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
-------
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
-------
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
-------
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
ml
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/
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