Office of Site Remediation
                                  Enforcement (2271 A)
                                  Washington, DC 20460
                                                           Summer 2005
                                                           EPA300-N-05-005
                                                           Issue #21
Environmental Protection
Agency
inside

Highlights
Centredale Manor
Pioneer Smelting

In the Spotlight
Nease Chemical
Performance-Based Contracting

Enforcement News
Employee Pleads Guilty

Superfund News
Syosset Landfill
PCC Strategy

In the Courts
Adobe Lumber v. Taecker
Syms v. Olin

Tidbits
ER3 Partners

Calendar
Glossary
                           cleanup
                                                        ^^^^_

CleanupNews is a quarterly
newsletter highlighting hazardous
waste cleanup cases, policies,
settlements and technologies.
                               EPA  Places   Superfund
                               Lien,   Hopes  to   Recover
                               $27  Million   in  Costs
                                      EPA has placed liens on
                                      554 acres of land at a
                                      former mine in Clear
                               Lake, California in order to recu-
                               perate  $27 million for past
                               cleanup costs. EPA's response ac-
                               tions to-date include stabilizing
                               waste piles, erosion control mea-
                               sures, removal of contaminated
                               soil, site investigations,  and the
                               emergency closure of some geo-
                               thermal exploration wells. The
                               Agency estimates that it may cost
                               $40 million more to complete the
                               remaining
                               cleanup activi-
                               ties.
                                 Liens  are legal
                               actions  that can
                               bar a property
                               owner from sell-
                               ing a property without the lien
                               enactor's permission.  The Com-
                               prehensive  Environmental  Re-
                               sponse,  Compensation,  and Li-
                               ability Act (CERCLA) at 42 USC
                               9607(1)  provides EPA with  the
                               authority to enact a lien against
                               the title of the  property upon
                               which response actions have been
                               taken.   Liens are  placed on
                               remediation  sites to recover
                               cleanup costs already incurred by
                               EPA and to ensure that poten-
                               tially responsible parties do not
                               profit from the increased value of
                               property improvedby EPA through
                               the cleanup process.
                                 The property is part of  the
                               former  Sulphur Bank Mercury
Liens help recover costs and
ensure PRPs do not benefit
from post-cleanup property
value increases.
Mine and is owned by Bradley Min-
ing Company and Worthen Brad-
ley Trust. Mining activities at the
site began in 1865 and continued
off and on until the site was aban-
donedin 1975. Mercury ore was the
primary product after the site was
initially mined for sulfur. The re-
maining waste piles contain heavy
metals including mercury, arsenic,
and antimony and are the source of
mercury polluting the local ground
and surface water.  The site also
includes an open pit mine known
               as the Herman
               Impoundment
               where acidic
               water  con-
               taminated
               with  heavy
               metals has ac-
cumulated.  The  site has been on
the National Priorities List since
1990.
 The impact of contamination
from the mine on the local environ-
ment has been documented prima-
rily through the bioaccumulation of
mercury found in plants, animals,
and soils in the nearby Clear Lake
ecosystem. The State of California
has issued fishing advisories for
Clear Lake due to the high mercury
levels.  The heavy metals contami-
nating the site, including antimony
and mercury, are toxic to people and
the environment.
 For additional information, contact
Larry Bradfish, EPA Region 9,
bradfish. larrv@eDa.sov.
                                                                                  § Printed on recycled paper

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 Settlements Will  Help  Clean   Up
 Centredale Manor  Restoration
       Two proposed settlements
       worth approximately $3.6
       million will help clean up con-
tamination at the Centredale Manor
Restoration
Project Site in
North Providence,
Rhode Island. The
owners  of  the
Centerdale Manor
and Brook  Vil-
lage apartment
buildings—which
provide low-cost
housing to the eld-
erly—agreed to
the settlement
through separate
consent  decrees.
Both proposed con-
sent decrees are sub-
ject to a 30-day public comment pe-
riod. If the consent decrees are final-
ized, the settlers will "cash out" their
liability, meaning that EPA will re-
lease the apartment complex owners
of any further responsibility related to
the existing contamination at the site.
The settlements will be paid to EPA,
the State of Rhode Island, and the De-
partment of the Interior; a portion will
also be placed in an escrow account.
             The settlement agreements should en-
             sure that the settlors remain finan-
             cially viable, thereby ensuring that low-
             cost housing will continue to be avail-
View of the Centredale Manor Restoration Project looking North
along the Woonasquatucket River.
             able for 223 elderly residents.
               From 1943 to 1971, Atlantic Chemi-
             cal Company (renamed Metro-Atlan-
             tic, Inc. in 1953) operated a woolens
             mill on the site. The New England Con-
             tainer Company ran incinerators on the
             site as part of its drum-reconditioning
             operation at different times from 1952
             to 1971. In 1972, a fire burned almost
             all of the existing buildings. The Brook
             Village and Centerdale Manor apart-
ments were constructed on the site
in 1977 and 1983 respectively. Di-
oxin contamination was identified in
the Woonasquatucket River, which is
        adjacent to  the site, in
        1996, and the site was
        added to the National Pri-
        orities List on February 4,
        2000.
          The Woonasquatucket
        River was designated an
        American Heritage river
        in 1998 and has been the
        focus of cleanup efforts for
        several contaminants in-
        cluding dioxin since 1996.
        To date, EPA  has com-
        pleted several initial re-
       moval actions to limit expo-
       sure to the contaminants and
       reduce  downstream migra-
tion. These actions include construct-
ing soil caps, reconstructing a dam,
and fencing off contaminated areas.
EPA continues to conduct its reme-
dial investigation for the long-term
cleanup of the site and seek assis-
tance in cleaning up the site from
other responsible parties.
  Foradditionalinformation, contact Eve
Vaudo, EPARegion 1, vaudo.eve@epa.gov.
Site  Work   Completed   at  Pioneer
Smelting
       EPA has removed 24,000 tons
       of contaminated soil and de-
       bris from the Pioneer Smelt-
ing site in Chatsworth, New Jersey.
Although no groundwater contamina-
tion was detected, concentrations of
lead in the surface soil were between

2      cleanupnews
             67 ppm and 18,200 ppm. Cleanup ac-
             tivities began in July 2003 and in-
             cluded the dismantling, decontamina-
             tion and disposal of several buildings
             and structures as well as the excava-
             tion and treatment of lead-contami-
             nated soil. An onsite pug-mill was
usedto treat 24,000 tons of contami-
nated material. 4,000 tons of waste
were sent off-site to a regulated haz-
ardous waste disposal facility.
Cleanup efforts also included recy-
cling 340 tons of scrap metal and re-
moving 300 feet of asbestos contain -
              continued on page 7

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Innovative  Cleanup  Strategies
Proposed for Nease Chemical
      EPA Region 5 is advising use
      of nanotechnology to clean up
      ground water contamination
at the Nease Chemical Site in
Columbiana County, Ohio. The
plan involves using iron
nanoparticles, which range in
size from l/500th to 1/5,000th
the width of a human hair.
Because of their microscopic
size, nanoparticles  can reach
contamination in small spaces
more effectively than some traditional
treatments. When the nanoparticles
come into contact with ground water
contaminants, oxidation occurs, pro-
ducing harmless or less toxic by-prod-
ucts. In addition to the ground water
remedy, EPA is recommending "strip-
ping/stabilization/solidification" or S/
S/S to address contamination in sev-
eral former ponds.  The process in-
volves stripping chemicals and solidi-
fying the soil using a cement-like sub-
    stance to prevent migration of remain-
    ing contaminants. The other ponds
    would be covered with plastic to pre-
    vent the spread of contaminants, and
Iron nanoparticles are a less expensive,
highly effective new treatment strategy.
These microscopic particles come into
contact with contaminants and produce
harmless by-products.
    shallow groundwater would be pumped
    and treated.  Comments on the rem-
    edies received during the public com-
    ment period, which endedin June, will
    be considered before the cleanup plan
    is finalized.
     From 1961 to 1973, Nease  Chemical
    produced household cleaning agents.
    fire retardants, and pesticides at the
    site. Some of the products contained
    mirex, a chemical banned for use in the
    US in 1978 because  of detrimental
health effects. Mirex, volatile organic
compounds, and other contaminants
seeped into groundwater and soil
from unlined ponds and leaking
    drums. In 1977, Ruetgers Organ-
    ics Corp. acquired the property.
    though the company never used
    the site.  Ruetgers has been
    evaluating on-site contamina-
    tion through EPA and Ohio EPA
    guidance and assisted both agen-
    cies in selecting the site rem-
edies. Nease Chemical has been on
the  National Priorities List since
1983.
 The proposed cleanup  strategies
are explained in a Region 5 fact sheet
entitled "'Cutting-Edge' Techniques
Proposed for  Nease Cleanup" avail-
able online at: http://www.epa.gov/
region5/sites/neasefs200506.pdf.
 For additional information, contact
Mary Logan, Remedial Project Man-
ager, (312) 886-4699.
U.S.  Army  Uses  PBC  to  Clean  Up
Hazardous Waste  Sites
By Janet Kim, U.S. Army Environmental Center s Technical Lead for PBC Implementation
      The U.S. Army is dedicated to
      cleaning up contaminated
      property from past practices
by promoting the use of safe, effective.
and efficient cleanup and procure-
ment methods. To that end, the Army
has turned to Performance-Based
Contracting (PBC) to expedite por-
tions of its remediation work.
  Under PBC guidelines, a contrac-
tor must  achieve identified cleanup
    objectives for a fixed price. PBC con-
    tractors must meet these objectives.
which are detailed in the Performance
Work Statement, as well as comply
with existing Federal Facility Agree-
ment schedules and commitments.
Contractors have an incentive to work
proficiently  and complete remedial
work on or ahead of schedule because
shorter timeframes generally trans-
late into increased corporate profits.
Most often the work is awarded to

             continued on page 4

             cleanupnews  3

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0)
o

Employee
Pleads
Guilty  to
Mail  Fraud
and   Making
False
Statement
       On May 31, 2005, Michael
       Klusaritz of Whitehall,
       Pennsylvania,  pleaded
guilty in district court  to mail fraud
and making false  statements.
Klusaritz could be sentenced to up to
30 years in prison, a $750,000 fine,
three years supervised release, and a
mandatory $300 special victim/wit-
ness assessment.
  While an employee of Boyko's Petro-
leum Services, Inc., Klusaritz falsified
laboratory reports, forged signatures.
and prepared false underground stor-
age tank (LIST) closure reports.  Be-
tween October 2001 and October 2003,
Boyko's billedits customers more than
$110,000 for the false reports.
  Klusaritz had a previous conviction
for falsifying environmental test re-
sults.
                       Army Uses PBC, continued from page 3
                       contractors at a price that is lower
                       than the Army's planned cost-to-
                       complete; as such, PBC allows
                       the Army to increase the buying
                       power of its annual cleanup bud-
                       get, which in turn accelerates the
                       overall cleanup program as cost
                       avoidances can be reinvested to
                       clean up
                       sites at
                       other in-
                       stalla-
                       tions.
                         Regu-
                       lators
                       also
                       benefit
                       under PBC. For example, benefits
                       to regulators include streamlined
                       and consistent documentation
                       produced by "A-team" contractors
                       who have an incentive to finish
                       the cleanup work rapidly and cor-
                       rectly. Regulators also have the
                       confidence of knowing that the
                       Army maintains ultimate liabil-
                       ity for the remediation.
                         While PBC may be used in
                       privatization projects, it is not a
                                                By using PBC, the Army has procured
                                                more than $400 million in environmental
                                                requirements and achieved a cost
                                                avoidance of approximately 20 percent
                                                while safely conducting cleanup.
privatization effort. The Army uses
these contracts on land that will be
turned over to local authorities as well
as land the Army will retain for its own
use. The Army piloted the program at
several installations in Fiscal Years
2000 and 2001. To date, almost 50 PBC
contracts, covering projects in all 10
                   EPA regions,
                   have been
                   awarded for
                   work at Base
                   Realign-
                   ment  and
                   Closure
                   (BRAG)
                   sites and ac-
tive installations. By using PBC, the
Army has procured more than $400
million in environmental requirements
and achieved a cost avoidance of ap-
proximately 20 percent while safely
conducting cleanup.
  PBC provides advantages to the
three main parties involved in con-
tracted environmental remediation
projects — the Department of Defense,
regulators and contractors.
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Syosset   Landfill   Deleted  from
National   Priorities   List
        On April 28, 2005, EPA re-
       moved the Syosset Landfill
       Superfund site in Nassau
County, New York from the National
Priorities List (NPL) because the site
no longer poses a threat to human
health or the environment. The Town
of Oyster Bay worked with EPA to
design and install a synthetic land-
fill cap, a project that was completed
in October 1996. The cap covers 6.7
million tons of contaminated mate-
rial left onsite. The town also im-
proved the existing  gas venting sys-
tem in order to lower landfill gas emis-
           sions to non-detectable levels. EPA
           certified that construction for the
           cleanup was complete at the site in
           September 1998. A fence was in-
           stalled around the perimeter of the
           property and restrictions put in place
           to prevent human exposure to the
           capped landfill material.
            The Town of Oyster Bay operated
           Syosset Landfill  from 1933 to 1975.
           Various types of wastes  were dis-
           posed at the site, including industrial
           sludges contaminated with heavy
           metals. The landfill stopped accept-
           ing waste when Nassau County de-
tected ground water contamination.
At the time the site was listed on the
NPL, two private wells and one public
well had elevated levels of volatile or-
ganic compounds. Although the town
of Oyster Bay continues monitoring
the local ground water, EPA deter-
mined  that  no  ground  water
remediation was necessary because
limited offsite contamination did not
pose a threat to the surrounding com-
munity.
  For additional information, contact
SherrelD. Henry, Remedial Project Man-
ager, henry.sherrel@epa.sov.
EPA  Outlines  Strategies  for  Ensuring
Post  Construction  Completion
Activities  are Effective
0)

   In May 2005, the Office of Solid
   Waste and Emergency Response
   (OSWER) released its recommen-
dations for ensuring the long-term ef-
fectiveness of post con-
struction completion
activities at Superfund
sites. The draft docu-
ment, entitled  "Na-
tional  Strategy to
Manage Post  Con-
struction Completion
Activities at Superfund
Sites" (PCC Strategy),
has been sent to stake-
holders for review and
may be revised based on comments
received. The final strategy should be
released in late summer 2005.
 After a site remedy is constructed.
post construction completion activities
are sometimes implemented to ensure
that the remedy remains protective of
human health and the environment
(e.g., site fencing) or to achieve greater
           protection levels (e.g., ongoing ground-
           water treatment). Post construction
           completion activities include, but are
           not limited to, operation and mainte-
           nance, five-year reviews, institutional
Five goals of the draft PCC Strategy
 *  ensure that remedies remain protective and cost-effective
 *  ensure that institutional controls required as part of the remedy are
   implemented and effective
 *  assure adequate financing and capability to conduct post
   construction completion activities
 *  support appropriate reuse of sites while assuring remedy reliability
 *  improve site records management to better ensure remedy reliability
           controls (ICs), NPL deletion, and re-
           use. The PCC Strategy outlines five
           goals for ensuring post construction
           completion activities are effective.
           First, EPA is encouraging the review
           of remedies overtime and to allow for
           changes in remedy decisions where
           appropriate to achieve protection and
           cost-effectiveness.  EPA is also rec-
ommending the review of ICs to en-
sure they give long-term protectiveness
and are not so restrictive as to pre-
vent redevelopment of a site, where
feasible. With regard to funding, EPA
                will see that po-
                tentially  re-
                sponsible  par-
                ties (PRPs) ful-
                fill their O&M
                re sp on sibilitie s
                and that  the
                states—who are
                often respon-
                sible for guaran-
                teeing that long-
term O&M occurs at Fund-financed
sites—have long-term O&M funding
available.  EPA will also support site
reuse by ensuring that unnecessary
barriers to reuse are eliminated and
encouraging the use of "Ready for Re-
use" determinations, easy-to-read re-
ports that notify developers of a site's

               continued on page 7
              cleanupnews  5

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o
 0)

District Court
Recognizes
Private Party
Contribution
Claim Under
Section 107 of
CERCLA
Adobe Lumber v. Taecker, (No. CVS02-
186 GEE GGH, E.D. Ca.  (May 24, 2005).
By David Dowton, Office of Site Remediation
Enforcement

  Ruling on cross-motions for partial
summary judgment, the district court
for the  Eastern District of California
has recognized that a private party
may bring a contribution action under
Section 107 of CERCLA.  After dis-
missing Adobe's claim under Section
113 as  Adobe had not been the sub-
ject of a civil action under Sections 106
or 107  as required under Cooper In-
dustries, Inc. v. Aviall Services, Inc. (125
S. Ct. 577 (2004)), the Court went on
to address whether Adobe could bring
a claim under Section 107. The dis-
trict court found that Adobe could not
proceed on a claim for joint and sev-
eral liability under Section  107 but
noted that Adobe is not prevented
from pursuing a recovery action on
some form of liability other than joint
and several.
  The Court  started its analysis by
pointing out that the Supreme Court
in Aviall did not rule on whether con-
tribution  is available for a private
party under Section 107 and therefore.
Ninth Circuit precedent governs. The
Court turned to the Ninth Circuit's
decision in Final Creek Group v.
Newmont Mining Corp. (118 F.3d 1298
(1997)), where the Ninth Circuit found
that "the essence of a claim for contri-
bution ... is imbedded in the text of §
107." This was further explained by
the Ninth Circuit in Western Proper-
ties Service Corp. v. Shell Oil Co. (358
F.3d678). Quoting Western Properties
the district court wrote, "Final Creek
held that the enactment of § 113 in
1986 did not replace the implicit right
to contribution many courts recog-
nized in § 107(a); rather, § 113 deter-
mines the 'contours' of § 107, so that a
claim for contribution requires the
rjoint operation'  of both sections."
Based on this Ninth Circuit precedent.
the district court  denied defendant's
motion for partial summary judgment
finding that in the  wake of Aviall.
Adobe's Section  107 claim is con-
strued as it was before the enactment
of Section 113.  The district court.
however, also denied Adobe's motion
as it did not address all the elements
of a Section 107 contribution claim.

Second Circuit
Acknowledges
Dilemma for
Parties Seeking
Contribution
under CERCLA for
Voluntary
Cleanup Costs
Syms v. Otin, 2005 U.S. App. LEXIS 8885
(2™1 Cir.  2005).

By David Dowton, Office of Site Remediation
Enforcement

  Finding that plaintiffs had not been
sued under Section 106 or 107 of
CERCLA, the Second Circuit ruled
that plaintiffs were not eligible to seek
contribution under Section 113(1) pur-
suant to the Supreme Court's decision
in Cooper Indus, v. Aviall Servs. (125
S. Ct. 577 (2004)). The Court, how-
ever, remanded to the district court the
issue of whether a liable party may
bring an action under Section 107(a)
to recover costs.  The Second Circuit
hadpreviously ruledin Bedford Affili-
ates v. Sills (156 F.3d 416 (1998J) that
a liable party may not bring a cost
recovery action under Section
107(a) but notedthat the rule put
forth in Bedford might no longer
be viable in light of the Supreme
Court's ruling in Aviall.
  In a lengthy footnote, the Court
acknowledged the dilemma cre-
ated by the Supreme Court's de-
cision in Aviall and the  Second
Circuit's  previous ruling  in
Bedford.  The Court noted that
together the two decisions "leave
a PRP with no mechanism for re-
covering response costs until pro-
ceedings are brought against the
PRP. This might discourage PRPs
from voluntarily  initiating a
clean-up, contrary to CERCLAs
stated purpose." The Court went
on to say that a PRP  that
remediates a facility on its own
initiative reduces the likelihood
that it will be the subject of a Sec-
tion 106 or 107 action and thereby
jeopardizes its opportunity  to
seek contribution from other
PRPs. The Court concludedin the
footnote  that if the Bedford deci-
sion remains unchanged it would
"create a perverse  incentive for
PRPs to  wait until they are sued
before incurring response costs."
  Although the Court acknowl-
edged the dilemma parties like
the plaintiffs face, they declined
to rule on whether the Bedford
decision  is still viable in light of
Aviall due to the fact that Aviall
was decided after oral argument
was held and the parties did not
have an  opportunity to brief the
issue.   Therefore, the Court
elected to vacate the judgment and
remand the issue to allow the dis-
trict court an opportunity to ad-
dress the plaintiffs' eligibility to
sue under Section 107(a)  of
CERCLA.
  For additional information, con-
tact David Dowton, OSRE,  (202)
564-4228.
                    cleanupnews

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Partners with
Expertise in
Sustainable
Development
Sought for  ER3
  The Office of Site Remediation En-
forcement (OSRE) is organizing a net-
work of organizations with sustainable
development expertise as part of the
Environmentally Responsible Rede-
velopment and Reuse (ER3) Initiative.
OSRE announced the plan to form the
network in an April 22, 2005 Federal
Register notice. ER3,  an effort to en-
courage sustainable redevelopment of
former  contaminated  sites, was
launchedin September 2004. The en-
visioned ER3 partner network will in-
clude non-profit organizations, univer-
sities, and other entities that will pro-
vide assistance to redevelopers wish-
ing to incorporate conservation-
minded practices. Partners have  to
have experience in various areas of
sustainable development such as the
use of renewable resources for energy,
reduction of pollution and energy use,
and the promotion of recycling.  Par-
ticipating entities will not be given fi-
nancial compensation  by EPA for the
assistance they provide.  They may
choose, however, to contract for paid
services to incorporate recommenda-
tions into a project design.
  Organizations wishing to participate
were asked to submit  statements of
interest by June 22, 2005.  These in-
clude details on their qualifications to
help redevelop contaminated land
with sustainable methods. OSRE will
select partners in the weeks following
the deadline and post its partners on
the ER3 website at: www.epa.gov/com-
pliance/cle anup/re develop/er 3/
  For additional information, contact
Phil Page, Office of Site Remediation
Enforcement, Dase.Dhil@eDa.sov.
Pioneer Smelting, continued from page 2

ing material.
The facility was built in 1939 by the
New   Jersey
Zinc Company,
which
conducted zinc
smelting and
metal
reclamation
activities  at
the      site.
Several
entities owned
the   facility
prior  to its
purchase  by
the  Pioneer
Smelting
Company  in
1973.  The facility was used by
several lessees for various recycling
and metal recovery operations until
it was abandoned in 1996.  In June
2001, the New Jersey Department of
Environmental Protection (NJDEP)
responded to  a fire  and  found
hundreds of deteriorating drums and
a massive slag pile. NJDEP asked
EPA to conduct an assessment of the
site,  and  in July 2002,  EPA's
Emergency   Response    Team
conducted an Expedited Removal
Assessment.
  The site is located within the New
Jersey pinelands, and there was evi-
                  dence of public use prior to cleanup in-
                  cluding motorcycle and all-terrain ve-
                  hicle tracks. Access to the site contin-
                  ues to be restricted although the con-
                  tamination  and structural hazards
                  have been abated. Future site use is
                  under consideration by  the current
                  owner, local government, and EPA at-
                  torneys.
                    Additional information is available on
                  the EPA's On-Scene Coordinator website at:
                  http://www.epaosc.org/
                  site Drofik.asp?site id=SJ.
Aerial view of Pioneer Smelting prior to site cleanup.
                  EPA Strategies,  continued from page 5
                  status.   And EPA is recommending
                  improving recordkeeping through stan-
                  dardizing recordkeeping procedures
                  and managing data electronically.
                    The draft PCC Strategy is available
                  on Superfund's Post Construction Com-
                  plete web site at:
                    http://www.epa.gov/superfund/action/
                  postconstruction/index.htm.
                    For additional information, contact Tracy
                  Hopkins, OSRT1, hopkins. tracy@epa. sov.
                                                                                      deanupnews   7

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     July 12-15, 2005
     2005 Community Involvement
     Conference and Training
     http ://www. epancic, org/2005/
     overview.cfm
     Buffalo, NY

     August  7-10, 2005
     College  &  University Hazardous
     Waste Conference
     http://center.uoreqon.edu/ronferences,
     September 19-23, 2005
     20th Annual Hazardous Materials
     Management Conference  on
     Household & Small Business
     Waste
     http://www.nahmma.orQ/
     2005conference/
     November 2-4, 2005
     Brownfields 2005
     http://www.brownfields2005.org/en/
                                                                   Glossary
  BRAG     Base Realignment and Closure

  EPA     Environmental Protection Agency

  CERCLA   Comprehensive Environmental
          Response, Compensation, and
          Liability Act

  DOD     Department of Defense

  ER3     Environmentally Responsible
          Redevelopment and Reuse

  ICs      Institutional controls

  NPL     National Priorities List

  O&M     Operation and maintenance
  cleanupne
CleanupNews is a quarterly publication of
EPA's Office of Site Remediation Enforcement,
in cooperation with the Office of Superfund
Remediation and Technology Innovation, Office
of Underground Storage Tanks, and Office of
Emergency Prevention, Preparedness and
Response. Past issues of CleanupNews can
be found at http://www.epa.qov/conipliance/
resoiirces/iiewsletters/deaniip
deaiuipnews.htnii
  OECA     Office of Enforcement Compliance and
          Assurance

  OSRE     Office of Site Remediation Enforcement

  OSWER    Office of Solid Waste and Emergency
          Response

  PBC      Performance-Based Contracting

  PCC      Post construction completion

  PRPs     Potentially responsible parties

  USAEC    US Army Environmental Center

  UST      Underground storage tank
^^^ww,epa.gov/compliance/abouVoffices.'.>. -.

Richard W. Popino, PhD REM, Editor in Chief

EPA Review Board; Diane Bartosh, Sandra Connors,
Karen Ellenberger, Elliott Gilberg, Jeff Heimerman,
Kenneth Patterson, Neilima Senjalia, Suzanne Wells

Christine Rueter and Cheryl Mueller,
DPRA Inc., writers
Mary Spencer,
DPRA Inc., designer
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To comment on the newsletter contact Richard W. Popino, PhD REM, at MC-2271A, U.S. EPA, 1200 Pennsylva-
nia Ave., NW, Washington, DC 20460, emaihpopino.rick® epa.gov.

To be added or deleted from the subscriber list, contact Christine Rueter at christine.rueter@dpra.com.

To receive CleanupNews by email, subscribe at http://www.epa.gov/compliance/resources/listserv/
cleanup.html.
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