Office of Site Remediation
Enforcement (2271 A)
Washington, DC 20460
Winter 2005
EPA300-N-05-002
Issue #19
Environmental Protection
Agency
cleanupne
inside
Cooper v. Aviall Ruling 2
Region 2 Administrator Resigns
Beede Waste Oil 3
Tri-Cities Barrel CD
"Return to Use" 4
Delaware River Oil Spill 5
In the Courts 6
Lavaca Bay Settlements
Tidbits 7
PRP Search Enhancement
Conference
Safe Needle Disposal
Calendar 8
Glossary
CleanupNews is a quarterly
newsletter highlighting hazardous
waste cleanup cases, policies,
settlements and technologies.
Leavitt Nominated for
Health and Human
Services Post
President George W. Bush looks on as Administrator Leavitt speaks
during the nomination announcement.
President George W. Bush
has selected EPA Ad-
ministrator Michael
Leavitt for Secretary of the De-
partment of Health and Human
Services, a post previously held
by Tommy Thompson who re-
signed December 3. During the
December 13 announcement at
the White House, the President
thanked Leavitt for his service to
EPA and said that while leading
EPALeavitt "enforced high stan-
dards and a spirit of cooperation
and with good common sense."
Leavitt said that he felt "under-
standable regret" in leaving EPA
and described the agency as "filled
with dedicated people whom I have
come to have great affection for."
Leavitt has served as EPAAdmin-
istrator since November 2003.
During his tenure, EPA finalized
two significant Superfund settle-
ments, a consent decree for the Fox
River cleanup worth $60 million
and a $40 million settlement for
the groundwater cleanup at San
Gabriel Valley. Leavitt also an-
nounced a record $75 million in
Brownfields grants; unveiled the
Clean Air Rules of 2004; and
oversaw the development of the
Great Lakes Regional Collabora-
tion, a collective of agencies dedi-
cated to restoring the Great Lakes
through an executive order.
Senate confirmation hearings are
scheduled for mid-January. Deputy
Administrator Stephen Johnson
will serve as Acting EPA Adminis-
trator pending Bush administra-
tion nomination and Senate confir-
mation of a replacement.
& Printed on recycled paper
-------
Supreme Court Rules No
Contribution Rights For Voluntary
CERCLA Cleanups
ByClarence Featherson, Office of Site Remediation Enforcement
The Supreme Court ruled in
Cooper Industries. Inc. v. Aviall
Services. Inc. (No. 02-1192) on Decem-
ber 13, 2004. By a 7-2 majority, the
Court held that a private party who
has not been sued under CERCLA Sec-
tions 106 or 107 is not permitted to
bring a contribution action under
CERCLA Section 113(f)(l)
against other potentially respon-
sible parties (PRPs) for response
costs. Petitioner Cooper Indus-
tries, Inc., supportedby an amicus
brief filed by the United States,
asked the Supreme Court to re-
verse an en bane decision by the United
States Court of Appeals for the Fifth
Circuit that CERCLA Section 113(f)(l)
allows a PRP to conduct a "voluntary"
cleanup and then seek contribution
from other PRPs.
Congress amended CERCLA in
1986 to include Section 113(f)(l),
which provides an express cause of ac-
tion for contribution. Section 113(f)(l)
states that any person may seek con-
tribution from any other person who is
liable or potentially liable under
CERCLA Section 107 during or follow-
ing any civil action under Section 106
or Section 107 of CERCLA. The last
sentence of CERCLA Section 113(f)(l)
states that, "[njothing in this subsec-
tion shall diminish the right of any per-
son to bring an action for contribution
in the absence of a civil action under
Section 9606 of this title or Section
9607 of this title."
Justice Thomas, writing the major-
ity opinion, found that the natural
meaning of Section 113(f)(l) is that
persons may only seek contribution
subject to specified conditions, i.e., "dur-
ing or following" a civil action under
Section 106 or Section 107. The Court
held a different reading would render
the "during or following" language su-
perfluous and eliminate the need for
contribution rights for settlements un-
The Court ruled 7-2 that private
parties who have not been sued
under CERCLA cannot bring
contribution actions against other
PRPs.
der CERCLA Section 113(f)(3)(B).
The Court stated that the last sen-
tence of CERCLA Section 113(f)(l) did
not change the precondition for a civil
action. Rather, the Court held the sole
function of the savings clause is to ac-
knowledge that any other rights to
contribution that may exist are not
"diminished." The Court also explic-
itly affirmed that CERCLA created
a separate right of contribution un-
der Section 113(f)(3)(B) for a PRP who
has resolved its liability to the
United States or a State in a judicial
or administrative settlement. The
majority opinion did not address
the question of whether a unilat-
eral administrative order (UAO)
under CERCLA Section 106 is a
"civil action" that would trigger
contribution rights. However, the
United States' amicus brief filed in
this case states that the position of
the United States is that a UAO does
not grant contribution rights. The
Court left open the possibility that
continued on page 5
Head of Region 2
Resigns
EPARegion 2 Administrator Jane Kenny resigned effective November
26, 2004. Kathleen Callahan, who has worked with EPAsince 1971 and
served as Deputy Regional Administrator under Kenny, is serving as
Acting Regional Administrator. Prior to her selection as deputy last
year, Callahan helped direct EPAs response to the World Trade Center
tracks, and she was appointed Assistant Regional Administrator for
New York City Response and Recovery Programs in May 2002. As
Acting Administrator, Callahan will be oversee a $750 million annual
budget and manage 1,000 Regional employees.
Callahan's biography is available online at:
http://www.epa.gov/region2/rabio.htm.
cleanupnews
-------
Small Contributors Resolve Beede
Waste Oil Liability
EPA and the New Hampshire
Department of Environmen-
tal Services (NH DES) announced a
settlement with 276 parties to the
Beede Waste Oil Superfund site in
Plaistow, New Hampshire on Decem-
ber 6, 2004. This is the fourth settle-
ment with de minimis parties (i.e.,
parties that contributed minimal
amounts of hazardous waste at the
site compared to other parties) and
will provide $10.7 million for the
cleanup. EPAhas collected about $17
million in four settlements with 1,199
parties, and the monies raised are be-
ing held in a site-specific Superfund
special account for application to
costs associated with cleaning up the
Beede site. To date, EPAand NH DES
have spent $22 million
on site investigation
and cleanup.
This settlement rep-
resents another EPA
success with targeting
small contributors first and working
to make Superfund a simpler, more
helpful process. Using this "bottom
up" enforcement strategy, EPA en-
sures that parties will provide funds
for the cleanup. Also, by offering
small contributors early settlements,
EPAsaves litigation costs and focuses
resources on pursuing major parties
to site contamination. Small con-
The on-site oil recovery system, which has been in operation since February
2000, has removed over 85,000 gallons from the site.
Targeting small
contributors first
ensures EPA will have
funds for the cleanup.
tributors benefit from early settlements
because they are able to quickly resolve
their liability and avoid
lengthy and costly litiga-
tion.
From the 1920s to
1994, the 40-acre site
was used for a variety of
oil-related activities, including waste
oil processing and resale. In 1995,
groundwater sampling identified vola-
tile organic compounds in on-site moni-
toring wells and two private residential
wells. Additional testing found un-
healthful levels of several contami-
nants, includingPCBs, in groundwater
and soils, and the site was added to the
National Priorities List in 1996. In 1996
and 1997, EPAand NH DES removed
approximately 100 above-ground stor-
age tanks and 800 drums. The Janu-
ary 2004 Record of Decision calls for
soil removal and disposal, a soil va-
por extraction system, long-term
monitoring, and institutional con-
trols. The remedy allows for future
redevelopment of the site for residen-
tial or recreational use.
Additional information about
Beede Waste Oil Superfund site and
the settlements is available online
at: http://www.epa.gov/ne/superfund/
sites/beede/index.htm.
For additional information, contact
Cynthia Lewis, EPA Region 1,
lewis. cindy@epa. gov.
"
Agreement Signed for Tri-Cities Barrel
On November 26, 2004, the
EPA Region 2 Regional Ad-
ministrator signed a consent decree
(CD) with Alcan Aluminum Corpora-
tion for the Tri-Cities Barrel
Superfund site in Broome County,
New York. Under the CD, Alcan has
agreed to reimburse EPA up to $1.4
million for its past and future response
costs and to pay a $360 thousand pen-
alty for violating a CERCLA cleanup
order.
Alcan was among a large number of
potentially responsible parties (PRPs)
at the site. EPA initially entered into
early de minimis settlements with 28
PRPs. Then, in an August 2001 con-
sent decree, 43 additional parties
agreed to implement the remedial de-
continued on page 6
cleanupnews 3
-------
"Return to Use" Initiative to
Spur Reuse
On November 10, 2004, EPA
launched a new initiative—
"Return to Use"—that encourages
reuse and redevelopment of
Superfund sites. Through "Return to
Use" (RTU), EPA will review imple-
mented site remedies for unnecessary
barriers to reuse and determine if
small modifications will enable com-
munities to reuse properties while
protecting human health and the en-
vironment. EPAwants to remove the
stigma typically associated with
former contaminated sites and spur
commercial, ecological and recre-
ational use of fenced, abandoned, and
underutilized properties.
RTU focuses on the approximately
500 National Priorities List sites
where remedies were implemented
before the 1999 launch of the
Superfund Redevelopment Initiative
(SRI). Prior to SRI, remedy selection
was focused primarily on removing
immediate threats to human health
and the environment and less on how
the site would be used after cleanup.
With the introduction of SRI, EPA
encouraged considering future site
use when determining a remedy
and ensuring that the remedy would
"Return to Use" will
encourage the reuse and
redevelopment of Superfund
sites.
be consistent with anticipated or
potential use. When reviewing sites
where remedies were initiated be-
fore 1999, EPA will consider modi-
fying restrictive fences or deedlimi-
tations that go beyond what is re-
quired for the site to remain pro-
tective, issuing Ready for Reuse
(RfR) determinations, and elimi-
nating misleading signs.
EPA has selected 11 demonstra-
tion projects for the initiative. One
of the sites, HOD Landfill in
Antioch, Illinois, is a former land-
fill where overly restrictive barri-
ers and concerns about the site be-
ing a Superfund site were prevent-
ing reuse. EPAand stakeholders re-
viewed and updated the risk assess-
ment, and EPA issued an Explana-
tion of Significant Differences remov-
ing unnecessary parts of the remedy.
EPA then issued an RfR determina-
tion assuring residents that the site
can be used for recreation, and the
former landfill is being turned into
athletic fields for a high school adja-
cent to the site. The RfR determina-
tion for HOD Landfill was highlighted
in CleanupNews II-February 2004,
which is available online at: http://
www.epa.gov/Compliance/resources/
newsletters/cleanup/cleanup 15s.pdf.
Additional information about the
initiative, including a fact sheet and
demonstration project descriptions,
is available online at: http://
www.epa.gov/superfund/programs/
recycle/rtu/index.htm.
For additional information, contact
Melissa Friedland, National Program
Manager for Superfund Redevelop-
ment, (703) 603-8864 or
friedland. melissa@ena. sov.
Vacant Field to be Converted to
Neighborhood Park
The Arlington Blending and Pack-
aging site in Tennessee is one of 11
"Return to Use" demonstration
projects. For seven years, the Arling-
ton site was used for formulating and
packaging pesticides, and spills led
to soil and groundwater contamina-
tion. In 1996,41,000 tons of contami-
nated soil were removed from the
property. Over the past 10 years, veg-
etation has returned to the site.
Residents and community leaders
had shied away from reusing the
property because it had been a
Superfund site. Through a "Ready
for Reuse" determination and com-
fort letter, EPA assured the com-
munity that the property was safe
to use for recreational purposes,
and the city will be converting the
land into a 2.3-acre neighborhood
park. EPA has determined that
the land can be used for this pur-
pose without interfering with on-
going groundwater monitoring.
For additional information
about the Arlington Blending and
Packaging demonstration project,
contact Derek Matory,
Remedial Project Manager,
matorv. derek@epa. sov.
In a few months, the unused Arlingtc
property will boast a playground,
walking and biking trails, and a
basketball court.
cleanup
-------
Agencies Respond to Oil Spill on
Delaware River
On November 27, 2004, a ves-
sel tanker heading for a Citgo
facility in Paulsboro, New Jersey
spilled approximately 30,000 gallons
of crude oil into the Delaware River.
The cause of the spill is still under in-
vestigation. The spill occurred as tug-
boats were assist-
ing the Athos I, a
750-foot vessel
with a Cyprus flag,
to the Citgo facili-
ties pier. Athos I listed 8 degrees to
the left, and the engine cut off. The
spill spread from just north of the Ben-
jamin Franklin Bridge south to the
Commodore Barry Bridge. A safety
zone was established around the spill
from the Tacony Palmyra Bridge to the
Commodore Barry Bridge, and this
section of the river was closed to all
pleasure and commercial craft for ap-
proximately 24 hours after the spill
occurred.
Many federal, state, and local agen-
cies and contractor personnel came to-
gether to assist in cleanup of the spill
Responders have collected
nearly 65,000 gallons of oil
and oily liquid.
and protect wildlife including: EPA, the
Pennsylvania Department of Environ-
mental Protection, New Jersey Depart-
ment of Environmental Protection, New
Jersey State Police, the Coast Guard
Marine Safety Office-Group, Delaware
Department of Natural Resources, U.S.
Fish and Wildlife,
National Oceanic
and Atmospheric
Administration,
Tri-State Bird Res-
cue, and representatives from Citgo
and the ship's owner. Thousands of feet
of protective boom was laid out to help
prevent the spread of crude oil to other
areas of the river and wildlife habitat.
As of early January, responders have
collected nearly 7,000 tons of oily sol-
ids, 65,000 gallons of oil and oily liq-
uid, and 2,000 gallons of submerged
oil. Also, 228 captured birds have been
released. The cleanup effort will con-
tinue over the next several months.
Updates on the cleanup effort and
the ongoing investigation into the cause
of the spill are available online at:
http ://www .incidentinfo .com/external/
index.cfm?cid=864.
For additional information, contact
the Joint Information Center, (267)
765-3441.
Supreme Court, continued from page 2
Aviall had a CERCLA Section 107 ac-
tion and remanded the case for fur-
ther proceedings on that issue consis-
tent with its opinion.
In a dissenting opinion, Justice
Ginsberg and Justice Stevens argued
that the issue of whether Aviall had a
right to file an action pursuant to
CERCLA Section 107 should have
been decided in this case by the Su-
preme Court and not remanded to a
lower court. The court did not address
whether a PRP has a cause of action
against other PRPs under section 107,
stating that the issue was not ad-
dressed by the courts below or fully
briefed by the parties.
The implications of the Court's de-
cision for EPA's site remediation en-
forcement and brownfields' programs
and state voluntary cleanup programs
will be monitored and assessed by EPA
and states.
Case background was provided in
CleanupNews Spring 2004, available
online at: http://www.epa.gov/Com-
pliance/resources/newsletters/
cleanup/cleanuplS.pdf. The Supreme
Court decision is available online at:
http://www.supremecourtus.gov/opin-
ions/04pdf/02-1192.pdf.
For additional information, contact
Clarence E. Featherson, OSRE, (202)
564-4234.
o
I
*
kers clean the shoreline December
cleanupnews 5
-------
Two Lavaca Bay Settlements
Announced
On December 10, 2004, the
U.S. Department of Justice,
EPA, National Oceanic and Atmo-
spheric Administration, Department
of Interior, and State of Texas an-
nounced two settlement agreements
with Alcoa Inc. and Alcoa World Alu-
mina related to Lavaca Bay and the
Point Comfort/Lavaca Bay Superfund
Site.
Sediments in Lavaca
Bay were contaminated
with mercury from past
operations at Alcoa Inc.'s
Point Comfort facility. Alcoa owned
the plant from 1948 until 1994 when
it was purchased by Alcoa World Alu-
mina. Alcoa operated a chlorine-al-
kali processing unit and discharged
wastewater containing mercury into
Lavaca Bay.
Under the two settlement agree-
ments lodged with the U.S. District
Court, Alcoa will undertake a variety
of restoration actions. Alcoa has al-
ready spent approximately $40 mil-
lion for early response actions and will
spend approximately $11.4 million to
complete the remaining cleanup ac-
tions. Alcoa will also pay governmen-
tal agencies for incurred costs. Under
the cleanup consent decree, Alcoa will
dredge contaminated sediments, op-
erate a groundwater recovery system
at the former chlorine-alkali plant,
cap portions of the plant, and monitor
sediments and fish.
Under the natural resource damages
consent decree settlement, Alcoa will
construct a 70-acre salt marsh on
Powderhorn Lake's north shore and an
11-acre oyster reef in southeast
Lavaca Bay; purchase and transfer
approximately 730 acres of land to the
U.S. Fish and Wildlife Service for ad-
dition to the Aransas National Wild-
life Refuge. To
Alcoa Will help restore the increase and
bay by Constructing a Salt enhance recre-
marsh and oyster reef. ational fishing
in Lavaca Bay,
Alcoa will replace the existing auxil-
iary boat ramp and construct a new
timber dock; modify an existing jetty;
and construct a new timber dock.
Alcoa will provide funding to local en-
tities for maintaining and insuring
these structures against loss for the
next 15 years.
Comments from the 30-day public
comment period will be considered
before the settlement is considered fi-
nal.
For additional information, contact
Gary Baumgarten, EPA Region 6, (214)
665-6749.
Tri-Cities, continued from page 3
sign and remedial action (RD/RA), but
Alcan refused to participate. In Sep-
tember 2001, EPA issued a Unilat-
eral Administrative Order (UAO) to
Alcan and to one other PRP directing
them to participate in the RD/RA.
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Alcan alone failed to comply with
the UAO, and EPAsought recovery
against Alcan of outstanding past
and future costs plus a penalty for
non-compliance with the UAO.
With the Alcan CD, all financially
viable PRPs are contributing to the
site cleanup.
From 1955 to 1992, Alcan and
other companies sent drums for re-
conditioning, and the resulting
wastewater was discharged into
unlined lagoons and on-site soils
and groundwater became contami-
nated with volatile organic com-
pounds, semi-VOCs, pesticides,
metals and PCBs. Tri-Cities Bar-
rel was proposed to the NPL on
May 5, 1987 and listed on October
4, 1989. In a PRP-lead removal
action in 1996, all drums, tanks,
and on-site containers were re-
moved; all structures were decon-
taminated, demolished, and dis-
posed; and operational equipment
was decontaminated and re-
moved. A March 2000 Record of
Decision outlined a remedy, then
estimated at $20.4 million, to ad-
dress soils, sediments and ground-
water. Under the CD, PRPs have
completed the cleanup of the soils
and sediments and are now evalu-
ating the groundwater remedy.
Approximately 350 drums and
93,000 tons of soil and sediment
have been excavated and disposed
offsite at appropriate disposal fa-
cilities. Some materials were in-
cinerated prior to disposal.
The CD with Alcan was lodged
with the United States District
Court on December 14, 2004, and
the 30-day public comment period
began December 29, 2004.
For additional information, con-
tact Michael Mintzer, EPA Region
2, (212) 637-3168.
cleanupnews
-------
PRP Search Enhancement National
Conference Held in Denver
By Nancy Deck, Office of Site Remediation Enforcement
Tie Fourth National Confer
jnce on PRP Search Enhance-
ment was held in Denver, Colorado,
on August 10 through 13, 2004. The
conference was planned and presented
by EPA's PRP Search Enhancement
Team. Conference participants ranged
from subject matter experts to those
new to the PRP search process. In ad-
dition to formal programs, the confer-
ence provided PRP search personnel
an opportunity to meet and share ex-
periences with their counterparts from
other agencies and areas of the coun-
try. Participants included represen-
tatives of all ten EPA regions, the
states of Arizona, California, Hawaii,
Kansas, Mississippi, Oklahoma,
South Carolina, and Tennessee, the
Navajo Nation, the U.S. Department
of Agriculture, and the U.S. Depart-
ment of Justice.
Conference sessions addressed nu-
merous issues encountered by PRP
search personnel. For example, in the
Environmental Liability Insurance
session two EPA subject matter ex-
perts and representatives of the In-
surance Archaeology Group and the
law firm Anderson, Kill & Olick dis-
cussed insurance law issues that are
commonly encountered at CERCLA
and RCRA cleanup sites, EPAs role
in seeking insurance coverage for such
cleanups, and the sometimes difficult
process of identifying insurance poli-
cies that may provide coverage at older
sites. Other session topics included
Bankruptcy and Ability to Pay, PRP
Search "Best Practices," Superfund
and Corporate Liability, Sites with
Numerous Generators, Conducting
Title Searches, Real Property Law,
Windfall Liens & Bona Fide Prospec-
tive Purchasers, Interviewing Tech-
niques, FOIA Procedures & PRP
Searches, and Alternative Dispute
Resolution & PRP Searches. In addi-
tion, an important interactive session
provided an opportunity for represen-
tatives of EPA, states, tribes, and other
federal agencies to discuss ways to en-
hance their partnerships in the PRP
search process.
By all accounts the conference was a
success, in large part due to the par-
ticipation of a broad spectrum of the
PRP search community and the well-
rounded expertise of the presenters.
During FY05, the PRP Search Enhance-
ment Team will follow up on ideas dis-
cussed at the conference for facilitat-
ing enhanced communication andtrain-
ing for PRP search personnel.
For additional information about the
conference or the PRP Search Enhance-
ment Team, contact Team Leader Nancy
Deck, OSRE, (202) 564-6039.
EPA Recommends Safer Disposal
Methods for Used Syringes
By Diane Bartosh, Office of Solid Waste
EPA recently issued new pub
lications that encourage
people to dispose of used needles
through community drop-off programs,
household hazardous waste facilities,
sharps mailback programs, or at-
home needle destruction devices. Pro-
tect Yourself, Protect Others: Safe Op-
tions for Needle Disposal (EPA530-F-
04-004) and Protecting Your Commu-
nity from Sharps: Options for Safe Dis-
posal of Sharps (EPA530-K-04-001)
were developed in collaboration with
the Coalition for Safe Community
Needle Disposal. The first document
aims to re-educate self-injectors about
better management of used needles,
and the second is designed for use by
states to help keep used syringes out
of all trash collections. The Coalition
for Safe Community Needle Disposal
is a collaboration of businesses, com-
munity groups, nonprofit associations,
and state, local, and federal govern-
ment entities committed to promot-
ing public awareness of the hazards
posed by improperly disposed sharps.
The purpose of the documents is to
encourage people to think about used
needles from a health standpoint
rather than as a waste management
or disposal issue. Approximately 8 to
9 million people use syringes for a
wide range of medicinal purposes,
which creates about 3 billion used
needles a year. The Agency is distrib-
uting the new publications not only to
promote safer disposal alternatives,
but also to encourage people to reduce
the amount of this waste. The new
publications are free and available
online at: www.epa.gov/epaoswer/other/
medical/sharps.htm. They can be or-
dered online at: http://www.epa.gov/
ncepihom/ordering.htm; by email:
ncepimal@one .net: or by calling 800/
490-9198. Self-injectors should re-
quest EPA530-F-04-004; state and lo-
cal governments should request
EPA530-K-04-001.
deanupnews 7
-------
CO
O
February 27 - March 3
WM'05, the 31st Waste
Management Symposium
Tucson, AZ
http://www,wmsym,org/
May 18 - 20
Solid/Hazardous Waste
Conference and
Exhibition
Gatlinburg, TN
http://www,state,tn, us/environment/
swm/conference/
July 12 - 15
2005 Community Involvement
Conference and Training
Buffalo, NY
http ;//www, epancic, org/2005/
overview, cfm
Glossary
CD
CERCLA
EPA
NHDES
OECA
OSRE
OSWER
Consent decree
Comprehensive Environmental Response,
Compensation, and Liability Act
Environmental Protection Agency
New Hampshire Department of
Environmental Services
Office of Enforcement Compliance and
Assurance
Office of Site Remediation Enforcement
Office of Solid Waste and
Emergency Response
PCBs
PRP
RTU
SRI
UAO
USCG
VOCs
Polychlorinated biphenyls
Potentially responsible party
Return to Use Initiative
Superfund Redevelopment Initiative
Unilateral administrative order
United States Coast Guard
Volatile organic compounds
cleanupne
CleanupNews is a quarterly publication of
EPA's Office of Site Remediation Enforcement,
in cooperation with the Office of Superfund
Remediation and Technology Innovation, Office
of Underground Storage Tanks, and Office of
Emergency Prevention, Preparedness and
Response. Past issues of CleanupNews can
be found at http://www.epa.qov/conipliance/
resoiirces/iiewsletters/deaiiiip
deaiuipnews.htinl
Richard W. Popino, PhD REM, editor-in-chief
EPA Review Board; Diane Bartosh, Paul Connor,
Sandra Connors, Karen Ellenberger, Elliott Gilberg,
Jeff Heimerman, Kenneth Patterson, Neilima Senjalia
Suzanne Wells
Christine Rueter, Anne Dowton, and Jon Kallen
DPRA Inc., writers
Mary Spencer,
DPRA Inc., designer
To comment on the newsletter contact Richard W. Popino, PhD REM, at MC-2271A, U.S. EPA, 1200 Pennsylva-
nia Ave., NW, Washington, DC 20460, emaihpopino.rick@epa.gov.
To be added or deleted from the subscriber list, Contact Christine Rueter at: christine.rueter@dpra.com
To receive CleanupNews by email, subscribe at http://www.epa.gov/compliance/resourct
cleanup.html.
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