United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9200.5-2161
October 1991
£ EPA
Superfund Records of
Decision Update
Office of Emergency and Remedial Response
Hazardous Site Control Division OS-220W
Quick Intermittent Bulletin
Volume 6 Number 4
This issue of the ROD Update summarizes the latest information and guidance for four topics: 1) No Migration
Variances; 2) Interim Measure ARAR Waivers; 3) Health and Safety Standards for Site Workers; and 4) New and
Revised MCLs and MCLGs.
No Migration Variances
For CERCLA Remedial
Actions
A No Migration Variance may be
sought to dispose of untreated RCR A
hazardous wastes that are otherwise
subject to treatment standards under
the RCRA land disposal restrictions
(LDRs).
A "No Migration" Variance permits
land disposal of RCRA restricted
wastes which do not meet the LDR
treatment standards in a specific unit
or engineered subunit within an area
of contamination (AOC). A demon-
stration "to a reasonable degree of
certainty that there will be no migra-
tion of hazardous constituents from
the disposal unit or injection zone for
as long as the waste remains hazard-
ous" must be made in order to obtain
a No Migration Variance. This dem-
onstration requires that actual or pre-
dicted concentrations of hazardous
constituents or emission rates at the
edge or boundary of the unit do not
exceed health-based levels or envi-
ronmentally protective levels for
ground water, surface water, soil, and
air for as long as the waste remains
hazardous. Monitoring of all envi-
ronmental media is/will be in place to
demonstrate compliance. A no mi-
gration petition generally pertains to
on-site treatment and/or disposal ac-
tions; however, under certain circum-
stances, disposal may occur at an off-
site, non-commercial facility.
Five Appropriate Scenarios
Several scenarios for which a No
Migration Variance may be appro-
priate are:
• Placement of compatible non-
volatile wastes in a massive and
stable geologic formation, such
as a salt dome;
• Placement of a waste consisting
of fairly immobile constituents
in a monofill located in an arid
area that has no groundwater re-
charge;
• Placement of a hazardous waste
in a land-treatment facility that
through active chemical, physi-
cal , biological, or other processes
renders it nonhazardous; (Note:
an Interim Measures ARAR
Waiver may be appropriate. See
interim measures ARAR waiver
in this issue);
Temporary storage of a hazard-
ous waste in a totally enclosed
indoor waste pile with a floor or
bottom liner for a purpose other
than to accumulate sufficient
quantities of the waste to allow
for proper recovery, treatment,
or disposal.
Under certain circumstances a No
Migration Variance may be appro-
priate for injection of hazardous
wastes into Class I injection wells.
For a Class I variance, the petitioner
must demonstrate that wastes will
not migrate from the "injection zone."
Demonstration of Compliance
The demonstration that there will be
no migration of the wastes for "as
long as the waste remains hazardous"
is a waste and site-specific determi-
nation. After a variance has been
granted, all environmental media
must be periodically monitored to
confirm that no migration of hazard-
ous constituents occurs beyond the
unit boundary.
Printed on Recycled Paper
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Documentation
Only substantive requirements of 40
CFR 268.6 must be met for on-site
variance requests. The opportunity
for public comment is provided
through the proposed plan and ROD
process. The variance is officially
granted upon signature of the ROD.
A formal No Migration Variance
petition process including EPA Head-
quarters review, publication of a no-
tice in the Federal Register, and an
opportunity forpublic comment must
be followed when seeking a No Mi-
gration Variance for wastes disposed
off-site. The variance is granted by
the Office of Solid Waste (OSW) and
a notice of the granted variance is
published in the Federal Register.
Documentation requirements for a
No Migration Variance should be
included in the RI/FS report. Docu-
mentation for a No Migration Vari-
ance in the ROD should include a
synopsis of the documentation in the
FS Report and a statement explaining
why a No Migration Variance is jus-
tified. The intent to seek a No Migra-
tion Variance also should be identi-
fied for all applicable alternatives in
the Proposed Plan.
Quick Reference Fact Sheet
A detailed discussion and listing of
documentation requirements for re-
medial action No Migration Vari-
ances can be found in the Quick Ref-
erence Fact Sheet Publication:
9347.3-IOFS, April 1991. This Fact
Sheet also addresses when it is ap-
propriate to consider a No Migration
Variance, health-based riteria, ap-
propriate test methods and models to
quantify potential migration,and how
to demonstrate compliance.
Questions regarding No Migration
Variances should be directed to Sha-
ron Frey, Hazardous Site Control Di-
vision (Fl’S 398-8367 or 703-308-
8367).
Interim Measure ARAR
Waiver
An applicable or relevant and appro-
priate requirement (ARAR) may be
waived for an on-site Superfund re-
sponse action where “the remedial
action selected is only part of a total
remedial action that will attain such
level or standard of control when
completed.” CERCLA section
121(d)(4)(A), 42 U.S.C. 9621(dX4)(A).
This type of waiver is the Interim
Measure ARAR Waiver.
The Interim Measure ARAR Waiver
may be used when an on-site interim
measure that does not attain all
ARARs within the scope of the in-
terim action is expected to be fol-
lowed by a final action that will
attain all ARARs. The interim mea-
sure should not cause additional mi-
gration of contaminants, complicate
the site response, or present an imme-
diate threat to public health or the
environment, and must not interfere
with or delay the final remedy.
For example, a site action for which
an Interim Measure ARAR Waiver
may be applied involves consolida-
tion and placement of RCRA re-
stricted waste including sludges and
dioxin wastes into an existing on-site
containment vessel, followed by ap-
plication of treaunent technology to
the consolidated wastes. Placement
of the dioxin restricted wastes in the
consolidation/treatment vessel prior
to treatment is prohibited under the
LDRs because they are brought into
an area of contamination (AOC) from
another on-site location that is con-
sidered outside of the AOC, thus trig-
gering “placement.”
The use of an Interim Measure ARAR
Waiver is appropriate in this type of
situation where on-site “placement”
of wastes occurs prior to achieving
treatment standards because the final
remedy will result in the attainment
of the best demonstrated available
technology (BDAT) treatment stan-
dards. If the final remedy does not
meet the BDAT standard or other
ARARs, then the remedy would need
to be modified.
Questions regarding the Interim Mea-
sure ARAR Waiver should be di-
rected to Sharon Frey, Hazardous
Site Control Division (Fl’S 398-8367
or 703-308-8367).
Health And Safety
Standards For Site
Workers
Pursuant to section 126 of the
Superfund Amendments and
Reauthorization Act of 1986 (SARA
Title I), the EPA and the U.S. Occu-
pational Safety and Health Adminis-
tration (OSHA) issued identical
health and safety standards to protect
workers engaged in hazardous waste
operations and emergency response.
Hazardous Waste Operations
And Emergency Response
(HAZWOPER) Worker
Protection Standards
The EPA and OSHA worker protec-
tion standards for hazardous waste
operations and emergency response
(HAZWOPER) affect employers
whose employees are engaged in the
following activities:
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• Clean-up operations at uncon-
trolled hazardous waste sites
when a government authority
requires the cleanup
• Corrective actions at treatment,
storage, and disposal (TSD) fa-
cilities regulated under the Re-
source Conservation and Recov-
ery Act (RCRA)
• Voluntary clean-up operations
at uncontrolled hazardous waste
sites
• Hazardous waste operations con-
ducted at RCRA TSD facilities
• Emergency response operations
withoutregard to location, where
there is the release or a substan-
tial threat of release of a hazard-
ous substance
EPA published worker protection
standards for HAZWOPER specify-
ing certain health and safety require-
ments to ensure the protection of the
employees engaged in hazardous
waste operations and emergency re-
sponse during these five specified
activities. HAZWOPER does not
address emergency responders who
engage only in handling traditional
fire and medical emergencies; other
OSHA programs protect these em-
ployees. HAZWOPER, however,
requires that an employer provide,
among other things, proper emer-
gency response planning, training,
and medical surveillance. Affected
workers must be protected during the
entire remedial process, from the pre-
liminary evaluation and initial site
entry to final closure of the site.
Emergency Response Planning.
An employer must develop an emer-
gency response plan to protect work-
ers in an emergency resulting from
the release of all kinds of hazardous
substances, including extremely haz-
ardous substances, CERCLA hazard-
ous substances, RCRA hazardous
wastes, and any substance listed by
the U.S. Department of Transporta-
tion as a hazardous material.
Training. An employer also must
ensure that workers receive the kind
of training specified in the regula-
tion. The standard reflects a tiered
approach to training, linking the
amount and type of training to an
employee’s potential for exposure to
hazardous substances and to other
health hazards during a hazardous
waste operation or an emergency re-
sponse. The greater the potential
hazard or time of exposure, the more
extensive and stringent are the train-
ing requirements.
Medical Surveillance.
HAZWOPER establishes a frame-
work for a medical monitoring pro-
gram for certain workers engaged in
hazardous waste operations and emer-
gency response. The medical sur-
veillance requirements include pro-
visions for a baseline, periodic, and
termination medical examination for
specific groups of employees.
HAZWOPER also requires that em-
ployees receive a medical examina-
tion as soon as possible if they are
injured or become ill from exposure
to hazardous substances on-site or
during an emergency, or develop
signs or symptoms that indicate a
possible overexposure to hazardous
substances. Although an attending
physician may determine the content
of medical examinations required
under the standard, the examination
must address key elements related to
handling hazardous substances.
Scope of EPA HAZWOPER
Standards
SARA section 126(f) requires the
EPA Administrator to issue standards
for HAZWOPER that are identical
to OSHA’s stAndards. EPA issued
these standards in June 1989. Al-
though the two sets of standards con-
tain identical substantive provisions,
EPA and OSHA address different
audiences. EPA’s authority extends
to state and local government em-
ployers conducting HAZWOPER in
states that do not have a delegated
OSHA program in effect. Currently,
27 states, one territory, and the Dis-
trict of Columbia fall under EPA’s
authority. The EPA regulations
cover both compensated and
uncompensated (vQlunteer) state and
local government employees engaged
in the covered activities. EPA stan-
dards, therefore, protect volunteers
such as volunteer fire fighters who
are responding to hazardous sub-
stance emergencies. Although Fed-
eral OSHA recommends that del-
egated state programs also cover
uncompensated employees, not all
states have followed this recommen-
dation.
Title I Worker Protection
Standards
EPA and OSHA have an agreement
to share responsibility forimplement-
ing the Title I workerprotection stan-
dards. Under the terms of this agree-
ment, OSHA performs the following
activities:
• Support of the National Response
Team and Regional Response
Teams.
• Technical Assistance. OSHA
advises EPA on the types of ac-
tions EPA should take at uncon-
trolled hazardous waste sites to
ensure full compliance with the
HAZWOPER requirements. As
an advisor, OSHA will identify
problems that EPA may face and
suggest appropriate solutions.
• Compliance Activities. OSHA
conducts inspections and takes
enforcement actions to ensure
compliance with the worker pro-
tection standards at Superfund
sites.
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• Implementation Activities.
OS HA supports EPA in conduct-
ing workshops to explain the re-
quirements of the standards, and
provides official interpretations
of the health and safety require-
ments.
Quick Reference Fact Sheet
A Fact Sheet titled “Hazardous Waste
Operations and Emergency Re-
sponse: General Information and
Comparison:” Publication 9285.2-
O9FS, April 1991, provides an in-
depth discussion of the scope and
purpose of the worker protection stan-
dards issued under SARA Title I.
The fact sheet also explains the inter-
face and differences of these stan-
dards with other regulations and con-
sensus standards covering the same
or similar subject matter including 1)
SARA Title III, specifically, its pro-
visions, as the Emergency Planning
and Community Right-to-Know Act
for reporting emergency releases; for
meeting the OSHA Hazard Commu-
nication Standard, and for reporting
routineor accidental toxic substances
released from a facility; 2) OSHA’s
Highly Hazardous Chemicals Notice
of Proposed Rulemaking; and, 3) the
National Fire Practice for Respond-
ing to Hazardous Materials Incidents.
Questions regarding health and safety
standards for site workers should be
directed to Rhea Cohen, Chief, Com-
pliance With Other Laws Section,
Policy and Analysis Staff, Office of
Program Management, (FTS 260-
2200 or 202-260-2200).
Phase II National Primary
Drinking Waster
Regulations: New
And Revised MCLs
and MCLGs
In January 1991 the EPA Office of
Drinking Water announced regula-
tions for 38 inorganic and synthetic
organic chemicals. These Phase II
National Primary Drinking Water
Regulations (NPDWRs) promulgate
Maximum Contaminant Level Goals
(MCLGs) and Maximum Contami-
nant Levels (MCLs) for 31 contami-
nants, repropose MCLGs and MCLs
for 5 additional contaminants (i.e.,
aldicarb, aldicarb sulfoxide, aldicarb
sulfone, pentachiorophenol, and
bariurn),andpromulgateMCLGs and
treatment technique requirements for
acrylamide and epichlorohydrin.
The Phase II regulations are autho-
rized by the 1986 Amendments to the
Safe Drinking Water Act (SDWA),
which require EPA to set MCLs for
83 specific contaminants. The origi-
nal Safe Drinking Water Act was
passedby Congress in 1974, and EPA
began rulemaking for national stan-
dards in 1975. With these new regu-
lations, there will be federally en-
forceable standards for 60 drinking
water contaminants. This number is
expected to rise to 85 by July 1992
when other standards are final.
Phase II National Primary
Drinking Water Regulations
Of the 38 drinking water contami-
nants affected by these regulations,
27 are being regulated by EPA for the
firsttime,andllarerevised. The27
newly regulated contaminants in-
clude: 12 pesticides; toluene; PCBs;
and, asbestos. (Asbestos is not clas-
sified as a carcinogen in the regula-
tions because EPA has determined it
is carcinogenic only when inhaled,
not ingested.) Of the 11 substances
already regulated, the Agency is tight-
ening standards for five, maintaining
them for two, and relaxng them for
four, based on new health informa-
tion. The five contaminants with
reproposed standards (both MCLs and
MCLGs) are barium, aldicarb,
aldicarb sulfone, aldicarb sulfoxide,
and pentachlorophenol. Table 1, on
page 6, provides a listing of the 38
organic and inorganic contaminants
and provides previous, final, and
reproposed MCLs, asappmpriate, and
the final MCLGs.
These new standards also identify the
best available treatment technologies
(BATs), which can achieve the
MCLs; provide mandatory language
that public water suppliers must use
to notify customers of standards vio-
lations; and establish requirements
for monitoring, reporting and state
implementation of the federal require-
ments. These rules include addi-
tional provisions for analytical meth-
ods and laboratory performance re-
quirements, BATs for compliance
with the MCLs and for the purpose of
issuing variances; secondary stan-
dards for silver and aluminum to ad-
dress aesthetic considerations; man-
datory health effects language to be
used by systems when notifying the
public of violations; and state report-
ing, recordkeeping and primacy re-
quirements. These standards are po-
tentially applicable toCERCLA sites
if they relate to water that is delivered
through a public water supply system
having at least 15 service connec-
tions or serving at least 25 year-round
residents. Highlight I provides a
reviewof definitions related toMCLs
and MCLGs.
Proposed, Promulgation, And
Effective Dates
The Phase II regulations were pro-
mulgated on January 30, 1991. The
final MCLs and non-zero MCLGs
for 31 contaminants became poten-
tial relevant and appropriate require-
ments forall decisiondocuments (i.e.,
Records of Decision (RODs) arid
Action Memoranda) signed on or af-
ter January 30, 1991.
The final MCLs and final non-zero
MCLGs for 31 contaminants and the
final non-zero MCLGs may be rel-
evant and appropriate but not appli-
cable for response actions carried out
during the interim period between
4
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HIghlight 1
Safe Drinking Water Act Terms And Applicability to Superfund
the promulgation date January 30,
1991 and the effective date July 30,
1992. On and after the effective date
July 30, 1992, the MCLs for 31 con-
taminants may be ARARs to
CERCLA cleanups.
The reproposed MCLs and non-zero
MCLGs for the 5 additional con tam i-
nants are “to be considered” (TBCs)
for all decision documents signed
after January 30, 1991 and up to
promulgation on July 1, 1991. These
MCLs and MCLGs may be relevant
and appropriate requirements (RARs)
but not applicable requirements for
decision documents signed between
the proposed promulgation date of
July 1, 1991 and theexpected date of
final promulgation in January 1993.
After final promulgation, these MCLs
will bepotential ARARs and the non-
zero MCLGs will be potential RARs.
RODs signed prior to January 30,
1991. The Phase II MCLs and
MCLGs should not affect RODs that
were signed prior toJanuary 30,1991.
The NCP states that ARARs “freeze”
at the time of ROD signature, and
newly promulgated requirements
necdonlybemctwherenecessary for
protectiveness. This means that only
requirements that are promulgated
(i.e., published as final regulations,
prior to the date of ROD signature)
are potential ARARs for those RODs.
Phase II requirements were not pro-
mulgated until January 30, 1991 so
they would not be ARARs for RODs
signed before that date.
Five-year reviews. While the Phase
II requirements would constitute
“newly promulgated requirements”
forpre January 30, 1991 RODs, they
are not expected to require changes
to existing RODs during the five-
year review of the remedy. The new
Phase II requirements are not replac-
ing any MCLs or MCLGs that were
outside the Superfund risk range, with
standards inside the Superfund risk
range. Therefore, they alone should
not require any remedy revisions to
ensure protectiveness during the five-
year review.
Other Recently Proposed
National Primary Drinking
Water Regulations
On June 7, 1991, final MCLGs for
lead and copper also were promul-
gated. Copper now has an MCLG of
1.3 parts per million and is a potential
RAR for aCERCLA site. The MCLG
for lead was set at zero, which is not
considered to be an “appropriate”
standard for CERCLA cleanups. This
group of regulations did not set any
MCLs foreithercontaminant, but did
set a treatment technique for lead. In
the absence of an MCL for lead,
guidance is being developed on how
Superfund will comply with the new
lead standard and to determine a level
for lead in groundwater that is pro-
tective. (For updates on issues and
developing policy relating to lead in
drinking water, contactTishO’Conor
FTS 678-8370 or 703-308-8370).
• Maximum Contaminant Levels (MCLs) are enforceable standards for public water supplies that apply to
specified contaminants that EPA has determined to have an adverse effect on human health above certain
levels. MCLs are set as close as feasible to MCLGs. Feasibility takes into account both technology and
cost considerations. MCLs are potentially ARARs at a CERCLA site.
• Maximum Contaminant Level Goals (MCLGs) are non-enforceable health-based goals for public water
supplies that have been established at levels for which no known or anticipated adverse effects on the health
of persons occur and which will allow an adequate margin of safety. MCLGs are potential relevant and
appropriate requirements at CERCLA sites.
• By definition, ARARs are promulgated, or legally enforceable Federal and State requirements. Because
CERCLA identifies non-zero MCLGs as potentially relevant and appropriate, they are considered potential
ARARs even though they are not otherwise enforceable standards. Zero MCLGs are TBCs.
• To be considered” (TBCs) include non-promulgated criteria, advisories, guidance, and proposed standards
issued by Federal or State governments. TBCs are not potential ARARs because they are neither
promulgated nor enforceable. TBCs, however, are consulted to interpret ARARs orto determine preliminary
remediation goals when ARARs do not exist for particular contaminants. Unlike ARARs, identification and
compliance with TBCs is not mandatory.
• Under the NCP, EPA determined that if an MCLG is equal to zero it is not appropriate for setting cleanup
levels, and the corresponding MCL will be the potentially relevant and appropriate requirement.
5
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Table 1
Phase II National Primary DrinkIng Water Regulations
1/91 1191 7/91 7/91
Final Final Reproposed Reproposed
lnorganlcs MCLGs 1 MCL& MCLGs 1 MCLs’
Asbestos 7.0 MFL 7.0 MFL -- --
Barium -- -- 2 2
Cadmium 0.005 0.005 -- --
Chromium 0.1 0.1 -- --
Mecury 0.002 0.002 -- --
Nitrate io.o (as N) 2 10.0 (as N) 2 -- --
Nitrite 1.0 (as N) 2 1.0 (as N) 2 -. --
Total Nitrate and Nitrite 10.0 (as N) 2 10.0 (as N) 2 -- --
Selenium 0.05 0.05 -- --
Organics
o-Dich lorobenzene 0.6 0.6
cis-1, 2-Dichloroethylene 0.07 0.07
trans-i, 2-Dichloroethylene 0.1 0.1
1, 2-Dichloro ropane 0 0.005
Ethylbenzene 0.7 0.7
Monochlorobenzene 0.1 0.1
Styrene 0.1 0.1
Tetrach loroethylene 0 0.005
Toluene 1.0 1.0
Pestlcldes/PCBs
Alachlor 0 0.002
Aldicarb -- - - 0.00 1 0.003
*Aldicafbsuffoxide -- -- 0.001 0.003
*Aldicarbsuffono -- -- 0.002 0.003
Atrazine 0.003 0.003 --
Carbofuran 0.04 0.04 - - --
Chlordane 0 0.002 -- --
Dibromochloropropane (DBCP) 0 0.0002 -- --
2,4-D 0.07 0.07 --
Ethylene dibromide (EDB) 0 0.00005 -- --
Heptach lor 0 0.0004 -- --
Heptachlor epoxide 0 0.0002 -- --
Lindane 0.0002 0.0002 -- - -
Methoxychlor 0.04 0.04 -- --
Polychiorinated biphenyls 0 0.0005 -- --
(PCBs) (as decachiorobiphenyl)
Pentachiorophenol -- -- 0 0.001
Toxaphene 0 0.003 --
2,4,5-TP (Silvex) 0.05 0.05 -- --
Reproposed MCLGs/MCLs
‘mg/I (except for asbestos which is expressed in million fibers/liter MFL)
2 As nitrogen
The policies and procedures set out in this document are intended solely for the guidance of response personnel. They are
not intended, nor can they be relied upon, to create any rights, substantive or procedural, enforceable by any party in litigation
with the United States. EPA officials may decide to follow this guidance, or to act at variance with these policies and
procedures based on an analysis of specific site circumstances, and to change them at any time without public notice.
6
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Phase V National Primary
Drinking Waster Regulations
The Phase V NPDWR for 24 con-
taminants were proposed on July 25,
1990. From July 25, 1990 until their
expected promulgation in March
1992, the MCLs and non-zero
MCLGs found in Phase V regula-
tions constitute TBCs for the cleanup
of ground water and may be consid-
ered for decision documents signed
during that period. Table 2 below
lists Phase V contaminants and their
corresponding proposed MCLs and
MCLGs.
Quick Reference Fact Sheet
A Quick Reference Fact Sheet titled
“ARARs Q’s & A’s: Compliance
with New SDWA National Primary
Drinking Water Regulations (Phase
II);” Publication 9234.2-15/FS pro-
vides an in depth discussion of the
Phase II regulations and their impact
on CERCLA cleanups.
Questions regarding the Phase II
National Primary Drinking Water
Regulations, new and revised MCLs
and MCLGs should contact Rhea
Cohen, Chief, Compliance With
Other Laws Section, Policy and
Analysis Staff, Office of Program
Management, (FTS 260-2200 or 202-
260-2200).
Table 2
Phase V National Primary Drinking Water Regulations
Inorganics MCLGs ’ MCLs 1
Antimony 0.003 0.01/0.0052
Beryllium 0 0.001
Cyanide 0.2 0.2
Nickel 0.1 0.1
Sulfate 400/5002 400/5002
Thallium 0.0005 0.002/0.0012
Organics
Dalapon 0.2 0.2
Di(ethylhexyl)adipat e 0.5 0.5
Di(ethylexyl)phthalat o 0 0.004
Dichloromethane (methylene chloride) 0 0.005
Dinoseb 0.007 0.007
Diguat . 0.02 0.02
Endothal 0.1 0.1
Endrin 0.002 0.002
Glyphosate 0.7 0.7
Hexachlorobenzene 0 0.001
Hexachlorocyclopefltadiefle 0.05 0.05
(HEX)
Oxamyl (Vydate) 0.2 0.2
PAHs [ Benzo(a)pyrene] 0 0.0002
Picloram 0.5 0.5
Simazine 0.001 0.001
1 ,2,4-Trichlorobenzefle 0.009 0.009
1,1,2-Trichloroethane 0.003 0.005
2,3,7,8-TCDD (Dioxin) 0 5E-8
‘mg/I
2 Proposed standard ______________
For submissions, ideas, or questions concerning the ROD Update, please contact Carol Bass, Hazardous Site Control
Division, 703.960-2788 or Fl’S 678-8444. Members of the public may obtain copies by contacting the RCRA/Superfiind
Hotline at 1-800-424-9346 or 703-920-9810. __________________________
7
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HighlIght 2
Regional Contacts
Fund Lead: RI/FS and ROD
Fund and Enforcement Lead:
Design and Construction
Enforcement Lead: RI/FS, ROD, RD/RA Negotiations
678-8626
678-8621
678-8614
678-8627
678-8608
678-8630
678-8646
Name
5 Trish Gowiand (IL, IN)
Ernie Watkins (Mi, WI)
Leslie Jones (MN, OH)
6 Filomena Chau
7 Jack Schad
8 Lori Boughton
9 Rick Popino (Site Specific)
Kurt Lamber (Site Specific)
10 Joe Teiger
FTS No. *
678-8622
678-8633
678-8631
678-8619
678-8629
678-8613
678-8628
678-8624
678-8632
&EPA
United States
Environmental Protection
Agency (OS-220W)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
First-Class Mail
Postage and Fees Paid
EPA
Permit No. G-35
Region Name
1 Robin Anderson
2 Loren Henning (NJ)
Shahid Mahmud (NY)
3 Sharon Frey
4 Tish O’Conor
5 Andrea McLaughlin
6 David Cooper
7 Tish O’Conor
8 Nancy Briscoe
9 David Cooper
10 Nancy Briscoe
Region
FTS No.*
678-8371
678-8392
678-8372
678-8367
678-8370
678-8365
678-8361
678-8370
678-8360
678-8360
678-8360
Region Name
1 JoAnn Griffith
2 Joe Cocalis
3 Florence Blair
4 Ken Skahn
5 Tracy Loy
6 JoAnn Griffith
7 Ken Skahn
8 Barbara McDonough
9 Steve Chang
10 Steve Chang
FTS No.*
678-8353
678-8356
678-8327
678-8355
678-8349
678-8353
678-8355
678-8347
678-8348
678-8348
Name FTS No.* Region
1 Amy Legare
2 Lanc Elson
3 Kathryn Boyle (VA, WV)
Wendy Thomi (PA)
Elisabeth Freed (DE, MD, DC, PA)
4 Neilima Senjalia (FL, AL, GA, MS)
Darlene Boeriage (KY, TN, NC, SC)
aCommercial phone number (703)308-8444
8
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