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Interoffice Communication TO: FROM: DATE: SUBJ: R. D. Garablin JgSI$):,gp- T. G. Grumbles August 2, 1991 XF:_______PQ-Syt \/l PROPOSED CONTENT FOR RWE QUARTERLY ENVIRONMENTAL SAFETY & HEALTH REPORTS Attached is the proposed content of RWE quarterly reports for environmental, safety and heAlth matters. I am providing copies for comment to the copy list below. The report will contain five basic sections; 1) Compliance Issues a. Environmental b. Safety and Health 2) Lawsuits 3) Capital Projects 4) Significant Regulatory Activity Impact 5) Product Safety and Acceptance Issues 1. Regulatory Compliance This section would include significant items related to non- compliance events. Non-compliance with State and Federal Regulations would be considered. Items considered for inclusion would be notices of violation, compliance orders, and penalty assessments that have a total financial impact (penalties, compliance capital, etc.) of greater than $500,000. 2. Lawsuits This section would include Department of Justice, Civil, State, Citizen Suit Action and Toxic Torts, A summary of the number of suits received with an analysis or brief discussion of any expected to exceed $250,000 in impact. 3. Capital Projects This section would include the development and progress of capital projects exceeding $2 million. The projects would be those directly related to regulatory or voluntary actions. Applicable cost-sharing or APA liability issues would be included in these discussions. y 00000^ Gamblin Memo Page 2 August 5, 1991 4. Major Regulatory Activity Impact This section would include regulatory activity that we believe will have a potential capital impact exceeding $2 million to achieve compliance. The activity may include new regulations and actions under existing regulations such as Superfund. 5. Product Safetv/Acceotance This section will include regulatory or commercial Issues affecting product viability. These items may include manufacturing restrictions, product end-use or product constituent issues. T. G. Grumbles dlj .218 cc: John Burns, Betsy Meyer, Mark Schneider yyV 000007^03