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(1) Systematic Design of Testing Protocols. The testing protocols were designed in <br /> advance of the testing period, and they reflect a conscientious effort to evaluate <br /> the facility's Y2K-related environmental compliance status and not to circumvent <br /> environmental compliance. <br /> (2) Violations Caused By Testing. The specific Y2K-related testing was the direct <br /> and proximate cause of the potential violations. <br /> (3) Testing Need. Timing & Leng. The specific testing that caused the potential <br /> violations was: <br /> (a) necessary to determine the effectiveness of specific Y2K-related modifications <br /> in ensuring environmental compliance; <br /> (b) part of a comprehensive testing program designed to correct all Y2K <br /> deficiencies at the facility; <br /> (c) conducted well in advance of the Y2K dates in question (i.e., normally at <br /> least 30 days in advance of the dates in question); and <br /> (d) conducted for the shortest possible period of time in order to determine the <br /> effectiveness of such modifications, not to exceed a testing period of 24 hours <br /> in duration. <br /> Where a facility, without making any modifications, tests existing equipment in <br /> order to determine whether Y2K-related problems may affect its environmental <br /> compliance status, the specific testing was: <br /> (e) necessary to determine the effectiveness of its existing operations in ensuring <br /> environmental compliance; <br /> (f) part of a comprehensive testing program designed to correct all Y2K-related <br /> deficiencies at the facility; <br /> (g) conducted well in advance of the Y2K dates in question (i.e., normally at <br /> least 30 days in advance of the dates in question); and <br /> E1-3 <br />