRC in order to be considered for financial ar,sistance in the training area. A table for tracking this information is also inc!uded at the end of this document. Submission of information identified in the questionnaire, at a minimum, is necessary for NRC to make a decision on funding support.
1' 1.
DETERWNATION OF NEED FOR TRAINING Each Stato siould have a tr ining program that would address items a and b below. A State should also oxamine a range of options or sources for fulfiiling its training needs (item c below).
This information shouid provide the basis for the State's development of a realistic estimate of their training needs and costs to accomplish their training program. The Agreament State Radiation Controi Program (RCP) snould use this estimate to develop their State'e budget request (item d below).
L Therefore, the RCP should cons! der and address the items listed below in determining their need for training; in estimating the funds required to meet their training needs; knd in determining whether their reeds, or a portion of their needs, are met by their current budget, a.
Documented training policy and qualification requirements to include:
Qualificatiors of new staff.
7 Routine training (e.g., refresher and specialty training) of existing staff.
p Training and qualification objectives that are consistent with the objectives of NRC Inspection Manual Chapter 1246, Formal Qualification Programs in the
~ luclear Material Safety and Safeguards Program Area.
b.
Training criticalto performance of program:
Integrated Materials Parformance Evaluation Program (IMPEP) finding regarding training of staff.
Needed to address a program weakness or deficiency.
c.
Sources of training:
NRC training courses, workshops and meetings.
2
Has the State evaluated other alternatives to meet their training need?
Did the State find no alternatives or the attematives ao not meet State needs?
d.
Documented financial information that incluis The number and category (e g., new hires versus more experienced) of individuals that need specific training courses not available in house.
The number of courses and spaces in coursea that the State can fund and those that cannot be funded given the current budget allocation for training and travel.
The total training and travel budget approved for the RCP and the portion of this budget allocated for the radioactive materials program. This should be presented in total dollars and in the percentage of the budgeted amount and the percentage of the anticipated need.
2.
DEMONSTRATlGN OF STATE NEED FOR NRC FUNDING a.
The Agreement State should submit a certification by a high ranking official (agency head, chief financial officer, or an equivalent official) that funds are not available. This would need to be done each State fiscal year following the legislative ' approval and signing of the budget appropriation for the RCP.
This certification should include certain demonstrations by the RCP such as:
l'he State has authority to spend funds on training and out of State travel, or has requested such authority.
The budget submitted to the legislature for the RCP included requests for the funds to meet the training and travel needs of the program.
The agency management supported the budget submittal.
The legislature has taken action on the budget submittal, but failed to approve the budget request in the training and travel area, or approved only a portion of this budget area, b,
The submission of the demonstration of need will ne6d to be done each State fiscal year, at a minimum, following the legist, 'ive approval and signing of the budget for thu RCP, This would allow the maximum ti,ne for NRC planning before actual training or travel requests must be submitted. The State must submit background information used to develop their budget, if the budget does not contain a line for training and travel, c.
The timing for the State's submission of the information needed by NRC to comple's evaluation of the reouest should be as soon as possible after the legislature or administration approval decis,ons or when another unfunded tralnlag need is identified.
Considerations include:
3
r Most State fiscal years do not coincide with the NRC fiscal year. Thus, the NRC will need to allocate funds for States based on the State fiscal year or it may leave gaps in the training for individual States.
When a State receives a decision on their budget and funding for training and travel and they identify it's not sufficient, they will likely not have much time prior to the beginning of their fiscal year.
Any other time they identify a training need which cannot be met or fulfilled, they will likely not have any significant lead time.
3.
EVALUATION OF STATE REQUESTS / DEMONSTRATION OF NEED AGAINST NRC CRITERIA The NRC staff would first evaluate the State's request / demonstration of need for NRC funding to confirm that the State hks provided documentation that it has legal authority to spend State funds for training and travel. Requests from States that have authority, or have requested authority, would then be evaluated against a set of additional criteria. The flow diagram (see page 6) presents the logic flow to be applied. The evaluation will be made against the following criteria.
Evaluation Criteria a.
The State has submitted a copy of its training and nualifications policy and program which documents the objectives of this oolicy and program are consistent with NRC Inspection Manual Chapter 1246, Formal Qualification Programs in the Nuclear Material Safety and Safeguards Program Area.
b.
The Agreement State has legal authority to spend State funds for training and travel out-of-Ste.te. In cases where an Agreement State does not have legal authority, the
/.greemmt State has requested authority to spend State funds for out-of-State training and travel.
Agreement utate programs that do not have authority to spend State funds on training and out of-State travel, and do not request such authority, will not be funded, and would not be evaluated further. NRC would further evaluate requests from Agreement States having legal authority and Agreeme< States thot have requested, but have been denied, authority to spend State funds for this purpose. Requests would be evaluated applying each of the additional criteria below. Amounts would be based on NRC review of the State's estimate based or, their documented program, c.
The Agreement State has requested funding to cover the required training and travel funds, but was denied funding for training and travel out-of-State, in whole or in part.
d.
The State agency head (cabinet level) or chief financial officer for the State has made and submitted a determination that State funds are not available for training and out of-State travel, or are insufficient as described in Criterion e. below. After review, NRC 4
concurs that funds available for out-of State training and travel are insufficient to satisfy Agreement State program training needs.
e.
The Agreement State RCP has limited funds. Of the requested budget amount of for Agreement State program training and out of State travel, the State funded and, therefore, the RCP can fund percent of its needed training and travel expenses.
f.
The limit on the amount of funding for any State will be appre>ximately 50% of the shortfall for the essential training needs identified for the Agreement State program.
The shortfall is equal to the requested budget amount minus the approved budget amount for essential training for the Agreement State program.
The NRC will evaluate each Agreement State's funding request that submits ths information needed to make the above findings. The approval for full or partial funding will be limited to the State's budget period (1 or 2 years). Without submittal of new budget information, the NRC funding for training and travel for that State will terminate. The NRC will consider unanticipated training needs when fully supported by documentation and cost estimates, if the need covers several years, the need should be incorporated into the next year's budget estimate for the RCP.
4.
DETERMINATION OF AVAILABILITY OF NRC FUNC1 Approvals for NRC funding support for Agreement State treming and associated travel costs will be in the form of identifying numbers of students attending designated NRC sponsored courses without the need to pay tuition. Travel costs will be paid by NRC through the approval of NRC travel authorizations and vouchers for invitational travel. If the total cost of valid requests for training and associated trave! funding support from NRC exceeds the NRC budgeted amount, the approvals will be prorated using the following considerations:
Evenness of dis:ribution, such as assuring that ell requesting States have the same or a comparable percentage of their total need satisfied.
Urgency of need. Ranking distribution based on (1) now staff meeting minimum training requirements, (2) specialty training to meet a program deficiency. (3) special training to broaden the program dep!h, and (4) refresher training for experienced staff.
The NRC staff considers that the number of approvals, based on the percentage of the training need being met togmner with urgency of need, as the most equitable method of distribution of funds if the total need exceeds the budgeted amount. The staff intends to provide approvals on a course by course basis and will use the information submitted by the State to determine, in conjunction with the State, the highest priority courses for each State.
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LOGO FLOW DIAGRAM FOR FUNDING OF AGREEMEf;T STATE TRAINING ANDTRAVEL Does the State have a documented training und quellfications N0 policy and program that contains objectives consistent with IMC 12467 YES 1r Does the State have NO Has the RCP N0 No NRC ir authority to fund training requested funding n
and travel?
authority to assistance, fund training YES and travel?
YES Has the State requested NO
(]
funding for training and travel?
YES
,r Has a high ranking State N0 otilcialcertified need for assistance from NRC?
YES y
NRC will consider funding 50% of the shortfall between appropriated amount IMC -Inspection Manual Chapter and budget request amount. Funding will be limited to a prorated amount if the RCP - Radiation Control Program total from all States is greater than OSP's OSP Office of State Programs budgeted amount.
i 6
DBAFT QUESTIONNAIRE FOR AGREEMENT STATE TRAINING AND TRAVEL FUNDING This questionnaire was developed to collect the information needed to make a decision on whether NRC will fund all or a portion of an individual Agreement State's training and/or travel needs. Please complete the following information and submit it to the contact specified below.
Without this inforrnation, NRC will not be able make a decision on whether to fund your travel sad training requests. Thank you for your assistance.
1.
The State of has/does not have a program for training and qualification of its staff that has objectives similar to those of the NRC as described in NRC Inspection Manual Chapter 1246, Formal Qualification Programs in the Nuclear Material Safety and Safeguards Area. The State should submit a copy of its training policy statement, if any, and a copy of its procedure that documents its training and qualification program. (if no training and oualification program documentation exists, the State is not eligible for NRC funding support.)
2.
The State of is on an annual _ or biennial _ budget cycle with the current fiscal year beginning on and endin0 on 3.
Have you been authorized to spend State funds:
for travel to workshops out-of State?
Yes _ No _
for training including travel to training out-of State?
Yes _ No _
4.
Given sufficient State funding, do State laws or regulations limit travel and training? (This question is requested to clarify the State's policy, not the funding issue.)
Yes _ No _
5.
Did you request full funding for your estimated training and out-of State travel needs in your budget?
Yes _ No _
Did your management support your request by submitting it to your legislature?
Yes _ No _
Did your legislature act on your training / travel request?
Yes _ No _
Did your legislature support your request?
In full _
In part _
No support _
6.
What is your total Agreement State materials budget?
7.
What was your estimate for the Agreement State training and travel needs?
8.
What was the RCP training and travel funding request for the Agreement State program?
9.
What was the level of funding for training and travel approved by your legislature?
10.
Are there any special considerations that you wouH like NRC to consider in determining potential assistance in the training and travel areas?
Please explain below.
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INFORMATION NEEDS FOR NRC DETERMINATION OF FINANCIAL ASSISTANCE IN THE TRAINING AND TRAVEL AREAS STATE' Cycle ASP LMgt' TRNG Ett' TRNG Bogt' Comment /
8 i
ALABAMA 1.1.
ARIZONA 1 M.
ARKANSAS 2.2, CAllF ORNIA 1,1, COLORADO 1,1, FLORIDA 1,1, GEORGIA i,1, IOWA 1.1, ILLINOIS 1.1, KANSAS 1,17/1 KENTUCKY 2.2.
LOUIS 1ANA 1,1, MAINE 1.2.
MARYLAND 1,1, MASSACHUSETTS 1,1,
, MISSISSIPPI 1,1, NEDRASKA 1.2.
NEBRASKA -(LLW) 1,2, NEVADA 2.2, NEW HAMPSHIRE 1,2, NEW MEXICO 1.1, NYDH 1,1, NYDOL 1,1, NYDEC 1.1, NYC 1.1, NORTH CAROLINA 2.2.
NORTH DAKOTA 2.2.
OREGON 2.2, RHODE I3 LAND 1,1, SOUTH CAROLINA 1,1, SOUTH CAROLINA. (LLW) 1,1, i TEMNESSEE 1.1.,
8
e' e
STATE' Cycle' asp Bdgt' TRNG Ett' TRNG Bogt'
%8 Comments' TEXAS.DRC 2.2.7/1 TEXAS.TNRCC 2.2.7/1 UTAH 1.1, WASHINGTON 1.27/1 OHIO 1.2, OKLAHOMA 1,1, PENNsYLVANLA 1.1, The SW s listed are current Agreement States and the last three are those States whic' ave submitted a letter of intent to become an Agreement State.
8 This wiumn includet the legislative cycle, the budget cycle, and the beginning date for the budget, respectively (L,B,M/D). An M in the B space indicates that the State has a mixed budget cycle and NRC needs additional information from the State to determine whether the RCP budget is on an annual or biennial cycle.
ASP Bdgt - This column is for the Agreement State Program (ASP) Budget within the Radiation Control program.
TRNG EST - This column is for the estimat0 of the training costs for the Agreement State program, submitted in the budget requist to the State legislature. We recognize that this will only be a portion of the overall tf aining costs for the RCP; however, NRC will only address this aspect of the RCP training program under this assessment.
TRNG Bdgt - This column contains the amount the RCP budgeted for the Agreement State program training.
% This column will contain the percentage of the estimated training budget that was funded by the State. This will give the NRC a quick estimate of those Stetes that might need assistance !n funding their training, travel and technical assistance.
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Comments - This column is reserved for comments such as special conditions or special hardships that have been identified by the State.
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< TRANSACTION REPORT >
,,_1,_,,,,,,
E E3R OADC AS T 3
NO.
DATE T it1E DESTItMTitt4 STATIOrJ PO.
OURAT IOtJ MUDE RESULT 351B8 12-15 18:15 610 337 5324 11 0*05'40*
t@ti. E OK 35189 18121 404 562 4955 11 0'05'44' NORM.E OK
)
35190 18:27 7085151096 11 0'11'07*
NORM.E OK 35191 18130 017 860 8122 11 0*05'38*
tJORM. E OK
.TS192 18:44 5109750381 11 C' 05 ' 53' NORM.E OK 35193 18:50 334 20G 5387 11 0'10'29' NORM.E OK 35194 19102 5010612458 11 0'06'33*
tJORM. E OK 35195 19i11 303 343 3697 11 0'06*04*
NORM.E f 35196 19117 904 487 0435 11 0*06'06*
NORM.E OK 35197 19 23
,04 362 2653 11 0*05'40*
tJORM. E OK I
Q 35199 19t29 217 524 4724 11 0'05'42*
NORti. E OK 35199 19335 IOUA 11 0*05'40' NORti.E OK 35200 19141 913 296 0904 11 0'06'06*
PGM. E QK 35201 19t40 502 564 6533 11 O* 05*39*
iJORM. E OK 35202 19254 LOUI$1ANA 11 0'06'13' NORM.E OK 35203 20t00 t % ifJE 11 0'07'20' NORMAL OK 35204 23:00 410 631 3199 14 O'06'01*
NORMAL OK 35205 20114 601+354+616~1 11 0'07'50*
tJORt1AL OK 35200 20:24 7026075751 11 0'07'52' NORt%Li OK 3S207 20132 503 225 2325 11 0*05'46*
tw)Rti. E OK 35208 20338 5058271544 11 O'07'10*
NORMAL OK 35209 20 46 518 458 6134 11 0'05'44*
NORti.E OK l
35210 20:52 919 571 4140 11 0'05'38' P40Rt1. E OK 35211 20:58 701 328 5200 11 0'05'35' NORM.E OK j
3S212 21104 503 731 4081 11 0*05'34*
, NORM.E OK 275 2*42*52' f I
i s
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k
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< TRANSACTION REPORT 12-15-1997 (MOfD 23:2S
'l 0
13ROADCAST 3
t y],
DATE T lt1E DEST ifJAT!OrJ STATICtJ PO.
IX. RAT ? Cr4 MODE RESULT 35213 J b -15 21:to 401 277 2J56 11 0'10'20*
t JORM, E OK 35214 21: 21 6037377412 11 0'05'52' tJORM. E OK 35215 21:27 615 532 7939 11 0*05'40*
iJORti. E OK i
3521G 21:33 5120340708 11 0'06'07" tJORt1. E OK 35217 21:39 801 533 4097 11 O'06'31" tJORM. I OK 35210 21:46 360 753 1496 11 0'05'35' IJORM. E OK 35219 21:52 516 457 2225 11 0'05'40" tORM.E OK 35220 21:59 510 457 5545 11 0'06'14*
NORM.E OK 35221 22:05 tJEW YORK CITY 11 0'11'26*
tJORti. E l OK 35222 22: 17 502 227 7862 11 0'06'10*
tJORt1AL OK 35223 22:23 AECS (613) 995-5086 11 0'05'58' t ort 1AL OK 35224 22:30 WACH!tJOTOrJ DC 11 0'05'35*
f 40Rt1. E OK 35225 22:35 7996726 11 0'05'37*
f J0Rti. E OK 3S226 22: 41 217 702 1326 11 0'06'27' tJORM. E OK 3522?
22:48 512 239 6362 11 O'05'45*
fJORM.E
, OK 3S220 22:54 4024714040 11 0*07'1S*
tJORt1AL OK 35229 23:02 912 262 3143 11 0'06'05*
NORt1AL OK 35230 23:09 602 437 0705 11 0* 0v 46
- tJORti. E OK f
35231 23:14 916 323 6491 11 0*05'41*
NORM.E OK 35232 23:20 402 471 9449 11 0'05'34*
f JORM. E OK 220 2'09*20*
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< TIMER COMMUNICATION CARD >
12-15-1997(MON) 13113 PO.
RESERVED ITEM RESRV.DATE CALL DESTitATION STATION 131354 DROADCAST 12-15 13: 13 18 15 RO RON!I RONI11 RONIV RIV/WC ALAB4 %
AR IZOfM ARK 44SAS CALIFORNIA COLORADO FLORIDA OEOROIA ILLitolS RCP 1 lOWA KNJSAS KENTUChV LOUI Sl#M t%1FE t%RYLAfD MlSSISSIPPI.
tEDRASKA PEVADA tEW HAMPSHIRE PEW t1EX1 PEW YORK DEPT HEALTH NORTH CAROLitM FORTH DAKOTA OREOON RHODE ISLND SC RCP TEr#ESSEE TEXAS RCP UTAH WASHlfCTON PEW YORK DEPT ENVIR NEW YORK LABOR tEW YORK ClTV CRCPD AECB CN ADA WASHitOTON DC SC WASTE SECTION IL RCP 2 (KERR)
TX PATURAL RESOUCE t2 DEC GA SE REGION e
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