Appendix A to Subpart M of Part 61 - Interpretive Rule Governing Roof Removal Operations
40:10.0.1.1.1.13.1.19.1 : Appendix A
Appendix A to Subpart M of Part 61 - Interpretive Rule Governing
Roof Removal Operations I. Applicability of the Asbestos NESHAP
1.1. Asbestos-containing material (ACM) is material containing
more than one percent asbestos as determined using the methods
specified in appendix E, subpart E, 40 CFR part 763, section 1,
Polarized Light Microscopy. The NESHAP classifies ACM as either
“friable” or “nonfriable”. Friable ACM is ACM that, when dry, can
be crumbled, pulverized or reduced to powder by hand pressure.
Nonfriable ACM is ACM that, when dry, cannot be crumbled,
pulverized or reduced to powder by hand pressure.
1.2. Nonfriable ACM is further classified as either Category I
ACM or Category II ACM. Category I ACM and Category II ACM are
distinguished from each other by their potential to release fibers
when damaged. Category I ACM includes asbestos-containing gaskets,
packings, resilient floor coverings, resilient floor covering
mastic, and asphalt roofing products containing more than one
percent asbestos. Asphalt roofing products which may contain
asbestos include built-up roofing; asphalt-containing single ply
membrane systems; asphalt shingles; asphalt-containing underlayment
felts; asphalt-containing roof coatings and mastics; and
asphalt-containing base flashings. ACM roofing products that use
other bituminous or resinous binders (such as coal tars or pitches)
are also considered to be Category I ACM. Category II ACM includes
all other nonfriable ACM, for example, asbestos-cement (A/C)
shingles, A/C tiles, and transite boards or panels containing more
than one percent asbestos. Generally speaking, Category II ACM is
more likely to become friable when damaged than is Category I ACM.
The applicability of the NESHAP to Category I and II ACM depends
on: (1) the condition of the material at the time of demolition or
renovation, (2) the nature of the operation to which the material
will be subjected, (3) the amount of ACM involved.
1.3. Asbestos-containing material regulated under the NESHAP is
referred to as “regulated asbestos-containing material” (RACM).
RACM is defined in § 61.141 of the NESHAP and includes: (1) friable
asbestos-containing material; (2) Category I nonfriable ACM that
has become friable; (3) Category I nonfriable ACM that has been or
will be sanded, ground, cut, or abraded; or (4) Category II
nonfriable ACM that has already been or is likely to become
crumbled, pulverized, or reduced to powder. If the coverage
threshold for RACM is met or exceeded in a renovation or demolition
operation, then all friable ACM in the operation, and in certain
situations, nonfriable ACM in the operation, are subject to the
NESHAP.
A. Threshold Amounts of Asbestos-Containing Roofing Material
1.A.1. The NESHAP does not cover roofing projects on single
family homes or on residential buildings containing four or fewer
dwelling units. 40 CFR 61.141. For other roofing renovation
projects, if the total asbestos-containing roof area undergoing
renovation is less than 160 ft 2, the NESHAP does not apply,
regardless of the removal method to be used, the type of material
(Category I or II), or its condition (friable versus nonfriable).
40 CFR 61.145(a)(4). However, EPA would recommend the use of
methods that damage asbestos-containing roofing material as little
as possible. EPA has determined that where a rotating blade (RB)
roof cutter or equipment that similarly damages the roofing
material is used to remove Category I nonfriable
asbestos-containing roofing material, the removal of 5580 ft 2 of
that material will create 160 ft 2 of RACM. For the purposes of
this interpretive rule, “RB roof cutter” means an engine-powered
roof cutting machine with one or more rotating cutting blades the
edges of which are blunt. (Equipment with blades having sharp or
tapered edges, and/or which does not use a rotating blade, is used
for “slicing” rather than “cutting” the roofing material; such
equipment is not included in the term “RB roof cutter”.) Therefore,
it is EPA's interpretation that when an RB roof cutter or equipment
that similarly damages the roofing material is used to remove
Category I nonfriable asbestos-containing roofing material, any
project that is 5580 ft 2 or greater is subject to the NESHAP;
conversely, it is EPA's interpretation that when an RB roof cutter
or equipment that similarly damages the roofing material is used to
remove Category I nonfriable asbestos-containing roofing material
in a roof removal project that is less than 5580 ft 2, the project
is not subject to the NESHAP, except that notification is always
required for demolitions. EPA further construes the NESHAP to mean
that if slicing or other methods that do not sand, grind, cut or
abrade will be used on Category I nonfriable ACM, the NESHAP does
not apply, regardless of the area of roof to be removed.
1.A.2. For asbestos cement (A/C) shingles (or other Category II
roofing material), if the area of the roofing material to be
removed is at least 160 ft 2 and the removal methods will crumble,
pulverize, reduce to powder, or contaminate with RACM (from other
ACM that has been crumbled, pulverized or reduced to powder) 160 ft
2 or more of such roofing material, the removal is subject to the
NESHAP. Conversely, if the area of the A/C shingles (or other
Category II roofing materials) to be removed is less than 160 ft 2,
the removal is not subject to the NESHAP regardless of the removal
method used, except that notification is always required for
demolitions. 40 CFR 61.145(a). However, EPA would recommend the use
of methods that damage asbestos-containing roofing material as
little as possible. If A/C shingles (or other Category II roofing
materials) are removed without 160 ft 2 or more of such roofing
material being crumbled, pulverized, reduced to powder, or
contaminated with RACM (from other ACM that has been crumbled,
pulverized or reduced to powder), the operation is not subject to
the NESHAP, even where the total area of the roofing material to be
removed exceeds 160 ft 2; provided, however, that if the renovation
includes other operations involving RACM, the roof removal
operation is covered if the total area of RACM from all renovation
activities exceeds 160 ft 2. See the definition of regulated
asbestos-containing material (RACM), 40 CFR 61.141.
1.A.3. Only roofing material that meets the definition of ACM
can qualify as RACM subject to the NESHAP. Therefore, to determine
if a removal operation that meets or exceeds the coverage threshold
is subject to the NESHAP, any suspect roofing material (i.e.
roofing material that may be ACM) should be tested for asbestos. If
any such roofing material contains more than one percent asbestos
and if the removal operation is covered by the NESHAP, then EPA
must be notified and the work practices in § 61.145(c) must be
followed. In EPA's view, if a removal operation involves at least
the threshold level of suspect material, a roofing contractor may
choose not to test for asbestos if the contractor follows the
notification and work practice requirements of the NESHAP.
B. A/C Shingle Removal (Category II ACM Removal)
1.B.1. A/C shingles, which are Category II nonfriable ACM,
become regulated ACM if the material has a high probability of
becoming or has become crumbled, pulverized or reduced to powder by
the forces expected to act on the material in the course of
demolition or renovation operations. 40 CFR 61.141. However, merely
breaking an A/C shingle (or any other category II ACM) that is not
friable may not necessarily cause the material to become RACM. A/C
shingles are typically nailed to buildings on which they are
attached. EPA believes that the extent of breakage that will
normally result from carefully removing A/C shingles and lowering
the shingles to the ground will not result in crumbling,
pulverizing or reducing the shingles to powder. Conversely, the
extent of breakage that will normally occur if the A/C shingles are
dropped from a building or scraped off of a building with heavy
machinery would cause the shingles to become RACM. EPA therefore
construes the NESHAP to mean that the removal of A/C shingles that
are not friable, using methods that do not crumble, pulverize, or
reduce the A/C shingles to powder (such as pry bars, spud bars and
shovels to carefully pry the material), is not subject to the
NESHAP provided that the A/C shingles are properly handled during
and after removal, as discussed in this paragraph and the asbestos
NESHAP. This interpretation also applies to other Category II
nonfriable asbestos-containing roofing materials.
C. Cutting vs. Slicing and Manual Methods for Removal of Category I
ACM
1.C.1. Because of damage to the roofing material, and the
potential for fiber release, roof removal operations using rotating
blade (RB) roof cutters or other equipment that sand, grind, cut or
abrade the roof material are subject to the NESHAP. As EPA
interprets the NESHAP, the use of certain manual methods (using
equipment such as axes, hatchets, or knives, spud bars, pry bars,
and shovels, but not saws) or methods that slice, shear, or punch
(using equipment such as a power slicer or power plow) does not
constitute “cutting, sanding, grinding or abrading.” This is
because these methods do not destroy the structural matrix or
integrity of the material such that the material is crumbled,
pulverized or reduced to powder. Hence, it is EPA's interpretation
that when such methods are used, assuming the roof material is not
friable, the removal operation is not subject to the
regulation.
1.C.2. Power removers or power tear-off machines are typically
used to pry the roofing material up from the deck after the roof
membrane has been cut. It is EPA's interpretation that when these
machines are used to pry roofing material up, their use is not
regulated by the NESHAP.
1.C.3. As noted previously, the NESHAP only applies to the
removal of asbestos-containing roofing materials. Thus, the NESHAP
does not apply to the use of RB cutters to remove non-asbestos
built up roofing (BUR). On roofs containing some
asbestos-containing and some non-asbestos-containing materials,
coverage under the NESHAP depends on the methods used to remove
each type of material in addition to other coverage thresholds
specified above. For example, it is not uncommon for existing roofs
to be made of non-asbestos BUR and base flashings that do contain
asbestos. In that situation, EPA construes the NESHAP to be
inapplicable to the removal of the non-asbestos BUR using an RB
cutter so long as the RB cutter is not used to cut 5580 ft 2 or
more of the asbestos-containing base flashing or other
asbestos-containing material into sections. In addition, the use of
methods that slice, shear, punch or pry could then be used to
remove the asbestos flashings and not trigger coverage under the
NESHAP.
II. Notification
2.1. Notification for a demolition is always required under the
NESHAP. However, EPA believes that few roof removal jobs constitute
“demolitions” as defined in the NESHAP (§ 61.141). In particular,
it is EPA's view that the removal of roofing systems (i.e., the
roof membrane, insulation, surfacing, coatings, flashings, mastic,
shingles, and felt underlayment), when such removal is not a part
of a demolition project, constitutes a “renovation” under the
NESHAP. If the operation is a renovation, and Category I roofing
material is being removed using either manual methods or slicing,
notification is not required by the NESHAP. If Category II material
is not friable and will be removed without crumbling, pulverizing,
or reducing it to powder, no notification is required. Also, if the
renovation involves less than the threshold area for applicability
as discussed above, then no notification is required. However, if a
roof removal meets the applicability and threshold requirements
under the NESHAP, then EPA (or the delegated agency) must be
notified in advance of the removal in accordance with the
requirements of § 61.145(b), as follows:
• Notification must be given in writing at least 10 working days
in advance and must include the information in § 61.145(b)(4),
except for emergency renovations as discussed below.
• The notice must be updated as necessary, including, for
example, when the amount of asbestos-containing roofing material
reported changes by 20 percent or more.
• EPA must be notified if the start date of the roof removal
changes. If the start date of a roof removal project is changed to
an earlier date, EPA must be provided with a written notice of the
new start date at least 10 working days in advance. If the start
date changes to a later date, EPA must be notified by telephone as
soon as possible before the original start date and a written
notice must be sent as soon as possible.
• For emergency renovations (as defined in § 61.141), where work
must begin immediately to avoid safety or public health hazards,
equipment damage, or unreasonable financial burden, the
notification must be postmarked or delivered to EPA as soon as
possible, but no later than the following work day.
III. Emission Control Practices A. Requirements To Adequately Wet
and Discharge No Visible Emission
3.A.1. The principal controls contained in the NESHAP for
removal operations include requirements that the affected material
be adequately wetted, and that asbestos waste be handled,
collected, and disposed of properly. The requirements for disposal
of waste materials are discussed separately in section IV below.
The emission control requirements discussed in this section III
apply only to roof removal operations that are covered by the
NESHAP as set forth in Section I above.
3.A.2. For any operation subject to the NESHAP, the regulation
(§§ 61.145(c)(2)(i), (3), (6)(i)) requires that RACM be adequately
wet (as defined in § 61.141) during the operation that damages or
disturbs the asbestos material until collected for disposal.
3.A.3. When using an RB roof cutter (or any other method that
sands, grinds, cuts or abrades the roofing material) to remove
Category I asbestos-containing roofing material, the emission
control requirements of § 61.145(c) apply as discussed in Section I
above. EPA will consider a roof removal project to be in compliance
with the “adequately wet” and “discharge no visible emission”
requirements of the NESHAP if the RB roof cutter is equipped and
operated with the following: (1) a blade guard that completely
encloses the blade and extends down close to the roof surface; and
(2) a device for spraying a fine mist of water inside the blade
guard, and which device is in operation during the cutting of the
roof.
B. Exemptions From Wetting Requirements
3.B.1. The NESHAP provides that, in certain instances, wetting
may not be required during the cutting of Category I asbestos
roofing material with an RB roof cutter. If EPA determines in
accordance with § 61.145(c)(3)(i), that wetting will unavoidably
damage the building, equipment inside the building, or will present
a safety hazard while stripping the ACM from a facility component
that remains in place, the roof removal operation will be exempted
from the requirement to wet during cutting. EPA must have
sufficient written information on which to base such a decision.
Before proceeding with a dry removal, the contractor must have
received EPA's written approval. Such exemptions will be made on a
case-by-case basis.
3.B.2. It is EPA's view that, in most instances, exemptions from
the wetting requirements are not necessary. Where EPA grants an
exemption from wetting because of the potential for damage to the
building, damage to equipment within the building or a safety
hazard, the NESHAP specifies alternative control methods (§
61.145(c)(3)(i)(B)). Alternative control methods include (a) the
use of local exhaust ventilation systems that capture the dust, and
do not produce visible emissions, or (b) methods that are designed
and operated in accordance with the requirements of § 61.152, or
(c) other methods that have received the written approval of EPA.
EPA will consider an alternative emission control method in
compliance with the NESHAP if the method has received written
approval from EPA and the method is being implemented consistent
with the approved procedures (§ 61.145(c)(3)(ii) or §
61.152(b)(3)).
3.B.3. An exemption from wetting is also allowed when the air or
roof surface temperature at the point of wetting is below freezing,
as specified in § 61.145(c)(7). If freezing temperatures are
indicated as the reason for not wetting, records must be kept of
the temperature at the beginning, middle and end of the day on
which wetting is not performed and the records of temperature must
be retained for at least 2 years. 42 CFR § 61.145(c)(7)(iii). It is
EPA's interpretation that in such cases, no written application to,
or written approval by the Administrator is needed for using
emission control methods listed in § 61.145(c)(3)(i)(B), or
alternative emission control methods that have been previously
approved by the Administrator. However, such written application or
approval is required for alternative emission control methods that
have not been previously approved. Any dust and debris collected
from cutting must still be kept wet and placed in containers. All
of the other requirements for notification and waste disposal would
continue to apply as described elsewhere in this notice and the
Asbestos NESHAP.
C. Waste Collection and Handling
3.C.1. It is EPA's interpretation that waste resulting from
slicing and other methods that do not cut, grind, sand or abrade
Category I nonfriable asbestos-containing roofing material is not
subject to the NESHAP and can be disposed of as nonasbestos waste.
EPA further construes the NESHAP to provide that if Category II
roofing material (such as A/C shingles) is removed and disposed of
without crumbling, pulverizing, or reducing it to powder, the waste
from the removal is not subject to the NESHAP waste disposal
requirements. EPA also interprets the NESHAP to be inapplicable to
waste resulting from roof removal operations that do not meet or
exceed the coverage thresholds described in section I above. Of
course, other State, local, or Federal regulations may apply.
3.C.2. It is EPA's interpretation that when an RB roof cutter,
or other method that similarly damages the roofing material, is
used to cut Category I asbestos containing roofing material, the
damaged material from the cut (the sawdust or debris) is considered
asbestos containing waste subject to § 61.150 of the NESHAP,
provided the coverage thresholds discussed above in section 1 are
met or exceeded. This sawdust or debris must be disposed of at a
disposal site operated in accordance with the NESHAP. It is also
EPA's interpretation of the NESHAP that if the remainder of the
roof is free of the sawdust and debris generated by the cutting, or
if such sawdust or debris is collected as discussed below in
paragraphs 3.C.3, 3.C.4, 3.C.5 and 3.C.6, the remainder of the roof
can be disposed of as nonasbestos waste because it is considered to
be Category I nonfriable material (as long as the remainder of the
roof is in fact nonasbestos material or if it is Category I
asbestos material and the removal methods do not further sand,
grind, cut or abrade the roof material). EPA further believes that
if the roof is not cleaned of such sawdust or debris, i.e.,
it is contaminated, then it must be treated as asbestos-containing
waste material and be handled in accordance with § 61.150.
3.C.3. In order to be in compliance with the NESHAP while using
an RB roof cutter (or device that similarly damages the roofing
material) to cut Category I asbestos containing roofing material,
the dust and debris resulting from the cutting of the roof should
be collected as soon as possible after the cutting operation, and
kept wet until collected and placed in leak-tight containers. EPA
believes that where the blade guard completely encloses the blade
and extends down close to the roof surface and is equipped with a
device for spraying a fine mist of water inside the blade guard,
and the spraying device is in operation during the cutting, most of
the dust and debris from cutting will be confined along the cut.
The most efficient methods to collect the dust and debris from
cutting are to immediately collect or vacuum up the damaged
material where it lies along the cut using a filtered vacuum
cleaner or debris collector that meets the requirements of 40 CFR
61.152 to clean up as much of the debris as possible, or to gently
sweep up the bulk of the debris, and then use a filtered vacuum
cleaner that meets the requirements of 40 CFR 61.152 to clean up as
much of the remainder of the debris as possible. On smooth surfaced
roofs (nonaggregate roofs), sweeping up the debris and then wet
wiping the surface may be done in place of using a filtered vacuum
cleaner. It is EPA's view that if these decontamination procedures
are followed, the remaining roofing material does not have to be
collected and disposed of as asbestos waste. Additionally, it is
EPA's view that where such decontamination procedures are followed,
if the remaining portions of the roof are non-asbestos or Category
I nonfriable asbestos material, and if the remaining portions are
removed using removal methods that slice, shear, punch or pry, as
discussed in section 1.C above, then the remaining portions do not
have to be collected and disposed of as asbestos waste and the
NESHAP's no visible emissions and adequately wet requirements are
not applicable to the removal of the remaining portions. In EPA's
interpretation, the failure of a filtered vacuum cleaner or debris
collector to collect larger chunks or pieces of damaged roofing
material created by the RB roof cutter does not require the
remaining roofing material to be handled and disposed of as
asbestos waste, provided that such visible chunks or pieces of
roofing material are collected (e.g. by gentle sweeping) and
disposed of as asbestos waste. Other methods of decontamination may
not be adequate, and should be approved by the local delegated
agency.
3.C.4. In EPA's interpretation, if the debris from the cutting
is not collected immediately, it will be necessary to lightly mist
the dust or debris, until it is collected, as discussed above, and
placed in containers. The dust or debris should be lightly misted
frequently enough to prevent the material from drying, and to
prevent airborne emissions, prior to collection as described above.
It is EPA's interpretation of the NESHAP that if these procedures
are followed, the remaining roofing material does not have to be
collected and disposed of as asbestos waste, as long as the
remaining roof material is in fact nonasbestos material or if it is
Category I asbestos material and the removal methods do not further
sand, grind, cut or abrade the roof material.
3.C.5. It is EPA's interpretation that, provided the roofing
material is not friable prior to the cutting operation, and
provided the roofing material has not been made friable by the
cutting operation, the appearance of rough, jagged or damaged edges
on the remaining roofing material, due to the use of an RB roof
cutter, does not require that such remaining roofing material be
handled and disposed of as asbestos waste. In addition, it is also
EPA's interpretation that if the sawdust or debris generated by the
use of an RB roof cutter has been collected as discussed in
paragraphs 3.C.3, 3.C.4 and 3.C.6, the presence of dust along the
edge of the remaining roof material does not render such material
“friable” for purposes of this interpretive rule or the NESHAP,
provided the roofing material is not friable prior to the cutting
operation, and provided that the remaining roofing material near
the cutline has not been made friable by the cutting operation.
Where roofing material near the cutline has been made friable by
the use of the RB cutter (i.e. where such remaining roofing
material near the cutline can be crumbled, pulverized or reduced to
powder using hand pressure), it is EPA's interpretation that the
use of an encapsulant will ensure that such friable material need
not be treated or disposed of as asbestos containing waste
material. The encapsulant may be applied to the friable material
after the roofing material has been collected into stacks for
subsequent disposal as nonasbestos waste. It is EPA's view that if
the encapsulation procedure set forth in this paragraph is followed
in operations where roofing material near the cutline has been
rendered friable by the use of an RB roof cutter, and if the
decontamination procedures set forth in paragraph 3.C.3 have been
followed, the NESHAP's no visible emissions and adequately wet
requirements would be met for the removal, handling and disposal of
the remaining roofing material.
3.C.6. As one way to comply with the NESHAP, the dust and debris
from cutting can be placed in leak-tight containers, such as
plastic bags, and the containers labeled using warning labels
required by OSHA (29 CFR 1926.58). In addition, the containers must
have labels that identify the waste generator (such as the name of
the roofing contractor, abatement contractor, and/or building owner
or operator) and the location of the site at which the waste was
generated.
IV. Waste Disposal A. Disposal Requirements
4.A.1. Section 61.150(b) requires that, as soon as is practical,
all collected dust and debris from cutting as well as any
contaminated roofing squares, must be taken to a landfill that is
operated in accordance with § 61.154 or to an EPA-approved site
that converts asbestos waste to nonasbestos material in accordance
with § 61.155. During the loading and unloading of affected waste,
asbestos warning signs must be affixed to the vehicles.
B. Waste Shipment Record
4.B.1. For each load of asbestos waste that is regulated under
the NESHAP, a waste shipment record (WSR) must be maintained in
accordance with § 61.150(d). Information that must be maintained
for each waste load includes the following:
• Name, address, and telephone number of the waste generator
• Name and address of the local, State, or EPA regional office
responsible for administering the asbestos NESHAP program
• Quantity of waste in cubic meters (or cubic yards)
• Name and telephone number of the disposal site operator
• Name and physical site location of the disposal site
• Date transported
• Name, address, and telephone number of the transporter(s)
• Certification that the contents meet all government
regulations for transport by highways.
4.B.2. The waste generator is responsible for ensuring that a
copy of the WSR is delivered to the disposal site along with the
waste shipment. If a copy of the WSR signed by the disposal site
operator is not returned to the waste generator within 35 days, the
waste generator must contact the transporter and/or the disposal
site to determine the status of the waste shipment. 40 CFR
61.150(d)(3). If the signed WSR is not received within 45 days, the
waste generator must report, in writing, to the responsible NESHAP
program agency and send along a copy of the WSR. 40 CFR
61.150(d)(4). Copies of WSRs, including those signed by the
disposal site operator, must be retained for at least 2 years. 40
CFR 61.150(d)(5).
V. Training
5.1. For those roof removals that are subject to the NESHAP, at
least one on-site supervisor trained in the provisions of the
NESHAP must be present during the removal of the asbestos roofing
material. 40 CFR 61.145(c)(8). In EPA's view, this person can be a
job foreman, a hired consultant, or someone who can represent the
building owner or contractor responsible for the removal. In
addition to the initial training requirement, a refresher training
course is required every 2 years. The NESHAP training requirements
became effective on November 20, 1991.
5.2. Asbestos training courses developed specifically to address
compliance with the NESHAP in roofing work, as well as courses
developed for other purposes can satisfy this requirement of the
NESHAP, as long as the course covers the areas specified in the
regulation. EPA believes that Asbestos Hazard Emergency Response
Act (AHERA) training courses will, for example, satisfy the NESHAP
training requirements. However, nothing in this interpretive rule
or in the NESHAP shall be deemed to require that roofing
contractors or roofing workers performing operations covered by the
NESHAP must be trained or accredited under AHERA, as amended by the
Asbestos School Hazard Abatement Reauthorization Act (ASHARA).
Likewise, state or local authorities may independently impose
additional training, licensing, or accreditation requirements on
roofing contractors performing operations covered by the NESHAP,
but such additional training, licensing or accreditation is not
called for by this interpretive rule or the federal NESHAP.
5.3. For removal of Category I asbestos containing roofing
material where RB roof cutters or equipment that similarly damages
the asbestos-containing roofing material are used, the NESHAP
training requirements (§ 61.145(c)(8)) apply as discussed in
Section I above. It is EPA's intention that removal of Category I
asbestos-containing roofing material using hatchets, axes, knives,
and/or the use of spud bars, pry bars and shovels to lift the
roofing material, or similar removal methods that slice, punch, or
shear the roof membrane are not subject to the training
requirements, since these methods do not cause the roof removal to
be subject to the NESHAP. Likewise, it is EPA's intention that roof
removal operations involving Category II nonfriable ACM are not
subject to the training requirements where such operations are not
subject to the NESHAP as discussed in section I above.
[59 FR 31158, June 17, 1994, as amended at 60 FR 31920, June 19,
1995]
II. Waiver
Requests
