United States Environmental Protection Agency Office of Site Remediation Enforcement (2271 A) Washington, DC 20460 &EPA cleanupnews Summer 2000 EPA300-N-00-011 Issue #5 inside Awards 2 In the Courts 4 Atlas Aronowitz CEPPO News 5 OERR News 6 Technology Insights 7 Calendar 8 Cleanup News is an occa- sional newsletter highlighting hazardous waste cleanup cases, policies, settlements, and technologies. EPA Moves to Full Cost Accounting at Superfund Sites Guidance Issued on Enforcement Discretion During Transition Period EPAs Office of Site Remediation En- forcement has provided guidance to the regional offices on the exercise of enforcement discretion between now and October 2,2000 when EPA moves to a full cost accounting approach to allocating costs at Superfund sites. (See notice in the The effect of applying the revised rates will vary from site to site. The new method allocates indirect costs in propor- tion to direct costs, instead of in propor- tion to the number of Superfund staff hours charged to a site. As a result, sites with large direct federal expenditures compared to the number of Superfund staff hours will generally see the largest indirect cost increases, and few if any de- creases. Sites with smaller federal expen- ditures compared to the number of Super- . fund staff hours, such as sites cleaned up Offe TS0SO IVing by potentially responsible parties (PRPs) „, „, . where EPAs costs are largely for over- O-Lv/CUlVT. sight performed by EPA staff, will gener- 7 ,r ally see smaller indirect cost increases, G t/o to U 6to e Cl O rl III tand are ajso more likely to see decreases. current indirect rates. Until the 1SS Ue d, EPA Will Ore Federal Registerjune 2, 2000, pp. 35339- 35345.) EPAs current indirect cost accounting methodology allocates to Superfund sites only about one-third of the indirect costs that are incurred by EPA and properly al- locable to sites. Full cost accounting will bring Superfund into compliance with cost accounting standards issued by the Fed- eral Accounting Standards Advisory Board in 1995 and the requirements of the Federal Financial Management Improve- ment Act of 1996. Enforcement Discretion After October 2,2000, site costs, including oversight costs, will be calculated using the revised rates. Here are some of the is- sues of particular enforcement interest and EPAs intended approach to ensure a fair and efficient transition to the revised accounting methodology. • Concluded MaftercEPArecognizes the importance of finality and has no plans to re-open any concluded cases to apply the revised rates to claims for past costs that were presented and resolved in those mat- •3 Printed on recycled paper ------- i National Notable Achievement Awards Given in April 2000 At a ceremony in Washington on April 24, the year 2000 Na- tional Notable Achievement Awards were presented to outstanding EPA Regional Superfund, RCRA Cor- rective Action, and Superfund En- forcement staff. Here are a few exam- ples of excellence in action. RCRA Corrective Action Award for Outstanding Stakeholder Involvement: Gary Miller, Region 6 Gary Miller received this award for his work as the corrective action enforce- ment project manager at a hazardous w aste facility with substantial contam- ination that was partially destroyed by an explosion and fire. Gary worked ef- fectively with the concerned sur- rounding community as well as with the state agency, EPA headquarters, and the facility owner to ensure that proper actions were taken to clean up the site. After the Chief Supply Company was partially destroyed by an explo- sion and fire in March 1997, environ- mental samples detected chlorinated solvents, benzene, toluene, ethylben- zene, and xylene contamination. Gary assembled the community, the state, and EPA headquarters for numerous discussions regarding community concerns, the best way to approach the facility, the purpose of EPA's ac- tions, and the safety of the facility's op- erations. In addition, he opened an on- going dialogue with the community via e-mail. Gary continues to work with the state agency and the facility owner to complete the cleanup. In a recent let- ter to the Regional Administrator and Legal Enforcer of the Year Thomas P. Turner accepts congratulations from OECA Assistant Administrator Steven Herman and OSRE Director Barry Breen. local Congressmen, a member of the community thanked EPA for its con- tinued efforts and specifically for Gary's exceptional work. Superfund Award for On-Scene Coordinator (OSC) of the Year: Martha A. Wolf, Region 8 As one of two recipients of the OSC award, Martha Wolf was recognized for her professionalism, dedication, and high-quality work inspecting re- fineries and large-scale petroleum storage facilities located on the banks of pristine rivers in the Rocky Moun- tain area. In addition, she organizes and directs diverse and sometimes dif- ficult stakeholder groups in Area Con- tingency Plan (ACP) negotiations, and establishes national regulations and policy for EPA's oil program. Martha supervises the FRP and SPCC programs that compel facility owners to identify their vulnerabilities and change their practices to prevent spills, and to be well prepared for any that do occur. In FY99, she managed a workload of more than 100 SPCC and FRP inspections and reviews, and con- ducted negotiations for five separate river environments, bring- ing groups together to re- solve conflicts and prepare ACPs despite their often contentious histories. In ad- dition, she initiated an effort to incorporate all informa- tion and maps in the plans into a computerized geo- graphic information system. On-Scene Coordinators need to exercise diplomacy, and Martha has demon- strated an amazing ability to commu- nicate effectively with uncooperative facility owners. Martha's patience has helped achieve the goal of safer, well- prepared facilities. Superfund Enforcement Award for Team of the Year: Casmalia Enforcement Team, Region 9 For its successful implementation of several key administrative reforms to achieve the largest de minimis settle- ment in the history of the Superfund program, the Casmalia Enforcement Team received the 2000 Superfund Enforcement Team of the Year Award. These reforms included expedited set- tlement; increasing fairness in the en- forcement process; reducing transac- tion costs; and providing a meaningful forum for stakeholder concerns. Through the team's efforts, EPA settled with more than 400 small waste generators, providing special legal protections to de minimis contribu- tors. These de minimis parties have contributed a record $26.5 million to- ward cleanup of the site. The Casmalia Disposal site in Santa Barbara County, CA, is one of the largest hazardous 2 Cleanup News ------- waste sites in the nation. During a four- year period in the early 1990s, EPA spent more than $17 million taking emergency response actions to stabi- lize the site. The team used several innovative approaches to achieve settlement, in- cluding: (1) utilizing a sophisticated management information system to en- hance communication with the de min- imis parties; (2) conducting special out- reach efforts to the de minimis parties; and (3) expediting the settlement process by consolidating payment with the submittal of signature pages. The case team actively encouraged de minimis parties to contact EPA using a dedicated toll-free number. In addition, the team hosted an informa- tional meeting attended by 350 people after the settlement offer was distrib- uted. And throughout the arduous process of producing the settlement, team members maintained their sense of humor and a strong sense of cama- raderie. The Winners! RCRA Corrective Action Awards: Outstanding Stakeholder Involvement: Gary Miller, Region 6 Outstanding Use of Environmental Indicators:Raphael]. Cody, EPA-New England Faster, Focused, More Flexible Cleanup: Matthew R. Hoagland, EPA-New England • Anniston PCB Work Group Team, Region 4 • Streamlining Team for RCRA Enforcement CA, Region 6 • Corrective Action Environmental In- dicator Evaluation Team, Region 9 Superfund Awards: flu-Scene Coordinator: Vincent E. Zenone, Region 3; Martha A Wolf, Region 8 Remedial Project Manager: Randy Sturgeon, Region 3 Site Assessment Manager: Cynthia Gurley, Region 4 Community Involvement Coordinator: Pat Seppi, Region 2; Sherryl A Carbonaro, Region 4 Exceptional Merit Award: Earl Liverman, Region 10 Leader/Mentor: Robert W Feild, Region 7 Superfund ROD: Sally Thomas, Region 10 (Pacific Sound Resources Site) Superfund Team: • Hurricane Floyd Response Team, Region 4 • Oklahoma Tornadoes Team, Region 6 Superfund Enforcement Awards: Legal Enforcer:Thomas P. Turner, Region 5 Technical Enforcer: Lois Elaine Green, Region 9 Enforcement Team: Casmalia Enforcement Team, Region 9 For more on the awards, go to: www.epa.gov/superfund/new/awards/ index.htm Superfund Accounting continued from page 1 ters. This includes consent decrees, lit- igated judgments, and administrative orders on consent. It also includes ceil- ings established in settlements and judgments for oversight or other re- sponse costs that the Agency can bill to PRPs under those existing settle- ments or judgments. • Oversight Billings: EPA has no plans to recompute oversight bills that were prepared and sent to PRPs be- fore the revised rates are issued. • Claims in Litigation Prior to Octo- ber 2, 2000: There may be special cir- cumstances in these cases, especially if the litigation is at an advanced stage, that cause the case team to decide not to seek to amend the claim by applying the revised indirect rates. An example might be certain cases in which costs have already been presented to the court and the parties are awaiting the court's decision. These decisions will be made by the EPA/Department of Justice case team on a case-by-case basis. • Interim Settlement Policy in Antici- pation of the Revised Rates.'One pur- pose of EPA giving advance notice of the change in rates is to provide PRPs who have unresolved cost recovery li- abilities an opportunity to settle with the United States at the current rates. Until the revised rates are issued, EPA will entertain settlement offers resolv- ing claims for CERCLA response costs based on the current indirect rates. • Proving Indirect CostsImplement- ing the new accounting method will not alter the burden of proof that EPA must meet when seeking recovery of indirect costs. EPA will continue to provide evidence acceptable in a court of law to prove that the indirect costs sought are allocable to the site that is the subject of the enforcement action. • National Consistency/Coodina- tion: EPA has a substantial interest in promoting a nationally consistent ap- proach during this transition period. As always, EPA will exercise its dis- cretion to ensure that resulting settle- ments are fair, reasonable, and consis- tent with CERCLA. For more information, contact OSRE's Policy and Program Evalua- tion Division at 202-564-5100. Cleanup News 3 ------- District Court Upholds EPA's Cost Recovery at Atlas Asbestos Mine In August 1992, the United States entered into a consent decree (CD) with potentially responsible parties (PRPs) Atlas and Vinnell Mining to per- form a cleanup at the Atlas Asbestos Mine Superfund Site. The CD required the PRPs to reimburse EPA for all fu- ture response costs, including over- sight costs and indirect costs. The CD permitted Atlas to contest payment of any future response cost on one of three grounds: (1) an accounting error was made by the government; (2) costs billed were inconsistent with the Na- tional Contingency Plan; or (3) costs billed were not actually incurred in con- nection with the site. In August 1994, EPA sent its first bill to the PRPs, for costs incurred be- tween December 1990 and December 1993. The PRPs disputed these costs, The opinion included very favorable language regarding EPA's use of its annual allocation and indirect cost methodologies. placed the disputed funds in an escrow account, and requested additional doc- umentation from EPA In December 1997, EPA sent a second bill. Again, the PRPs disputed these costs, but did not establish an escrow account for the disputed amount until ordered by the district court in June 1998. Following a period of informal, and then formal dispute resolution, EPA issued a deci- sion requiring the PRPs to pay roughly $641,000 of the roughly $677,000 orig- inally billed. The PRPs challenged EPAs ruling in district court alleging, amongst other things, that EPA failed to adequately document costs, had im- properly billed non-site-specific costs, and was not entitled to recover attor- ney's fees incurred in defending the dispute. Addressing each type of cost sepa- rately, the court broadly interpreted the provisions of the CD to permit the col- lection of all contested costs (including attorney's fees, annual allocation costs, and indirect costs). The court did find that in some instances EPA had failed to provide enough supporting docu- mentation, and failure to remedy this deficiency would prevent the recovery of those costs (roughly $67,000). The opinion included very favor- able language regarding EPA's use of its annual allocation and indirect cost methodologies. Although the court ac- knowledged that EPA employs a "complicated methodology" to appor- tion indirect and annual allocation costs, the court did not find EPA's methodology arbitrary or capricious. In addition, the court was not per- suaded by the argument that EPA was not entitled to recover non-site-spe- cific costs. The court found that the CD unambiguously requires the pri- vate parties to pay indirect costs, and although the CD does not specifically mention annual allocation costs, the court held that "these costs are in- curred in connection with the Site" and therefore are recoverable. For more information, contact OSRE's Regional Support Division, 202-564-4200 [U.S. v. Atlas Corp. and Vinnell Mining, E.D. CaL, 1/12/00]. Corporate Officer Held Individually Liable in U.S. v. Aronowitz On January 31, 2000, the U.S. District Court for the Southern District of Florida held that Jack L. Aronowitz, president and owner of Technical Chemicals & Products, Inc. (TCP) was individually liable as an operator and arranger under CERCIA Sections 107 (a) (2) and (a) (3), as was his com- pany TCP. EPA filed a cost recovery action against Aronowitz and TCP for response costs incurred in responding to release problems at the Lauderdale Chemical Warehouse site in Broward County, Florida. The court held that Aronowitz and TCP were jointly and severally liable for $401,177 plus post- judgement interest. From 1985 to 1992, TCP operated the site when hazardous substances (toxic and volatile chemicals) were dis- posed of, and arranged for the disposal of hazardous substances located at the site. The court held TCP and Aronowitz liable because of the spe- cific activities TCP conducted at the site and because Aronowitz directed, managed, and controlled the environ- mental operations of TCP. The court found that Aronowitz's actions met the criteria for direct oper- ator liability under CERCIA, as articu- lated by the Supreme Court in United States v. Bestfoods, 524 U.S. 51 (1998). The Supreme Court in Bestfoods ad- dressed the issue of parent/subsidiary liability under CERCIA In finding Aronowitz individually liable as an op- erator, the court applied the same stan- dard of control for operating a facility to corporate officers as was used in Bestfoods, where a parent corporation was alleged to have operated facilities owned or operated by its subsidiary. The court also held that Aronowitz's actions in operating TCP were suffi- cient to find him liable as an arranger under CERCIA For more information, contact OSRE's Regional Support Division, 202-564-4200 [United States v. Aronowitz, No. 98-6201 (S.D. Fla. 2000)]. 4 Cleanup News ------- EPA Participates in Counter- Terrorism Drills A series of counter-terrorism drills conducted on May 20-25, 2000 at the behest of Congress helped federal planners assess national readiness in the event of a terrorist at- tack. Code-named "TOPOFF" for Top Official, the Federal Disaster Drill was masterminded by the Department of Justice and the Federal Emergency Management Agency to measure the integrated capabilities of federal, state, district, and local resources — includ- ing personnel, procedures, direction and control, communications, facilities, and equipment — in the event of a Weapons of Mass Destruction terrorist incident. EPA has formal responsibility for cleanup of any hazardous materials releases in such an event. Personnel from EPA headquarters (OERR, CEPPO, Radiation and Indoor Air) and regional counterparts worked closely with local emergency respon- ders to ensure that quick local and fed- eral responses would hold civilian ca- sualties down to a minimum during the simulated exercise. Participating responders were not informed of the specific scenarios in advance. The three-part exercise began when a simulated explosion occurred in Portsmouth, NH, on May 20 at the start of a charity race. The response was complicated by the simultaneous release of a chemical agent, deter- mined to be mustard gas. Local law en- forcement officials, firefighters, and rescue crews scrambled to deal with fake deaths and injuries. A similar scene took place in Den- ver where a simulated attack involving a biological agent, first thought to be anthrax, was subsequently deter- mined to be the pneumonic plague. The nation's capital was also pulled Mutual Aid Personnel Treat Simulated Victims in Portsmouth, NH. into the mix when simulated explo- sions laced with uranium occurred at St. Elizabeth's Hospital in Washing- ton, D.C. and at the U.S. Airways Arena in Largo, MD. The exercises aimed to assess the nation's ability to manage crises and consequences, and to highlight areas in which more training might be needed to fend off the possibility of ter- rorist attacks and to respond quickly and effectively in their aftermath. For more information, contact CEPPO at 202-260-8600. A Snapshot of Risk Management Plans In June 1999, an EPA regulation called the Risk Management Pro- gram (RMP) prompted 15,000 U.S. facilities that use hazardous chemicals to submit reports describing their po- tential risk to surrounding communi- ties. The Risk Management Program captures information from businesses such as cold storage warehouses, water utilities, oil refineries, fertilizer makers, and farm suppliers as well as chemical manufacturers. One of the most valuable pieces of data in the re- ports is the history of actual chemical accidents that occurred at these facili- ties in the past five years. EPA's Chemical Emergency Pre- paredness and Prevention Office (CEPPO), industry associations, state and local emergency managers, and others are reviewing the data to find ac- cident frequencies by industrial sector, correlations between facility character- istics and accidents, findings about po- tential consequences of accidents to off- site populations, and significant trends in chemical industry hazards and acci- dents. Preliminary data from the RMP accident histories indicate that over a five-year period, there were: • 1,900 serious accidents among these 15,000 facilities; • 33 deaths and 8,300 injuries; and • Evacuation or sheltering of 221,000 individuals. con I 0) o a a 8 Cleanup News ------- I 0) 0) o To Permanently Relocate or Not? by Pat Carey, OERR The decision to permanently relo- cate residents away from areas near Superfund sites was the topic of discussion at the Relocation Forum Stakeholder Meeting held March 2-3, 2000, in Washington, DC. Representatives from industry, state and local government, public health, environmental justice and other fed- eral agencies convened to review, dis- cuss, and give input on the Interim Final Policy on the Use of Pemanent Relocation as Part of Superfund Reme- dial Actions. The interim final policy, issued June 30,1999, states EPA's preference to clean up and restore property so people can live safely in their homes. The policy explains when to consider permanent relocation as part of a cleanup at an NPL site, and gives ex- amples of situations where permanent relocation could be considered. The policy, which emerged out of a 1995 request by the National Environ- mental Justice Advisory Council, also recognizes the importance of early, di- rect, and meaningful public involve- ment in relocations. EPArecommends that Community Advisory Groups be formed to engage all interested parties in a dialogue about cleanup and how relocation fits into a community's long- term vision and plans. In the last few years, EPA has undertaken a number of initiatives to widen its understand- ing of the issues associated with relo- cation: • A national relocation pilot was se- lected in Pensacola, Florida at the Escambia Woodtreating Site. • EPA reviewed sites where cleanups were done in residential areas, then sponsored a series of forums to hear stakeholder views and experience on the subject of relocation. • In 1996, a Relocation Forum was held in Pensacola, Florida, with community and environmental jus- tice groups. Seven additional fo- rums were held in 1996 and 1997 with representatives from various stakeholder groups. EPAs next steps include developing case studies of five sites where perma- nent relocations have taken place; issuing mini-guidance on issues that need to be addressed quickly, such as the release of appraisals, advisory services, etc.; and disseminating the necessary information to regional of- fices, federal agencies, and all those responsible for the successful imple- mentation of relocations. For more information, contact OERR at 703-603-8960. Access our web- site for the Interim Final Policy and re- lated documents, at www.epa.gov/ superfund/tools/topics/relocation/ind ex.htm Safer, More Livable Communities EPA's Office of Solid Waste and Emergency Response has released a new report titled Innovations in OSWER: Making Safer, More Livable Communities. Prepared for key customers in states, tribes, other agencies, industry, and communities, the report describes a range of new strategies, new partnerships, and new approaches to help make communities safer and more livable. The report is available on OSWER's What's New page at: www.epa.gov/swerrims/whatsnew.htm. RMPs continued from page 5 Higher accident rates were found at facilities with ammonia refrigeration units (35.4%), followed by water utili- ties (22.7%), refineries (19.3%), fertil- izer manufacturers (11.6%), and farm suppliers (11.0%). The Wharton School at the Univer- sity of Pennsylvania also is studying the data. Wharton has issued a work- ing paper that presents preliminary findings on accident frequencies and severities available from RMP*Info, the database set up to store Risk Man- agement Plans and accident history data. The paper analyzes which facili- ties actually filed plans, and then pre- sents results for various segments of the U.S. chemical industry on ob- served accident frequencies between June 21, 1994 through June 20, 1999. The report is available at www.epa. gov/ceppo/ap_arcs.htm In the future, we can expect to see industry sector-specific and chemical process-specific studies. The key question remains whether there are predictors of accident frequency and severity and, if so, how can industry, CEPPO, and others work together to lower the risk to communities. Cleanup News ------- Brownf ields Tech Center Supports Local Decision-Makers Faced with a brownfields rede- velopment opportunity and a variety of complicated recom- mendations from contractors, brown- fields decision-makers now have a place to go for help. The Brownfields Technology Support Center helps de- cision-makers become aware of the full range of technologies available in order to make informed, "smart tech- nology" decisions for their sites. Tech- nologies that lower costs, decrease time frames, and/or positively impact other decision considerations (e.g., community acceptance, logistics, etc.) can significantly affect the rede- velopment poten- tial of brown- fields sites. At no cost to localities, the Brownfields Center of- fers unbiased assessments on options relevant to specific sites. The center can also provide a technology-oriented review of investigation and site-specific cleanup plans. Operated by EPA's Technology Innovation Office, the cen- ter provides five types of assistance: • Document Kviews:The center can review sampling and analysis plans, quality assurance project plans, feasibility studies, engineer- ing designs, or work plans, and evaluate the documents in terms of technology options, implemen- tation processes, or other factors. • Technology scoping\3smg informa- tion provided by EPA Regional staff for specific brownfields pilot sites, the center can prepare lists of potentially applicable technolo- gies, along with brief analyses of their advantages and disadvan- tages under specific conditions at a site and in light of the specific fea- tures and needs of a site. • Technology descriptionS:he center can develop a brief "layman's" guide describing a specific tech- nology or technique. The guides can help decision-makers fully un- derstand the principles of the tech- nology (along with the cost and time necessary to implement it) and communicate information about the technology to con- stituents and stakeholders. • Review of literature and electvnic resourcesfThe center can provide a list and description of available in- formation resources for technolo- gies relevant to specific decisions at a site. This can help stakehold- ers broaden their understanding of the technology options available for use at their sites. • Demonstration support: Drawing upon the expertise of the EPA Su- perfund Innovative Technologies Evaluation (SITE) program, the center provides planning assis- tance and technical review capabil- ities to localities seeking to arrange demonstrations and evaluations of innovative sampling, analytical, and treatment technologies. For more information, contact the EPA Regional Brownfields Coordina- tors, or the center directly at 1-877-838- 7220 (toll-free), or www.brownfield- stsc.org. SWITCH TO E-MAIL!!! Cleanup News is trying to move to an electronic format If you send us your e-mail address, we will notify you when each issue of Cleanup News is available on the Web, and you can read it or download it at your conve- nience. Please fill out this form, and fax it to 301 -652-7001, or e-mail the information to rfrance@scicomm.com. Cleanup News is available on the Web at www.epa.gov/oeca/osre. Name: Organization: Address: E-Mail: o "o 1 Cleanup News 7 ------- 8 Aug 14-16,2000 ATSWMO Superfund Managers Meeting Phoenix, AZ Contact: Jim Konz, 703-603-8841. Aug 28-Sept 1,2000 National Community Involvement San Francisco, CA Contact: Helen DuTeau,703-603-8761. October 11-13,2000 Brownf ields 2000 Atlantic City, NJ http://www.brownfields2000.org. November 1-3,2000 Health Risk Communication Symposium: Uncertainty, Stakehold- ers, and Public Health Action Bethesda, MD Sponsors:DOE,EPA,HHS. Focus on risk communication issues in U.S. and in developing and transitioning na- tions. Includes half-day breakout sessions analyzing case studies. Contact: Lisa Carroll, 865-576-2266, carrolle@orau.gov. Acronyms ADR Alternative Dispute Resolution AGP Area Contingency Plan CD Consent Decree CEPPO Chemical Emergency Preparedness and Prevention Office CERCLA Comprehensive Environmental Response, Compensation, and Liability Act {Superfund law) DoD Department of Defense FEMA Federal Emergency Management Agency FRP Facility Response Plan ITT Innovative Treatment Technologies NPL National Priorities List (Superfund) OERR Office of Emergency and Remedial Reponse (EPA) cteanupnews Cleanup News is a publication of EPA's Office of Site Remediation Enforcement, in cooperation with the Office of Emergency Response and Remediation,Office of Underground Storage Tanks, Chemical Emergency Preparedness and Prevention Office, and the Technology Innovation Office. OMB Office of Management and Budget OPA Oil Pollution Act OSC On-Scene Coordinator OSRE Office of Site Remediation Enforcement (EPA) PCB Polychorinated Biphenyls PRP Potentially Responsible Party RCRA Resource Conservation and Recovery Act (hazardous waste) RMP Risk Management Plan SITE Superfund Innovative Technologies Evaluation SPCC Spill Prevention Control and Countermeasure TCP Technical Chemicals & Products, Inc. www, epa.gov/oeca/osre Rick Popino, Ph.D., editor EPA Review Board: Rick Popino, Ph.D.,Paul Connor, Karen Ellenberger, Ken Patterson, Helen DuTeau. Jeff Heimerman, Carole Macko Cameron Gilah Langner, writer Robin Foster, SciComm lnc.,designer To comment on the newsletter, contact Rick Popino, Ph.D. (MC-2271A), U.S. EPA.401 M Street SW, Washington.DC 20460,e-mail:popino.rick@epa.gov. For mailing list inquiries.contact Robert France, SciComm Inc.,7735 Old Georgetown Rd, Bethesda.MD 20814,tax:301 -652-7001 ,e-mail:rfrance@scicomm.com. ooe$ Eua<£ sssirisng IEPUJO 99-0 'ON Vd3 dlVd S33d ^ BOVlSOd SSNTIO ISdld 09TOS 0(1 'u (VUZZ) AouaSy uopoajojj ------- |