Office of Site Remediation
                               Enforcement (2271 A)
                               Washington, DC 20460
                                 Spring 2005
                                 Issue #20
    United States
    Environmental Protection

Notable Achievement Awards

1C Strategy

Plymouth State Fines

Triad Approach
Southeast Federal
Center Remedy

In the Courts
Cooper v. Aviall Update
Companies Fined

Hazardous Waste Rules
Call for Presentations

CleanupNews is a quarterly
newsletter highlighting hazardous
waste cleanup cases, policies,
settlements and technologies.
                                 Bush  Selects  Johnson
                                 as  Administrator
         President George W. Bush announces Stephen Johnson as his
         nominee for EPA Administrator in the Roosevelt Room at the
         White House Friday, March 4, 2005.
              Current Acting EPA Ad-
              ministrator  Stephen
              Johnson has been se-
        lected for the permanent post by
        President Bush.  At the March
        4th nomination announcement at
        the White House, the President
        described Johnson as "a talented
        scientist and skilled manager
        with a lifelong commitment to en-
        vironmental stewardship" and
        welcomed his experience as a sci-
        entist in helping "set clear, ratio-
        nal standards for environmental
        quality." In his remarks, Johnson
        said that he was "deeply honored"
        by the nomination.  He also ac-
        knowledged the contributions of
former Administrators Michael
Leavitt, now head of Health and
Human Services,  and Christine
Todd Whitman.
 If confirmed by the Senate,
Johnson would be the first EPA
employee to become Administrator.
In his 24 years of service with the
Agency, he has held a number of
posts, including Deputy EPA Ad-
ministrator and Assistant Admin-
istrator of EPAs Office of Preven-
tion, Pesticides, and Toxic Sub-
 Johnson's biography is available
administrator/biography .htm.
        EPA  Marking  35th
        Anniversary  of  Earth  Day
                                    In a 1980 EPA Journal ar-
                                    ticle,  Senator  Gaylord
                                    Nelson, Earth Day founder,
                                 said his main motivation for cre-
                                 ating Earth Day "was to show the
                                 political leadership of the Nation
                                 that there was broad and deep sup-
                                 port for the environmental move-
                                            continued on page 3
                                                                           & Printed on recycled paper

2005  National  Notable  Achievement
Award  Winners  to  be  Honored

       The  Office  of  Superfund
       Remediation and Technology
       Innovation has announcedthe
winners of the 2005 National Notable
Achievement Awards. The recipients
will be honored in a ceremony at 1:30
pm at the Crystal Plaza Hotel in Crys-
tal City, Virginia on April 27, 2005.
Award winners will receive a cash
award and plaque.
  The Notable Achievement Awards
acknowledge individual and collabo-
rative  Regional achievements in:
Brownfields, Emergency Manage-
ment, Superfund, Superfund Enforce-
ment, RCRA Corrective Action.
Regional  Science, Underground
Storage Tanks, Federal Facilities
Response, Environmental Justice.
Cross Program Land Revitaliza-
tion,  and  Resource Conservation
Challenge.  Here are  some high-
   would bring an enforcement action. For
   the GE-Pittsfield Site, he revised the
   consent decree's model deed restric-
   tions to facilitate redevelopment while
   protecting human health and the envi-

    Superfund - Technical Enforcer
    Technical Enforcer of the Year Carlyn
   Winter Prisk of Region 3's Hazardous
   Site Cleanup Division.  Carlyn is in-
   volved in all parts of enforcement, in-
   cluding PRP investigations and settle-
   ment negotiations. She has effectively
   used ability to pay evaluations to in-

 The winners of the Enforcement
  Team award used mediation to
 achieve a consent decree for the
  Tennessee Products Superfund
Site worth more than $23 million.
  Superfund - Legal Enforcer
  Each year, the Agency gives four
awards for Superfund Enforcement:
Legal Enforcer, Technical Enforcer.
Financial Management, and Enforce-
ment Team.  This year's Legal En-
forcer award will be presented to John
Kilborn of Region 1's Office of Envi-
ronmental  Stewardship,  Superfund
Legal Office. John used his real es-
tate expertise to assist with the rede-
velopment  of the Raymark Site in
Stratford, Connecticut, including en-
couraging a local bank to use "green
building" principles when construct-
ing a new branch on the former site.
He also crafted a "comfort letter" to
municipalities that were concerned
about converting former railroad
tracks to bike trails for fear that EPA
   vestigate potentially responsible par-
   ties (PRPs). For the AIW Frank Site,
   Carlyn discovered that the PRP was
   gambling significant sums of money
   while asserting an inability to pay EPA
   for costs at the site. In addition, Carlyn
   helped identify PRPs to the Maryland
   Sand Gravel & Stone Site and negoti-
   ated a consent decree worth over $20

    Superfund - Financial Manage-
   ment Team
    The Region 3 Special Accounts Man-
   agement Team—Laura Janson, Bar-
   bara Borden, Linda Baric, Leslie
   Vassallo, Millie DeLeon-Ramos, Robin
   Faux—will receive the Financial Man-
   agement Team of the Year Award for
   reviewing all Region 3 special accounts.
   with a combined worth of $54 million.
Special accounts are Superfund sub-
accounts containing settlement money
to be used at particular sites, and in
some cases money remains unused in
accounts. The team held site-specific
meetings for each account, identified
more effective ways to manage the
accounts, and produced comprehen-
sive site-by-site analysis.  They iden-
tified 24 out of the 32 accounts re-
viewed that could be paid down, for a
payroll benefit of nearly $1 million.
They also developed procedures for
managing special accounts that can
be adopted by other Regions.

    Superfund - Enforcement
    The winners of the Enforcement
  Team Award accomplished a con-
  sent decree for the Tennessee Prod-
  ucts Superfund  Site in Chatta-
  nooga, Tennessee worth over $23
million. The consent decree requires
the potentially responsible parties to
perform the remedy and  reimburse
EPA for some of its past costs.  The
team members from EPA Region 4—
Nestor Young, Janice Thomas, Cheryl
Smout, Kent Mayo, William Sapp.
and Stacey Haire—were able to con-
vince the defendants to settle because
they assembled and presented com-
pelling evidence in the negotiations.
The team, assisted by David Batson
of EPA's Conflict Prevention and Reso-
lution Center, also effectively used
alternative dispute  resolution to ne-
gotiate the consent decree, thereby
affording lengthy and costly litigation.

  For additional information, contact
Dr.  Richard W. Popino,  (202)  564-

Earth Day, continued from page 1

ment."  Reflecting back on that first
Earth Day, April 22, 1970, and the
nearly 20 million people that partici-
pated, Nelson said that even he was
surprised by the overwhelming public
  Today, several hundred million par-
ticipants from over 100 countries join
in Earth Day activities each year, from
cleanup efforts to environmental film
festivals.  If you are interested in a
volunteer opportunity or participating
in an Earth Day event, the Earth Day
Network, available online at:  http://
searchEvent.aspx, offers an extensive
list of US and international events.
  EPA will be involvedin many events
across the United States.  EPA Re-
gion 3 and the Fairmount Park Com-
mission will host a special 35th An-
niversary Earth Day Celebration in
Center  City, Philadelphia.  The edu-
cational event, featuring regional en-
vironmental organizations and inter-
active exhibits, will take place in Love
Park (15th and JFK Boulevard) be-
tween 10 am and 2 pm on April 22,
2005.   For additional information,
contact  Jordan  Parman   at  And EPA
       Earth Day founder Gaylord Nelson (right) with Administrator
       William K. Re illy, Earth Day 1990.
Region 2 will present its Environmen-
tal Quality Awards honoring individual
and group achievements in late April.
Information regarding the awards is
available at:
    Earth Day Resources

       EPAs Earth Day website at: provides
       a variety of information resources.
       EPAs Superfund Office has a kids Earth Day page with a recom-
       mended reading list at:
       Region 5 has a "Happy Earth Day Coloring and Activities Book,"
       US Army Environmental Center's Earth Day website at: http:// offers educa-
       tional materials, including a "disaster cleanup exercise."
Institutional  Controls   Implementation
Strategy  Announced
       The    Office   of   Site
       Remediation Enforcement,
       the Office  of Superfund
Remediation and Technology Innova-
tion and the 10 EPA Regional Offices
have launched a nationwide effort to
review institutional controls (ICs) at
all Superfund sites where remedy con-
struction activities have been com-
pleted. ICs are non-engineeredinstru-
ments,  such as administrative and
legal controls, that help minimize hu-
man exposure to contamination and
protect the integrity of the remedy. The
offices and Regions announced a strat-
egy to review ICs in a September 2004
memorandum, "Strategy to Ensure In-
stitutional Controls Implementation at
Superfund Sites."  The strategy calls
for identifying.priority sites with poten-
tial 1C issues and developing Region-
specific action plans;  outlines site-spe-
cific follow-up activities; establishes a
new 1C coordination  and communica-
tion structure; and describes steps to
improve EPAs capacity for evaluat-
ing 1C effectiveness. Through a com-
bination of priority reviews and regu-
larly scheduled Five-Year Reviews,
EPA anticipates a five-year schedule
to evaluate all potential 1C issues at
Superfund sites where remedy con-
struction activities are complete.
  Recently, EPA has imp roved its ap-
proach to ICs by issuing guidance,
               continued on page 4

              cleanupnews   3

Controls,  continued from page 3
adding IC-related language to model
documents (e.g., the Model RD/RA
Consent Decree), developing the Insti-
tutional  Controls Tracking System
(IGTS), identifying both program and
legal 1C coordinators for each region.
and forming the national Management
Advisory Group for ICs. These im-
provements, however, have tended to
benefit recently remediated sites. The
strategy ensures that sites addressed
earlier in the Superfund program also
receive the benefit of subsequent 1C
experience. Because 1C information
at older sites is sometimes not  cen-
tralized  or reliable, EPA gathered
baseline information about ICs at 899
construction complete sites, and iden-
tified and prioritized sites where 1C
implementation either had not oc-
curred or might have been per-
formed incorrectly.
  EPA expects that evaluation and
corrective measures will be initiated
at priority sites within one year af-
ter issuance of the strategy. EPAis
also working on improving 1C use
and ensuring that all construction
completion sites are critically evalu-
atedin the next five year review and
all sites  in the future receive ad-
equate 1C evaluations. In FY 2005.
EPA plans to supplement the five-
year review and operation and main-
tenance plan guidance, provide fo-
cused training on ICs and ICTS, and
conduct outreach activities to in-
volve other parties in identifying
and resolving IC-related issues. EPA
has also begun developing guidance
for Institutional Controls Implemen-
tation and Assurance Plans, devel-
oping guidance for calculating the full
life-cycle costs of ICs,  and revising
model CERCLA and RCRA enforce-
ment documents to reflect new 1C
  The memorandum outlining the
strategy  is available at http://

  For additional information, contact
K.C. Schefski,  OSRE, (202) 564-8213
or Michael E. Bellot, OSRT1, (703)
Plymouth  State   University   Fined  for
Hazardous   Waste  Violations
      EPA has proposed penalizing
      Plymouth State University
      $171,050 for hazardous waste
violations observed during a June 2003
inspection. Through the inspection.
EPA found that the university was not
making hazardous waste determina-
tions or properly storing waste. There
was also a lack of "no smoking" signs.
and spill and fire control equipment
were not maintained.
  Universities and colleges typically
store hazardous waste for use in labo-
ratories and  university operations.
Region 1 has been aggressively iden-
tifying college non-compliance and en-
couraging schools to conduct self-au-
dits through its College and Univer-
sity Initiative, an initiative that re-
cently closed. Schools in the Region
can still take advantage of EPAs
Audit Policy to ensure that they are
meeting all federal requirements.
  For additional information, contact
Sheryl Rosner, EPA Region 1, (617)
918-1865or rosner.shervl@eDa.sov.
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  change requests to

Triad  Approach   Streamlines  Site
Activities   and   Reduces   Costs
By Ann Eleanor, Office ofSuperfund Remediation and Technology Innovation

      EPA's waste programs, and a
      number of other practitioners
      in the waste cleanup commu-
nity, are exploring the Triad approach
to site cleanup. Triad replaces the tra-
ditional prescriptive approach to site
characterization, cleanup, and moni-
toring with a more dynamic and com-
prehensive approach that is flexible
and recognizes site-specific decisions
and data needs. This approach incor-
porates advancing science, technology.
and lessons-learned from the field.
EPA's Technology Innovation Program
minedpractitioner experiences for tech-
niques leading to successful, effi-
cient  and less expensive remedial
projects. The Triad approach was
assembled around the common
factor that made projects success-
ful: management of all sources of
uncertainty in project data.
  The three elements of Triad—sys-
temic project planning, dynamic work
strategies, and real-time measure-
ment technologies—are integrated to
attain more efficient and affordable
project management.  By including 'if-
then'  approaches, scientifically sound
site models can be developed and cor-
rected in real-time, streamlining site
activities and cutting life-cycle costs
and lifespan by a third or more. Sys-
   tematic planning keeps all concerned
   parties informed, involved, and fo-
   cused on project objectives through-
   out the cleanup process.
    Triad was used successfully for the

 The Navy estimates it saved $2.5
 million using the Triad approach
for a chlorinated solvent source
 investigation at Camp Pendleton.

   Milltown Redevelopment Project for
   the New Jersey Department of Envi-
   ronmental Protection. Through sys-
   tematic planning, stakeholders were
   continuously involved which enabled
   efficient resource distribution be-
   tween planning phases, and the
   sample collection phase was stream-
   lined. EPA's Environmental Re-
   sponse Team used a freeware data-
   base decision-support tool to manage
data and direct real-time sampling for
organic compounds and metals. After
more than a year of planning, the ac-
tual field work took only eight weeks.
The redevelopment company is very
pleased with the Triad approach and
the time saved. The continuously-re-
fined conceptual site  model has al-
lowed the developer to re-examine site
reuse and efficiently align reuse de-
signs with site conditions.
  For a chlorinated solvent source in-
vestigation at Camp Pendleton Ma-
rine Corps Base, this approach helped
manage  decision uncertainty and ex-
   pedite the site management pro-
   cess. Direct-push deployed in situ
   sensors provided real-time, high-
   density data sets to delineate sub-
   surface contamination, confirming
   a very small solvent mass that
   regulators readily agreed posed no
threat to receptors.  The Navy esti-
mated that Triad saved $2.5 million
and cut the project schedule by three
  Additional information on Triad is
available through the Triad Resource
Center at:
The center contains a growing selec-
tion of resources for design, implemen-
tation, and legal defensibility of the
Triad approach.
EPA  Proposes  Groundwater  Remedy
for  Southeast  Federal  Center
      EPA is proposing long-term
       treatment and monitoring of
       groundwater and institu-
tional controls preventing use of
groundwater for drinking water for the
Department of Transportation par-
cel of Southeast Federal Center. The
proposed remedy will eventually re-
store groundwater at the site to drink-
   ing water standards. Drinking water
   is currently pumped in from a local
    The Department of Transportation
   (DOT) parcel constitutes 11 acres of
   the 55-acre Washington Navy Yard.
   a former military ordnance produc-
   tion site on the Anacostia River in
   DC that is being cleaned up and rede-
veloped. Construction of a new 1.35-
million-square-foot DOT headquarters
at the site began in 2004, following the
excavation and removal of contami-
nated soils. The building is scheduled
to open in 2006.
  The public comment period for the
proposed remedy ends March 28, 2005.

              cleanupnews   5

District Courts  Digest  Cooper v. Aviall  Ruling
By David Dowton, Office of Site Remediation Enforcement

        On December 13, 2004, the
        Supreme Court  held in
        Cooper Industries v. Aviall
Services 125 S. Ct. 577, that the plain
language  of CERCLA  Section
113(f)(l) allows a potentially respon-
sible party to  seek contribution only
"during or following" a "civil ac-
tion" under CERCLA Sections
106 or 107(a).  Two recent district
court decisions cited the Supreme
Court's decision when  denying
private party claims to recover
cleanup costs.
  In AMWMat'ls Testing, Inc v. Town
of Babylon, 348F.Supp.2d4 (E.D.N.Y,
2004), the district court denied AMW
and the property owner's claim to re-
cover costs from the cleanup of haz-
ardous substances discovered after a
fire in AMWs  paint room. The plain-
tiffs argued that the Town and local
fire department were liable as opera-
tors under CERCLA.  The plaintiffs
asserted causes of action under
   CERCLA Sections 107 and 113 and
   certain common law theories.  The
   court held that the plaintiffs: (1) had
   not offered material evidence that the
   defendants were CERCLA operators;
   (2) could not bring a claim under Sec-
   tion  107 because they were not inno-

Two recent New York District
Court  decisions cite Cooper v.
Aviall  when denying private party
claims to recover cleanup  costs.

   cent parties; and (3) pursuant to Aviall,
   could not bring a contribution claim
   under Section 113 because they had
   incurred cleanup costs voluntarily and
   in the absence of "judicial or adminis-
   trative measures to compel cleanup."
     The Southern District of New York
   reached the same conclusion on the is-
   sue of whether a liable party can bring
   a claim under Section 107. In Elementis
   Chenis., Inc. v. TH Agriculture & Nutri-
tion, 2005 U.S. Dist. LEXIS 1404
(S.D.N.Y., 2005), the district court
found that  Elementis could not
bring a claim under Section 107 to
recover costs it had incurred per-
forming a voluntary cleanup. Fol-
lowing the Supreme Court's Aviall
  decision, the Plaintiff acknowl-
  edged in  a supplemental brief
  that it could not recover its vol-
  untary costs  under Section
  113(f) because it had not been
  subject to a Section 106 or 107
  action. Elementis maintained.
however,  its claim under Section
107, arguing that the Aviall deci-
sion effectively overruled prior Sec-
ond Circuit  case law holding that
a liable party could not bring such
a claim. The Court disagreed and
held that Elementis had no valid
CERCLA claim under Section 107.
 For additional information, con-
tact David Dowton, OSRE,  (202)
Companies Fined for Violations  of RCRA Order
A        group of current and former
        owners of a south Seattle.
        Washington industrial site
will be required to pay $720,250 to
EPA for the failure to abide by  the
cleanup terms of a 1993 Administra-
tive Order. This industrial site manu-
factured and processed a wide variety
of chemicals until closing in April
1991. From the 1930s through 1986,
chemical products were manufactured
at the site including glues, resins, and
hardeners. Beginning in 1952, the fa-
cility was usedto make vanillin, which
is used in flavoring foods and manu-
facturing drugs.  These  manufactur-
ing processes have resulted in a long
history of above and below ground re-
leases of contaminants such as tolu-
    ene, arsenic, cadmium, copper, mineral
    oil, sulfuric acid, and other pollutants.
    Sampling at the site has detected con-
    tamination of groundwater flowing
    into the Lower Duwamish  River, a
    Superfund site.
     The group of companies which in-
    clude the current site owner Container
    Properties LLC., as  well as Bayer
    CropScience (the successor of Rhone-
    Poulenc Inc.) and Rhodia, Inc.,  were
    required by the 1993 Administrative
    Order, issued under the authority of
    the Resource Conservation and Recov-
    ery Act, to  follow a work plan to con-
    struct and operate facilities to prevent
    contaminants from entering the Lower
    Duwamish River. The companies
    failed to comply with several require-
ments of the Order, including failing
to construct the approved groundwa-
ter treatment system and to conduct
sampling in accordance with the ap-
proved Work Plan. EPA will now con-
sider each company  as a Significant
Non-Complier, a term usedto identify
chronic violators or those who deviate
substantially from the terms of an or-
der. In both 1998 and 2000, the same
companies paid penalties of $320,000
and $159,500, respectively, for failing
to conduct required cleanup work at
this site.
  For additional information, contact
Shawn Blacker,  EPA Region  10,
b locker. shawn@epa. sov.

Two  New  Hazardous  Waste  Rules Finalized
By Diane Bartosh, Office of Solid Waste

Hazardous  Waste Manifest

  On January 27, 2005, EPAimproved
the tracking of hazardous waste ship-
ments by establishing a nationally
standardized manifest form. This new
form makes  the nation's hazardous
waste tracking system more efficient
by replacing differing state formats
with one national form. This stream-
lined approach will benefit waste han-
dlers and regulators by reducing the
costs and time  associated with man-
aging multiple forms, while maintain-
ing the safety of EPA's well-estab-
lished  cradle-to-grave hazardous
waste tracking system.
  EPA estimates the change in paper-
work burden resulting from  this rule
will save states and industry between
$12-20 million  annually.  More than
139,000 businesses in approximately
45 industries are expected to achieve
time and cost efficiencies through the
new tracking system.  These  busi-
nesses ship approximately 12 million
tons of hazardous wastes annually and
use between  2 and 5 million Hazard-
ous Waste Manifests.
  By using a streamlined and consis-
tent national standard, hazardous
waste handlers can better track com-
plicated shipments, such as container
residues, rejected wastes and  inter-
national shipments.  The new form
also makes it easier to collect data
for hazardous waste reporting. The
new form will be phased in over an
18-month transition period. Once the
new form is in place, handlers will be
able to obtain new forms from any
source that has registered with EPA
to print and distribute them. The rule
was published in the Federal Register
March 4, 2005. More information is
available  at:
Some Dye and Pigment Pro-
duction  Waste  Is Listed as

  In a final rule signed on February
15, 2005, EPA took steps to better
protect ground water resources and
human health by  listing  certain
wastes generated by  the dye, pig-
   Call  for  Presentations  for
   Brownfields  2005
           rownfields 2005 will be held in Denver, Colorado, Novem-
           ber 2-4. Conference co-sponsors EPA and ICMA are seek-
           ing suggestions for presentations, sessions, marketplace
    roundtables, and best practice case studies. Ideas can be submitted
    online, or there is a "Call for Presentations"  form that can down-
    loaded at: The
    submission deadline is April 29, 2005.
ment, and food, drug and cosmetic in-
dustries as hazardous waste K181.
While listed hazardous waste must be
strictly managed under Subtitle C of
the Resources Conservation and Recov-
ery Act (RCRA), the Agency is using a
flexible regulatory approach that fo-
cuses on total quantities of chemical
constituents of concern in a waste that
present the greatest risk. The K181
listing focuses on seven hazardous con-
  Waste that  contains less  than the
specified threshold levels of constitu-
ents of concern are not hazardous (e.g..
aniline levels below 9,300 kg/yr). More-
over, regulatory exemptions are pro-
vided for waste either sent for disposal
in landfills that meet  specific design
standards or treated in  an  approved
combustion unit. Waste that does not
qualify for these exemptions, and that
meets or exceeds the specified thresh-
olds for any of the specific constituents
of concern, must be managed as listed
hazardous waste K181. These dye and
pigment classes are commonly used for
coloring  textiles,  paper,  plastics.
leather, inks, paints/coatings, food.
drugs, and cosmetics.  EPA estimates
that  about 36 facilities annually gen-
erate about 36,000 metric tons of po-
tentially affected waste. This rule was
published in the Federal Register on
February 24, 2005.
  This regulation is a major milestone
for EPA because it is the final action
resulting from a lawsuit filed by the
Environmental Defense Fund (now En-
vironmental Defense) in 1989.  The
lawsuit was filed to enforce  EPA's le-
gal deadlines under the 1984 Hazard-
ous and Solid Waste Amendments for
listing hazardous waste. Additional
information is available online at:
                                                                                    cleanupnews   7


April 13, 2005
Waterfront  Redevelopment
Conference and Deal Flow
New York, NY

April 20-21, 2005
ASTSWMO Mid-Year Meeting
Keystone, CO

May 3-4, 2005
National Corrective Action
Denver,  CO

May 15-19,  2005
2005 International Oil Spill
Miami Beach, FL

July 12-15,  2005
2005 Community  Involvement
Conference and Training
Buffalo,  NY
ASTSWMO Association of State and Territorial
        Solid Waste Management Officials

CERCLA   Comprehensive Environmental
        Response, Compensation, and
        Liability Act




        Department of Transportation

        Environmental Protection Agency

        Institutional controls




        Institutional Controls Tracking System   RD/RA

        Office of Enforcement Compliance
        and Assurance
Office of Site Remediation Enforcement

Office of Superfund Remediation and
Tecnology Innovation

Office of Solid Waste and Emergency

Potentially Responsible Party

Resource Conservation and Recovery Act

Remedial Design/Remedial Action
                                               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/
                                     Richard W. Popino, PhD REM, editor-in-chief

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

                                     Christine Rueter, Don Allen, and Jon Kallen
                                     DPRA Inc., writers
                                     Mary Spencer,
                                     DPRA Inc., designer
                                               To comment on the newsletter contact Richard W. Popino, PhD REM, atMC-2271A, U.S. EPA, 1200 Pennsylva-
                                               nia Ave., NW, Washington, DC 20460,

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