US EPA New England Region
Office of Environmental Stewardship
2003 Annual Report
&EPA
United States
Environmental Protection
Agency New England
-------
US EPA New England
Office of Environmental Stewardship
1 Congress Street, Suite 1100
Boston, MA 02114-2023
617-918-1700
February, 2004
On behalf of all the employees of EPA New England's Office of Environmental Stewardship, I am pleased
to present our Annual Report for 2003. This report captures the results of the integrated efforts of our
Enforcement and Assistance & Pollution Prevention Offices.
Our work this past year continues to show that we are most effective when we identify environmental, public
health or compliance problems and appropriately integrate the tools at our disposal to solve them. The
organization of this report reflects how we view and go about tackling the challenges remaining in New
Engknd.
We've also learned that there are readers who are interested in greater detail about the work of either the
Enforcement or Assistance & Pollution Prevention Offices. We will be making reports for each office and
other information relating to our work available on EPA New England's Enforcement and Assistance web
page: www.epa.gov/ne/enforcementandassistance.
We hope you will find this report informative and that it will inspire you—whether as a citizen, a public sector
official, or a company owner—to embrace your role as a steward of New England's environment We
welcome your feedback on this report; send us an email at rlweb.mail@epa.gov or call us at 617-918-1831.
Stephen S. Perkins, Director
Office of Environmental Stewardship
EPA New England
-------
Table of Contents
Introduction 4
Protecting the Health of Our Most Sensitive Populations 5
Reducing Environmental Impacts on Our Communities 9
Addressing Widespread Non-Compliance 13
Homeland Security and Emergency Preparedness 15
Promoting Continuous Environmental Improvement Through
Environmental Management Systems 16
Advocating for Superior Environmental Performance 18
Conclusion 20
For Further Information 21
-------
introduction
The Office of Environmental Stewardship is
home to the enforcement and compliance
assistance programs in EPA's New England
Office. We protect the environment and public health
by improving the environmental performance within
both the private and public sectors through ensuring
compliance with environmental requirements,
preventing pollution and promoting environmental
stewardship.
Highlights of our achievements in New England over
the past federal fiscal year (October 2002 through
September 2003) include:
•$12.24 million paid by violators to settle
enforcement cases, including a record $8.7
million for environmental projects that will
result in tangible environmental and public
health benefits to New Englanders;
•158 settlements and orders completed for a
total of $87 million in expenditures by
violators to come into compliance and to
reduce, treat, or properly manage 14.3
million pounds of pollutants;
•$42.3 million recovered from responsible
parties for past and future clean-up costs at
Superfund sites throughout New England;
•700 inspections carried out across the region,
a 33 percent increase from last year;
•115 self-disclosures of environmental
problems identified and fixed; and
•25,000 New Englanders reached through
319 workshops and 74 stakeholder meetings.
But numbers alone do not tell the entire story of our
accomplishments. This report will provide you with
the details of how we achieved these impressive
results. It places our work in the context of the tools
and approaches we use to achieve our compliance
mission. For example, our work with area colleges
and universities exemplifies how we have integrated
aggressive enforcement and assistance to achieve
improved environmental compliance at these
institutions of higher learning. In this report, we
discuss why and how we are working to reduce
childhood lead poisoning in New Engknd and
striving to create an environment that is safe for our
children. And, we want you to know that through
negotiated enforcement settlements, which result in
environmental projects, we are producing tangible
environmental and public health results for the
benefit of all New Englanders.
We continue to present our accomplishments in this
annual report around the problem-solving themes
adopted by our office in 2002. Our intent is to help
you better understand how our actions support our
mission. These themes include:
•Health effects on sensitive populations;
•Environmental impacts on communities;
•Persistent and widespread non-
compliance;
•Homeland security and emergency
preparedness;
•Continuous improvement through
Environmental Management Systems;
and
•Advocacy for superior environmental
performance.
-------
Protecting the Health of Our Most Sensitive Populations
~W~VT"7hile protecting human health and the
\ \ I environment is the overall mission of EPA,
V V we focus particular attention on certain
groups of people such as children, the elderly, and
minority and low income groups because of their
increased vulnerability to environmental threats.
Children, for example, breathe more air, drink more
water and eat more food in proportion to their size
than adults. This puts them at greater risk of
exposure to pollutants. Abo, children's bodies are less
able to metabolize, detoxify and eliminate pollutants.
As we age, our bodies become more susceptible to
pollutants because the capacity of our immune
system diminishes. This is due in part to the aging
process itself, medications we may take or chronic
illnesses we may have developed. In addition, older
adults already have a lifetime of exposures to toxic
substances that persist in their bodies. These factors
become even more troubling when you consider that
the United States is undergoing a demographic
transformation. By 2030, the number of elderly is
expected to double to 70 million. The 85 and older
population represents the fastest growing age group,
which is expected to number 14 million by 2030.
EPA is committed to ensuring that everyone enjoys an
equal level of environmental protection. Unfortunately,
we know from the past that some communities, such as
those in minority or low income areas, may not have had
the access or resources to get their concerns addressed.
As a result, these communities suffer a disproportionate
impact from pollution or public health threats. Since
1993, when EPA's New England Regional Office
established its first environmental equity policy, we have
been incorporating environmental justice principles for
fair treatment and meaningful involvement into our
enforcement and compliance assistance programs.
Whether establishing office priorities or settling
enforcement violations, we look for opportunities to
promote and support environmental justice for all
New Englanders.
In the next sections of this report, you will read about
our enforcement and compliance assistance activities
over the past year and how they reflect the Agency's
focus on our most vulnerable citizens.
Improving the K-12 School Environment
Typically, you can find a wide variety of chemicals in
a school environment such as cleaning solutions,
pesticides, and laboratory supplies. Over the past
year, we have continued to assist schools with
selecting, utilizing and managing these chemicals. We
have found that schools are interested in improving
procedures for handling and storing chemicals so that
they can reduce the risk of an accidental release of
these hazardous materials. We disseminate technical
information on regulatory requirements, as well as on
the proper selection, handling, storage and disposal
of these chemicals. In 2003, we provided chemical
management training at three workshops in Maine
and Massachusetts to over 200 participants. With
$22,000 in grant funds, we are supporting a project in
Massachusetts that will assist K-12 schools in
increasing their ability to purchase "greener"
products, such as less toxic cleaning supplies.
Lead in drinking water is another area that we are
working colkboratively with our New England states
and K-12 schools to address. Through our outreach
efforts, we want school administrators to understand
the seriousness of the issue and the importance of
testing drinking water for lead. Unless a school is
considered a drinking water system by EPA or state
regulation, regular testing for lead in a school's
drinking water is not required. Lead can be found in
schools in both urban and suburban communities.
Improving Air Quality
Pollutants in the air we breathe come from a
multitude of sources and degrade the quality of our
air by creating smog, causing cancer, and triggering
asthma and other respiratory illnesses. Over the past
year, we pursued several significant Clean Air Act
enforcement cases that will reduce the levels of air
pollutants such as volatile organic compounds
(VOCs), particulate pollutants, and methane gas.
For example, the Rhode Island Resource Recover)'
-------
Corp., owner/operator of Central Landfill, the largest
landfill in the state, will pay a $321,000 penalty and
spend more than $5 million on air pollution control
measures for alleged violations of the Clean Air Act
Central Landfill, located in Johnston, RI, is a 190-acre
landfill which handles most of the state's household
and commercial waste. Noxious odors from the landfill
gas have been a long-standing source of complaints
among residents living near the landfill, and controlling
and capturing landfill gas at this site is a complex
challenge.
As part of its settlement, the Rhode Island Resource
Recovery Corp. will install new pollution control
systems that will capture and control over 30,000
tons of methane (a global warming pollutant), 215
tons of VOCs (a contributor to smog air pollution),
and 175 tons of nitrogen oxides between now and
2010. Also, the corporation will boost the facility's
overall capture/control efficiency of landfill gas to 90
percent or better, and will retire 175 tons of emission
credits (allowances to emit smog-causing pollutants).
This case represents one of the first enforcement
actions in the country taken against a solid waste
landfill for violations of the Clean Air Act's New
Source Review requirements and should lead to
significant improvements in air quality for Rhode
Islanders living in close proximity to the facility.
Retiring emission credits provides
environmental benefits by reducing pollution.
Under the market-based pollution trading
rules, companies can sell their rights to emit
certain amounts of air pollution to other
companies that may be building a new facility
or expanding an existing one. However, once
these credits are retired, the pollutants they
represent are no longer available for trading.
In another action, MacDermid Graphic Arts Inc. of
Waterbury, CT agreed to pay a penalty of $230,000
and to permanently retire as much as 150 tons of
VOC emission credits per year to settle an
enforcement case regarding alleged Clean Air Act
violations at its former manufacturing plant in
Adams, MA. Between 1997 and 2001, MacDermid
exceeded allowable emission limits for VOCs at its
plant, which manufactured rubber products for the
commercial graphic arts industry. The agreement
ensures that these VOC credits will never be
available to be used by other sources of pollution.
Also, Allied Waste Systems, Inc., a Boston trash
hauler, paid a penalty of over $780,000 and will
spend $2.3 million on an environmental project to
improve Boston's air quality surrounding its transfer
station in Roxbury, MA. The settlement stems from
the company's alleged violations of Clean Air Act
rules intended to protect the stratospheric ozone
layer from harmful effects of certain chemicals
known as chloroflurocarbons (CFCs) and
hydrochloroflurocarbons (HCFCs). These
chemicals, commonly found in refrigerants, are
known to cause the depletion of the stratospheric
ozone kyer that protects the earth's surface from
harmful ultraviolet radiation. Under EPA
regulations, waste haulers who dispose of
household appliances containing CFCs or HCFCs,
such as refrigerators, freezers and air conditioners,
must take steps to ensure that these chemicals are
not released into the atmosphere.
Between July 1997 and August 1998, the company
allegedly compacted or crushed discarded appliances
picked up in Boston's neighborhoods without
recovering remaining refrigerants from the appliances
or verifying that the refrigerants were already
removed. Allied's environmental project involves
constructing a new building at its Roxbury transfer
station and installing state-of-the-art emissions
control technology capable of reducing dust, odors
and VOCs. This will not only improve the aesthetics of
the station and provide for more efficient waste transfer
operations, but more importantly, it will improve the
quality of the air in the surrounding neighborhoods.
In another case involving ozone-depleting chemicals,
we ordered Pratt & Whitney of East Hartford, CT, to
-------
adopt a more accurate method for calculating leak
rates of its refrigeration equipment and to provide
more information about the recovery and disposition
of approximately 50,000 pounds of CFCs and
HCFCs at its Andrew Willgoos Turbine Laboratory.
The facility tests commercial and military gas turbine
engines and uses an older refrigeration system to
simulate the low temperatures encountered at high
altitudes. Pratt & Whitney will cease using these
chemicals in May 2004.
Also, Ethan Allen, a Vermont-based wood
manufacturer and retailer, agreed to pay a $74,00
penalty for allegedly emitting particulate matter at a
rate more than twice the legal limit in 2001 at its
manufacturing facility in Orleans, VT. The company
promptly shut down the two violating wood-fired
boilers and repaired the pollution controls. After the
repairs, the boilers were tested and determined to be
back in compliance with their emission limits.
Particulate matter (PM) is a term for particles
found in the air, including dust, dirt, soot, smoke
and liquid droplets. These particles come from a
variety of sources such as vehicle exhaust, factories,
construction sites, unpaved roads, and the burning
of wood. They are formed indirectly when gases
from burning fuels react with sunlight and water
vapor. PM causes a variety of health and
environmental impacts, which can be especially
serious for people with heart and lung disease.
Reducing Lead Paint Exposure
Lead is a toxic metal that causes a variety of health
effects from behavioral problems and learning
disabilities to seizures and death. Children under the
age of six are most at risk because their bodies are
growing rapidly. The problem is of particular concern
to us here in New England due to the age of our
housing stock, much of which pre-dates 1978, and a
housing shortage that forces many low-income
families in urban areas to remain in older housing
with deteriorating lead paint or face homelessness.
In order to tackle the problem of childhood lead
poisoning, EPA New England set a goal to eliminate
medically confirmed blood levels greater that 10
micrograms per deciliter among children under age 6
in New England by 2010. A critical component of
the strategy includes increased compliance assistance
and enforcement activity to ensure that landlords and
property owners are complying with the federal law,
known as the "Disclosure Rule." This rule requires
them to notify tenants and prospective buyers of
potential lead paint hazards in their buildings. This
year, we conducted more than 100 inspections
affecting more than 40,000 housing units within New
Engknd.
Because the Disclosure Rule is an important part of
our work in creating an environment that is safe for
our children, we have taken enforcement actions
against several property owners and managers across
the region for failing to notify prospective tenants of
potential lead paint hazards. For example, we have
filed complaints against landlords and property
managers in Pepperell, MA (Nissitissit Group, Ltd.), in
Hartford, CT (Intown Management Corporation;
Intown West Associates, Limited Partnerships; and
Apartment Investment and Management Company),
and in Biddeford, ME ( 94 Cleaves Street) for alleged
Disclosure Rule violations.
The Lead Disclosure Rules apply to all landlords,
including agencies of the federal government. As a
result, we cited three Veterans Administration
Hospitals in Maine and Massachusetts for allegedly
failing to notify VA employees of potential lead paint
hazards in their rental housing units. These medical
centers provide a total of 61 units of on-site housing
for employees and their families.
In one of the first actions of its kind, a Portland, ME
lead abatement contractor faces a potential $112,000
fine from EPA for allegedly violating state regulations
regarding lead paint removal work at nine residences
-------
in Portland, Lewiston, and Livermore Falls. Because
lead poisoning can cause a lifetime of problems for
children, it is also important that procedures for lead
paint abatement work be followed.
While we 'have placed a great deal of attention on
Section 1018/Real Estate Notification
and Disclosure Rule requires landlords,
property management companies, real estate
agencies and real estate sellers of pre-1978
housing to notify potential tenants and buyers
of the presence of lead paint and its hazards.
Section 406(b)/Pre-Renovation
Education Rule requires remodelers,
renovators, contractors and landlords of pre-
1978 housing to notify owners and tenants of
the presence of lead paint before the remodeling
or renovation work is performed.
outreach and enforcement to reduce the risk of lead
paint exposure, we are also working to identify and
support the development of new lead removal and
encapsulation technologies. During the process of
home renovation and remodeling, large amounts of
lead dust can be produced. Unfortunately, traditional
cleaning methods often leave hazardous levels of
lead dust behind. The result is that children and
workers face an increased risk of acquiring elevated
blood lead levels. In order to lower the risk, it is
necessary to develop efficient and cost-effective
technologies for stabilizing lead-based paint or
removing the paint without creating dust.
Working with EPA's national Research and
Development Office, we were able to secure
$365,000 in funding through the Small Business
Innovative Research program for two companies,
Phoenix Science and Technology of Chelmsford,
MA and Pennsylvania-based EMEC, to develop and
test lead removal technologies that do not create
lead dust. These technologies will be ready for
demonstration and testing in 2004.
-------
Reducing Environmental Impacts on Our Communities
Creating healthy communities for us to live and
raise our families in requires that we work
hard to protect the quality of our water and
land resources. Pollutants continue to impact our
communities from a variety of sources. Some
pollutants occur naturally, such as arsenic in
groundwater. Ever}' time it rains or snows, however,
storm water runoff negatively impacts the quality of
our surface waters. Municipal sewer systems that are
not operating properly can also pose a significant
public health threat. In addition, contaminated
Superfund sites continue to remain as legacies of
yesterday's poor waste disposal practices. Following
are the highlights of our work last year to reduce
environmental impacts in communities throughout
New England.
Reducing Arsenic Levels in Small Drinking
Water Systems
More than 100 small public water systems in Maine
have levels of arsenic in their drinking water that
exceed the new 2006 federal limit of 10 parts per
billion (ppb) and a large number of these systems are
schools. Research studies link ingested arsenic with
health effects, including cancers of the bkdder, skin,
lung, and kidney, as well as non-cancerous conditions
such as high blood pressure and diabetes.
To help small drinking water systems comply with the
stricter arsenic standard, we teamed up with the
Maine Drinking Water Program, the Maine Rural
Water Association and the University of Maine to
conduct four workshops on the regulations and
treatment options. These workshops attracted 110
participants .who represented nearly half of the 102
small public water systems and 42 schools in the state
with high arsenic levels. As part of the workshops,
participants identified a number of challenges they
will face in meeting the upcoming regulatory standard
and developed an action plan that will help them to
meet their obligations. Similar outreach efforts are
planned for New Hampshire and Vermont in 2004.
Controlling Runoff from Storm Water
Storm water runoff is caused by rain and melting
snow that runs off land, pavement, construction
sites, rooftops, and other surfaces and flows into
water bodies. The runoff accumulates sediment and
pollutants as it travels across land. In addition, heavy
precipitation or snow melt can cause sewer overflows
which, in turn, leads to contamination of water
sources with untreated human waste, industrial
waste, toxic materials and other debris.
While significant progress has been achieved in
controlling and reducing pollutants in our waterways,
storm water runoff remains a leading cause of water
quality problems nationwide. In New England, more
than one-third of our streams and rivers remain
unsafe for swimming, boating and other activities,
especially after wet weather events.
Storm water runoff transports pollutants
such as oil and grease, toxic chemicals,
pesticides, nutrients, and bacteria from land
to our surface water resources. These waters
are vital to meeting our drinking water
needs, supporting wildlife, and for our
recreational enjoyment.
Because storm water runoff remains the leading
cause of water quality problems, we are continuing
our efforts to bring municipalities and the
construction industry into compliance with storm
water regulations and new permitting requirements
that went into effect in March 2003. These efforts
include extensive outreach and increased inspections
and enforcement As a result of our outreach
activities, 90 percent of the regulated municipalities
and municipal operations in the non-delegated states
of Massachusetts and New Hampshire applied for
permit coverage. In addition, through our
construction workshops and presentations, we
reached over 1,100 people with information on
compliance. Since 2001, we have conducted nearly
50 inspections at construction sites across the region
and more are planned.
-------
Many of the inspections led to enforcement actions
against violators. For example, Lowe's Home Centers,
Inc. agreed to pay a penalty of $137,500 for allegedly
failing to obtain the necessary federal permits for
storm water discharges and to prepare required storm
water pollution prevention plans for four
construction sites in Massachusetts. In addition, the
company allegedly failed to implement adequate
storm water controls in 2001 at its Woburn, MA site.
As a result, silt-laden water was discharged into a
storm drain that led to the Aberjona River.
Lowe's, the second largest home improvement retailer
in the world and the 14th largest retailer in the
country, has more than 800 stores in 45 states and is
in the midst of an expansion plan that involves
opening a new store on an average of every three
days across the country. As a result of our action, the
national chain has embarked on a comprehensive
nationwide pkn to improve its storm water
management program. The company has set up new
criteria and staff training to ensure that all of its sites
meet or exceed EPA storm water criteria.
In a second case, Brox Industries, Inc. of Dracut,
MA, agreed to pay more than $260,000 for allegedly
tailing to comply with various provisions of the
federal storm water rules at six of its eight asphalt
manufacturing and mineral mining sites in
Massachusetts and New Hampshire. The company
will also spend a minimum of $138,000 on an
environmental project at its Hudson, NH facility to
reduce discharges of process waste water and
increase the use of recycled water for its operations.
Protecting and Restoring Wetlands
Wetlands are among the most biologically important
and productive ecosystems on earth. Not only do
they provide critical habitat for fish and wildlife,
wetlands also offer protection against flooding and
erosion. They replenish the groundwater, improve
water quality, and provide countless recreational
opportunities. Our New England states estimate that
up to 250 acres of wetlands are being lost or altered
annually in each state. In the face of continuing
population growth and development pressure, our
efforts to eliminate wetland loss and restore these
valuable ecosystems become increasingly important
For example, Tuckahoe Turf Farm, a Berwick, ME
sod farm, agreed to pay a $27,500 penalty and restore
54 acres of destroyed wetlands in Berwick to settle a
claim that it illegally dredged and filled these
wetlands. The company will also spend $150,000 to
create conservation easements on two parcels of land
in Berwick, including 108 acres of ecologically
significant land. These easements will protect habitat
for endangered and threatened species of turtles and
provide access to the public for hiking and other low-
impact recreational activities.
Improving Water Quality
Properly managed municipal wastewater treatment
plants play an important role in protecting community
health and local water quality. Under the National
Pollutant Discharge Elimination System (NPDES)
permit program, we regulate the discharge and
treatment of the wastewater that enters our
waterways by setting limits on the amounts of certain
pollutants contained in a facility's wastewater. We are
committed to taking the necessary enforcement
action to ensure these plants operate within their
permit limits.
For example, kst year in Massachusetts, we resolved
a case regarding alleged sewage treatment plant
violations with the City of North Adams, the Town
of Williamstown and the Hoosac Water Quality
District, which manages sewage treatment for the two
municipalities. The sewage treatment plant, which
discharges to the Hoosic River, allegedly violated its
permit limits for total suspended solids, biochemical
oxygen demand, wastewater flow volume and fecal
coliform. Excess suspended solids and oxygen
demand can adversely impact the river's ecosystem,
while excess fecal coliform creates heath risks for
humans in contact with the rivet Under the
settlement, North Adams will pay a penalty of
$70,000, while Williamstown will pay a penalty of
$30,000 and undertake a project valued at $168,000
10
-------
to map thek storm drain system. These communities
are also taking steps to upgrade thek collection
systems to reduce infiltration and inflow. The Hoosac
Water Quality District is required to take a number of
corrective steps to come into full compliance with all
permit limits.
Cleaning Up Superfund Sites
The Superfund Program investigates and cleans up
the worst hazardous waste sites. The law requires that
companies and individuals responsible for a
contaminated site perform and pay for the
investigation and cleanup. If the responsible parties
are unwilling to cooperate, EPA can either issue an
order requking them to carry out the cleanup or can
perform the cleanup ourselves, often in cooperation
with the state, using funds appropriated by Congress.
Once the cleanup is complete, we will seek to
recover our costs from those responsible. Over the
past year, we continued to carry out clean-up
activities at numerous sites throughout New Engknd
and received $42.3 million in cost recovery claims
against potentially responsible parties.
For example, we ordered several potentially
responsible parties (Saltke Industrial Inc., Joseph
Cakbrese, Calabrese Construction Company and
Store Avenues Associates, LLC) at the Scovill
Industrial Landfill Superfund Site in Waterbury, CT,
to continue site investigation studies begun by us in
2002. These studies will help to determine the type
and extent of contamination and the potential
envkonmental and health risks posed by the
contaminants at the site, which was used from 1919
until the mid-1970s for disposal of ash, cinder and
other industrial wastes. The majority of the site has
already been developed with residential and
commercial buildings. The remaining portion of the
site was in the process of being developed when
industrial wastes, contaminated with polychlorinated
biphenyls, or PCBs, were discovered. When the
results from the studies are known and we have a
better understanding of what contaminants are
present, we will hold a public meeting to discuss the
findings with interested citizens.
Over the past year, we completed temporary clean-up
measures valued at SI.5 million and reached a S10
million agreement with the U.S. Army, the U.S.
Department of Energy, Whittakker Corporation,
MONY Life Insurance Company, and Textron, Inc. to
conduct extensive studies at the Nuclear Metals
Superfund Site in Concord, MA. These studies will be
designed to determine clean-up options at the site,
which was used from 1958 to the present as a
specialized research and metal manufacturing facility
licensed to possess low-level radioactive substances.
The agreement calls for the federal government
agencies to pay 98 percent of the expected costs of
the studies. The settlement allows this project to
move forward and ensures that a comprehensive
evaluation of all areas of potential contamination be
conducted. Ultimately, these measures will provide
for the development of a clean-up pkn.
Last year, we also settled several long-standing cost
recovery cases, which we had pursued to recover our
clean-up costs from potentially responsible parties
and, ultimately, to provide more funding for future
cleanups. For example, at the Re-Solve Superfund
Site in North Dartmouth, MA, the Vulcan
International Corporation agreed to reimburse $3.8
million to the Superfund account To date, over 400
parties have agreed to settlements worth $64 million,
representing close to 95 percent of the costs
associated with the site.
Charles George Trucking Co. will also pay $3.8
million for clean-up costs incurred at the Charles
George Landfill site and for natural resource damages.
The settlement is the last at the site and ends 17
years of contentious cost recovery litigation. The
Charles George Landfill, located in Tyngsborough,
MA, consists of 69 acres of mixed industrial,
municipal and hazardous waste. Clean-up actions
have now been completed, but we continue to
monitor groundwater at the site.
At the Johns Manville Superfund Site in Nashua, NH,
we were able to recover $2.5 million from responsible
parties, including Johns Manville International Inc. of
11
-------
Denver, CO; BNZ Materials of Littleton, CO; and
Samuel Tamposi, Jr. and Elizabeth Tamposi, both as
individuals and trustees of Bridge Street Realty Trust
The four-acre site in Nashua was used for over 80 years
as an asbestos product manufacturing facility. EPA
performed a cleanup at the site from 1995 to 1997.
After the cleanup, the site was developed as a soccer
field and is now owned by the City of Nashua.
We also reached a settlement last year with the Kayser-
Roth Corp. for $7.2 million for the reimbursement of
EPA clean-up and oversight costs at the Stamina Mills
Superfund Site in North Smithfield, RI. The site is a
five-acre parcel of land that was originally a textile mill
in the early 1900's. In 1981, the state discovered that the
groundwater was contaminated with volatile organic
compounds, primarily trichloroethylene. All residences
that relied on private wells have since been connected to
the public water supply. We are continuing to work with
the Rhode Island Department of Environmental
Management to ensure that the required clean-up levels
are achieved.
We also filed suit against the Atlas Tack Corp. and its
president, M. Leonard Lewis, seeking approximately $6
million to reimburse EPA for clean-up activities already
performed, and seeking an order for payment for future
clean-up costs, currently estimated to be $18 million
The Atlas Tack Corporation facility in Fairhaven, MA,
was built in 1901. Metal products, including tacks, steel
nails, rivets, bolts, and eyelets, were manufactured at the
site until about 1985. Soils and sediments at the site are
contaminated with hazardous substances including
cyanide, heavy metals, polychlorinated biphenyls,
pesticides, and polycyclic aromatic hydrocarbons.
Groundwater at the site is contaminated with hazardous
substances including toluene, cyanide, nickel, and zinc
We were able to reach a settlement with General
Electric regarding GE's reimbursement of EPA's indirect
costs related to the 1.5 Mile Reach Removal Action at
the GE Pittsfield, MA Superfund Site. In September
2000, GE and EPA entered into a consent decree
whereby GE is required to dean up its plant and the
Housatonic River. For a 1.5 mile portion of the river,
EPA is performing the cleanup, and EPA and GE are
sharing the costs for the work. GE objected to a
nationwide change in EPA's accounting methodology,
claiming the revision would increase the indirect costs
that GE was required to pay by $4.75 million.
According to the terms of the settlement agreement,
we will receive approximately one-half of the estimated
increase in indirect costs, or nearly $2.4 million.
Over the past year, we also issued numerous
administrative orders and sought judicial warrants that
enabled us to gain access to properties so that we could
take immediate and necessary action to remove
hazardous waste. Often, these properties are
abandoned or their ownership is unclear. For example,
we were able to remove drums and containers of
hazardous waste from an abandoned furniture factory,
the Sanborn Wood Factory, located at the Gellallen Mill
in Winchedon, MA. In Houlton, ME, an access warrant
was necessary to remove high levels of PCBs and lead
in surface soils at the Green Street Superfund Site.
In other instances, we have sought judicial warrants
because site owners refuse to cooperate. For example,
we obtained a warrant for access to property owned by
Louis Vinagro Jr. of Green Hill Road in Johnston, RI.
This property contains more than one million cubic
yards of construction and demolition debris. The debris
has been smoldering below the surface and would
periodically break out into surface fires. The smoke
from the burning waste contains hazardous substances
some of which are known carcinogens.
In Plainfield, CT, we issued an administrative order to
the Old Village Mill LLC, to gain access to and initiate
a removal action at the Brunswick Mill and Carvell
Combing Company Superfund sites. A fire destroyed an
abandoned mill building at the site, causing the release
of asbestos into the air. Initially, the owners had
granted access for us to begin removing the hazards,
but later rescinded it The order was necessary for us to
take immediate action to protect this residential area
and the Moosup River, which is a source
water for the residents.
12
-------
Addressing Widespread Non-Compliance
~W~TT"7hUe we continue to maintain a strong
\ \ I enforcement presence within the regulated
\ V community, we are also developing new
and innovative ways to achieve environmental
compliance. We have, for example, developed
integrated strategies that include coordinating
enforcement actions with compliance assistance in
sectors where we believe there is significant and
widespread non-compliance with environmental laws.
Our work over the past several years with colleges
and universities is just one example of such an
integrated strategy. Also, we are encouraging
particular sectors, including municipal public works
departments, to take advantage of EPA's audit policy.
On the other hand, we still use a strong enforcement-
based strategy to deal with the widespread
mismanagement of hazardous wastes and toxic
substances across the region.
Improving Environmental Performance and
Compliance at Colleges and Universities
Since the mid-1990s, we conducted inspections at
sixteen New England colleges and universities. Many
of these inspections detected serious compliance
problems that led to significant enforcement actions
with penalties ranging from $300,000 to well over $1
million. Last year, we invited the region's 330
colleges and universities to take advantage of EPA's
audit policy as one way to encourage them to be
responsible for their own environmental performance.
This policy encourages regulated entities to identify
environmental violations, disclose them to us and
voluntarily correct them. By disclosing and correcting
violations, it is possible that facilities will get reduced
penalties of up to 100 percent.
As of October 2003, 141 out of the 176 educational
institutions participating in the audit initiative
received penalty reductions for violations that might
otherwise be fully assessed through an enforcement
action. Most of the disclosed violations involved
hazardous waste management, oil spill prevention
and control, emergency planning, storm water
management, water supply and wastewater disposal.
We are also encouraging colleges and universities to
use Web-based tools to improve their environmental
performance. For example, the Virtual
Environmental Campus, www.c2e2.org/evc. is a tool
developed by the Massachusetts Institute of
Technology. The Web site uses an engaging and easy-
to-navigate format to highlight potential environmental
issues in nine subject areas, including arts/theater
areas, cafeterias, dormitories, drains/sewers, grounds/
vehicles, labs, medical areas, power plants and waste
storage. The site also provides compliance information
and good management practices.
MIT developed this Web site as part of a 2001
settlement of an enforcement case with EPA. The
site is hosted by the Campus Consortium for
Environmental Excellence, a consortium of colleges
and universities dedicated to improving their
campuses' environmental performance in higher
education through environmental professional
networking, information exchange, the development
of professional resources and tools, and the
advancement of innovative regulatory models.
The second Web site, www.epa.gov/ne/assistance/
univ/bmpcatalog.html. is a Best Management
Practices Catalog that provides a useful tool to assist
colleges and universities that want to implement best
management practices, but need practical information
to convince administration, faculty, or staff to move
forward. The catalog also answers such basic
questions as "How do I get started?" and "What are
the potential cost savings?" The catalog currently
contains 16 case studies highlighting environmentally
sustainable practices such as energy efficiency, green
building design, recycling, composting, environmental
revolving funds, water conservation, storm water
control, green chemistry, management of
construction debris, pollution prevention in the arts,
integrated pest management, and environmental
performance reporting.
13
-------
Improving Public Sector Environmental
Compliance
Also since the mid-1990s, we have focused a portion
of our enforcement efforts on municipal departments
of public works (DPWs). DPWs manage diverse
facilities such as auto service and repair operations,
wastewater treatment plants, drinking water systems,
hazardous waste management operations, landfills
and incinerators. These municipal departments face a
wide range of public health and environmental
compliance issues. Because the New England DPW
sector comprises numerous facilities across the
region, we found it difficult to achieve compliance
through traditional means such as inspections and
penalties.
Following a number of significant enforcement
actions against municipal highway garages, we
developed the DPW Audit Initiative in partnership
with the New England Chapter of the American
Public Works Association as a way for municipalities
across New England to improve their environmental
performance through EPA's audit policy. More than
350 facilities in 250 municipalities are participating in
this voluntary program.
The initiative has produced 322 self-disclosures of
environmental violations. The environmental benefit
of this program is enormous. Among the violations
being reported and corrected are: improper handling,
disposal and storage of hazardous wastes and
petroleum products; inadequate emergency
procedures, training programs and plans; unpermitted
discharges of wastewater to ponds, streams and
wetlands; and improper use of floor drains. These are
all problems that if left unchecked could cause
substantial environmental harm.
Improving Hazardous Waste and Toxic
Substances Management
Over the past year, we settled a case with the Rogers
Corporation in Rogers, CT, in which the company will
pay a $45,000 penalty and undertake three innovative
supplemental environmental projects that will cost an
estimated $269,000. The settlement stems from
allegations of the improper disposal of PCBs
discovered at the company's East Woodstock, CT
facility. In addition to the cash penalty, Rogers agreed
to install solar photovoltaic lighting at the East
Woodstock facility to conserve fossil fuels and
diminish conventional power plant emissions; provide
hazardous materials training and equipment to the
local fire department so that they are better prepared
to deal with a broader array of fire events; and switch
the fuel used at its South Windham, CT facility to a
lower sulfur fuel oil, thus decreasing sulfur emissions
from the plant.
Federal law requires that any product making claims
about killing pests, including viruses and bacteria, be
registered with EPA. The pesticide registration
process is intended to ensure that before a product is
sold to the public, it is found by EPA to be effective
and used in strict compliance with the label directions
so as not to present any unreasonable risks. As a
result, we continue to pursue fines against pesticide
firms who fail to properly register or mislabel their
products.
Among our pesticide cases last year, we are seeking a
significant penalty against the American Biophysics
Corporation of East Greenwich, RI for failing to
properly register a mosquito attractant used in its
popular "Mosquito Magnet" insect control
equipment. The company allegedly produced and sold
the Mosquito Magnet between March and July 2002
without having a valid registration for the attractant.
The company also included false or misleading
information on the product's labeL Upon receiving an
approved registration application from EPA and
including proper labeling on its products, the
company resumed worldwide sales of the product.
In addition, the Doctor's Research Group of
Plymouth, CT, faces federal penalties for allegedly
not properly registering and labeling a plastic cover
called SafeSeal, in accordance with federal law. The
cover, which is designed to be placed over a medical
stethoscope, contains an antimicrobial compound
intended to protect the diaphragm itself from
bacteria, but the company was marketing the product
14
-------
as though it would also protect patients and medical
professionals from harmful bacteria.
We are also pursuing penalties against two Rhode
Island companies (Johnston Pool Supply of Johnston
and AMCO Inc. of Central Falls that distribute
swimming pool disinfectants) for selling and
distributing their products with a concentration of
sodium hypochlorite that was significantly below the
concentration indicated on the products' labels.
Individuals who swim in pools without the proper
level of protection are exposed to viruses and
bacteria that can lead to skin irritations and possible
gastrointestinal problems.
In addition to registering pesticide products, federal
kw also requires each company to submit an annual
production report to EPA on or before March 1 each
year. These reports allow EPA to track the amount of
pesticides that are being produced and distributed
either domestically or for export. This information is
crucial in the event of a product recall. We have
approximately 160 pesticide-producing
establishments in New Engknd. Last year, all but sLx
of these companies submitted their annual reports.
Under expedited setdement agreements, these
companies paid a total of more than $17,000 in
penalties.
Homeland Security and Emergency Preparedness
Chemical releases, whether accidental or
deliberate, have the potential to seriously
impact public health and the environment. We
continue to vigorously enforce laws that improve the
safely of facilities, which use, handle, produce or
store hazardous chemicals. We are also devoting
considerable effort working with local and state
emergency planning committees to assist these
facilities in improving their security and preparedness.
Training New England's First Responders
Over the past year, we have participated in numerous
terrorism and hazardous materials exercises that help
prepare the local, state and federal response
community in the unlikely event of an incident
happening in New England. These exercises stress
communication, information exchange and resource
needs, as well as the need for protecting critical
infrastructure, such as water supplies and power
generating capacity. In addition to diese exercises, our
emergency preparedness training program, which is
designed to prepare and support state and local
emergency responders, instructed over 7,600
individuals at 150 workshops over die past year.
Reducing Risk from Chemical Releases
The Clean Ak Act requires facilities to identify and
assess their chemical hazards and earn' out certain
activities designed to reduce the likelihood and
severity of accidental chemical releases. This process is
known as risk management planning. These plans are
designed to ensure that facilities, which store certain
quantities of hazardous materials, have implemented
procedures to minimize the adverse effects from any
accidental release of these materials. One such facility,
Morgan Advanced Ceramics of Hudson, NH, has
agreed to pay a penalty of more than $44,000 for
allegedly failing to submit a risk management plan for
its plant, which uses highly toxic chemicals as part of
its ceramics manufacturing process.
15
-------
Promoting Continuous Environmental Improvement Through
Environmental Management Systems
A nother way we are working with the regulated
f-\ community to do more than just simply
_/. -^comply with environmental laws is through
the use of an environmental management system
(EMS). Through an EMS,-fatalities are encouraged to
adopt sound management practices to address
environmental compliance. In addition, an EMS also
encourages facilities to address important
environmental issues not fully covered by laws and
regulations, such as efficient water and energy use,
recycling, and reduced greenhouse gas emissions. An
EMS encourages responsible environmental behavior
and is applicable to a wide range of entities from
schools and private businesses to government
agencies.
An Environmental Management System is a
systematic approach to ensuring that
environmental activities are well managed in any
organisation. It requires an organisation to
identify the environmental impacts of its
operations, decide which ones are the most
significant, and then set measurable
pollution reduction goals. EMSs vary from one
organisation to another, but there are common
elements such as training, high-level management
involvement, data measurement,
and documentation of procedures and results.
Environmental Management Systems
within Schools
Elementary and secondary schools are responsible for
a number of environmental matters, such as
maintaining indoor air quality, properly managing
chemicals, ensuring safe drinking water and
minimizing diesel bus idling. Last year, we initiated
several projects, which were designed to test the use
of an EMS as a tool to help K-12 schools identify,
prioritize and address environmental issues, and
ultimately, adopt a systematic approach for
continuous environmental improvement. In Maine,
such projects are underway at schools in Wiscasset,
South Portland and Farmington. In Massachusetts,
schools in Lee, Lenox and Montery are working
together on an EMS project while individual projects
are underway in Amherst and Newton. We are eager
to learn what motivates or prevents schools from
implementing an EMS, compare different EMS models
for their effectiveness in schools and to determine if
long-term behavioral and environmental changes have
occurred.
At the college and university level, we are
collaborating with the University of Massachusetts-
Lowell to assist several area colleges and universities
in implementing EMSs at their respective campuses
by using our EMS Guide for Colleges and Universities.
These institutions include the University of
Massachusetts-Amherst, the University of New
England, Wentworth Institute of Technology, the
University of New Hampshire, the University of
Rhode Island, and Westfield State College.
Environmental Management Systems for the
Metal Finishing Industry
Many of the small manufacturing facilities regulated
in New England are suppliers to krger companies in
the aerospace and electronics industries. To
encourage small facilities to go beyond compliance
and to embrace the environmental ethics of the
larger corporations, we developed a Corporate
Sponsor Program. Companies involved in this
program so far include Raytheon, Pratt & Whitney
and New Hampshire Ball Bearings.
Pratt & Whitney is sponsoring two EMS User groups
for metal finishing suppliers, one at its Hartford, CT
facility, where four suppliers have completed EMSs,
and one at its North Berwick, ME facility where 11
suppliers and other companies from the area are
developing EMSs for their facilities. Nine suppliers to
New Hampshire Ball Bearings completed a six-month
EMS training course hosted by the company at its
16
-------
Peterborough, NH facility. The results of these EMSs
ranged from one small laboratory saving $600 per
year on solid waste costs to one large machine shop
saving $230,000 per year by recycling scrap metal. All
companies involved agreed that the EMS process
introduced them to the theory of continuous
improvement and going beyond compliance.
Environmental Management System for Our
Regional Office
Executive Order 13148, "Greening the Government
Through Leadership in Environmental Management,"
requires the development of an EMS at all federal
facilities by December 2005. EPA New England is
well ahead of the federal deadline. In January 2003,
the Boston Office's environmental policy was signed
by the Regional Administrator and co-signed by the
building management. This policy confirms our
commitment to reach a higher standard of
environmental excellence and to serve as a public
example, fostering an understanding of the
relationships among natural and man-made
environments, economics, and society as a whole. As
part of the EMS development process, we have
identified the significant environmental impacts of
our regional offices in Boston and Chelmsford and
prioritized them in order to address the most
important issues. The list of impacts, the status of
our current improvement programs, and the priority
list will be reviewed and updated annually.
17
-------
Advocating for Superior Environmental Performance
"W "V T" Tt recognize that regulations often fail to
\ \ I provide positive incentives that will
V Y motivate businesses to do more than is
required by law, that is, to go beyond compliance.
We also realize that regulations may not address an
emerging environmental issue that requires a new
solution. In the following sections, you will read
about some of the innovative projects we have
undertaken to further improve environmental
protection in New England.
Performance Track
EPA's National Environmental Performance Track
program recognizes and rewards facilities, which
consistently exceed regulatory requirements, work
closely with their communities and excel in protecting
the environment and public health. Launched in
2000, Performance Track has grown from 228 charter
members to over 300 members in 41 states, including
34 in the six New England states. The Performance
Track facilities represent virtually every manufacturing
sector, as well as facilities in the public sector.
Performance Track applicants must demonstrate that
they have maintained a record of sustained
compliance as well as established and maintained an
EMS. In addition, they must be committed to public
outreach and reporting and to continuous
environmental improvement in areas that go beyond
legal requirements. During the first year in the
program, Performance Track facilities nationwide
reported a reduction of 692 tons of hazardous wastes
generated First year results for New England
Performance Track companies include a reduction of
189 tons of hazardous wastes generated and 138
million gallons of water saved. Six of these companies
reduced their VOC emissions by approximately 13.5
tons or 24% of their baseline amount.
New England Performance Track Companies
Acushnet Rubber Company Inc. DBA Prefix lac.,
New Bedford, MA
BAE Systems - South Nashua Facility, Nashua, NH
Clairol Worldwide Beauty Care-P&G, Stamford, CT
DDLC Danielson, Danielson, CT
DDLC Energy, New London, CT
DePuy Orthopaedics Inc., New Bedford, MA
DePuy Orthopaedics Inc., Raynham, MA
Fairchild Semiconductor Corp., South Portland, ME
Gillette Andover Manufacturing Center, Andover, MA
Heidelberg Web Systems Inc., Dover, NH
Henkel Loctite, Seabrook, NH
IBM Burlington, Essex Junction, VT
Interface Fabrics Group Inc., Guilford, ME
International Paper - Androscoggin Mill, Jay, ME
International Paper- Bucksport Mill, Bucksport, ME
Naval Undersea Warfare Center Division, Newport, RI
New Hampshire Ball Bearings Inc., Peterborough, NH
Nexfor Fraser Papers Inc., Madawaska, ME
Oil Express, East Falmouth, MA
Perkin Elmer Optoelectronics, Salem, MA
Shipley Company LLC, Marlborough, MA
Skanska USA Building - New England Division,
Boston, MA
Snap-On Natick Plant, Natick, MA
Teradyne Inc., North Reading, MA
Texas Instruments Inc., Attleboro, MA
The Topflite Golf Company, Chicopee, MA
Timken U.S. Corporation, Watertown, CT
U.S. Coast Guard Air Station, Cape Cod, MA
U.S. Postal Service - Hartford Processing and Distribution
Center, Hartford, CT
U.S. Postal Service - Hartford Vehicle Maintenance Facility,
Hartford, CT
US. Postal Service - Portland Processing and Distribution
Center, Portland, ME
Unilever Home & Personal Care USA, Clinton, CT
USGen New England, Inc.- Hydro Generation,
Concord, NH
Valley Oil Company, Willimantic, CT
18
-------
Healthy Hospitals
In providing quality health care, New England's 280
hospitals use large volumes of material, generate
diverse waste streams (including biological, chemical
and radioactive waste), and consume great amounts
of energy. In particular, healthcare facilities
contribute to the presence of mercury, dioxin and
other persistent toxins in the environment. The
Hospitals for a Healthy Environment Program is a
national voluntary program created to help hospitals
take a leadership role in reducing their impact on the
environment The goals of the program are to
eliminate the use of mercury by 2005; to reduce
overall hospital waste through prevention, reuse and
recycling; and to identify and eliminate other
persistent toxins in the healthcare system.
Hospitals are the fourth largest source of mercury
discharged into the environment.
Hospitals generate two million tons of solid waste,
which represents one percent of the
total municipal solid waste in the US, and manage
a host of hazardous wastes.
Hospitals rank second in intensity of energy usage
and use more than twice as much energy per square
foot as office buildings. In total, hospitals consume
almost 50 billion kilowatt hours of electricity and
spend close to S3 billion each year in electricity
alone, a cost that represents as much as eight
percent of operating expenses.
conservation. Three states (CT, RI and NH) adopted
the template and conducted site visits to 25 hospitals
in order to collect data assessing environmental
performance and potential opportunities at each
hospital. We are also planning to use the data
collected to evaluate hospital mercury programs, to
identify sector-wide issues, to develop compliance
assistance tools, and to further define healthcare
sector activities.
Leveraging Environmental Improvements
Last year, we conducted over 700 inspections at
regulated facilities throughout New England. During
these times of decreasing resources, we are always
looking for ways to leverage further environmental
improvements. Last year, we developed a
standardized letter called the Post Inspection Letter
and now mail it out to each facility that has been
inspected as a way to encourage compliance and
beyond compliance behavior. The Post Inspection
Letter provides a summary of publicly-available
information regarding environmental sustainability
and compliance. This information is also accessible
on a dedicated Web site with extensive links to other
helpful sites. During the first year, we sent 108 letters
and received 1,670 hits on our Solutions web site.
Since this site is not available through any search
engine, these statistics tell us that inspected facilities
are very interested in finding ways to improve their
compliance with environmental kws.
We are actively promoting this program in New
England. Of the 491 national partners in this
program, 104 of them are from our region. Last year,
we developed a Hospital Assessment Tool Template
as a way to collect information from hospitals on
environmental performance indicators, waste
generation, pollution prevention and energy/water
19
-------
Conclusion
Protecting human health and the environment have achieved notable success by using a variety of
is the mission of EPA New England. The enforcement and assistance approaches that address
Office of Environmental Stewardship is today's environmental problems and promote
responsible for improving the environmental environmentally sustainable performance. We hope
performance of businesses, government and the that this report has illustrated our'problem-solving
public through compliance with environmental philosophy. Once again, your feedback on our
requirements, preventing pollution and promoting efforts is important to us.
environmental stewardship. Over the past year, we
20
-------
For Further Information
Contacts for Stories Covered in this Report:
Audit Policy
Joel Blumstein
617-918-1771
blumstein.joel@epa.gov
Clean Air Act
Enforcement
Fred Weeks
617-918-1855
weeks. £ted@epa.gov
Clean Water Act
Enforcement
Karen McGuke
617-918-1796
mcguke.karen@epa.gov
Colleges and Universities
Peggy Bagnoli
617-918-1828
bagnoli.peggy@epa.gov
or
Josh Secunda
617-918-1736
secunda.josh@epa.gov
Drinking Water
Mary Dever
617-918-1717
dever.mary@epa.gov
Emergency Preparedness
Len Wallace
617-918-1835
wallace.len@epa.gov
Federal Facilities
Anne Fenn
617-918-1805
fenn.anne@epa.gov
Hazardous Materials & Wastes
Ken Rota
617-918-1751
rota.ken@epa.gov
Homeland Security
Jim Gaffey
617-918-1753
gaffey.jim@epa.gov
Hospital Sector
Janet Bowen
617-918-1795
bowen.janet@epa.gov
K-12 School Sector
Joan Jouzaitas
617-918-1846
jouzaitas.joan@epa.gov
or
Lee Fiske
617-918-1847
fiske.lee@epa.gov
Lead Paint Enforcement
Deborah Brown
617-918-1706
brown.deborah@epa.gov
Metal Finishing Sector
Linda Darveau
617-918-1718
darveau.linda@epa.gov
Performance Track
Martha Curran
617-918-1802
curran.martha@epa.gov
21
-------
Pesticides Enforcement
Wayne Toland
617-918-1852
toland.wayne@epa.gov
Post Inspection Letter
Maggie Theroux
617-918-1613
theroux.maggie@epa.gov
Public Works Audit Initiative
Nancy Barmakkn
617-918-1016
barmakian.nancy@epa.gov
Storm Water Outreach - Municipal
Jack Healey
617-918-1844
healey.jack@epa.gov
or
Chris Jendras
617-918-1845
jendras.chris@epa.gov
Storm Water Outreach - Construction
Abby Swaine
617-918-1841
swaine.abby@epa.gov
Superfund Enforcement
JoannaJerison
617-918-1781
jerison.joanna@epa.gov
Wetlands
Dan Arsenault
617-918-91562
arsenault.dan@epa.gov
Other Office Contacts... 617-918-1700
Stephen Perkins, Director
Sam Silverman, Deputy Director
Thomas D'Avanzo, Manager, Assistance and
Pollution Prevention Office
Ken Moraff, Manager, Enforcement Office
Web Pages of Interest
For more detailed information on the programs and
activities of the Office of Environmental
Stewardship:
www.epa.gov/ne/enforcementandjissistance
For information on the EPA New England Office:
www.epa.gov/ne
Acknowledgments
Writer: Carol Kilbride
Editor Bill Chin
22
-------
23
-------
xvEPA
United States
Environmental Protection
Agency New England
EPA-R-04-001
www.epa.gov/ne/enforcementandassistance
February 2004
------- |