WQARF
A N N UA L
REPORT
2004
(A.R.S. 49-282.G)

TABLE OF CONTENTS
WQARF Program Overview ......................................................................................1
Major Issues and Accomplishments ...........................................................................4
Activities and Accomplishments of WQARF Sites....................................................6
Activities and Accomplishments of Federal Sites.......................................................9
Emergency Response Program .................................................................................11
Voluntary Remediation Program .............................................................................13
Water Quality Assessment and Management Program............................................14
Well Inspection and Approval Program...................................................................14
Risk Assessment Program.........................................................................................14

Appendices:
1 - Revenues and Expenditures
2 - Water Quality Advisory Board Retreat
3 - Voluntary Remediation Program
4 - Water Quality Assessment and Management Program
5 - Well Inspection and Approval Program
6 - Risk Assessment Program

Appendices to this report are available by contacting the ADEQ Records Center at (602) 771-4380.

Remedial Projects
Donald L. Richey, Manager
ADEQ/Waste Programs Division/Remedial Projects

A.R.S. ''49-281 to 49-296
(602) 771-4191
EVA0305.SUB

This annual report has been prepared pursuant to A.R.S. § 49-282(G) and SB 1402 (FY 2004 – FY
2005 General Appropriations Bill), Laws 2004, Chapter 275, page 39, as approved by the
Governor on May 28, 2004 and filed by the Secretary of State on the same day.

WQARF PROGRAM OVERVIEW
Program Description
Through the Water Quality Assurance Revolving Fund (WQARF) Program, the Arizona
Department of Environmental Quality (ADEQ) identifies, assesses, and cleans up soil and
groundwater that is contaminated with hazardous substances. The program conducts these efforts
state-wide with support from state funds and also oversees privately-funded cleanup efforts.
Responsible parties are identified and notified, and then legal and technical evidence is gathered
for recovery of ADEQ=s costs and enforcement of cleanup requirements.
WQARF was created under the Environmental Quality Act of 1986 to support clean up efforts in
the state. The program underwent significant revisions as a result of what is know as the WQARF
Reform Legislation of 1997 (Laws 1997, Chapter 287). The major provisions of the WQARF
Reform Legislation are as follows:

Proportionate Liability – Liability for the costs of the cleanup of contaminated sites is
proportionate, rather than joint. Cleanup costs are proportionately allocated among
responsible parties using a process defined in statute. Identification of responsible parties
and the allocation of cleanup costs are the responsibilities of ADEQ. A non-judicial
allocation hearing process is available for the resolution of disputes regarding ADEQ’s
allocations.

Program Funding – The adoption of a proportionate liability system increased the need
for adequate and dedicated program funding. To ensure that WQARF program funding is
sufficient to administer the program and to pay allocated, uncollectible orphan shares, the
legislature supports the WQARF program with an annual $18 million expenditure. The
fund is dependent upon the direct transfer of funds from legislative appropriations,
corporate income tax, cost recovery, and special fees.

Site Prioritization – Sites are to be prioritized with a greater emphasis on risk to human
health. The statute provides a process to score sites according to actual and potential
exposure to hazardous substances. This score and other factors are considered when
prioritizing the expenditure of WQARF funds.
ADEQ WQARF Annual Report 2004 - Page 1

Cleanup Methods and Goals – WQARF Reform provided for increased flexibility in the
selection of groundwater cleanup methods and levels. ADEQ has adopted remedy
selection rules that incorporate analysis of a range of cleanup options, from remediation of
the contamination to no action. Significantly, the statute clarifies that the cleanup need
not always result in the achievement of drinking water standards in the aquifer itself.

Community Involvement – Enhanced community involvement is provided for at all stages
of the cleanup process. The statute establishes a process to encourage active community
involvement, including provisions for notices, community involvement plans, and the
formation of a community advisory board for each site.

Settlements – Prompt settlements as an alternative to litigation are encouraged. ADEQ is
authorized to offer a 25 percent discount to responsible parties who settle after the
Department provides notice to them of their proportionate share of liability.
In addition to the costs of administering the program and conducting remedial actions, A.R.S. §
49-282(E) authorizes WQARF funding for other uses. Descriptions of the following
uses/programs and their accomplishments are discussed later in the report:
• Emergency Response Program
• Voluntary Remediation Program
• Water Quality Monitoring Program
• State matching monies or to meet other obligations prescribed by § 104 of CERCLA
• Well Inspections and Approval Program at the Arizona Department of Water Resources
• Risk Assessment Program at the Arizona Department of Health Services
Program Process Overview
The date that a site is added to the WQARF Registry generally does not indicate the date that
cleanup is started. Under most circumstances, numerous investigative, planning, community
involvement, risk assessment, and legal steps must be executed before a cleanup can begin.
Once in the WQARF program, sites undergo a remedial investigation/feasibility study (RI/FS). An
RI/FS is a two-phase investigation conducted by ADEQ or interested parties to investigate the
scope of contamination and determine the alternatives for remediation. The RI/FS requires
extensive technical information that may include soil and groundwater sampling and analysis of
both the site property and adjoining areas that may also be contaminated. The objective of the
RI/FS is to gather sufficient data to evaluate and select the most appropriate cleanup alternative
for the site. Concurrently, ADEQ is required at most sites to conduct an extensive search to
identify potentially responsible parties (PRP) searches.

ADEQ WQARF Annual Report 2004 - Page 2

During and following the RI/FS, legal negotiations may be undertaken in response to a party=s
request to settle liability early and to gain access to private properties for investigation or cleanup
implementation. Community involvement activities take place during investigations and prior to
development of the proposed remedial action plan (PRAP), depending on site specific issues.
These community involvement efforts may include the formation of community advisory boards
(CABs) to assist in relaying information and concerns between the public, ADEQ, and interested
parties. The Arizona Department of Health Services (ADHS) may also have input on the
investigative activities because they may evaluate the subsequent data to determine the potential
risk to human health.
Once the FS is completed and cleanup alternatives are identified, a PRAP is developed. At this
point in the process, activities to allow the public to comment on the PRAP are conducted. A
record of decision (ROD) documenting the selected cleanup alternative is signed, followed by an
allocation process in which past and future costs are distributed among responsible parties.
After the ROD is finalized, extensive design development and review must be undertaken. Several
months to several years may be needed to finalize a design, construct the remedy, and start the
actual cleanup. After the cleanup is implemented, operation and maintenance may be conducted
for a period of time specific to the remedy.
Because formal investigation and remediation can take many years, ADEQ developed a process to
address contamination that requires immediate action. The early response action process can be
used at any time prior to the implementation of a final remedy. Early response actions can be
conducted to address any of the following conditions:
• To mitigate an immediate threat to public health or the environment;
• To clean up a source of contamination;
• To prevent migration of contamination to uncontaminated areas; or
• To provide drinking water to residents whose drinking water supply has
been contaminated

ADEQ WQARF Annual Report 2004 - Page 3

MAJOR ISSUES & ACCOMPLISHMENTS FOR FY 2004
WQARF Funding
As described earlier in the report, ADEQ’s ability to administer and implement the WQARF
Program depends on $18 million in dedicated funding. A.R.S. § 49-282(B) specifies that $15
million of that $18 million is designated from the Corporate Income Tax. However, due to
budget shortfalls, the WQARF Program received a total of $20 million from the Corporate
Income Tax for Fiscal Years 2002, 2003, and 2004 (Please see table below). This has left the
Program with insufficient funds to address all existing and new sites on the registry.
Underfunding of the program has caused ADEQ to postpone the implementation of several
investigations and has delayed progress on several final cleanups, though the department continues
to direct its limited resources on early response actions and other activities where human health is
at risk.
WQARF Corporate Tax Revenue Comparison
FY 02 - FY 04

All Numbers Expressed in Thousands

16,000.0

15,000.0

15,000.0

15,000.0

14,000.0
12,000.0

10,000.0
10,000.0
8,000.0
6,000.0

5,000.0

5,000.0

4,000.0
2,000.0
0.0
FY 02

FY 03

Mandated

FY 04

Received

Two New Sites Added to the State’s Superfund List
ADEQ listed 2 new sites on the Water Quality Assurance Revolving Fund (WQARF) Registry.
The WQARF Registry is a list, created pursuant to A.R.S. §287.01, of sites in Arizona where
groundwater and/or soil contamination is known to be present. Sites listed on the Registry qualify
for WQARF Funds for investigation and/or cleanup of contamination. Currently, there are 36
sites on the Registry, with 2 sites added during FY 2004 and 1 in FY 2005 (to be addressed in next
year’s report). The following sites are the first to be listed on the Registry since 2000:

56th Street & Earll Drive – Listed on the WQARF Registry on June 2, 2004, the site consists
of an arsenic and trichloroethylene (TCE) contaminated groundwater plume located near 56th
Street and Earll Drive in Phoenix. The site was originally investigated as part of the Motorola
ADEQ WQARF Annual Report 2004 - Page 4

52nd Street National Priorities List (NPL) site. However, groundwater data from both sites
indicate that the two are separate and distinct plumes. Therefore, the site was disassociated
from the larger Motorola 52nd Street NPL. ADEQ is working cooperatively with a party
potentially responsible for the contamination to further evaluate the site and develop a
cleanup strategy.

Cooper Road & Commerce Avenue - The site was listed on the WQARF Registry on June
14, 2004. Tetrachloroethylene (PCE) has been detected in soil and groundwater at the site
located near Guadalupe Road and Baseline in Gilbert. Groundwater contamination is
near a Town of Gilbert drinking water production well and could threaten its use if
appropriate actions are not taken. ADEQ is currently evaluating the site for an early
response action.
Early Response Actions
ADEQ’s WQARF Program continues to place a high priority on early response actions where
human health is potentially impacted, where sources of contamination can cause significant
environmental impact, or where early actions can save significant WQARF funds by limiting the
spread of contamination. Operation and maintenance continues at eight early response actions
that were initiated in prior years. In FY 2004, the WQARF Program initiated the following three
significant early response actions:

East Central Phoenix: 32nd Street and Indian School Road WQARF Site – In April 2004,
ADEQ constructed an early response action to remove the source of contamination at a
former dry cleaner located on the southeast corner of 32nd St. and Indian School Road in
Phoenix. Soil contaminated with PCE was present beneath an existing building which
resulted in PCE vapors in the building. PCE is also a continuing source of contamination
to groundwater. ADEQ constructed an air sparge and soil vapor extraction (SVE) system
to remove groundwater and soil contamination.

East Central Phoenix: 40th Street and Indian School Road WQARF Site - In April 2004,
ADEQ constructed an early response action to remove the source of contamination at a
former dry cleaner facility located on the northeast corner of 40th St. and Indian School
Road in Phoenix. Soil contaminated with PCE is present in soil and represents a
continuing source of contamination in groundwater. ADEQ constructed an air sparge and
SVE system to remove groundwater and soil contamination.

South Mesa WQARF Site – In June 2004, ADEQ constructed an early response action to
remove the source of contamination at a former facility located at 1545 North McQueen
Road in Gilbert. Soil contaminated with PCE is present beneath the existing office
building which resulted in PCE vapors migrating into the building. PCE is also as a
continuing source of contamination to the groundwater. ADEQ constructed an SVE
system to remove subsurface soil contamination.

ADEQ WQARF Annual Report 2004 - Page 5

FY 2004 ACTIVITIES AND ACCOMPLISHMENTS AT WQARF SITES
Summaries are provided below of activities and accomplishments for sites on the WQARF
Registry. The revenues and expenditures for the WQARF Program can be found in Appendix 1.
A detailed description of activities and accomplishments of the Program can be found in
Appendix 2. Appendix 2 is a complete presentation to the WQARF Advisory Board on the
WQARF Program that was presented on September 24 and October 29, 2004.
Remediation
#

Millions of gallons of groundwater treated:
214.00
42.71
11.60
426.50
1729.94
9.00
.07
2,434.45

Broadway-Panatano
Central and Camelback
Los Reales Landfill
Payson PCE
Pinal Creek
Shannon Road - Rillito Creek
Tyson Wash
FY 2004 Total

#

Pounds of volatile organic compounds removed from the environment:
87.24
Central and Camelback
1.06
Los Reales Landfill
476.35
Payson PCE
1.80
Shannon Road - Rillito Creek
31.00
Silverbell Landfill
550.00
West Central Phoenix – East Grand Avenue
West Central Phoenix - North Plume
864.00
2,011.45
FY 2004 Total

#

Pounds of metals removed from the environment:
3285238.03 Pinal Creek
3,285,238.03 FY 2004 Total

#

Tons of contaminated soil removed:
88636 Vulture Mill
88,636
FY 2004 Total

ADEQ WQARF Annual Report 2004 - Page 6

Community Involvement Activities
#

Fact Sheets and/or Public Notices:
1
7th Street & Arizona Ave.
2
West Central Phoenix – East Grand Avenue
2
West Central Phoenix – West Grand Avenue
5
FY 2004 Total

#

Public Meetings:
2
Broadway – Pantano
1
Camelback Rd. & Central Avenue
1
El Camino Del Cerro
1
Miracle Mile
1
Park Euclid
1
Payson PCE
1
Shannon Road & Rillito Creek
1
South Mesa
1
West Central Phoenix – North Canal Plume
1
West Central Phoenix – North Plume
2
West Central Phoenix – West Grand Avenue
1
West Central Phoenix – West Osborn
14
FY 2004 Total

Legal Activities
#

Total Consent Decrees/Consent Orders completed (ARS § 49-282.G.3):
5
FY 2004 Total

#

Terms of WQARF Consent Decrees (ARS § 49-282.G.3):
Settlor
Frazee Industries, Inc.
GAC, Inc.
Honeywell, Inc.
Safety-Kleen Systems, Inc.
Waste Management of Arizona, Inc.
FY 2004 Total

Settlement Amount
$90,000.00
$140,000.00
$1,125,000.00
$99,000.00
$219,000.00
$1,673,000

ADEQ WQARF Annual Report 2004 - Page 7

#

Qualified Business or Financial Hardship Settlement applications received (ARS § 49282.G.4(a)):
No applications for qualified business or financial hardship settlements were received in
FY 04.

#

Qualified Business or Financial Hardship Settlements denied (ARS § 49-282.G.4(b)):
No applications for qualified business or financial hardship settlements were denied in
FY 04.

#

Qualified Business Settlements completed (ARS § 49-282.G.4(c)):
No qualified business settlements were completed in FY 04.

#

Financial Hardship Settlements completed (ARS § 49-282.G.4(d)):
No financial hardship settlements were completed in FY 04.

#

Prospective Purchaser Agreements completed:
3
FY 2004 Total

#

Access Agreements completed:
4
FY 2004 Total

#

Potentially Responsible Party (PRP) Searches started:
1
FY 2004 Total

#

Cost Recovery Activity
Description

# of
Packages

Dollar
Amount

At the beginning of the year

5

368,366.94

New Packages

5

271,287.81

Payments Received

6

388,700.67

Adjustments
Package reduction
Balance at end of year

1,356.00
4

249,598.08

ADEQ WQARF Annual Report 2004 - Page 8

FY 2004 ACTIVITIES AND ACCOMPLISHMENTS AT FEDERAL SITES
Pursuant to A.R.S. § 49-282(E)(1), WQARF can be used to provide state matching monies or to
meet other obligations as prescribed by § 104 of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA). WQARF monies are also used for remedial actions
at state-lead CERCLA sites which are reimbursed by the responsible parties. Summaries are
provided below of activities and accomplishments at federal sites supported by ADEQ.
#

Millions of gallons of groundwater treated:
19.9
Apache Powder
2.844
Hassayampa Landfill
3025.0
Luke AFB
141.00
Motorola 52nd St. - OU1
842.16
Motorola 52nd St. - OU2
6.264
North Indian Bend Wash
293.00
Phoenix-Goodyear Airport - South
671.00
Phoenix-Goodyear Airport - North
2,170.00
TARP - Tucson Airport Remediation Project
63.30
TIAA/Arizona Air National Guard Tucson
7.30
TIAA/Burr Brown
8.10
TIAA/Former West Cap
831.0
US Air Force Plant 44, Tucson
8,080.868
FY 2004 Total

#

Pounds of volatile organic compounds removed from the environment:
11,904
Davis-Monthan AFB – TPH (jet fuel)
8927
161st Air National Guard
32
Hassayampa Landfill
3538
Luke AFB
736
Motorola 52nd Street/OU1
1300
Motorola 52nd Street/OU2
5503
North Indian Bend Wash
177.9
Phoenix-Goodyear Airport/South
1296
Phoenix-Goodyear Airport/North
2.94
AANG 162nd (TIAA)
0.74
Burr Brown (TIAA) Texas Instruments
0.13
Former West Cap (TIAA)
325
TARP - Tucson Airport Remediation Project
545
US Air Force Plant 44, Tucson
34,287.71
FY 2004 Total

ADEQ WQARF Annual Report 2004 - Page 9

#

Pounds of hazardous substances removed from the environment:
44,579
Apache Powder (nitrate)
3,068
Motorola 52nd Street – Honeywell (solvent/jet fuel mixture)
47,647
FY 2004 Total

#

Pounds of other contaminants removed from the environment:
20.5
Phoenix Goodyear Airport North (perchlorate)
20.5
FY 2004 Total

#

Pounds of metals removed from the environment:
0
FY 2004 Total

#

Tons of contaminated soil removed:
2,969.28
Camp Navajo
2,969.28
FY 2004 Total

Community Involvement Activities at Federal Sites
#

Fact Sheets and Public Notices:
1
Apache
1
Williams Field Bomb Target #6 - FUDS
4
Williams AFB
2
Camp Navajo
1
Motorola 52nd Street
1
Phoenix Goodyear Airport North & South
10
FY 2004 Total

#

Public Meetings:
1
Williams Bomb Target #6
1
Davis-Monthan AFB
4
Williams AFB
4
Camp Navajo
1
Motorola 52nd Street
1
PGA South
1
Phoenix Goodyear Airport North and South
6
UCAB - TARP, TIAA, AZ Air National Guard, USAF Plant 44
19
FY 2004 Total

ADEQ WQARF Annual Report 2004 - Page 10

Legal Activities at Federal Sites
#

Access Agreements:
0
FY 2004 Total

#

Consent Decrees/Consent Orders:
1
FY 2004 Total

#

Applicable or Relevant and Appropriate Requirements:
0
FY 2004 Total

#

Records of Decision (ROD) and ROD Amendments:
0
FY 2004 Total

EMERGENCY RESPONSE PROGRAM
Pursuant to A.R.S. § 49-282(E)(8), WQARF monies are used for all reasonable costs incurred in
remedial actions taken in response to a release or threat of a release of a hazardous substance or
pollutant that presents an emergency to the public health or the environment.
FY 2004 Activities and Accomplishments
The Emergency Response Team (ERT) received and responded to 175 reported incidents, 37 of
which required a response action. The ERT also was involved in several emergency drills and
exercises including the Arizona / Sonora Binational Full-Scale Terrorism Response Exercise and
the annual Palo Verde Nuclear Generating Station Drill. In addition, the ERT dedicates
significant staff resources in support of several local, state and federal agencies during wildfire
operations and as a member of the Regional Response Team for the lower Colorado River.
Because of ERT involvement in these actives, ADEQ has received hundreds of thousands of
dollars in grant monies from the U.S. EPA and ODP. Grants funding will be utilized to upgrade
the Team’s ability to respond to threats to public health and safety. Significant emergency
response actions include:

Unsafe Storage of Hazardous Waste: During an inspection of a hazardous waste transfer
facility near Tucson, ADEQ hazardous waste inspectors discovered several drums and
containers of hazardous waste that appeared to be in an unstable condition due to age and
improper storage. At the request of the inspectors, the ERT responded and determined
that materials stored at the facility did pose a significant threat to the health and safety of

ADEQ WQARF Annual Report 2004 - Page 11

the surrounding community. ERT personnel then undertook response actions to stabilize
and secure the materials. ADEQ worked cooperatively with EPA to remove the hazardous
materials after they were stabilized. The operator of the facility has been charged with
environmental crimes.

Release of Chlorine Gas: At the request of a local fire department, the ERT responded to a
release of chlorine gas at a facility located in Glendale. This action took place after a large
amount of chlorine gas was released from a 90-ton railcar during a cross-loading operation.
During this incident, the ERT provided on-site technical assistance to local response
agencies and assumed the role of State On-Scene Coordinator for additional state
resources that were involved in the response.

Cross Border Release of 30 Million Gallons of Raw Sewage: At the request of Nogales
Arizona, the ERT undertook a response action to treat and remove the remains of 30
million gallons of raw sewage released into the Nogales Wash south of the US / Mexico
Border. During this operation, ERT personnel provided oversight during the removal of
more that 200 tons of solid debris and the deployment of several hundred pounds of
chlorine that was used to treat the sewage that remained in the wash.
A.R.S. '49-282(E)(11) also provides for reimbursement to political subdivisions for costs incurred
in response to a release or a threat of a release of a hazardous substance or pollutant that presents
an immediate and substantial endangerment to the public health or the environment. There were
no new applications received in FY 2004, but there were two applications received in FY 2003 that
were denied in FY 2004. The total amount denied was $12,405.82

ADEQ WQARF Annual Report 2004 - Page 12

VOLUNTARY REMEDIATION PROGRAM
Senate Bill 1454 went into effect on July 18, 2000 which created a new Voluntary Remediation
Program (VRP) to be implemented by the ADEQ. The VRP provides an opportunity for property
owners, prospective purchasers and other interested parties to step forward to investigate and
remediate a contaminated site in cooperation with ADEQ. The volunteer reimburses ADEQ for
oversight costs as arranged through a signed reimbursement agreement. Upon successful
completion of remediation activities, the volunteer has the opportunity to receive either a no
further action (NFA) or conditional NFA determination from ADEQ for a site or portion of a site.
A.R.S. § 49-282(E) and §49-187 authorizes the use of WQARF for this program.
FY 2004 Accomplishments
VRP continues it success in encouraging property owners, prospective purchasers, and other
interested parties to investigate and cleanup contaminated sites in cooperation with the agency.
Benefits of the program include reducing exposures to contaminants and ensuring that cleanups
meet applicable requirements. In exchange for their initiative and cooperation, program
participants benefit from ADEQ’s expedited review of the clean up and upon successful
completion, a closure document that is accepted by all relevant ADEQ programs. In addition,
applicants can utilize the closure document to demonstrate to potential purchasers and lending
institutions that all applicable cleanup standards have been achieved.
Due to aggressive marketing, referrals from successful applicants, and program enhancements, the
numbers of applicants to the VRP continues to grow. In 2004, the VRP accepted 18 new sites,
containing both soil and groundwater contamination. ADEQ continues to educate consultants
and potential applicants about the benefits of the program by relaying other success stories.
Several applicants that have gone through the VRP for one site have returned to the program for
additional sites where remediation is needed. In addition, ADEQ has integrated the VRP into its
enforcement strategy for facilities that have been identified by the regulatory programs as requiring
remediation. These facilities are encouraged to enter the VRP in lieu of enforcement action. This
not only provides for a facility to return to compliance, it allows both the facility and ADEQ to
focus time and money on the cleanup instead of on efforts to compel the clean up. It also allows
the agency’s inspection and enforcement staff to focus on identifying new sites and allows VRP
staff to ensure that remediation is conducted in a consistent manner across the agency.
There are currently 79 active and 81 closed sites in the VRP with remediation of 568,213 tons of
soil at participating VRP sites. A detailed description of VRP activities and accomplishments can
be found in Appendix 3.

ADEQ WQARF Annual Report 2004 - Page 13

WATER QUALITY ASSESSMENT AND MANAGEMENT PROGRAM
Pursuant to A.R.S. § 49-282(E)(3), WQARF monies are used for the costs of monitoring, assessing,
identifying, locating, and evaluating the degradation, destruction, loss of or threat to the waters of
the state resulting from a release of a hazardous substance to the environment. Pursuant to A.R.S.
§ 49-282(E)(6), WQARF monies are also used for the costs of the water quality monitoring
program described in A.R.S. § 49-225. A description of Water Quality Assessment and
Management Program FY 2004 activities and accomplishments can be found in Appendix 4.

WELL INSPECTIONS AND APPROVAL PROGRAM
Pursuant to A.R.S. 282(E)(12) WQARF monies are used to fund the Arizona Department of
Resources to conduct well inspections, remedial actions, and review of and approval well
construction necessary to prevent vertical cross-contamination. The FY 2004 accomplishments of
the Well Inspections and Approval Program can be found in Appendix 5.
RISK ASSESSMENT PROGRAM
Pursuant to A.R.S. 282(E)(15) WQARF monies are used to fund the Arizona Department of
Health Services to assess and evaluate the effect of a release or a threatened release of hazardous
substances to the public health, welfare, or the environment. The FY 2004 accomplishments of
the Risk Assessment Program can be founding Appendix 6.

ADEQ WQARF Annual Report 2004 - Page 14