UNITED STATES ENVIRONMENTAL PROTECno
                              WASHINGTON, D.C. 20460

                                                               SEP 2 7 B95
                                 September 15, 1995
                                                          ^^
                                                                   GENERAL COUNSEL
MEMORANDUM

SUBJECT:   U. S. District Court Decision Interpreting Certain CERCLA ARARs
             Provisions Favorably to the United States
FROM:      Laurence MGroner l-*
             Attorney
             Solid Waste and Emergency Response Division (2366)
THROUGH: Lisa K. Friedman
             Associate General Counsel
             Solid Waste and Emergency Response Division (2366)

TO:         Elliott P. Laws
             Assistant Administrator
             Office of Solid Waste and Emergency Response (5101)

             Steven A. Herman
             Assistant Administrator
             Office of Enforcement and Compliance Assurance (2201)
       On August 15, 1995, Judge Nangle issued an order in U.S. v. Bliss, et al.. C.A. No. 84-
200C-1 et sea,., slip opinion (E.D. Mo. Aug.  15, 1995), which concerns operation of the
incineration remedy selected for cleanup of the "Missouri Dioxin sites".  This order provides
precedent favorable to the United States which may be useful in disputes concerning the elements
of Applicable or Relevant and Appropriate Requirements ("ARARs") under CERCLA and the
National Contingency Plan ("NCP").  A copy of the order is attached for your review
          These are twenty-eight discrete sites in eastern Missouri which were contaminated
 with dioxin in the early I970's.
                                                                          Printed on Recycled Paper

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             Background

             In September, 1988, EPA signed the Record of Decision (." ROD") selecting an
incineration remedy for disposition of hazardous substances from these sites.  In December, 1990.
the Court entered a consent decree settling the "Syntex Defendants'" ("Syntex") liability to the
United States and to Missouri in this matter.. Syntex agreed in the decree, among other things, to
construct the incinerator and to obtain two permits concerning its operation: a RCRA/Hazardous
Waste Management Permit from the United States and Missouri (the "RCRA%srnii«:"), and an air
emissions permit from St. Louis County (the "County Permit"). •  .            ; • \

             In December, 1994, EPA and Missouri jointly issued the draft RCRA Permit,
which permitted a dioxin emission level of 1 nanogram ("ng") per cubic meter  In February,  199S,
St. Louis County promulgated an ordinance and issued the County Permit, each of which allowed
a far more stringent dioxin emission level of. 15 ng/cubic meter. -In April, 1995. EPA and
Missouri issued the final RCRA permit, with the dioxin emission limit unchanged  from  their draft
permit.

             The Litigation
                                                                         .              «
             In May, 1995, Syntex filed a motion to construe and enforce the consent decree,
representing among other things that it believed it was not required to comply with the County
Permit.  The United States filed a memorandum in support of the Syntex motion  The United
States argued among other things that the understanding of all the panics at the time of entry of
the consent decree was that the County Permit would concern exclusively "conventional"
pollutants, that only the RCRA Permit would concern dioxin emissions, and that in any event the
County Permii air emissions level did not-constitute an ARAR which Syntex would be required to
meet.3

             The Decision

             Judge Nangle decided for the United States and Syntex.  He ruled that the
applicable dioxin air emission standards for the incinerator are limited to those set forth in the
RCRA Permit, and that the scope of the County Permit is limited to conventional air pollutants
       -   This notwithstanding § 12i(e)(i) of CERCLA, 42 U.S.C § 9621(e)(l). which
provides that "[njo Federal, State, or local permit shall be required for the portion of any
[response] action conducted entirely onsite ..  "

          Also before the Court were St. Louis County's motion to intervene as plaintiff, either
as of right or permissively. and its memorandum in opposition to the Syntex motion, filed in June
and July,  1995, respectively.

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             In his ARARs analysis, Judge Nangle concluded that" ARARs can be State or
federal ARARs but not local", sJififig. at 9 (citing § 12l(d)(2)(A)(ii) of CERCLA, 42 U.S C.
§ 962 l(d)(2)(AXu)), and that therefore

              the County permit.. .  cannot be an ARAR even if it were
              to otherwise meet the requirements for an ARAR, which it
              does not.                .

Id.  This is, so far as we are aware, the first time that this issue has been addressed in a court
decision.                                                              ••-•-.

              Continuing this analysis, the Court found that the County Permit would fail to
qualify as an ARAR on two additional grounds. First, the Court found that, "to be an ARAR, a
standard must be of general applicability", jd.(citing40 C.F.R. § 300.400(g)(4)), and it determined
that the County Permit was not, applying as it did only to the single incinerator in the State
"intended" to burn dioxin.  Second, the Court found that the County tailed to show that the
County Permit's requirements, promulgated as they were well after issuance of the ROD,  were
"necessary to ensure that the remedy is protective of human health and the environment".  The
Court noted that this showing must be made in order to impose requirements established after    •
ROD signature, because ARARs are "frozen" at the time of signature except in unusual
circumstances. Id. at 10, 12 (quoting 40 C.F.R. § 300.430(f)(J)(ii)(B)(l) and citing §
121(d)(2)(A)(ii) of CERCLA, 42 U.S.C. § 9621(d)(2)(A)(ii)).'

              Impact of the Decision

              The principal impact of this decision may be to provide useful precedent for the
proposition that requirements established by governmental entities smaller than states may not
constitute ARARs under CERCLA. In addition, it may signal that courts in analogous ARARs
disputes will not defer to state-established environmental requirements without a searching
analysis of whether they comport with CERCLA and NCP ARARs requirements. In particular,
while the concepts of "freezing" ARARs, and of requiring "general applicability", are already
contained in the NCP, it will be helpful to  have a decision in which the court affirmed the
application of the NCP to a specific set of facts.     .

       The Court also cited the fact that the County had not nominated its standard as an ARAR
before  the ROD was finalized.  This provides helpful precedent for cases where states and other
parties seek to raise  issues for the first time after the ROD is signed.

              Please contact me at (202) 260-4022 if you have any questions regarding this
decision.                                               .

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Attachment

cc:    Jon Cannon
      .Scott Fulton
      GaryGuzy
      Marcia Muikey
      Linda Boornazian
      Jerry Clifford
      Sandra Connors
      ORC CERCLA Branch Chiefs
      Regional Counsel, Regions I-X
      Waste Division Attorneys

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                                                     V. A
                   UWZTEB STATES DISTRICT COURT
                   EASTER* DISTRICT OP MISSOURI
                         CASTER* DZVZSZOV
URITED STATES OF AMERICA,

                    Plaintiff,

          vs.

RUSSELL MARTI* BLISS, «t ml.,

                    Defendants.
                                                         FILED
                                                          AU61
           U.S. DISTRICT COURT;.
            E. DISTRICT OR MO.
Civil Action Ros.
 84-200C-1,
 S9-351C-1 through
 S9-371C-1 and
 90-65«C-1
 (Consolidated)
STATE OP MISSOURI,
                    Plaintiff,
I1TDEPEVDE1IT PETROCEEMICAL
CORPORATZOH, «t'•!.,    .
                    D«f•ndaata.
                                              Civil Action Mo.
                                              83-2670C(2)
STATE OP MISSOURI,
                    Plaintiff,
RUSSELL MARTI* BLISS, et al..

                    Defendants.
                                              Civil Action Mo.
                                              S4-1447C(«)
STATE OP MISSOURI,
                    Plaintiff,
           vs.
SYHTEX  (U.S.A.)  Inc.,  et  al.,

                     Defendants.
 Civil Action Ho,
 S5-2S56C(6)

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          This matter  is  before the Court on  the Motion  of the
Syntex defendants1 asking the Court  to construe, effectuate and
                                     \
enforce the Consent Decree as to  the 5yntex -defendants' obligations
to proceed  with  the implementation of the Deere* in light  of a
recent ordinance enacted by  the St.  Louis  County Council.   Also
before the  Court is St.  Louis  County's Motion  to Intervene as
plaintiff and  St.  Louis  County's Memorandum Opposing the  Syntex
Defendants' Motion to Construe, Effectuate and Enforce Compliance.
X.  Motion to Intervene
          St. Louis County seeks to intervene in this litigation as
plaintiff as of right.  Fed.R.Civ.P. 24(a).  Plaintiff asserts that
because the Court has been asked to interpret an  ordinance of St.
Louis County, no other party will adequately represent  St. Louis
County's interest.  Alternatively, St..Louis County argues that it
should be  allowed  to  permissively intervene  in  the  litigation.
Fed.R.Civ.p. 24(b).
          In order  to intervene as a matter of right, one must make
a timely  application,  nust  have a  recognizable  interest  in the
subject matter of  the  litigation,  the interest must be one that
might be impaired  by the  disposition of the litigation,  and the
interest must not be adequately  protected by the parties.   Mille
Lacs Band of Indians v. State of  Minnesota. 989 P.2d 994, 997  (8th
     1     Syntex   Corporation,   Syntex  (U.S.A.)   Inc.,   Syntex
Laboratories,  Inc.,  and  Syntex  Agribusiness,   Inc.  are  herein
collectively referred to as  "the  Syntex defendants."   The entity
performing work pursuant to this Court's Consent Decree is Syntex
Agribusiness, Inc., referred to as "Agribusiness."

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Cir.  1993).   "The timeline**  of the motion  to intervene  is a
threshold consideration."   United States v. Bliss. 132 F.R.D.  58,
59  (E.D.Mo. 1990). Timeliness is left to the Court's discretion
and is  determined by all  of  the circumstances.   Three factors
receive special consideration,  however:   how far the proceedings
have  gone when intervention is sought, the prejudice swhich delay
                                                   •-',.. -•£"
may cause  to the parties,  and the reason  for  £he ^delay.    14.

Inc..  772 F.2d 401, 403  (8th Cir. 1985)).
           St. Louis County's motion to intervene clearly does  not
meet  the timeliness requirement in this case.  The litigation  was
commenced in  1984 and the Consent Decree entered in  1990.    The
                                                                 •
                                                                 >
County has long been avare of the litigation as evidenced by  its
comments in September, 1990; on the proposed Consent Decree through
its then County Executive B.C. Mil ford.  Moreover,  this case had a
high  media profile.  The  prejudice of any delay to the original
parties would be great given that both the Syntex defendants  and
the United Stats* have'spent millions  of dollars proceeding under
the Consent decree.  Accordingly, St. Louis County does not meet
the requirements to intervene  as a matter of right.
           St. Louis County's request  to permissively intervene in
this   case has effectively been granted.   It  appears  from  the
County's  motion to  intervene  that the  County merely  seeks  to
 address the issues raised in Syntax's motion. The County has filed
 its brief opposing the motion and the Court has considered it in

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its ruling on Syntex's motion.   Therefore, the  County has had its
views on this matter represented as  to those  issues.
II.  Motion  to  Construe, Enforce, and Effectuate Compliance with
the Consent Decree
          In their notion,  the Syntex defendants have represented
that they do "not believe  that they are required  to attempt  to
comply with  the St. Louie County ordinance.  However,  the Syntex
defendants  have indicated that  they are fearful  of  proceeding
without clarification and guidance from this Court as to whether or
how the St. Louis County ordinance affects their obligations under
the Consent Decree.  Having considered the motions and pleadings of
the  parties, including St.  Louis  County's  memorandum  opposing
Syntex's motion, the Court finds as  follows:                     '•
                       A.  riHPIHCS OF FACT
          1.   This  litigation has  been  before this  Court since
1984.    It  initially  involved twenty-eight different  sites  in
Eastern  Missouri that  were contaminated with dioxin  in the early
1970's.   Dioxiri-contaminated materials from eleven of these sites
have already been excavated and stored*
          2.    After  years of heavily-contested  litigation and
lengthy  negotiations,  the United States and the State of Missouri
reached  a settlement with the  Syntex defendants that  calls for the
parties  to  remediate  Times  Beach  and  twenty-six other  Eastern
Missouri sites.  This Court, in its Memorandum Opinion,  reviewed in
great detail the Consent Decree, EPA's September 29, 1988 Record of
Decision (sometimes referred to herein as the "ROD")  selecting the
incineration remedy, and the five Syntex Work Plans incorporated by
                                 4

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reference  into  the Decree,  including  the Site  Administration,
Demolition,  Remediation,  Thermal Treatment, and Restoration Work
Plane.   United State* v.  Bliss.  133 P.R.D. 559  (E.D.Mo.  1990).
This  Court  -concluded  that  the  Consent  Decree,  calling  for
incineration as  the selected remedy,  "was not arbitrarily  or
capriciously selected, but that it is  in  fact  technically sound,
appropriate  and sufficient for remediation of  the  .  ,  .  sites.*
Id- *t 570.
          3. The Consent Decree and its  Work  Plans contemplated
that  the Syntex defendants  would  apply  for  a  Hazardous  Waste
Management Permit  from the United States Environmental Protection
Agency  ("EPA")  and the State  of Missouri to construct and operate
                                                                 •
the  incinerator.    By  reviewing  this  permit  application  and
conducting  any necessary  health risk  assessments concerning the
incinerator, EPA and the  State  of  Missouri would fulfill  their
statutory mandates to protect human health and the environment.
Agribusiness submitted  its permit application  on July 30,  1993.
This application exceeded  10 volumes of material and required over
six  months   to  produce.   It involved a massive effort by a full
range of health, safety and environmental  experts.   A governmental
review  of  the permit application and the  attendant health  issues
has  been ongoing since July of 1993,  which has  required input from
numerous governmental agencies, including EPA, the Agency for Toxic
Substances  and Disease Registry  (a component of the United  States
Public  Health  Service),  the Missouri Department of Health,  the
Missouri Department of Natural Resources  ("MDNR"), and the  St.

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Louis County Department of Health, as well a* numerous independent
consulting firms retained by those agencies.
          4.   A  draft EPA/Missouri Hazardous  Waste  Management
Facility Permit ('Draft Permit*)  was issued  on December 16, 1994.
This Draft Permit proposed to establish the  allowable quantity of
dioxin and metals emissions  by way of a formula designed to assure
that  these  emissions  did  not   exceed   health-based  standards
established by law.   This formula was based upon  a site-specific
Times Beach Risk Assessment, also issued  by  the  EPA in draft form
in  late  1994, analyzing risks conservatively projected  for the
initial phase of this particular incineration project.  The Permit
and  the  Risk  Assessment  concluded that, so long  as  less  than
                                                                 •
                                                                 »
approximately one nanogram of dioxin per  dry standard cubic meter
of air* was emitted from the incinerator  at  any  time, the project
could be conducted safely.  For .this project, the term "safely" has
been defined  by  EPA and the State of Missouri  as not subjecting
:even the most heavily exposed individuals to more than a one in  a
million chance of developing cancer.  This level of risk, which is
also often  expressed as  1  x 10"*, constitutes the most stringent
level that EPA is authorized to impose upon any Superfund project.
40 C.F.R. 300.430(e)(2).  On January 31, 1995, a public  hearing was
held concerning the Draft Permit.  Written comments  were also
invited and several hundred  pages of suggestions  and reactions were
received.
      *  One nanogram is one billionth of a gram.  Hereafter,  this
 unit will be  referred  to as "1 ng/mj".

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          5.   On February  8,  1995,  shortly  after the  hearings
concerning the EPA/Missouri Draft Permit, the County Council of St.
Louis  County,  Missouri,  approved  Ordinance  Ho.  17,420,  which
amended St.. Louis County's Air Pollution Control Code by adding the
following provision to Section 612.180:                 .
     No  [County air] permit shall be issued for  operation of
     an  incinerator intended to burn known concentrations of
     2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)  unless it is
     first demonstrated in emissions burns that  emissions of
     toxic equivalents shall not exceed 0.15 ng./dry standard
     cubic meter as demonstrated .on feed  stock, nor may  any
     such  incinerator continue  to operate if this  emission
     standard  is  violated.    The  operator  of   any  such
     incinerator shall conduct periodic testing  of emissions
     and shall maintain a log of testing results which shall
     be  open for inspection.
Among other things,  this ordinance purported to establish (without
                                                    •            i
any  supporting  findings  or  justification)  a  dioxin  emissions
standard of .15 ng/m', more than six times as  restrictive as the 1
ng/mj standard that EPA and  the State of  Missouri had determined
(in their  Draft Permit  and  Risk Assessment) to  be appropriate to
protect  human health and the environment.
          6.  On April 14,  1995, EPA and Missouri isaued the final
Hazardous  Waste Management  Facility  Permit  ("Final  Permit")  in
conjunction  with  a  "Responsiveness  Summary'',  in  which  they
discussed  the comments received  from the public  concerning the
Draft  Permit.   After  careful consideration, and based upon their
Risk Assessment, which  had  been finalized on  March 28, 1995, EPA
and the  State  left intact their original  formula for establishing
dioxin and metals emission  limits that had been introduced  in the
Draft  Permit.    As  a  consequence,  under their  Final Permit,

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emissions  from  the  incinerator  are  restricted  to  less  than
approximately 1 ng/m* of dioxin at any  tine,  and the conservative
and protective 1 x 10'* health-based standard has been retained from
their Draft Permit.  Although EPA and Missouri were well aware of
the issuance of the County ordinance more than two months, earlier,
they  did  not adopt  the more restrictive  0.15 :ng/»J  standard
                                                  '• .-:y.j--'- .,         -  .
established   by  that   ordinance;   they  found  Jjistead   that
approximately  1  ng/m3  was  protective  of  .human health and  the
environment.
          7.  The Consent Decree  calls for this Court to retain
jurisdiction over the Decree and the parties.   Specifically, the
Decree provides as follows:
                                                                 •
     This Court  will  retain jurisdiction for the purpose of
     enabling any of the Parties to apply to this Court  at any
     time for such further order, direction and relief  as may
     be  necessary or appropriate  for  the construction  or
     modification of  this Decree or  to  effectuate or enforce
     compliance  with  its terms, or  to resolve  disputes  in
     accordance with the Dispute Resolution provisions herein.
Paragraph 97.
          8.  Syntex  has  demolished  and landfilled more than 600
houses  and  structures  at  Times Beach.     It  has  successfully
remediated all dioxin. contamination at  Times Beach, and more than
20, 000  cubic yards  of  excavated material are safely stored  in
buildings at Times  Beach.   The company has constructed a massive
ring levee to protect the excavated materials and the  incinerator
from  flooding events.   It  has prepared and submitted hazardous
waste,  air and water  permit applications for activities at  Times
                                8

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Beach.     Work  has  already  begun  to  prepare  the  eit«  for
installation.
                      fl. ^Conclusions  of Law
          -1.   /ARARs can be State  or federal ARARs but nyt local.
           The  SPA points out in its .brief that all references to
non-federal  applicable or relevant and appropriate rreguirements
                                                   "'•''*'•
("ARARs")  in both CERCLA and the national Contingency JPlan refer to
State,  rather  than  local,  ARARs.    See  e.g.,  42  U.S.C.  $
962l(d) (2) (A) (ii).  Therefore, the County permit at issue cannot be
an ARAB even if it  were to otherwise aeet the requirements for an
ARAR, which it does not, as discussed below.
           2.     The County  Permit  is not of  one  of  general.
                 ^^^^-^^.^•fc-i
applicability..   To be  an ARAR,  a .standard must be of  general
applicability.
     For   purposes  of  identification  and  notification  of
     promulgated state standards, the term promulgated means
     that  the  standards are  of general  applicability and are
     legally enforceable.
 10 C.F.R.  5 300.400(g) (4) (emphasis in  original).  The emissions
standard  in the County Ordinance  applies  only to incinerators
 "intended  to burn known concentrations  of  2,3,7,8-tetracholorodi-
benzo-p-dioxin."   Since the  Tines  Beach  incinerator is the  only
 incinerator in the  County  and State "intended" to burn dioxin, the
 standard  is not one of general applicability.
           3.    Applicable  Standards are Frozen  as of 199|.   The
 Consent  Decree, the Work  Plans,  and the  Federal regulations
 applicable to all  Superfund projects generally  require  that the
 remedial action selected in the Record of  Decision (the "ROD") must
                                 9

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attain only those ARARs identified at the time of the ROD, which in

this case was September 29,  1988.  Requirements promulgated after

the ROD  is  issued  oust be determined  by  EPA to be  "necessary to

ensure that the remedy  is  protective of  human  health and  the

environment" in order to become applicable:

     Requirements that are promulgated or modified aft«r ROD
     signature  must  be' attained  (or  waived)  «nly  when
     determined  [by  EPA] to be applicable  or relevant and
     appropriate and necessary to ensure that the  remedy is
     protective of human health and  the environment.

40C.F.R. 300.430(f)(l)(ii)(B)(l)(emphasis added).  This regulatory

requirement  was incorporated  into  the Consent  Decree and  its

attached Thermal Work Plan:

     The Work, as defined in the  Consent Decree, must attain
     a  requirement that is promulgated or modified  after
     September  29,  1988  (the  date of  signature of  the ROD)
     only  when  the  EPA  Administrator  (or  his   delegate)
     determines, upon a finding based-on the best  scientific
     judgment available'to EPA, that such requirement is .  .
     . necessary to ensure  that  the  Work  is protective of
     human health and the environment  ....

Thermal Treatment Work Plan  at Page  6-11.  See also Consent Decree

at Paragraphs 6 and 7.

          EPA's rationale for freezing the applicable standards as

of the date the ROD was signed is  explained in the preamble  to its

March 8,  1990 rulemaking concerning Superfund regulations:


     [I]t  is necessary to  -freeze ARARs*  when  the  ROD is
     signed rather than at  initiation  of  remedial  action
     because continually changing remedies to accommodate new
     or  modified  requirements would  .  .  .  disrupt  CERCLA
     cleanups,  whether the remedy is in deeign, construction,
     or  in remedial action.  Each of these stages represents
     significant  time  and   financial  investments   in   a
     particular remedy . .   . . If ARARs were not frozen ...
     promulgation  of  a new  or  modified requirement  could
     result in  a reconsideration of the remedy and  a re-start

                                10

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     of the lengthy design process, even if protectiveness j.»
     not compromised.  This lack of certainty could adversely
     affect  the operation of the  CERCLA program, would  be
     inconsistent with the Congress' mandate to expeditioualy
     cleanup  sites .... neither the explicit  statutory
     language   nor  the  legislative  history  supports   a
     conclusion that a  ROD aay  be  subject  to  indefinite
     revision as a result of shifting requirements.
55 Fed. fitfl. 3666, 8757.
          EPA has not and could not logically make a determination
that the County's new .15 ng/m3  standard  is  "necessary",  since it
has  already  determined  in  its  recent   Final  Permit   that
approximately 1 ng/m* is adequate.  Zn fact,  EPA was aware of the
County ordinance standards when it issued  its  Final Permit and Risk
Assessment  and  declined  to adopt   that  ordinance's  stricter
standards.  The County Ordinance had been approved in February and
thus preceded EPA's  Final Permit by more than  two months.  Finally,
the most  stringent  level of  protection  that EPA is  allowed to
impose upon  any  Superfund project  is  one in a million (1 x 10*')
risk.   40  C.F.R.  300.430(e) (2) .   Since the  1  ng/m3  emission
standard  in the  Final  Permit correlates  with  that  one in one
million  risk level,  EPA can go no  lower  than  1 ng/m3 in its
emissions standards.
          4 .  The County Ordinance is Inapplicable Because it Was
Passed After 198$.   Since the St.  Louis  County ordinance was not
approved until February 8,  199.5, more than  seven years after the
date the ROD froze the relevant  standards, it is  not applicable to
the Times  Beach project.  Nor can the County  alter this fact by
inserting  the more  restrictive language of the ordinance into its
county  air permit.   See  40 C.F.R. S  300.515(d) (1) ; U.S. v.  Ak»o
                                11

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Coatings  of America.  Inc.. 949  F.2d  1409,  1454-55  (6th  Cir.
1991) (once  a consent  decree is  entered by a federal  court under
CERCLA, alternative state remedies may not be pursued).
          5.    The  County  Did  Wet  Ava^l  Itself  of  S*vt>r^
Opportunities to  A^^*»pt»t to Make  its Dioxin %pjfs-.'**|>ns Standard
Applicable  to  this Prciect.   In the  selection, -«f.  « Superfund
Remedy,  EPA has  established a  procedure whereby  a  state3  can
nominate candidates for ARARs, prior to the selection of the remedy
in  the Record  of Decision.  Zt  is then EPA's responsibility to
review each candidate requirement to  determine  if it  meets the
statutory prerequisites that will qualify it  for inclusion in the
Record of Decision.  40 C.F.R.  300.515(h) (2).  The County did not
nominate any standard regarding dioxin emissions to be included in
the Record of Decision in 1988.  Furthermore, the Superfund statute
specifically requires that the nomination of  more stringent ARARs
must be "timely",  i.e..  before  the ROD is finalized.   42 U.S.C.
9621(d)(2)(A)(ii).  Seven years after the ROD is signed can hardly
be considered timely.  Moreover, as discussed above, only recently
has the County requested to intervene in this litigation.  For all
of  these  reasons,  the  County's regulation  concerning  dioxin
emissions is. inapplicable to this project.
          6.  The Work Plan Does Not Authorize the Ccunty to j"pp<->«*
Dioxin Standards Passed After 1988.  By  statute and regulation,  a
Superfund  project  does not need to  apply for  federal, state,  or
      '  The County could have found a way to communicate its views
 through the State.
                                12

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local  permits in order  to proceed.   42 O.S.C. $9621(e)(l);  40
C.F.S.  300.400(e)(l).   However,  th« Thermal Treatment  Work Plan
appended  to the Consent -Decree reflects a limited agreement among
the parties to the  Consent Decree t&at Syntex  would apply to the
St.  Louis  County Department 
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this cave in 1988), as described above.  Nowhere docs the Work Plan
grant  the  County authority  to unilaterally  modify  the  ARARs
established  in the  Record  of Decision.   To the  contrary,  the
Thermal Treatment Work Plan specifically states as  follows:
     The Work, as defined in the Consent Decree, oust attain
     a  requirement  that  is promulgated or  modified  after
     September 29,  1988  tthe  date  of signature «f ^the ROD)
     only  when  the EPA Administrator  (or hie  llelegate)
     determines, upon a finding based on the best scientific
     judgment  available  to EPA,  that  such  requirement  is
     applicable or relevant  and appropriate, and necessary to
     ensure  that the Work is protective of human health and
     the environment ....
Page 6-11.  No such finding  of necessity has been or caa logically
be made by EPA in this  instance:  since EPA has  already determined
that 1  ng/m3 is  protective  of human health and the environment,
then the County's more  restrictive standard of .15 ng/mj is clearly
not  "necessary"  to  insure  such protection.   Consequently,  the
County ordinance cannot be made applicable  to this  project.
          7.   The  Ordinance  Will   Impede  Troplementation  of  the
Consent Decree.   Upon  inspection of  the County's permit for this
project,  it appears that  the County  intends  to  apply  its  new
ordinance  to  this  project,  notwithstanding  the  provisions  of
Federal  law,  the   Consent  Decree,  the  Work  Plans  and  the
EPA/Missouri Final Permit.  The  St.  Louis  County standard has an
adverse  effect on this  critical Superfund project,  because the
incinerator operator  nay  not  be  able to measure,  much less
consistently  achieve  this  standard.    Interference  by other
compounds  may be  such that  laboratory equipment  cannot  detect
dioxin  emissions  below  .15  ng/m1,  and,   therefore,  the  Syntex
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defendant* could not "demonstrate" having achieved the standard as
required by the St.  Louie  County ordinance  and permit even if no
dioxin mere detected.  In addition,  the County ordinance contains
other  objectionable provisions  that  are at odds  with  the
State/Federal Demit.
          8.    Exclusive  Jurisdiction  lies  with  "this  Court.
Exclusive jurisdiction for direct or indirect challenges or attacks
concerning the response action pursuant to  the Consent Decree in
the  United States v.  flllss natter lies with the  United 'States
district  courts  and, specifically,  this Court,  since continuing
jurisdiction over  the  Decree has been retained.  Consent Decree,
Paragraph 97? 42 O.S.C. 5 9613(b).  The fact  that EPA and the State
                                                                 •
issued permits  for  the project does  not create any independent
jurisdictions pursuant to  the  Resource Conservation and Recovery
Act, or .otherwise, in any other court. The  fact  is clearly stated
in both EFA's and  the State's permits.
          WHXRZFORC, for all the above stated reasons, this Court
orders as follows:
           1.  The regulatory standards applicable to this Superfund
project  are  limited to those enumerated in the 1988 Times Beach
Record of Decision,  along with any additional standards that EPA
has  subsequently  determined to  be  applicable or  relevant and
appropriate,  and necessary  to  protect human health  and the
environment;  and
           2.    The  only  permits  appropriate  for  this  on-site
Superfund project are  those specifically identified in the Consent

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Decree  and Work  Plans,  and that the  scope of  said permits  is
limited to that described in the Consent Decree and Work Plans; and
          3.  The scope of the air permit to be  secured from St.
Louis County for the Tiaes Beach incinerator is limited to control
of conventional air pollutants, not  including dioxin; and
          4.  St. .Louie County Ordinance No. 17,420, *nd Conditions
of the St. Louis County Air Pollution Control Permit 45942 related
thereto are inapplicable to  the Times Beach project for the reason
that they are  inconsistent with Federal  lav  and  regulations, the
ROD,  the Consent  Decree, the Work Plans,  and  the  EPA/Missouri
Hazardous Waste Management Facility  Permit;  and
          5.  This Court will retain continuing jurisdiction over
                                                                 •
the Consent Decree and the Parties to this matter and, therefore,
exclusive jurisdiction fpr direct or  indirect  challenges or attacks
concerning  this natter  lies with this Court; no other  court has
jurisdiction  pursuant to the  Resource Conservation  and Recovery
Act,  or otherwise,  by virtue of the issuance of the EPA/Missouri
Hazardous Waste Management Facility Permit.
 Dated: August 15, 1995
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