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              UNFTED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON D.C. 20460
                                             OSWER Directive No. 9200.4-22A
MEMORANDUM
SUBJECT:

FROM:
TO:
          CERCLA Coordination with Natural Resource Trustee,
          Timothy Fields, Acting Assistant Administrate
          Office of Solid Waste and Emergency Response
          Steve Herman, Assistant Adminis.tr
          Office of Enforcement and Compli
                                                 surance
          Director, Office of Site Remediation and Restoration
            Region I
          Director, Emergency and Remedial Response Division
            Region II
          Director, Hazardous Waste Management Division
            Regions III, IX
          Director, Waste Management Division
            Region IV
          Director, Superfund Division
            Regions V, VI, VII
          Assistant Regional Administrator, Office of Ecosystems
          Protection and Remediation
            Region VIII
          Director, Environmental Cleanup Office
            Region X
          Regional Counsels  (Regions I-X)

     This memorandum provides direction  for ensuring that  the
requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act  (CERCLA) for coordination  with
Natural Resource Trustees  (Trustees) are met, and clarifies
Trustee activities that may be funded under CERCLA.  Sections
104(b)(2) and 122(j) of CERCLA require coordination with all
affected Trustees and an even greater degree of coordination with
the Federal Trustees, in site characterization, response actions,
and settlement negotiations.  We ask that your managers,
technical, and legal staffs dealing with site identification,
ranking, response,  and legal actions under CERCLA meet their

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obligations to coordinate fully with Trustees in these activities
and that they take full advantage of existing Interagency
Agreements with Trustees to support that coordination.

     Trustees often have information and expertisev.abo,ut the
biological effects of hazardous substances, and the location of
sensitive species and habitats that can assist EPA in
characterizing the nature and extent of site-related
contamination and impacts.  Coordination at the investigation and
planning stages also provides the Trustees early access to
information they need to assess injury to natural resources and
to meet statutory time lines.  That, in turn, allows Trustees to
make early decisions about whether restoration is needed in light
of the response actions and should generally result in more
efficient settlement negotiations and an opportunity to address
all liabilities at the site more quickly.

     Trustee coordination efforts are aimed at achieving three
goals:  providing Trustees the information needed to meet their
legal obligations for actions; sharing information to better
protect the public health and the environment; and reducing the
time to settlement for all liabilities. CERCLA requirements for
the coordination with Trustees are a means to achieve these three
goals.

     This Directive reinforces a previous directive issued in
1989 by Henry Longest  (Director, Office of Emergency and Remedial
Response) and Bruce Diamond  (Director,  Office of Waste Programs
Enforcement)  on Natural Resource Damages Coordination.  To
achieve that end, we plan to provide greater support to Regions
for the implementation of this Directive by disseminating
information on identification of Trustees and encouraging
Trustees to meet their obligations for coordination.

     The Trustees shall be given the opportunity to 'review and
provide comments on decision documents to the extent practicable.
These provisions for sharing information are consistent with
those outlined in the OSWER Directive 9295.0-02 (April 1992 MOU
between the National Oceanic and Atmospheric Administration and
the U.S. EPA concerning the Notification and Coordination of
Activities pursuant to CERCLA).

     If natural resource liability is not resolved in connection
with a settlement for CERCLA response or in the absence of a
settlement, the Trustees may undertake natural resource damage
assessment (NRDA) efforts.  A NRDA assesses damage to public
trust resources in order to restore' injured resources and
services and to compensate the public for their interim loss.  As
outlined in the National Contingency Plan Subpart G and 43 CFR

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11,  the development, funding,  review,  and adoption of an NRDA is
the responsibility of the Trustees.

     Documents produced during CERCLA response by other federal
agencies responsible for cleanup (such as DOE/DOD) at facilities
under their jurisdiction, custody or control should be reviewed
by EPA Remedial Project Managers or On-Scerie Coordinators.
However, if any portion of these documents addresses restoration
of trust resources and/or compensation for injured resources and
services, that portion of the document would be the sole
responsibility of Trustees and EPA review is not sought.  In
order to avoid confusion, these documents should separate the
restoration of trust resources and/or compensation for injured
resources and services from other assessments.

Roles and Responsibilities of EPA and Natural Resource Trustees

     EPA and the Trustees have different but complementary roles
under CERCLA.  In general, EPA selects response actions to
protect health and the environment at EPA lead sites.  When
assuming this responsibility,  EPA applies those provisions of
CERCLA that pertain to the development and implementation of
removal and remedial actions at CERCLA sites and related
activities, including site characterization  (extent and nature of
contamination and baseline risk assessment), remedial
alternatives evaluation, and remedial selection, design, action,
and monitoring.  EPA is responsible for the development of
Remedial Investigation/Feasibility Studies  (RI/FS), Engineering
Evaluation/Cost Analyses  (EE/CA),  and ecological risk
assessments, proposed plans and Records of Decision, Action
Memoranda, and remedial design and remedial effectiveness
monitoring plans.

     The NRDA is used to identify additional actions, beyond the
response needed, to address natural resources. These include
actions needed to restore the productivity of habitats or the
species diversity that were injured by the past releases or to
replace them with substitute resources).  A Trustee may also seek
to determine compensation for the loss of injured natural
resources from the time of injury until the time they are fully
restored by assessing lost human and ecological services.

     EPA guidance recommends an ecological risk assessment as
part of its process for assessing the impacts of site-related
contamination.  Ecological risk assessments analyze the actual or
potential impacts of a hazardous substance release, and of the
various removal or remedial action alternatives.  Ecological risk
information may be relevant in a NRDA and both EPA and the

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 Trustees  should  benefit  from  sharing  information  and  coordination
 in  the  conduct of  ecological  risk  assessments.

 Identification of  Trustees

      Executive Order  12580  Section 1(c)  and  Section 300.600  of
 the National  Contingency Plan (NCP) designate  the Federal
 Trustees,  which  include  the Department  of  Interior (DOI),  the
 National  Oceanic and  Atmospheric Administration  (NOAA)  (by
 delegation from  the Secretary of Commerce) and the Secretaries of
 Agriculture,  Defense,  and Energy.   Section 300.615(b)  states that
 Trustees  are  responsible for  designating to  the Regional Response
 Teams appropriate  contacts  to receive notifications.   Section
 300.615(c)  outlines actions for Trustees to  take.  Executive
 Order 12580 should also  be  reviewed to  more  fully understand the
 identification,  roles, and  authorities  of  the  Trustees.  Appendix
 A provides an excerpt from  the NCP on these  subjects.  Appendices
 B,  C, and D includes  a listing of  current  Federal and State
 Natural Resource Trustee representatives.  This listing  is
 incomplete-because it does  not identify native American  Tribes,
 who must  also identify their  representatives to EPA regional
 offices for inclusion in the  Regional Contingency Plan.  The
 OSCs/RPMs should use  the listing of trustees in the Regional
 Contingency Plan to notify  trustee agencies  of potential injuries
 to  natural resources.  Per  NCP 300.615  Trustees should coordinate
 with each other  to facilitate the  exchange of  information.
 Notification  of Natural  Resource  Trustees

      Section  104(b)(2) of  CERCLA  requires  that  EPA promptly
 notify Federal  and State Trustees of  potential  natural  resource
 injuries  and  that  EPA seek to  coordinate the  assessments,
 investigations,  and planning of.response activities, with  them.
 As  a  matter of  policy, EPA should 'not only comply  with  these
 statutory directives,  but  should  make every, effort to encourage
 Trustee participation at all stages of response.   The statutory
 requirements  are reflected in  the National Contingency  Plan (40
 CFR Part  300).   Section  300.410(h) requires that On-Scene
 Coordinators  (OSC's)  and Remedial Program  Mangers  (RPM's)  "ensure
 that  ...  Trustees  are promptly notified" of releases that  may
 injure natural  resources.   Section 300.430(b)(7) requires  that
.EPA "seek to  coordinate  necessary assessments,  evaluations,
 investigations  and planning with  ...  Trustees." Similarly,
 section 122 (j) (1)  of CERCLA requires  not just that we notify  the
 Federal Trustees of negotiations  concerning releases that  may
 have  resulted in natural resource injury,  but also requires that
 we  shall  encourage their participation in  those negotiations.

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Trustee participation is important because EPA is not. authorized
to negotiate on behalf of the Trustees.

     EPA's policy is to encourage participation by all affected
Trustees at every stage in the CERCLA process.  Coordination with
natural resource Trustees will help EPA assure that environmental
impacts are more fully addressed as early .as practicable and will
facilitate timely and simultaneous settlement of all liabilities.
Through the exchange of information regarding site conditions and
response action impacts, EPA and Trustees can provide for more
efficient use of resources,  reduce costs, and reduce the time to
reach final settlement.  Coordination may also help Trustees
identify actions that may trigger the statute of limitations for
NRD actions.

     1.  Pre-Listing Coordination

     EPA Regions should notify each Federal, State, and Tribal
Trustee of the development of packages supporting the proposal or
finalization of a site on the National Priorities List (NPL).
Information from Trustee agencies can be useful in characterizing
sites and should be considered in the preparation of listing
packages.

     OERR plans to provide both national lists and some site-
specific information supporting listing decisions to Trustees.
This approach is intended to reduce the workload of Regional
offices and serve to help identify relevant Trustees.

     2.  Coordination of Response Activities

     In order to promote the sharing of information and reduce
the time required to identify and settle all liabilities,  EPA
will invite and encourage Trustee involvement in planning
response activities.

     Regions should use Biological Technical Assistance Groups
(BTAGs) that include representatives from other Federal Agencies
that serve as resource managers. Each Region is expected to
maintain a fully functioning BTAG and involve this group in
review of each stage of the Remedial Investigation/Feasibility
Study, including early planning and scoping.  Finally, as
indicated in the section on identifying Trustees, Regions should
encourage BTAGs to help in the identification of Trustees for a
site but should not assume that BTAGs will identify all relevant
Trustees.

     3.   Time lines for Notification

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     A court decision  (Kennecott Utah Copper Corp. v. Department
o_f the Interior  (D.C. Cir. July 16, 1996)) on natural resource
claims at National Priorities List  (NPL) and non-NPL sites
reinforced the potential importance of both EPA's listing
decisions as well as construction completion determinations on
the damage claim statute of limitations for sites on the NPL.

     Section 113(g)(1)(A) provides a general rule that natural
resource damage claims must be brought within three years from
the date of the discovery of the loss and its connection with the
release in question.   For NPL sites, claims for Natural Resources
Damages must be brought within .3 years of completion of .the
remedial action  (excluding operation and maintenance activities).
The-Department of Justice, Federal Trustees, and EPA generally
argue that "completion of the remedial action" does not occur at
multiple-operated unit  ("OU")  sites until the final OU is
completed.  However,  .the law on this issue is unsettled,  and the
completion of an interim OU might be found to trigger the statute
of limitations period at some sites.

     In order to assure that Trustees are notified of the
completion of construction of each operable unit at sites, EPA
will revise its guidance on Construction Completion to explicitly
provide for notification of Trustees listed in the Regional
Contingency Plans.  While this stage may or may not be determined
to be the "completion of the remedial action"  for purposes of
the statute of limitations, notification of Trustees is intended
to ensure that they have adequate time to evaluate and present.
claims. Section 113(g)(1) of CERCLA provides that claims for
natural resource damages at sites where the Federal Government is
diligently proceeding with an RI/FS cannot be brought before
selection of the remedial action and must be brought within 3
years after completion of the remedial action (excluding
operation and maintenance activities).  Therefore, Trustees have
a compelling interest in knowing the status of pre-remedial and
remedial activities at sites.   To ensure that Trustees have
adequate time to evaluate and present claims,' EPA is revising
guidance on. Construction Completion.  Also,  EPA will seek to
consult with Trustees prior to delisting.  In the interim period
before revision of the Construction Completion guidance,  you
should refer questions on Construction Completions to Rafael
Gonzales, OERR (703)  603-8892.

Implementation

     In order .to facilitate notification and coordination between
EPA and Trustees, we have taken two steps:  (1) attached to this
memorandum is the central contact each Region should use to

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notify a Federal Trustee of a release or threatened release that
may injure a natural resource under its jurisdiction, and  (2) the
Trustees must still work with EPA Regions to revise the Regional
Contingency Plans, established pursuant to the NCP, to identify
Trustee representatives for coordination during subsequent stages
of response activities  (e.g., planning, investigations,
negotiations,  construction completion/deletion).
Funding of Other Federal Agency Activities

     CERCLA Section 111(c) authorizes using the Fund to pay the
costs of (1) assessing natural resources damages, and  (2)
restoring damaged natural resources.  Note, however, that SARA
Section 517(c) (1) (A) (ii)  [26 U.S.C. Section 9507(c) (1) (A) (ii) ]
provides that amounts appropriated from the Fund may not be used
for the costs described in CERCLA Section lll(c)(1) and  (2)
(i.e.,  for NRDA for Natural Resource restoration.

     EPA may request assistance from other agencies in evaluating
releases and possible responses under Section 104. The overriding
SARA prohibition leaves intact the authority of Section lll(c)(3)
to use the Fund to notify the Trustees and to coordinate with
them on 'site assessments, investigations, and planning activities
being conducted under CERCLA Section 104.  Such coordination
costs,  including those incurred by Trustees, can be paid out of
the Fund.  Thus, although the Fund cannot be used to pay the
costs of NRDA or of natural resources restoration, the Fund can
be used to pay Trustee agency costs for investigation and
coordination activities supporting EPA's efforts.

     Thus,  Regions can provide supplemental funding to be used
for such assistance through existing lAGs with Federal Trustees,
which are managed by OERR.  David Charters  (908-906-6825) of
OERR's Environmental Response Team in Edison,  N.J., manages lAGs
that may be used to augment funding for coordination and
technical assistance.

     Through increased coordination efforts with the Trustees we
are seeking to make more efficient use of resources and reduce
the time required to achieve settlements. In order to evaluate
the effects of these efforts it is important that Regions
thoroughly document their coordination actions with the Trustees
and promptly communicate to Headquarters issues that arise in the
implementation of this guidance.

     If you have questions regarding EPA responsibilities under
the statute or how to implement these responsibilities, please

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                                8

contact Joe Tieger in OSRE  (202-564-4276) on matters related to
coordination of negotiations, and Larry Zaragoza in OERR  (703-
603-8867) on matters related to notification of releases or
coordination of planning, investigation or evaluations.

cc:  Federal Trustees
     ASTSWMO Task Force on NRD

Attachment

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                                      Appendix A
                  SUBPART G of the Final National Contingency Plan
                        TRUSTEES FOR NATURAL RESOURCES
 300.600 Designation of federal trustees.

       (a) The President is required to designate in the National Contingency Plan (NCP) those
federal officials who are to act on behalf of the public as trustees for natural resources.  Federal
officials so designated will act pursuant to section 107(f) of CERCLA and section 311(0(5) of the
Clean Water Act (CWA) and section 1006 of the Oil Pollution Act (OPA). Natural resources
means land, fish, wildlife, biota, 'air, water, ground water, drinking water supplies, and such other
resources belonging to,  managed by, held in trust by, appertaining to, or otherwise controlled
(hereinafter referred to as "managed or controlled") by the United States (including the resources
of the exclusive economic zone).

       (b) The following individuals shall be the designated trustee(s) for general categories of
natural resources, including their supporting ecosystems.  They are authorized to act pursuant to
section 107(f) of CERCLA, section 311(f)(5) of the CWA, or section 1006 of the OPA when there
is injury to, destruction of. loss of, or threat to natural resources, including supporting
ecosystems, as a result of a release of a hazardous substance or a discharge of oil.
Notwithstanding the other designations  in this section, the Secretaries of Commerce and the
Interior shall act as trustees of those resources subject to their respective management or
control.

       (1) Secretary of Commerce.  The Secretary of Commerce shall act as trustee for natural
resources managed or controlled by the Department of Commerce (DOC) and for natural
resources managed or controlled by other federal agencies and that are found in, or controlled
under, or using waters navigable by deep draft vessels, tidally influenced waters, or waters of the
contiguous zone, the exclusive economic zone, and the outer continental shelf.  However, before
the Secretary takes an action with respect to an affected resource under the management or
control of another federal agency, he shall, whenever practicable, seek to obtain the concurrence
of that other federal agency.  Examples of the Secretary's trusteeship include the following
natural resources and their supporting ecosystems:  marine fishery resources; anadromous fish;
endangered species and marine mammals; and the resources of National Marine Sanctuaries
and national Estuarine Research Reserves.

       (2) Secretary of the Interior. The Secretary of the Interior shall act as trustee for natural
resources managed or controlled by DOI. Examples  of the Secretary's trusteeship include the
following natural resources and their supporting ecosystems: migratory birds; anadromous fish;
endangered species and marine mammals; federally  owned minerals; and certain federally
managed water resources. The Secretary of the Interior shall also be trustee for those natural
resources for which an Indian tribe would otherwise act as trustee in those cases where the
United States acts on behalf of the Indian tribe.

       (3) Secretary for the land managing agency.  For natural  resources located on, over,  or
under land administered by the United States, the trustee shall be the head of the department in
which the  land managing agency is found. The trustees for the principal federal land managing
agencies are the Secretaries of the DOI, the U.S. Department of Agriculture (USDA), the
Department of Defense  (DOD), and the Department of Energy (DOE).

       (4) Head of authorized agencies. For natural  resources located in the United States  but

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not otherwise described in this section, the trustee shall be the head of the federal agency or
agencies authorized to manage or control those resources.

 300.605 State trustees.

       State trustees shall act on behalf of the public as trustees for natural resources, including
their surrounding ecosystems, within the boundary of a state or belonging to, managed by,
controlled by, or appertaining to such state.  For the purposes of subpart G of this part, the
definition of the term "state" does not include Indian tribes. The governor of a state is
encouraged  to designate a state lead trustee to coordinate all state trustee responsibilities with
other trustee agencies and with response activities of the RRT and OSC.  The state's lead
trustee would designate a representative to serve as a contact with the OSC. This individual
should have ready access to appropriate state officials with environmental protection, emergency
response, and natural resource responsibilities. The EPA Administrator or United States Coast
Guard (USCG) Commandant or their designees may appoint the state lead trustee as a member
of the Area Committee.  Response strategies should be coordinated between the state and other
trustees and the OSC for specific natural resource locations in an inland or coastal zone and
should be included in the Fish and Wildlife Sensitive Environments Plan annex of the ACP.

300.610 Indian tribes.

       The tribal chairmen (or heads of the governing bodies) of Indian tribes, as defined in 
300.5, or a person designated by the tribal officials, shall act on behalf of the Indian tribes as
trustees for the natural resources including their supporting ecosystems,  belonging to, managed
by, controlled by, or appertaining to such Indian tribe, or held in trust for the benefit of such Indian
tribe, or belonging to a member of such Indian tribe, if such resources are subject to a trust,
restriction on alienation. When the tribal chairman or head of the tribal governing body
designates another person as trustee, the tribal chairman or head of the tribal governing body
shall notify the President of such designation.  Such officials are authorized to act when there  is
injury to, destruction of, loss of, or threat to natural resources, including their supporting
ecosystems  as a result of a release of a hazardous substance.

 300.612 Foreign trustees.

       Pursuant to section 1006 of the OPA, foreign trustees shall act on behalf of the head of a
foreign government as trustees for natural resources belonging to, managed by,  controlled by, or
appertaining to such foreign government.

300.615 Responsibilities of trustees.

       (a) Where there are multiple trustees, because of coexisting or contiguous natural
resources or concurrent jurisdictions, they should coordinate and cooperate in carrying out these
responsibilities.
       (b) Trustees are responsible for designating to the Regional Response Teams (RRTs)
and the Area Committees, for inclusion in the Regional  Contingency Plan (RCP), appropriate
contacts to receive notifications from the OSCs/RPMs of discharges or releases.
       (c)(1) Upon notification or discovery of injury to,  destruction of, loss of, or threat to
natural resources, trustees may, pursuant to section 107(0 of CERCLA or section 311(f)(5) of  the
CWA, take the following or other actions as appropriate:
       (i)  Conduct a preliminary survey of the area affected by the discharge or release to
determine if  trust resources under their jurisdiction are,  or potentially may be, affected;
       (ii) Cooperate with the OSC/RPM in coordinating assessments, investigations, and

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planning;
       (iii)  Carry out damage assessments: or
       (iv)  Devise and carry out a plan for restoration, rehabilitation, replacement, or acquisition
of equivalent natural resources.  In assessing damages to natural resources, the federal, state,
and Indian tribe trustees have the option of following the procedures for natural resource damage
assessments located at 43 CFR Part 11.
       (2) Upon notification or discovery of injury to, destruction of.  loss of, or loss of use of.
natural resources, or the potential for such resulting from a discharge of oil occurring after
August 18,  1990, the trustees, pursuant section 1006 of the OPA. are to take the following
actions:
       (i) In accordance with OPA section 1006(c), determine the need for assessment of
natural resource damages, collect data necessary for a potential damage assessment, and,
where appropriate, assess damages to natural resources under their trusteeship; and
       (ii) As appropriate, and subject to the public participation requirements of OPA section
1006(c), develop and implement a  plan for the restoration, rehabilitation, replacement, or
acquisition of the equivalent, of the natural resources under their trusteeship;
       (3)(i) The trustees, consistent with  procedures specified in the Fish and Wildlife Sensitive
Environments Plan Annex to the Area Contingency Plan, shall provide timely advice on
recommended actions concerning trustee  resources that are potentially affected by a  discharge
of oil. This may include providing assistance to the OSC in identifying/recommending
preapproved response techniques and in predesignating shoreline types and areas in the ACPs.
       (ii) The trustees shall assure, through the lead administrative trustee, that the OSC is
informed of their activities regarding natural resource damage assessment that may affect
response operations in  order to assure coordination and minimize any interference with such
operations.  The trustees shall assure,  through the lead administrative trustee that all data from
the natural resource damage assessment  activities that may support more effective operational
decisions are provided in a timely manner  to the OSC.
       (iii) Carry out damage assessments; or
       (iv) Devise and carry out a plan for restoration, rehabilitation, replacement, or acquisition
of equivalent natural resources.  In assessing damages to natural resources, the federal, state,
and Indian tribe trustees have the option of following the procedures for natural resource damage
assessments located at 43 CFR part 11.
       (2) Upon notification or discovery of injury to, destruction of,  loss of, or loss of use of,
natural resources, or the potential for such, resulting from a discharge of oil occurring after
August 18,  1990, the trustees, pursuant to section 1006 of the OPA, are to take the following
actions:
       (i) In accordance with OPA section 1006(c), determine the need for assessment of
natural resource damages, collect data necessary for a potential damage assessment, and,
where appropriate, assess damages to natural resources under their trusteeship; and
       (ii) As appropriate, and subject to the public participation requirements of OPA section
1006(c), develop and implement a  plan for the restoration, rehabilitation, replacement, or
acquisition of the equivalent, of the natural resources under their trusteeship;
       (3)(i) The trustees, consistent with  procedures specified in the Fish and Wildlife Sensitive
Environments Plan Annex to the Area Contingency Plan, shall provide timely advice on
recommended actions concerning trustee  resources that are potentially affected by a discharge
of oil. This may include providing assistance to the OSC in identifying/recommending
preapproved response techniques and in predesignating shoreline types and areas in ACPs.
       (ii) The trustees shall assure, through the lead administrative trustee, that the OSC is
informed of their activities regarding natural resource damage assessment that may affect
response operations in  order to assure coordination and minimize any interference with such
operations.  The trustees shall assure,  through the lead administrative trustee, that all data from
the natural resource damage assessment  activities that may support more effective operational

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decisions are provided in a timely manner to the OSC.
       (iii) When circumstances permit, the OSC shall share the use of federal response
resources (including but not limited to aircraft, vessels, and booms to contain and remove
discharged oil) with the trustees, providing trustee activities do not interfere with response
actions. The lead administrative trustee facilitates effective and efficient communication between
the OSC and the other trustees during response operations and is responsible for applying to the
OSC for non-monetary federal response resources on behalf of all trustees.  The lead
administrative trustee is also responsible for applying to the NPFC for funding for initiation of
damage assessment for injuries to natural  resources.
       (d) The authority of federal trustees includes, but is not limited to the following actions:
       (1) Requesting that the Attorney General seek compensation from and the responsible
parties for the damages assessed and for the costs of an assessment and of restoration
planning; and
       (2) Participating in negotiations  between the United States and potentially responsible
parties to obtain PRP-financed or PRP-conducted assessments or protection for threatened
resources and to agree to covenants not to sue, where appropriate.
       (3) Requiring, in consultation with the lead agency, any person to comply with the
requirements of CERCLA section 104(e) regarding information gathering and access.
       (4) Initiating damage assessments, as provided in OPA section 6002.
       (e) Actions which may be taken by any trustee pursuant to section 107(f)(5) of CERCLA,
Section 311(f)(5) of the CWA or section 1006 of the OPA include, but are not limited to any of the
following:
       (1) Requesting that an authorized agency issue an administrative order to pursue
injunctive relief against the parties responsible for the  discharge or release: or
       (2) Requesting that the lead agency remove, or arrange for the removal of, or provide for
remedial action with respect to, any oil or hazardous substances from a contaminated medium
pursuant to section 104 of CERCLA or section 311 of CWA.

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                                      13
                    Appendix B. NOAA CRC Phone/Address List
                                  (June 1997)
ALYCE FRITZ
Hazardous Materials Response and
Assessment Division
Coastal Resource Coordination Branch
CRC Branch Chief
7600 Sand Point Way NE
Seattle, WA 98115
(206) 526-6305
Fax (206) 526-6865

JOHN LINDSAY
Hazardous Materials Response and
Assessment Division
Coastal Resource Coordination Branch
CRC Section Chief
7600 Sand Point Way NE
Seattle, WA 98115
(206) 526-4560
Fax (206) 526-6865
Sky Pager 1-800759-7243
PIN# - 2380985

KEN FINKELSTEIN
CRC EPA Region 1
Waste Management Division
JFK Federal Bldg
Boston, MA 02203-3211
(617)223-5537
Fax (617)573-9662

LISA ROSMAN
JENNIFER SCOTT
CRC EPA Region 2
18th Floor, Room 31
290 Broadway
New York, NY 10007-1866
Lisa (212) 637-3259
Jennifer (212) 637-3257
Fax (212) 637-3253
PETER KNIGHT
CRC EPA Region 3
JEFF HENNING
Associate CRC EPA Region 3
Superfund Branch
841 Chestnut Building 3HW02
Philadelphia, PA 19107
Peter (215) 566-3321
Jeff(215) 566-3329
Fax (215) 566-3001

DENISE KLIMAS
CRC EPA Region 4
MELISSA WATERS
Associate CRC EPA Region 4
EPA Waste Management Division Reg 4
100 Alabama St SW
Atlanta, GA 30303
Denise (404) 562-8639
Melissa (404) 562-8637
Fax (404) 562-8662

TODD GOEKS
CRC EPA Region 5
Mail Code SRT-4J
77 West Jackson
Chicago, II 60604
(312)886-7527
FAX (312) 353-9281

RON GOUGUET
CRC EPA Region 6
EPA Superfund Management Branch
1445 Ross Avenue 10th Floor
Dallas, TX   75202-2733
(214)665-2232
Fax (214) 665-6660
Fx Data-line (214) 665-83 87
Sky Pager 800 759-7243  PIN #1854101

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                                     14
LAURIE SULLIVAN
CRC EPA Region 9
HELEN HILLMAN
75 Hawthorne Street H-8-5 9th Floor
San Francisco, CA  94105-3901
Laurie (415) 744-3126

Helen (415) 744-2273
FAX (415)744-3123
Lt. CHRIS BEAVERSON
CRC EPA Region 10
1200 6th Avenue  HW-113
Seattle, WA  98101
(206)553-2101
FAX (206)553-0124
NOAA Hazmat 7600 Sand Point Way NE, Seattle, WA (206)526-6317

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                                           15

                   Appendix C.   U.S.  DEPARTMENT  OF THE INTERIOR
                   OFFICE OF  ENVIRONMENTAL POLICY AND COMPLIANCE
           REGIONAL ENVIRONMENTAL OFFICERS,  ASSISTANTS AND SECRETARIES
                                        (June,  1997)
BOSTON - CT,MA,ME,NH,NJ,NY,RI,VT

Andrew L. Raddant
Vacant
Vacant
FAX: 617-223-8569
617-223-8565
408 Atlantic Avenue,  Room 142
Boston,  Massachusetts 02210-3334
PHILADELPHIA -  DC,DE,IL,IN,MD,MI,MN,OH,PA,VA,WI,WV
Donald R. Henne
Michael T. Chezik
Denise A. Wiggins
FAX: 215-597-9845  (Primary)
     215-597-5012  (Alternate)
215-597-5378
Custom House,  Room 244
200 Chestnut Street
Philadelphia,  Pennsylvania  19106
ATLANTA - AL,FL,GA,KY.MS,NC,PR,TN,SC,VI

James H. Lee
Gregory L. Hogue
Carolyn E. Hendricks
FAX: 404-331-1736
404-331-4524
Russell Federal Building,  Suite  345
75 Spring Street,  S.W.
Atlanta,  Georgia 30303
ALBUQUERQUE - AR,LA,NM,OK,TX

Glenn B. Sekavec
Stephen R. Spencer
Vacant
FAX: 505-766-1059
505-766-3565
Post Office Box 649
Albuquerque, New Mexico 87103
(625 Silver Ave.,  SW,  Suite  190
 87102)
DENVER - CO,IA,KS,MO.MT,NE,ND,SD,UT,WY

Robert F. Stewart
Barbara M. Schmalz
William C. Allan  
Anna Aytes
FAX: 303-236-4093
303-236-6900
P.O. Box 25007 (D-108)
Denver Federal Center
Denver,  Colorado 80225-0007
(Building 56,  Room 1003
 6th and Kipling)
SAN FRANCISCO - AS,AZ,CA,CM,GU,HI,NV

Patricia S. Port
Harry (Chip)  E. Demarest
Tracey Y. Queripel
FAX: 415-744-4121
415-427-1477
600 Harrison Street,  Suite  515
San Francisco,  CA  94107-1376
PORTLAND - ID,OR,WA

Preston A. Sleeger, Acting
Vacant
Vacant
FAX: 503-231-2361
503-231-6157
500 NE Multnomah Street
Suite 600
Portland, Oregon 97232-2036
ANCHORAGE - AK

Paul D. Gates
Pamela A. Bergmann
Douglas L. Mutter
Vacant
FAX: 907-271-4102
907-271-5011
1689 C Street,  Room 119
Anchorage,  Alaska 99501-5126

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                                                  16
                      Appendix  D.   Listing of  Scate Trustee Representatives
                                             (April,  1997)
                             State Natural Resource Damages Contacts
                               for EPA Notification and Coordination
ALABAMA
Jim Warr
Director
AL Dept. of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
PH: (334)271-7700
FAX: (334)279-3043
ALASKA
Michele Brown
Director
AK Dept. of Environmental Conservation
410Willoughby
Juneau,AK 99801-1795
PH: (907)465-5065
FAX: (907) 465-5070
ARIZONA
Jeffrey Kulon
AZ Dept. of Environmental Quality
CERCLA Program
3033 North Central Ave.
Phoenix, AZ 85012
PH: (602) 207-4181
FAX: (602) 207-4236

Mark Dahlberg
AZ Dept. of Fish & Game
2221 WestGreenway
Phoenix, AZ 85023
PH: (602) 789-3260
FAX: (602) 789-3920
ARKANSAS
Randall Mathis
Director
AR Dept. of Pollution Control and Ecology
800 National Drive
P.O. Box 8913
Little Rock, AR 72219-8913
PH: (501) 682-0959
FAX: (501)682-0798

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CALIFORNIA
                  17

Michael Martin
CA Dept. of Fish & Game
20 Lower Ragsdale Dr., Suite 100
Monterey, CA 93940
PH: (408) 649-7178
FAX: (408) 649-2894

Paul D. Blais
C A Dept. Of Toxic Substances Control
P.O. Box 806
Sacramento, CA 95816
PH: (916) 323-3577
FAX: (916) 323-3700
COLORADO
Patti Shwayder
Executive Director
CO Dept. of Public Health and Environment
4300 Cherry Creek Drive South
Denver, CO 80222-1530
PH: (303) 692-2100
FAX: (303) 782-0095

Ron Cattany
Deputy Director
CO Dept. of Natural Resources
1313 Sherman Street
Denver, CO 80203
PH: (303) 866-3311
FAX: (303) 866-2115

Gail Norton
Attorney General
CO Dept. of Law
1525 Sherman Street, 5th Floor
Denver, CO 80203
PH: (303) 866-4500
FAX: (303) 866-3052
CONNECTICUT
Elsie Patton
Assistant Director
CT Dept. of Environmental Protection
Bureau of Water Management
79 Elm St.
Hartford CT 06106
PH: (860) 424-3762
FAX: (203) 4244057

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                                                        18
DELAWARE
Robert Allen
Environmental Scientist
DE Dept. of Natural Resources & Environmental Control
89 Kings Highway
P.O. Box 1401
Dover, DEI 9903
PH: (302) 739-4403
FAX: (302) 739-6242
DISTRICT OF
COLUMBIA
Ferial Bishop
Administrator
DC Dept. of Consumer & Regulator}' Affairs
Environmental Regulations Administration
2100 Martin Luther King Ave., SE
Washington, DC 20020
PH: (202) 404-1136
FAX: (202) 404-1141
FLORIDA
John Costigan
Deputy General Counsel
Natural Resources Litigation Section
FL Department of Environmental Protection
3900 Commonwealth Blvd., MS 35
Tallahassee, FL 32399-3000
PH: (904) 921-9701
FAX: (904) 414-1228
GEORGIA
Bill Mundy
Manager
Corrective Action Program, Environmental Protection Division
GA Dept. of Natural Resources
205 Butler St., Suite 1154, Floyd Tower East
Atlanta, GA 30334
PH: (404) 656-7802
FAX: (404) 651-9425

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HAWAII
                  19

Bruce Anderson
HI Dept. of Environmental Health
P.O. Box 3378
Honolulu, HI 96809
PH: (808) 586-4424
FAX: (808) 586-4444

Francis Oishi
HI Dept. of Land and Natural Resources
P.O. Box 621
Honolulu, HI 96801
PH: (808) 587-0094
FAX: (808) 537-0115
IDAHO
Phillip E. Batt
Governor
State of Idaho
P.O. Box 83720
Boise, ID 83720
PH: (208) 334-2100
FAX: (208) 3 34-2175
ILLINOIS
Candy Morin
IL Bureau of Land
NPLUnit
P.O. Box 19276
Springfield, IL 62794-9276
PH: (217) 785-9397
FAX: (217) 557-0877

Stephen Davis
IL Waste Management & Research Center
PH: (217) 557-0877

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INDIANA
Jim Smith
IN Dept. of Environmental Management
100 N Senate
P.O. Box 6015
Indianapolis, IN
PH: (317) 308-3003
FAX: (317) 308-3063

Wayne Faatz
Contaminants
IGC-South
IN Dept. of Natural Resources
Fish & Wildlife, Room W273
402 West Washington St.
Indianapolis, IN 46204
PH: (317) 232-4098
FAX: (317) 23 2-8150
IOWA
Larry Wilson
Director
IA Dept. of Natural Resources
Wallace State Office Building
East 9th and Grand
DesMoines.IA 50319-0034
PH: (515) 281-5385
FAX: (515) 281-6794
KANSAS
Gary R. Mitchell
Secretary
KS Dept. of Health and Environmental Sciences
900 SW Jackson Street, #620
Topeka,KS66612-1290
PH: (913) 296-0461
FAX: (913) 368-6368

Ronald Hammerschmidt
Director
KS Dept. of Health and Environmental Sciences
Forbes Field
Topeka,KS 66620-0001
PH: (913) 296-1535
FAX: (913) 291-3266

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                                                       7
KENTUCKY
Leah MacSwords
Commissioner's Office
K Y Dept. of Environmental Protection
MReillyRd.
Frankfort, KY 40601
PH:(502) 564-2150
FAX: (502) 564-4245
LOUISIANA
Jim Hanifen
LA Dept. of Wildlife and Fisheries
P.O. Box 98000
Baton Rouge, LA 7098-9000
PH: (504) 765-2390
FAX: (504) 765-2624

Chris Pielher
LA Dept. of Environmental Quality
P.O. Box 82215
Baton Rouge, LA 70884-2215
PH: (504) 765-0671
FAX: (504) 765-0866

Linda Pace
LA Dept. of Natural Resources
Office of Coastal Restoration and Management
P.O. Box 44487
Baton Rouge, LA 70804-4487
PH:(504) 342-7936
FAX: (504) 342-9439

Roland J. Guidry
Authorized Official
LA Oil Spill Coordinator's Office
Office of the Governor
1885 Wooddale Blvd., 12th Floor
Baton Rouge, LA 70806
PH: (504) 922-3230
FAX: (504) 922-3239

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MAINE
                                                         8
Steven Timpano
Environmental Coordinator
ME Dept. of Inland Fisheries and Wildlife
287 State St.
State House Station 41
Augusta, ME 04333
PH: (207) 287-3286
FAX: (207) 287-6395

Pen Esterbrook
Deputy Commissioner
ME Dept. of Marine Resources
State House Station 21
Augusta, ME 04333
PH: (207) 624-6550
FAX: (207) 624-6024

Stephen Oliveri
Resource Administrator
ME Dept. of Environmental Conservation
Bureau of Parks and Lands
State House Station 22
Augusta, ME 04333
PH: (207) 287-4912
FAX: (207) 287-3823

Mark Hyland
Director
Division of Remediation
ME Dept. of Environmental Protection
State House Station 17
Augusta, ME 043 3 3
PH: (207) 287-7673
FAX: (207) 287-7826
MARYLAND
Bob DeMarco
MD Dept. of the Environment
2500 Broening Highway
Baltimore, MD 21224
PH: (410) 631-3084
FAX: (410) 631-3888

John Griffin
Secretary
MD Dept. of Natural Resources
Tawes State Office Bldg., 580 Taylor Ave.
Annapolis, MD 21401 -2397
PH: (410) 974-3041
FAX: (410) 974-5206

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MASSACHUSETTS
Sharon Pelosi
Executive Office of Environmental Affairs
100 Cambridge St.
Boston, MA 02202
PH: (617) 727-9530  x426
FAX: (617) 727-2754
MICHIGAN
Nanette D. Leemon
MI Dept. of Environmental Quality
Environmental Response Division
P.O. Box 30426
Lansing, MI 48909-7926
PH: (517) 373-4828
FAX: (517) 373-2637
MINNESOTA
Marilyn Danks
MN Dept. of Natural Resources
500 Lafayette Rd.
Box 25
St. Paul, MN 55155-4025
PH: (612) 296-0777
FAX: (612) 296-1811

Steve Enger
MN Dept. of Natural Resources
500 Lafayette Rd.
Box 25
St. Paul, MN 55155-4025
PH: (612) 296-0782
FAX: (612) 296-1811

Gary Pulford
Solid Waste Section Manager
MN Pollution Control Agency
520 Lafayette Rd. North
St. Paul, MN 55155-4194
PH: (612) 296-7340
FAX: (612) 296-9707
MISSISSIPPI
Russell Smith
Office of Pollution Control, Hazardous Waste Division
MS Dept. of Environmental Quality
P.O. Box 10385
Jackson, MS 39289-0385
PH: (601)961-5072
FAX: (601)961-5741   .

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                                                      10
MISSOURI
David S. Schorr
Director
MO Dept. of Natural Resources
P.O.Box 176
Jefferson City, MO 65102
PH: (573) 751-4422
FAX: (573)-751-7627
MONTANA
NEBRASKA
Mark Simonich
Director
Dept. of Environmental Quality
1520 East 6th Avenue
PO Box 20091
Helena, MT 59620-0901
PH: (406) 444-2544
FAX: (406) 444-4386

Rob Collins
Supervisory Assistant Attorney General
1310E. Lockey
Old Livestock Building
PO Box 201425
Helena, MT 59620-1425
PH: 406-444-0205
FAX:  406-444-0236

Randolph Wood
Director
NE Dept. of Environmental Quality
Box 98922
Lincoln, NE 68509-8922
PH: (402) 471-4231
FAX: (402) 471-2909
NEVADA
Lewis H. Dodgion
NV Div. of Environmental Protection
333 W. Nye Lane
Carson City, NV 89706-0866
PH: (702) 687-4670
FAX: (702) 687-5856
NEW HAMPSHIRE
Carl Baxter
NH Dept. of Environmental Services
Waste Management Division
6 Hazen Dr.
Concord, NH 03 3 301-6509
PH: (603) 271-2908
FAX: 603) 271-2456
                                                        10

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                                                      11
NEW JERSEY
Martin McHugh
Chief
Office of Natural Resource Damages
NJ Dept. of Environmental Protection
501 E. State St., CN 404
Trenton, NJ 08625
PH: (609) .984-5475
FAX: (609) 984-0836
NEW MEXICO
Steve Gary
Office of the Natural Resource Trustee
P.O. Box 26110
1190 St. Francis Dr.
Sante Fe, MM 87502
PH: (505) 827-1035
FAX: (505) 827-1049
NEW YORK
Sharon Brooks
Senior Economist
Natural Resource Damages Unit
NY Dept. of Environmental Conservation
50WolfRd.,Rm.403
Albany, NY 12233-1090
PH: (518) 302-323-4540
FAX: (518) 485-8424
NORTH CAROLINA
Rob Gelblum
Assistant Attorney General
NC Dept. of Environmental Health & Natural Resources
P.O. Box 27687
Raleigh, NC 27611
PH: (919) 733-2801 x3O4
FAX: (919) 733-8352
NORTH DAKOTA
Frances Schwindt
Chief
Environmental Health Division
ND Dept. of Health
600 E. Boulevard Avenue
2nd Floor Judicial Wing
Bismarck, ND 58506-5520
PH: (701)328-5520
                                                        11

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OHIO
                 12

Frank Basting
OH Environmental Protection Agency
P.O. Box 1049
Columbus, OH 43216-1049
PH: (614) 644-2320
FAX: (614)644-3146

Vanessa Steigerwald
OH Environmental Protection Agency
P.O. Box 1049
Columbus, OH 43216-1049
PH :(614)644-2286
FAX: (614) 644-3146'
OKLAHOMA
Gary Scherrer
Secretary of the Environment
State of Oklahoma
3800 N. Classen St.
Oklahoma City, OK 73118
PH: (405) 530-8800
FAX: (405) 530-8900
OREGON
Langdon Marsh
Director
OR Dept. of Environmental Quality
811 SW6thSt.
Portland, OR 97204
PH: (503) 229-5300
FAX: (503) 229-5850
                                                       12

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PENNSYLVANIA
                 13

John Arway
Chief
Environmental Services
PA Fish & Boat Commission
3532 Walnut St.
P.O. Box 67000
Harrisburg, PA 17106-7000
PH: (814) 359-5147

Robert Orwan
Chief
Remediation Services Division
PA Dept. of Environmental Protection
State Office Bldg., P.O. Box 2063
400 Market St.
Harrisburg, PA 17105-2063
PH: (717) 787-2814
FAX: (717) 783-8926

Donald Madl
Executive Director
PA Game Commission
2001 ElmertonAve.
Harrisburg, PA 17110-9767
PH: (717) 787-3633
FAX: (717) 772-0502
RHODE ISLAND
Warren Angell
Supervising Engineer
RI Dept. of Environmental Management
Office of Waste Management
235 Promenade St.
Providence, RI 02908
PH: (401) 277-3872
FAX: (401)277-2591
SOUTH CAROLINA
Keith Lindler
Director
Site Assessment & Remediation Division
SC Dept. of Health & Environmental Control
2600 Bull St.
Columbia, SC 29201
PH: (803) 896-4052
FAX: (803) 896-4001
                                                        13

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SOUTH DAKOTA
                                                       14
Nettie H. Myers
Secretary
SD Dept. of Environment and Natural Resources
423 East Capitol Avenue
Pierre, SD 57501-3181
PH: (605) 773-5559
FAX: (605) 773-6035
TENNESSEE
Joe Sanders
Office of General Counsel
TN Dept. of Environment & Conservation
312 Eighth Ave., North
Nashville, TN 37243-1548
PH: (615) 532-0131
FAX: (615) 532-0145
TEXAS
Richard Seller
Manager
Natural Resource Trustee Program
TX Natural Resource Conservation Commission
P.O. Box 13087, MC 142
Austin, TX 78711-3087
PH: (512) 239-2523
FAX: (512) 239-2527

Diane Hyatt
Director
Damage Assessment
T'X General Land Office
Legal Division
Stephen F. Austin Bldg.
1700N. Congress Ave.
Austin, TX 78701-1495
PH: (512) 475-1395
FAX: (512) 463-5367

Don Pitts
NRDA Coordinator
TX Parks and Wildlife
Resource Protection Division
4200 Smith School Rd.
Austin, TX 78744
PH: (512) 389-4640
FAX: (512) 389-4394
                                                         14

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                                                       15
 UTAH
Dianne R. Nielson
Executive Director
UT Dept. of Environmental Quality
168 North 1950 West
Salt Lake City, UT 84116
PH: (801) 536-4402
FAX: (801)536-0061
VERMONT
George Desch
Chief Sites Management Section
VT Dept. of Environmental Conservation
West Building
103 S. Main St.
Waterbury.VT 05671-0404
PH: (802) 241-3491
FAX: (802) 244-1102
VIRGINIA
Becky Norton-Dunlop
Secretary of Natural Resources
P.O. Box 1475
Richmond, VA 23212
PH: (804) 371-8333
FAX: (804) 786-0044
WASHINGTON
Thomas C. Fitzsimmons
Director
Dept. of Ecology
P.O. Box 47600
Olympia, WA 98504
PH: (360) 407-7001
FAX: (360) 407-6989
WEST VIRGINIA
Pamela Hayes
Asst. Chief
Office of Waste Management
Div. of Environmental Protection
1356HansfordSt.
Charleston, WV 25305
PH: (304) 558-2745
FAX (304) 558-0256
                                                        15

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WISCONSIN
                  16

Brenda Hagman
WI Dept. of Natural Resources
Office of Environmental Enforcement EE15
101 S.Webster St.
P.O. Box 7921
Madison, WI 53707
PH: (608) 266-5883
FAX: (608) 266-3696
WYOMING
TERRITORIES:

PUERTO RICO
U.S. VIRGIN ISLANDS
Dennis Hemmer
Director
WY Dept. of Environmental Quality
Herschler Building
Cheyenne.WY 82002
PH: (307) 777-7938
FAX: (307) 777-7682

John Baughman
Director
WY Game and Fish Department
5400 Bishop Blvd.
Cheyenne, WY 82006
PH: (307) 777-4501
FAX: (307) 777-4699
Denaro Torres
Director Emergency Response Area in Superfund
Environmental Quality Board
Box 11488
Santurce, Puerto Rico 00910
PH: (787)-766-2823
FAX:(787)-766-0150

Bula Dalmida-Smith.
Department of Planning and Natrual Resources
Government of the Virgin Islands
Foster's Plaza
391-1  Anna's Retreat
St Thomas
USVI00802
PH: (340)774-3320
FAX: (340)775-5706

Vinca  Liane Jarrett, Esq.
1236 Strand Street, Suite 103
Christiansted, St. Croix
U.S. Virgin Islands 00820-5008
PH: (809)773-6142
FAX: (809)773-3944
                                                       .  16

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