A FORUM CONCERNING THE ESTABLISHMENT OF A CLEARINGHOUSE FOR CERCLA/RCRA CLEANUP TECHNOLOGIES HELD AT THE ANDOVER INN ANDOVER, MASSACHUSETTS April 22-23, 1987 Sponsored by: U.S. Environmental Protection Agency Managed by: Center for Environmental Management Tufts University Curtis Hall, 474 Boston Avenue, Medford, MA 02155 June 1987 ------- DISCLAIMER Although the information in this document has been funded wholly or in part by the United States Environmental Protection Agency under assistance agreement CX-811592-01-A to the Center for Environmental Management at Tufts University, it may not necessarily reflect the views of the Agency and no official endorsement should be inferred. This report is a compendium of positions about the proposed structure and operation of a Clearinghouse made at a forum sponsored by the EPA. The statements expressed in this report reflect the positions made by the participants and they do not necessarily reflect the position of the Center for Environmental Mangagement. ------- The Tufts University Center for Environmental Management (GEM) was established in 1984 to develop an effective multidisciplinary approach to environmental problems through innovative health effects and technology research, policy analysis, education programs and information transfer activities. CEM also acts as a neutral and independent forum center where citizens and representatives from government, academia, industry, and public interest/environmental groups can meet to discuss and resolve critical policy issues. The Center's activities are performed by a staff of scientists, engineers, policy analysts and numerous faculty from the many schools and resource centers of Tufts University. The Center also sponsors research at other universities. Funding for the Center's projects is derived from state and federal grants, awards from foundations, and contributions from industry to the Center's Corporate Affiliates Program. Further information on the enclosed report or on the activities and publications of the Center can be obtained by writing to the Center for Environmental Management, Tufts University, Curtis Hall, 474 Boston Avenue, Medford, MA 02155, or by calling the Center at (617) 381-3486. 11 ------- TABLE OF CONTENTS Page I EXECUTIVE SUMMARY iv II INTRODUCTION 1 III THE FORUM AND OVERVIEW 6 IV POTENTIAL COMPONENTS OF A CLEARINGHOUSE 8 Central Reference Library 8 The Clearinghouse Hotline 9 Specialized Publication Services 11 Technical Information Network 11 Data Base Overview 12 ACTION and WIN Data Bases 13 Case History File and Countermeasure Selection System 16 V DISCUSSION GROUPS 17 Introduction 17 Question 1: Would You Find a CERCLA/RCRA Cleanup Technology Clearinghouse Useful? 17 Question 2: What Conponents of a Clearinghouse Would Be Most Useful? 18 Question 3: What Types of Information Would You Need from a Clearinghouse? 18 Central Reference Library. 20 Clearinghouse Hotline 20 Specialized Publications 21 Computerized Data Bases 22 Question 4: In What Forms Should the Information Be Presented? 25 Question 5: How Should the Agency Obtain the Information? 26 Question 6: Should the Agency Guarentee Quality Assurance and Quality Control (QA/QC) of the Data? ...27 Other Issues and Recommendations 29 VI CONCLUSIONS OF THE FORUM 32 VII FUTURE DIRECTIONS 35 IX Appendix A - Agenda 37 Appendix B - Group Composition 39 Appendix C - Participants List 40 PRELIMINARY BACKGROUND MATERIALS (in a separate packet) 111 ------- EXECUTIVE SUMMARY Section 311(b)(8) of the Superfund Amendments and Reauthorization Act (SARA) of 1986 required the Environmental Protection Agency (EPA) to establish a "central reference library" to collect and disseminate information on alternative or innovative treatment technologies. EPA identified an existing collection within its headquarters library which could serve as the nucleus for the mandated "central reference library". In addition, EPA recognized the need for additional sources of information about hazardous waste treatment technologies. On April 22 and 23, 1987, the Office of Environmental Engineering and Technology Demonstration (Office of Research and Development) and the Office of Program Management and Technology (Office of Solid Waste and Emergency Response) convened a forum of interested parties to discuss recommendations about an information transfer system. The EPA requested that the Center for Environmental Management (GEM) at Tufts University organize and manage this forum. Potential users and contributors from the EPA, other Federal agencies, state governments, potential responsible parties (PRP's), technology vendors, Superfund contractors, environmental group representatives, and citizen groups were identified and asked to attend the forum. Prior to the forum, IV ------- the Agency identified the following as potential components of an information transfer system: o a library o specialized publications o a hotline o a database Collectively, these components were identified as a RCRA/CERCLA Cleanup Technology Clearinghouse. The forum addressed the following questions: 1. Would you find a Comprehensive Environmental Response Compensation and Liability Act/Resource Conservation and Recovery Act (CERCLA/RCRA) Cleanup Technology Clearinghouse useful? 2. What components of a Clearinghouse would be most useful? 3. What types of information would you need from a Clearinghouse? 4. In what forms should the information be presented? 5. How should the Agency obtain the information? 6. Should the Agency guarantee Quality Assurance and Quality Control (QA/QC) of the data? The participants also evaluated components of a potential Clearinghouse of information about hazardous waste cleanup technologies and recommended to EPA the factors they believed would maximize information transfer. ------- Computerized data bases were demonstrated to illustrate their value as Clearinghouse components. Following presentations of potential components, participants were divided into four discussion groups A, B, C and D. Each group was provided with a facilitator and was instructed to discuss the six major questions. Then each group would report back to all the attendees. It should be noted that each group did not discuss all of the questions in the same manner or with the same amount of detail. An effort has been made to present all information discussed in a neutral and balanced manner based upon reports submitted to CEM by each group's facilitator. Participants in the forum concluded that the purpose of a Clearinghouse would be to provide readily accessible, quality-controlled, objective data to serve the needs of the following user groups: (See Table I). TABLE I USER GROUP APPLICATION EPA/State Officials Community organizations, local officials and citizens Potential Responsible Parties (PRP's), and other private industry Researchers, academics, manufacturers, and investors to facilitate sound cleanup and permit decisions to enhance the ability to understand, evaluate, and comment upon cleanup plans and permits. to improve the basis for decision-making about cleanup alternatives and equipment selection to provide a better understanding of finished and ongoing development and demonstration work VI ------- Most participants agreed that the first activity of a Clearinghouse should be collecting existing data since a broad range of materials, information, and data bases about CERCLA and RCRA cleanup technologies already exists. Many specialized publications are also available. There is a need for centralization of this material at the EPA headquarters library and throughout the EPA library system. The EPA library system could be a readily-accessible source of hard copies of summaries, fact sheets, and final data, reports, and rules. Computerized data are ever increasing in volume and breadth of coverage, but they are not available from a single accessible source. Many people are still reluctant or unable to use computers. A decision should be made to identify the most effective way to disseminate each type of information. There should be a hierarchy of levels of information to enable users to access data in a form that meets their needs. The selection should be well-publicized so that new data will be directed through the appropriate channels. Not everything needs to be computerized, and no one system can meet everyone's needs. The utility of a particular method of data storage and retrieval will depend upon the user and the need. A process should be developed to regularly review the effectiveness, utilization, and quality of data in the Clearinghouse. vn ------- Several groups of participants recommended that initially the Clearinghouse should have limited scope and focus. The Clearinghouse should not attempt to be "all things to all people." Efforts should be made to expand the existing EPA library's Hazardous Waste Collection and the current RCRA/CERCLA hotline. Also, a computerized data base similar to the current Department of Energy (DOE)/EPA model should be constructed. The Clearinghouse should be a vehicle for disseminating quality-controlled data on the development and demonstration of hazardous waste treatment/remedial technologies. This information should include cost data whenever feasible, but safeguards should be taken to ensure that the Clearinghouse does not become a public relations vehicle for manufacturers of such technologies. Group A did not determine the most important component or establish a priority ranking, but Groups B, C, and D ranked the importance of each of the components of a potential Clearinghouse. (See Table II). Vlll ------- TABLE II PRIORITY RANKING BY GROUP CLEARINGHOUSE COMPONENT Reference Library Hotline Specialized Publications Computerized Database Directory for Technical Assistance II — 1 - - 2 III 1 - - 2 — IV 1 3 - 2 — 1 High Priority 2 Medium Priority 3 Low Priority - Not ranked as one of the three most important components of a Clearinghouse The quality control issue received much spirited discussion. Basically, there were two perspectives. First, information must be totally accurate, complete, and verified by peer review and formal EPA approval. Second, QA/QC would severely limit the amount of data that would be in the data base, thus, defeating the purpose of a Clearinghouse. The group that supported the latter position believed that the sources of data should be identified. Protocols and testing methods should likewise be specified. This approach allows the user to evaluate the validity of the information. Refining different levels of QA/QC may satisfy the needs of both user groups. The report which follows describes the presentations and computer demonstrations. It examines each question discussed at the forum, and summarizes the responses from each group. IX ------- EPA will circulate the findings of this forum, and accept further comments about the proposed Clearinghouse. It should be understood that the findings of this forum, priority ranking, and guidelines for development do not have any binding obligation upon EPA. The suggestions, however, will be carefully reviewed. ------- INTRODUCTION The Superfund Amendments and Reauthorization ACT (SARA) of 1986 directed the Environmental Protection Agency (EPA) to establish a "central reference library" to compile information about Superfund Innovative Technology Evaluation (SITE) program. The SITE demonstration program, established in Section 311(b) of SARA, develops, collects, evaluates, coordinates, and disseminates information about specific innovative and alternative treatment technologies for hazardous waste response actions. SARA Section 311(b)(8), quoted below, requires that the central reference library shall be made available to the public. No other requirements were specified. "(8) TECHNOLOGY TRANSFER.—In carrying out the program, the Administrator shall conduct a technology transfer program including the development, collection, evaluation, coordination, and dissemination of information relating to the utilization of alternative or innovative treatment technologies for response actions. The Administrator shall establish and maintain a central reference library for such information. The information maintained by the Administrator shall be made available to the public, subject to the provisions of section 552 of title 5 of the United States Code and section 1905 of title 18 of the United States Code, and to other Government agencies in a manner that will facilitate its dissemination..." ------- The EPA felt that technology transfer about treatment technologies for response actions could be enhanced by providing more types and sources of information than a central reference library; therefore, they convened a group of potential contributors and users of such information to design an effective informational system for cleanup technologies. The Agency identified a library, specialized publications, a hotline, and a data base as possible components of an information transfer system. Collectively/ these components were identified as a Clearinghouse. The Center for Environmental Management (CEM) of Tufts University was asked by the EPA to organize and manage a two day forum which was convened in April 1987. The participants of this forum included potential users and contributors from the EPA, other federal agencies, state governments, potential responsible parties (PRP's), technology vendors, Superfund contractors, environmental group representatives, and citizen groups. (See Appendix A for the agenda, and Appendix C for a list of attendees.) They were invited to evaluate components of a potential Clearinghouse of information about hazardous waste cleanup technologies. They were also asked to recommend the factors which would maximize information transfer. ------- Experts were invited to demonstrate the possible Clearinghouse components to the forum. These presentations included descriptions of the following: o A Central Reference Library - Loretta Marzetti, USEPA o A Clearinghouse Hotline - Patricia Conn, Geo/Resources Consultants, Inc. o Specialized Publication Services - Beverly Campbell, Technical Resources, Inc. o Technical Information Network composed of: - Treatment Technology Data bases - C.C. Lee, EPA/HWERL (Hazardous Waste and Environmental Research Laboratories) - Cincinnati DOE Waste Information Network - Cathy S. Fore, Oak Ridge National Laboratory Case History File and Countermeasure Selection System - Richard Griffiths, EPA/HWERL - Edison. Following these presentations, participants were divided into four discussion groups, each of which was provided with a facilitator. Each group was instructed to discuss these six major questions: 1. Would you find a Comprehensive Environmental Response, Compensation and Recovery Act/Resource Conservation Recovery Act (CERCLA/RCRA) Cleanup Technology Clearinghouse useful? ------- 2. What components of a Clearinghouse would be most useful? 3. What types of information would you need from a Clearinghouse? 4. In what forms should the information be presented? 5. How should the EPA obtain the information? 6. Should the EPA guarantee Quality Assurance and Quality Control (QA/QC) of the data? Upon completion of the individual group discussions, each facilitator reported back to all forum participants. The following is an overview of activities at the forum, a summary of all findings, and reports of major discussion points and conclusions reached by each of the individual workshop groups. It should be noted that not all of the groups discussed each of the topics in the same manner or with the same amount of detail. An effort has been made to present all information discussed in a neutral and balanced manner based upon the reports submitted to CEM by each facilitator. It was soon apparent that the group did not have a common language. To some individuals 'hotline' meant the existing RCRA/CERCLA hotline. To others it meant personnel provided to respond to telephone inquiries made to the EPA central reference library, and to still others it meant the telephone response component to provide guidance about how to access and use the computerized databases, or to provide expert recommendations for cleanup technologies. ------- 'Data base', likewise, had different meanings. To some it meant expansion of the existing EPA case history and countermeasure files or the DOE/EPA Thermal Treatment Technology data base. To others it meant the development of a new system housed to the EPA central reference library. To still others data base meant an entirely new system, designed exclusively for the Clearinghouse, which would be operated by an independent contractor. This latter system might be located at a university or a commercial facility. The forum did not adopt a formal definition of either of these terms. ------- THE FORUM AND OVERVIEW On April 22, 1987 a group of experts on cleanup technologies and treatment of hazardous wastes were convened to exchange information, review progress in areas of potential Clearinghouse components, and express needs. (See Appendix A for the agenda and Appendix C for a list of attendees). Alfred Galli, USEPA, a key player in the organization of the forum, welcomed the group. To provide participants with a better understanding of existing computerized data bases, demonstrations were provided which included presentations by the US Department of Energy (DOE), EPA's Hazardous Waste Engineering Research Laboratory (EPA/HWERL-Edison and Cincinnati), the Maryland Hazardous Waste Siting Board/Waste Exchange, and the EPA headquarters library. The presentation included descriptions of each data base and a demonstration of how it operated. At the conclusion of the formal demonstrations, participants were invited to ask questions or to briefly experiment "hands on" with the system. On the following day, the group was greeted by Thomas Devine, USEPA and David Standley, Tufts University. Alfred Lindsey of EPA explained that the meeting was jointly sponsored by the Office of Environmental Engineering and Technology Demonstration (Office of Research and Development (ORD)) and the Office of Program Management and Technology (Office of ------- Solid Waste and Emergency Response (OSWER)). Representatives of EPA headquarters and regional staff, contractors, potential responsible parties, state governments, environmental groups, citizens, and other federal agencies had been invited to discuss the formation of a proposed Clearinghouse for hazardous waste cleanup technologies. The agenda included summaries of the status of information presently available, and descriptions of relevant systems which were proposed. Each participant, briefed on potential Clearinghouse technologies, had the opportunity to discuss these components and to recommend the services which EPA could provide given the limitations of its budget. ------- POTENTIAL COMPONENTS OF A CLEARINGHOUSE Each potential component of a Clearinghouse, a central reference library, a hotline, a specialized publication services, and a technical information network, was described by an expert. Some of these components already exist either within the EPA or in the public sector. CENTRAL REFERENCE LIBRARY Loretta Marzetti, Chief, Information Services Branch, EPA, described the EPA library's special Hazardous Waste Collection and the commercial hazardous waste databases to which the library has access. In 1986, the EPA Headquarters library developed a special hazardous waste collection and database for the EPA library network. The collection includes materials on remedial and emergency removal activities, groundwater, landfills, incineration, underground storage tanks, enforcement and alternative technologies. As of March 30, 1987, the collection contained over 1,200 bibliographic records. Additions are being made at roughly 200 records a quarter. The hazardous waste collection and database are currently available in the EPA headquarters and regional libraries, as well as the National Enforcement Investigation Center and the Ada, Cincinnati, Edison, Las Vegas, and Research Triangle Park (RTF) laboratories of EPA. ------- The entire collection is accessible on a data base, using an IBM PC/AT. It provides automated search and retrieval capability by the following access points: key word/subject heading, abstract, title, author, sponsoring organization or office, project manager's name, and contract number. The database and hard copy printouts of the database are updated and distributed quarterly to the EPA network libraries cited above. The. data base is available through the National Technical Information Service (NTIS), PB87 - 152690. Emma McNamara, Head Librarian of EPA Headquarters Library, described the Hazardous Waste Collection file structure for monographs, periodicals, and the commercial data base file. Sample keyword searches were demonstrated. The system is compatible with d-base III software systems and is "user-friendly." The menus for the library reference system prepared by EPA/HWERL-Edison enable extraction by users who are not computer professionals. THE CLEARINGHOUSE HOTLINE . The existing RCRA/CERCLA hotline was described by Patricia Cohn of Geo/Resources Consultants, Inc., (the firm which manages the hotline). The major federal hotlines include RCRA/CERCLA, Small Business, US Department of Agriculture (USDA), Poultry, and Toxic Substance Control Act (TSCA). The major purpose of any hotline is to answer questions. The hotline can respond to dynamic events, such as revisions to regulations or status ------- of RCRA/CERCLA projects. Many hotlines presently exist. The users of the existing RCRA/CERCLA hotline have requested information about a variety of hazardous waste regulations. Seventy-three percent of the calls were about RCRA, 15% about Underground Storage Tanks (UST), and 12% of the questions concerned CERCLA. Information dissemination and feedback examples were presented. Other aspects of the hotline that were explained included integration of the hotline into the EPA program, training of staff, automation, feedback mechanisms, operational needs, and advertising and promotion. Some of the forum participants suggested that a proposed Clearinghouse Hotline could be designed to provide information about cleanup technologies, and it could perform a variety of additional functions. The principal function would be to disseminate information. It could also provide a technical/regulatory interface for facilities that must comply with RCRA. The Clearinghouse Hotline could also respond to requests for written material. Patricia Cohn proposed that a Clearinghouse Hotline could serve as a reference or access point. The Hotline could inform potential users about the type of information available in the Clearinghouse and how to access it. The Clearinghouse Hotline could also serve as the vehicle for distribution of a manual for data base users. 10 ------- SPECIALIZED PUBLICATION SERVICES Newsletters and technology fact sheets were identified by Beverly Campbell of Technical Resources, Inc. as the most important types of specialized publication services. There are a number of specialized publications and data bases which presently exist within EPA and DOE. Presently, these specialized publications and data bases include a Treatment, Storage and Disposal Facility (TSDF) vendor list, a disposal facility list, a remedial response contracts list, and an inventory of analytical laboratories. Many commercial hazardous waste newsletters already exist, however, there is no centralized or accessible inventory. A fact sheet about EPA°s SITE program presently exists, and a corresponding fact sheet for each of the demonstration projects will be available soon. Site-specific, technology-specific, and project-specific fact sheets produced by the EPA will also be available. TECHNICAL INFORMATION NETWORK A technical information network composed of a variety of computerized data bases was proposed as a potential Clearinghouse component. The existing and potential.data bases, which could be included in a cleanup technology Clearinghouse network, were also discussed by C.C. Lee, Cathy Fore, and Richard Griffiths. 11 ------- Several computerized data base management systems have already been designed to make new technical information more readily available to cleanup personnel and researchers. There is no centralized repository for these systems which is readily available to all potential users. EPA projects currently include a case history file on hazardous spills and hazardous waste sites, and a countermeasure selection system on recommended response technology. A library search system for locating useful technical publications, and a data base on innovative technology have been established. The newest project is a data base for on-site mobile treatment equipment. This data base will allow access to performance and cost data. HWERL is currently developing six expert systems to provide advice concerning hazardous waste questions/issues for use by Agency decision makers. These systems are designed to emulate the same decision logic used by knowledgeable persons (experts) and are prescribed in EPA regulations or guidance documents. Systems currently under development will assist in evaluation of the chemical compatibility of flexible membrane liners with waste materials, evaluation of the waste analysis plan specified in Part B permits, evaluation of closure plans for land disposal facilities, and screening of containment, removal, or treatment technologies for Superfund sites. Data Base Overview Three data base technology systems were described. C.C. LEE, EPA/HWERL-Cincinnati, provided a conceptual description of 12 ------- how an existing thermal treatment technology data base, jointly funded by EPA and DOE, could be expanded to incorporate detailed data on other treatment technologies. The data base concept could support both RCRA and CERCLA technology transfer needs, and it would provide a basis for matching hazardous wastes with applicable technologies. ACTION and WIN Data Bases Cathy S. Fore, DOE (Hazardous Waste Remedial Actions Program, Support Contractor Office), presented a conceptual description of a computerized Clearinghouse network approach, (ACTION) and an overview of the existing Waste Information Network (WIN). She discussed three data bases that have been developed to support technology transfer within DOE and EPA. Any Clearinghouse data base network would be composed of a central location for the collection and intrepretation of data and accessed by individual users. This information would be electronically retrievable through personal computers at EPA Headquarters and regional EPA libraries, or through a user's personal computers and telephone modems. Clearinghouse data base software should be "user-friendly". The purpose of a conceptual network would be to serve as a central and comprehensive resource for the use of alternative or innovative technologies. The major benefit of this proposed data base is that it would provide a centralized resource for technology transfer information. 13 ------- This conceptual network could accommodate major user applications. Among the many options which it might perform are developing and tracking permit conditions, determining future research strategies for EPA and DOE, and conducting similarity analyses for comparing technologies. It could support the waste disposal hierarchy of elimination/reduction; recycle, reuse, and recovery; treatment; destruction; and disposal. The conceptual network could decide upon major on-line data base applications. Some possibilities that have been identified include RCRA/CERCLA available technologies, and EPA/Department of Defense (DOD)/DOE cooperative efforts, waste characterization, and research directories. The Waste Information Network (WIN), an existing national communications network developed by DOE's Hazardous Waste Remedial Action Program of Support, was described by Cathy Fore. It is designed to function as an information tool for conducting data analyses in support of hazardous waste minimization efforts. It also helps to promote technology transfer within the hazardous waste community. WIN represents a central resource for detailed data on hazardous waste technologies which provides rapid communications through sophisticated interactive programs. It also offers direct user interface with raw data for purposes of conducting on-line analyses and report generation. 14 ------- Some of the major applications of the WIN system include identifying and tracking hazardous wastes from generation to final destination, and identifying available commercial resources. WIN can also be used to generate user-specified on-line data reports and to determine technology alternatives. WIN is also frequently used to perform data analyses to support waste minimization programs, or to locate experts in the field to respond to specific needs. In addition to general on-line data bases, the WIN system encompasses interactive information exchange tools consisting of electronic mail, file transfer, and an electronic bulletin board. The current EPA/DOE Hazardous Waste Control Technology Data Base System is designed to aid permit writers, researchers, industry, and decision-makers by providing detailed information on thermal treatment technologies for managing, analyzing, and comparing similar waste components and technologies. Major applications include tracking permit conditions, research and development, determining future research strategies, and identifying key parameters to support data submission standards. The system also supports regulatory standards and procedures, and implements on-line report generation features. Data for this system have been collected from numerous resource documents currently covering 90 facilities. For any given facility, information pertaining to design, installation, operating conditions, waste characteristics, and trial burn results can be obtained. Retrieval can be made for either 15 ------- summary reports or user-defined reports. On-line reports can be generated about general facility information, operating conditions, waste characteristics, design installation, and trial burn results. Case History File and Countermeasure Selection System Richard Griffiths of EPA/HWERL-Edison described the data bases developed by his office or under his direction. The Countermeasure File exists as a practical working system which details response measures to hazardous waste spills. This data base system is based on the technology which was in common use in 1982, and it could be updated. Data about newer technologies also could be incorporated into this system. A Mobile Treatment Unit File will be available in the coming months. This data base will contain performance and cost data about mobile and portable systems developed by EPA and private industry. Obtaining useful information from state and local EPA's on-scene coordinators (OSC's) is a major problem when there is no requirement to submit these data. If the OSC has a contractor, however, there can be a stipulation placed in the contract requiring submission of this data. The OSC data requires continuous updating; consequently, it is very personnel-intensive. The value of a computerized data base for OSC's is that it would serve as a means for field personnel to communicate with each other. 16 ------- DISCUSSION GROUPS INTRODUCTION Following the demonstrations and briefings, four groups were formed. Each group, composed of members representing diverse backgrounds and interests, discussed the same wide range of issues relating to establishing a CERCLA/RCRA Cleanup Technology Clearinghouse (See Appendix B). Although the group members expressed varied opinions, the discussion generally resulted in consensus among the members. The conclusions and priority ranking of issues varied slightly from group to group, but extensive common ground was established both within each group and common to all groups. Participants were cooperative and constructive. Many insightful comments and ideas were added to the pre-established common agenda. The six questions posed to each group are summarized in the sections which follow. QUESTION 1: WOULD YOU FIND A CERCLA/RCRA CLEANUP TECHNOLOGY CLEARINGHOUSE USEFUL? Each group agreed that there is a clear and demonstrated need for a CERCLA/RCRA Cleanup Technology Clearinghouse. A wide range of potential users were identified, each with differing applications and levels of use. The groups agreed that Clearinghouse can be planned most effectively by identifying user groups and then selecting the most appropriate components to meet these needs. 17 ------- Group A identified Clearinghouse users according to the following classification system: Users 1 - Public Interest Groups Citizens Users 2 - States EPA Regions Other Federal Agencies: DOD, DOE, Department of Transportation (DOT) Users 3 - Contractors Potential Responsible Parties (PRP's) Vendors Other Private Entities (Including Academics) Within each of the three user categories there are members with divergent needs, interests, and priorities. These internal variations should be acknowledged during planning. [Note that EPA headquarters and laboratories inadvertantly were excluded from Group A's classification system.] QUESTION 2: WHAT COMPONENTS OF A CLEARINGHOUSE WOULD BE MOST USEFUL? QUESTION 3: WHAT TYPES OF INFORMATION WOULD YOU NEED FROM A CLEARINGHOUSE? (In the workshop groups' discussions and responses, Question 2 and Question 3 were usually combined; therefore, they are combined in this summary). 18 ------- Four major components of a Clearinghouse system were discussed. The degree of interest in each component, as it varied by the user categories defined by Group A, is shown below. UTILITY RANKING BY CATEGORY OF USER CLEARINGHOUSE COMPONENT Reference Library Hotline Very High Specialized Publications Computerized Databases USERS 1 Public Medium Medium Low High USERS 2 States Medium Medium Low High USERS 3 Contractors Medium Low High According to Group D, the Clearinghouse should primarily provide information for the user groups identified below: o federal and state officials legally responsible for remediating hazardous waste sites o federal and state officials responsible for developing hazardous waste standards and regulations o citizens and community organizations affected by hazardous waste sites and facilities o private industry members responsible for addressing and correcting hazardous waste problems o public and private sector research and development staff 19 ------- Group IV presented this classification of users to the other groups at the general session, but no one from the other groups made any comment either about this system as a whole or about any specific component. Each group discussed the relative merits of each of the potential Clearinghouse components. Their comments have been summarized under each of the component headings. Central Reference Library The information must be readily and easily accessible, because the user is unlikely to spend much time in the search. An expansion and upgrading of the existing reference library would be sufficient to meet these needs of the Clearinghouse. It was agreed among the groups that the rate of expansion of documents could be accelerated, and hard copies of documents should become more readily available. Clearinghouse Hotline Group IV stated that a Clearinghouse Hotline is most valuable to members of the public, who have limited understanding of hazardous wastes and limited familiarity with the programs which address these problems. A Clearinghouse Hotline could be a useful starting point for information-gathering by even the most sophisticated researchers. The current RCRA/CERCLA hotline has been particularly helpful to keep the states current about regulations and to provide hazardous waste generators with current regulatory information. 20 ------- A hotline would be only as good as the information available to it from other components of the Clearinghouse. The most logical means of providing this service would be by extension of the existing hotline. Group B considered the Clearinghouse Hotline to be its highest priority. The primary function, given limited resources, would be to refer a caller to an expert source or a written resource. A secondary Clearinghouse Hotline person, according to Group D, should be a trouble-shooter for either a field problem or a computer search problem. Group C suggested incorporating the Clearinghouse hotline into the reference library and providing a toll-free number and a publication service. This system would locate information, and build on the strengths of the current system. (An emergency response hotline was not strongly supported by Group C, as this requires both 24-hour staffing with legal and technical expertise). Group C, however, believed a user should be able to know how to obtain specific types of clean-up technology information. Specialized Publications Because many specialized publications are already available, the need for additional specialized publications as a component of a Clearinghouse was low. The need for centralization of the available materials was recognized to be very important. Group B identified a computerized directory 21 ------- for technical assistance as its second priority. If a directory is developed, help must be available to search for information. Not all potential users know how to access data. The proposed directory should contain information on alternative technologies, evaluations of projects, and approaches to cleanup that have been completed. The data could include identification of the responsible party, methodology, and cost. There was strong support in Group B to expand the information base beyond alternative technologies to include: Development phase treatment techniques Existing treatment technologies (experience-based) Innovative land disposal Capping of landfills Community and site information Group B was especially interested in learning whether each technology was operational or evaluated. This information would be useful for feasibility studies particularly when cost data are included. Computerized Data Bases Group A felt that a hybrid data base is needed. It would focus on remedial measures and corrective actions. (It should be similar to the countermeasure selection system data base but with an emphasis on long term treatment solutions, including existing, alternative, and innovative technologies.) Initially, the data base could consist of short narratives on 22 ------- treatment options and descriptions of current application sites. This initial data base could be expanded to include more detailed data about testing of applicability and performance of each of the technologies. The expanded base should be patterned after the EPA/DOE incineration data base, but it could be broadened to include other technologies as well. This type of database is currently being developed by some of EPA's remedial contractors. The data base could be expanded to include general information about cleanup technologies. Such data can be used by interested parties, and the public when reviewing the type of action they believe is most appropriate for a specific site. The data base would also contain information about the latest technological developments and the costs of treatments. These components would enable contractors and vendors to keep abreast of the market. Eventually, the data base could also contain more detailed performance data for use by states and EPA regional staff. This more detailed data would assist them in selecting technologies. The screening of input was considered a difficult, resource intensive problem by Group A. They viewed an interactive system as useful, but limited by the quality of data entered. Group B was concerned that a lack of computer hardware and expertise would limit access to the data. EPA personnel as 23 ------- well as individuals desiring to access the data, would need both training and equipment. The group concluded that the crucial components for effective use of the database are a well-publicized telephone number and highly-trained personnel to trouble shoot computer problems. Group C limited its discussion of a Clearinghouse to a computer-based system. They specified the proposed computer data base must be both easy to access, consistent with existing data bases, and provide technical assistance to users. It was suggested that this support could be modeled after the Office of Solid Waste (OSW) Permit Assistance Teams (PAT's). Sources of data, defined by Group B, include the following: 1. EPA Activities o SITE program concerning demonstrations and research (including applications of technologies) o ORD research and demonstration tests (including actual and developmental technologies) o Alternative technology studies o Superfund pilot projects, treatability studies, bench scale studies, and field experience reports 2. Industry o RCRA permit trial burns o Consultants (to industry or EPA) o SITE, Superfund, permit application, developmental work by PRP's, pilot studies, and feasibility studies 24 ------- o RCRA corrective action o Private cleanup efforts. Although companies and vendors are reluctant to report unsuccessful experiences, failures should be documented. 3. DOD/DOE site work. (This source, was not enumerated by Group B, but contributed by a reviewer). 4. Academia o Research and development funded by EPA through state funds or by industry 5. States o Research and development funded by EPA, state, or industry o Cleanups funded by EPA 6. Citizen Groups and Environmental Groups 7. Experience from foreign countries should be tapped to identify new technologies and effective types of site management. QUESTION 4: IN WHAT FORMS SHOULD THE INFORMATION BE PRESENTED? This topic was not discussed explicitly, but Group B suggested case studies and bibliographic abstracts as an initial format. It was assumed by each of the groups that the 25 ------- form of presentation depended upon the type of information, its source, and most importantly upon the user and the user's needs. QUESTION 5: HOW SHOULD THE AGENCY OBTAIN THE INFORMATION? All groups agreed that the effort of gathering information for a Clearinghouse varied with the data source. They also agreed that contractors to the EPA should be required to gather and submit data as a part of their contract. Regions and states could be strongly encouraged to provide information when it becomes available. PRP's could have conditions written into consent decrees. Information from privately funded cleanups, however, is extremely difficult to gather. Group C suggested that a staff of at least one or two people would be needed to ensure consistent quality and coordination of materials collected. In addition to sources identified above, Group C and Group D cited EPA research results and vendor proposals. Group D also included other federal agencies, specifically DOE, DOT, and DOD, as potential sources of information for the Clearinghouse. The inclusion of case studies was strongly supported. Group D focused upon potential conflict that could arise from a Clearinghouse providing technical information. The need for factual data and evaluations of technologies must be counterbalanced by EPA's current efforts to develop treatment 26 ------- standards under statutory mandates. Consequently, the Agency should not compromise rulemaking by processing "evaluations" through a Clearinghouse. Official Agency evaluations can occur only through formal rulemaking, otherwise, EPA could be subject to legal challenge. However, quality-controlled data without EPA value judgment could be disseminated through a Clearinghouse provided that it was clear that such dissemination did not imply endorsement. A Clearinghouse could provide impartial technical information without making technical judgements. QUESTION 6: SHOULD THE AGENCY GUARANTEE QUALITY ASSURANCE AND QUALITY CONTROL (QA/QC) OF THE DATA? Systems of QA/QC which already exist for the reference library were considered adequate, but procedures for the computer database were questioned. The consensus was that it is virtually impossible to require consistent QA/QC procedures for all material to be entered. Group A suggested reporting the specific procedures used and providing a list of sources to accompany each data entry. This documentation will provide sufficient information to users which could allow them to judge the validity of the information for themselves. Group B determined that the EPA should encourage consistency by establishing a QA/QC format. Group C believed that a rigorous method of ensuring the accuracy of data entry was essential for users to have confidence in the 27 ------- system and a strong desire to use it. Group D recommended that EPA establish a 'filter1 process to ensure that QA/QC is applied prior to Clearinghouse data entry. That group also suggested that QA/QC data be included with any information provided to prospective users. According to Group C, potential engineering design users did not want to limit the availability or timeliness of information by the delays necessitated by extensive peer review or quality control. For Remedial Investment/Feasibility Studies (RI/FS) type evaluations, all data has some value to the decision-making process. For new technologies, no peer reviewed data may be available for a few years. Some indication of the level of QA/QC and of peer review could be indicated for each data set entered. Then the user can evaluate the data for his own needs. Furthermore, Group C believed that establishing burdensome requirements for contributing data to the system would discourage private researchers and developers from entering data. Speed of entering data and completeness were judged the most important data characteristics. Technical users familiar with sources and the level of review or quality assessment should be able to judge the utility and applicability for their intended use. 28 ------- Group D believed EPA's "peer review" system would unreasonably expand the time required for data entry. Except for its own projects and reports, EPA should not be responsible for performing QA/QC. The responsibility for performing QA/QC procedures could be the responsibility of the originators of data and reports. As a compromise for the sake of timeliness and accuracy, guidelines could include possibly as many as four levels of stringency. This would allow inclusion of preliminary data and reports as well as final reports. EPA evaluation, by contrast, would only be included in a Clearinghouse as a final Agency document, report, or rule. OTHER ISSUES AND RECOMMENDATIONS o User fees and/or charges would help to determine budget requirements, staffing needs, and the frequency of use. Group A assumed that if a charge for access were . imposed, it might hinder public use of a Clearinghouse. Consequently, Group A recommended that there should be no charge for use of the Clearinghouse hotline or the reference library. To defray operating expenses, a fee should be charged for more detailed information. A fee could be charged for either computer access or for consulting information. o A 900 hotline telephone number was suggested as an alternative to an 800 number. The purpose of imposing a charge was to reduce the incidence of frivolous calls. 29 ------- Group B believed that industry would gladly pay to use a Clearinghouse, but that data input might possibly be accepted as their "currency" for access. Citizen groups, by contrast, should not be charged anything, or they could be required to pay only a nominal fee. o Funding - A recommendation was made by Group A to allocate 10% of the SITE program budget to the proposed Clearinghouse activities. This would provide immediate funds for a pilot project. Additional funding could be budgeted in successive years. o Prototype Clearinghouses - The EPA was encouraged to use existing Clearinghouses as models (provided that they have operated successfully). Competition for users among the data bases that already exist was noted. o Two-Tier Referral - This first-tier should consist of a trained Clearinghouse hotline staff member who refers a caller to a consultant, a field worker, or an appropriate service representative. The second-tier person should be a troubleshooter who can respond to either a field problem or to a computer search problem. o Minimal Response - Group B suggested the following alternative approach if sufficient funding for a full-scale program is not available, or if industry is unwilling to input information. 30 ------- 1. A bibliography 2. A data base of appropriate types of treatment, or chemical, or site. o Ultimate Response - Fact sheets should analyze each technology and make projections about its efficiency and cost. The fact sheets should be supplemented with a technical resource person who can back up and amplify the information provided with a telephone conversation. o In addition to technical data, and contract terms and conditions, a Clearinghouse should also include internal directives, policies, and procedures. o The proposed system should be capable of instant response, and should also be able to be updated quickly and regularly. 31 ------- CONCLUSIONS OF THE FORUM The principal conclusions and recommendations from the forum include the following: Would you find a Clearinghouse useful? o The group concluded that a Clearinghouse for information about hazardous waste cleanup technologies should be established. What components would you find most useful? What types of information would you need from a Clearinghouse? o The most useful components of a Clearinghouse would be a central reference library and a hotline. These should be established as soon as possible, and they should build on existing systems. o A technical information network of computerized data bases would also be useful. o There was limited interest for additional specialized publication services, but the need to collect existing publications of data, and preference for different data components varies according to need. 32 ------- o Whenever possible information about hazardous waste treatment and remedial technologies should include cost data. In what form should the information be presented? o Information should be presented through a library collection, a hotline, specialized publication services, and new and existing data bases. o Initially, the Clearinghouse should have a limited scope and focus rather than attempting to be "all things to all people." How would EPA obtain the information? o Information about hazardous waste cleanup technologies should be obtained from the SITE program, government agencies, contractors, industry and academics. o There should be a hierarchy of levels of information available from a Clearinghouse. o A Clearinghouse should provide impartial technical information without making technical judgements. 33 ------- Should EPA QA/QC the data? o EPA was encouraged to established QA/QC procedures for the detailed technical information to be included in a clean-up technology data base. o It is virtually impossible to require consistent QA/QC procedures for all data to be entered in a Clearinghouse, o Since all treatment technology information was thought to have some potential value, information with little or no QA/QC could also be included in a technology data base provided the source of the data was identified. o A process must be developed to regularly review the effectiveness/ utilization/ and quality of data of whatever system or systems are established. What other conclusions were made? o User fees or charges should vary according to the level of detail provided and the ability to pay. o Public use of the Clearinghouse should be encouraged through publicity, simplicity, and little or no charges. 34 ------- FUTURE DIRECTIONS Alfred Lindsay, EPA/OEET, ORD, concluded the forum by discussing future directions of a Clearinghouse. Efforts to create a RCRA/CERCLA Clearinghouse have benefitted from the input of regional EPA staff, contractors, PRP's, other Federal agencies state governments, environmental groups, and citizens. This forum has provided EPA with valuable expertise and insight about the specific needs of cleanup technology information users. Information obtained from the forum will help EPA understand a variety of views and needs of potential users of a Clearinghouse. Because funding for a Clearinghouse is limited, it is important that EPA understand the priorities and attitudes of the conferees about user fees. Participants would receive the draft report. After their comments were incorporated, a final report would be distributed. Knowledge from the forum will help EPA to determine the nature and scope of the Clearinghouse. EPA plans to further evaluate responses, develop options, and make a decision about what, it any, actions will be taken to supplement the central reference library. If an expanded program is approved a coordinator could be selected, allocation of resources determined, and schedules set. The expanded system could be one that incorporates phone-in access. 35 ------- Mr. Lindsey concluded the forum by thanking participants on behalf of EPA. 36 ------- APPENDIX A AGENDA OF THE CERCLA-RCRA CLEANUP TECHNOLOGY CLEARINGHOUSE April 22, 1987 Reception Dinner Greetings: Alfred Galli, USEPA Computerized Data Base Demonstrations DOE HWERL/Edison Maryland Hazardous Waste Siting Board USEPA Library April 23, 1987 Breakfast Greetings: Thomas Devine, US EPA; David Standley, Tufts University Purpose of the Meeting: Alfred Lindsey, USEPA Assessment of Needs Clearinghouse Composition Types of Wastes Included Types of Technologies Covered Potential Clearinghouse Components Central Reference Library: Loretta Marzetti, USEPA Clearinghouse Hotline: Patricia Conn, Geo/Resources Specialized Publication Services: Beverly Campbell Technical Resources Newsletters Fact Sheets Site Specific Technology Specific Project Specific TSDF Vendors Remedial Contractors Resource Directory 37 ------- Technical Information Network Data Base Overview: C.C. Lee, EPA/HWERL-Cincinnati Data Bases: Cathy S. Fore, DOE HAZWRAP Case History File: Richard Griffiths, EPA/HWERL-Edison Countermeasure Selection System: Richard Griffiths, EPA/HWERL-Edison Break Discussion Group Sessions Would you find a Clearinghouse useful? What components would be most useful? What types of information would you need from a Clearinghouse? Lunch Continuation of Discussion Groups: In what form should the information be presented? How would the EPA obtain the information? Should the EPA QA/QC the data? Break Discussion Group Reports Future Directions for Establishing a Clearinghouse: Alfred Lindsey, USEPA 38 ------- APPENDIX B CERCLA/RCRA CLEARINGHOUSE MEETING DISCUSSION GROUPS Group A 3 Charles Gardner 0 Doris Cellarius 2 Clarence Clemens Alfred Galli 5 Jud Hill 2 Maggie Lesher 4 Steven Paquette 3 Kim Wilhelm Group B 3 Susan Shaer 2 Bill Hagel Alfred Lindsey Loretta Marzetti Jane Powers 0 Susanne Schmidt Jack Stanton 3 David Thomas Group C 3 Susan Wiltshire Thomas Devine 4 Tom Donley Dana Duxbury Jannette Hansen 6 William MacDonald Greg Ondich 9 William Porter 7 Matthew Prastein 3 William Sloan Group D 3 Barry Jordan Jim Berlow 6 Norine Brodeur 2 William Cawley 8 John Lehr 8 O.S. Ratterman David Standley u> VO 4 Beverly Campbell 4 Patricia Conn 8 Cathy Fore RESOURCE PEOPLE 2 Dan Greathouse 4 Rich Griffith Eileen Schell 2 C.C. Lee Emma McNamara Barbara Roth PERSONNEL CODING EPA Headquarters 2 EPA Regions 3 State Government 4 Superfund/RCRA Contractor 5 Vendor 6 Citizen Group 7 Department of Defense (DOD) 8 Department of Energy (DOE) 9 Potential Responsible Party (PRP) 0 Environmentalist Academia 2 EPA - Cincinnati Laboratory 3 Facilitator 4 EPA - Edison Laboratory ------- APPENDIX C CLEARINGOJSE MEETING ATTENDEES LIST 4/22-23/87 it Berlow .ief, Treatment Technology USEPA, Office of Solid Waste 401 M Street, SW, (WH-565A) Washington, DC 20460 (202) 382-7917 Norine Brodeur Ayer City Homeowners Association 3 Waverly Avenue Lowell, MA 01852 (617) 454-5792 Beverly Campbell Technical Resources, 3203 Monroe Street Rodcville, MD 20852 (301) 231-5250 Inc. William Cawley Deputy Director, HWERL USEPA, Office of Research & Development 26 West St. Clair Street Cincinnati, OH 45268 (513) 569-7896 Doris Cellarius Toxics Laws Implementation Campaign Sierra Club 2439 Crestline Olympia, WA 98502 f206) 943-6875 Clarence Clemens CERI, USEPA 26 West St. Clair Cincinnati, OH 45268 (513) 569-7391 Patricia Cohn Director, RCRA/CERCLA Hotline Geo/Resources Consultants, Inc. 401 M Street, SW, Room 5212 (WH-562) Washington, DC 20024 (202) 488-1487 Thomas Devine Director, Office of Program Mgmt & Tech. Office of Solid Waste & Emergency Respon 401 M Street, SW, Room S-306 Washington, DC 20460 (202) 475-8716 John W. Donley Manager, Government Division AT Kearney, Inc. 699 Prince Street Alexandria, VA 22314 (703) 836-6210 Dana Duxbury Senior Environmental Analyst Tufts University, CEM Curtis Hall, 474 Boston Avenue Medford, MA 02155 (617) 381-3486 Cathy S. Fore "<•:. HAZWRAP J. Box Y Oak Ridge, TN 37831 (615) 574-7769 Alfred Galli Chief, Air and Energy Staff USEPA, Env. Eng. & Tech. Dev. 401 M Street, SW Washington, DC 20460 (202) 382-5753 (RD-681) 40 ------- ^rles Gardner, Facilitator .- Tower Street Jamaica Plain, MA 02130 (617) 367-6058 Daniel Greathouse Project Officer USEPA, HWERL 26 West St. Glair Cincinnati, OH 45268 (513) 569-7859 Richard Griffiths Physical Scientist, USEPA Releases Control Branch, HWERL Woodbridge Avenue, Rariton Depot, Bid 10 Edison, NJ 08837-3679 (201) 340-6629 William Hagel Regional Project Manager USEPA, Region III 841 Chestnut Street, Mailcode 3HW24 Philadelphia, PA 19107 (215) 597-0517 Jannette Hansen Permits and State Programs Division USEPA, Office of Solid Waste (WH-563) 401 M Street, SW Washington, DC 20460 '•>02) 382-4754 A. Judson Hill Regional Vice President Shirco Infrared Systems, Inc. 6 Montgomery Village Avenue, Suite 620 Gaithersburg, MD 20879 (301) 670-6300 Barry Jordan, Facilitator President Jordan Communications, Inc. 121 Mt. Vernon Street Boston, MA 02108 (617) 742-2763 C.C. Lee Research Program Manager, HWERL USEPA, Alternative Technologies Division 26 West St. Clair Street Cincinnati, OH 45268 (513) 684-7520 John C. Lehr Environmental Engineer US Department of Energy (DP-124) Washington, DC 20545 (301) 353-3007 Robb Lenhart Environmental Technology Division Westinghouse Electric Corporation P.O. Box 286, Mail Bin #37 Madison, PA 15663-0286 (412) 722-5248 Margaret Leshen "PA, Region I ..nn F. Kennedy Bldg, Room 2203 Boston, MA 02203 (617) 565-3715 Alfred Lindsey Deputy Director, USEPA, Env. Eng. & Tech. Dev. (RD-681) 401 M Street, SW Washington, DC 20460 (202) 382-4073 41 ------- \liam MacDonald i.jss Toxics Network 761 Berkely Street Berkley, MA 02780 (617) 823-2200 Loretta Marzetti Chief, Information Services Branch USEPA Office of Information Resources 401 M Street, SW, Room 2005 (PM211D) Washington, DC 20460 (202) 475-8710 Emma McNamara Head Librarian USEPA Headquarters Library (PM-221A) 401 M Street, SW Washington, DC 20460 (202) 382-5922 Gregory Ondich Chief, Hazardous Waste & Superfund Staff USEPA, Env. Eng. & Tech. Dev. (RD-681) 401 M Street, SW Washington, DC 20460 (202) 382-&6S3 J. Steven Paquette COM Federal Programs Corporation 7611 Little River Turnpike Annandale, VA 22003 (703) 642-0544 William M. Porter Engineering Department E.I. du Pont de Nemours & Co. P.O. Box 6090 Newalk, DE 19714-6090 (302) 366-4439 Inc. Jane Powers Office of Program Mgt. & Technology USEPA, Office of Solid Waste (WH-54SA) 401 M Street, SW, Room M2003 Washington, DC 20460 (202) 475-8710 S. Matthew Prastein Special Assistant to the Director of Environmental Restoration The Pentagon, Room 3D.833 Washington, DC 20301-8000 (202) 695-7820 0.S. Ratterman Monsanto Corporation 800 N. Lindbergh Blvd., F2WJ St. Louis, MO 63167 (314) 694-6729 Barbara Roth Information Services Branch (PM-211D) USEPA Office of Information Resources 401 M Street, SW, Room M-2003 Washington, DC 20460 (202) 382-7879 Eileen Schell ets Unversity, CEM w-rtis Hall, 474 Boston Avenue Medford, MA 02155 (617) 381-3486 Susanna Schmidt Natural Resources Defense Council 122 E. 42nd Street, 45th Floor New York, NY 10168 (212) 949-0049 42 ------- ;an Shaer, Facilitator rresident League of Women Voters of MA 2 Seminole Circle Andover, MA 01810 (617) 470-1133 William Sloan Maryland Hazardous Waste Facilities Siting Board 60 West Street, Suite 20 Annapolis, MD 21401 (301) 269-3432 David Standley Tufts University, GEM Curtis Hall, 474 Boston Avenue Medford, MA 02155 (617) 381-3486 Jack Stanton Office of Regional Operations (A-101) USEPA, Office of the Administrator 401 M Street, SW, Room 1222-West Tower Washington, DC 20460 (202) 382-4123 David L. Thomas Director of Hazardous Waste Research & Information Center for IL 1808 Woodfield Drive Savoy, IL 61874 333-8940 Kim Wilhelm Sr. Engineer, Alternative Technologies Department of Health Services 744 P Street Sacramento, CA 95814 (916) 322-5347 Susan Wiltshire Facilitator 77 Fox Run Road S. Hamilton, MA 01982 (617) 468-2702 John Zipeto Environmental Engineer USEPA, Region I JFK Federal Building, Mailcode HRR-CAUS Boston, MA 02203 (617) 223-1353 43 ------- |