Office of Site Remediation Enforcement (2271 A) Washington, DC 20460 Spring 2004 EPA300-N-04-002 Issue #16 Environmental Protection Agency cleanupne ^^^^_ inside ^^^^•H Spotlight 3 Contiguous Property Owner Guidance Highlights 4 Poudre River Cleanup O'Brien Redevelopment OSWER News 5 RCC Annual Report In the Courts 6 Bunker Hill Tidbits 7 Service Station Dealers Liability Calendar 8 Glossary CleanupNews is a quarterly newsletter highlighting hazardous waste cleanup cases, policies, settlements and technologies. Supreme Court To Decide Contribution Rights for Voluntary Cleanups On January 9, 2004, the Supreme Court agreed to hear to hear the case of Cooper Industries v. Aviall Ser- vices (also known as Aviall). In Aviall, the Supreme Court will decide whether a potentially re- sponsible party (PRP) under CERCLA Section 107(a) who has neither been sued under Section 106 or 107(a) of CERCLA nor re- solved its CERCLA liability through an administrative or ju- dicially approved settlement may conduct a voluntary CERCLA cleanup and then seek contribu- tion from other PRPs under CERCLA Section 113(f). On February 23, 2004, the United States filed an Amicus brief with the Supreme Court asserting that under CERCLA Section 113(f)(l) a prerequisite for PRPs seeking con- tribution under CERCLA Section 113(f)(l) is being sued under CERCLA Section 106 or 107(a). On March 3, 2003, the Supreme Court's calendar of cases scheduled for oral arguments in the April 2004 ses- sion was made public, and it does not include the Aviall case. It is anticipated the Court will hold this continued on page 6 Leavitt Cuts Ribbon for New Emergency Operations Center By Bryan Byrd, Office of Emergency Prevention, Preparedness, and Response On January 14, 2004, EPA Administrator Mike Leavitt and Assistant Administrators Morris Winn, Kim Nelson, and Marianne Horinko cut the ceremonial ribbon celebrating the opening of EPAs new Emergency Operations Cen- ter (EOC). The opening concluded a collaborative effort by the Office of Solid Waste and Emergency Re- sponse, Office of Environmental In- formation, and Office of Admin- istration and Resource Manage- ment to transform EPAs EOC into one of the most technologically-ad- vanced centers in the nation. The EOC's improved technology and capability resulted from "les- sons learned" from large national events, including the terrorist at- tacks of September 11th and the continued on page 2 on recycled paper ------- Leavitt, continued from page 1 anthrax response. Experience in these events showed the need for EPA to strengthen internal communication and interaction with other federal agencies. The new EOC was designed to be used by numerous offices within the EPA. EPA is involved in a wide range of emergencies from almost-daily rou- tine spills of hazardous substances to nationally-significant incidents, such as the response to the Columbia Shuttle recovery mission last year. The EOC receives about 30,000 inci- dent notifications a year. Of these, EPA responds to 250 hazmat incidents and 300 oil spill responses. In addition, EPAs role in homeland security, criti- cal infrastructure protection, and pre- paredness has increased. Design and Construction of the Center "Lessons learned" from recent events drove the design of the new EOC. One lesson was that during a large complex event, additional space is needed for multiple organizational elements to work with breakout capa- Workstations in the new Emergency Operations Center "This center is to be a resource for the entire Agency. — Debbie Dietrich, Director of the Office of Emergency Prevention, Preparedness, and Response bility. To address this needfor space, the new EOC was designed with an op- erations center accommodating 12 workstations, a watch officer post, and a data management station. Three separate breakout rooms each holding up to 10 additional people and a sepa- rate 30 person executive conference room are connected to the operations center. The addition of the breakout rooms and executive conference room provide the EOC with fully functional, partitioned capacity allowing indepen- dent meeting space. 2 cleanupnews Capabilities/Utilization The EOC will be used for all aspects of emergencies including preparedness and critical infrastructure protection. During daily operations, the EOC handles incident notifications, gathers intelligence, analyzes the information. and rapidly shares the information with appropriate Agency personnel. EOC staff is in con- stant con- tact with Regional Response Centers. On-Scene Coordinators, and the Environmental Response Teams as well as other fed- eral agency EOCs, including the Depart- ment of Homeland Security Operations Center. Classified information is handled through the EOC's Secure Ac- cess Facility and Sensitive Compart- mented Information Facility. As part of EPAs National Approach to response, during a Nationally Sig- nificant Incident, members of the Agency's developing Response Support Corps will assemble and work together in the operations center. The Re- sponse Support Corps is made up of volunteers from the Offices of Water, Air and Radiation, and Public Affairs and others who have made it a prior- ity to help in time of an emergency. RSC staff will have access to work stations fully equipped with the lat- est technology. They will have the ability to communicate with each other, the field, and other agencies. With video-conferencing ability, 8 x 20 video wall, 9 screens, and poten- tial to hold responders from offices across the Agency as well as inter- agency staff, the EPAs new EOC is fit to handle any crisis. During a nationally significant event or in the course of daily opera- tions, the EOC is a resource that will improve and support decision-mak- ing for the entire Agency. Having the latest technology enhances Agency ef- forts to analyze data, communicate with the field, and to be prepared for the unexpected. For additional information, contact Bryan Byrd, Office ofEmergency Prevention, Preparedness and Response, (202) 564-9499. ------- OSRE Releases Guidance on "Contiguous Property Owners" By Gate Tierney, Office of Site Remediation Enforcement On January 13, 2004, EPA issued an interim guidance entitled Interim Enforcement Discretion Guidance Re- garding Contiguous Property Owners ("Contiguous Property Owner guid- ance"). This guidance addresses CERCLA § 107(q), the "contiguous property owner" liability protection added to CERCLA by the 2002 Brownfields Amendments. "Contiguous property owners" are those who Congress identified as vic- tims of their neighbor's pollution. These landowners own property that is not the original source of the hazardous substance contamination, but whose property is or may be contaminated due solely to the actions of a different property owner. EPAs guidance fo- cuses on the most common questions and big picture issues EPA has heard about contiguous property owners. First, the Contiguous Property Owner guidance discusses some of the statutory criteria a landowner must meet in order to be a contiguous prop- erty owner and evidences EPAs intent to implement the new landowner liabil- ity provisions in a manner that provides real and meaningful liability protection to landowners. For example, the guid- ance provides that, in exercising its en- forcement discretion, EPA may treat a landowner as a protected Section 107(q) party even if he owns property that is not immediately adjacent to the source of the contamination. Second, the guidance discusses the application of Section 107(q) to current and former owners of property and pro- vides that EPA may treat former own- ers of property as contiguous property owners as long as they met the statu- tory criteria of Section 107(q) while they owned the property. Third, the guidance discusses the re- lationship between new Section 107(q) and EPAs Residential Homeowner and Contaminated Aquifers Policies. The guidance notes that Section 107(q) pro- tects from CERCLA liability many land- owners that EPA did not generally pursue, through the exercise of its en- forcement discretion, prior to the pas- sage of the Brownfields Amendments. The guidance points out that these previously-existing policies are still in effect and, to the extent that they are broader (i.e., apply to more land- owners) than Section 107(q), EPA may still apply these policies through the exercise of its enforcement dis- cretion. Finally, the guidance discusses the mechanisms EPA may provide, in its discretion, to resolve the remaining liability concerns of contiguous prop- erty owners. These mechanisms in- clude no action assurance letters and settlements under Section 107(q). The guidance and a reference sheet are available at: http://cfpub.epa.gov/ compliance/resources/policies/ cleanup/superfund/. For additional information, contact Gate Tierney, OSRE, (202) 564-4254. Bush Administration Proposes $45 Million for Great Lakes Cleanup On January 29, 2004, EPA Administrator Mike Leavitt announced that President Bush's 2005 budget pro- posal includes $45 million for cleaning up contaminated sediments in the Great Lakes. Leavitt made the announcement while visiting Belle Isle, one of 31 "Areas of Concern" within the Great Lake system. The "Areas of Concern" are areas where the sediments are heavily contaminated with PCBs, heavy metals, and polycyclic aromatic hydrocarbons (PAHs). The Great Lakes Legacy Act, signed in November 2002, authorizes up to $270 million between 2004-2008 to clean up the contaminated sediments. The proposed amount represents a $35 million increase over the 2004 Great Lakes Legacy Act funding. Leavitt said that the increase "demonstrates the President's commitment to preserving and protecting these Great Lakes" and that "accelerating the cleanup of these contaminated areas will help keep the pollution from moving out into the lakes where cleanup becomes dramatically more diffi- cult." The proposed 2005 funding will address between four and six of the Areas of Concern. EPA will partner with the states, tribes, and stakeholders to determine which cleanup projects to fund with the funding. Additional information about the Great Lakes Legacy Act and the Great Lakes Program are available at: http:// •www. eva. zov/zlla. 0) cleanupnews 3 ------- (ft Poudre River Investigation and Cleanup Begin In September 2002, a contractor for the City of Fort Collins assisting with a Brownfields pi- lot study noted an oily sheen on the Cache la Poudre River, a river that runs through Fort Collins, Colorado. Since that discovery, EPA's Office of Brownfields Cleanup and Redevelop- ment has studied the 1/8-mile section of the river where the substance—coal tar—was identified and 19 acres of adjacent commercial and residential property. Investigation results have not pointed to a definitive source for the contamination, but analysis of the river sediments has revealed that the tar is similar in composition to waste at the nearby former Poudre Valley Gas Plant. The coal gasification plant. which operated from 1904 to 1926, con- verted coal into fuel for heat and elec- tricity. The Public Service Company of Colorado (doing business as Xcel Energy) owns a portion of the gas plant site and has agreed to fund the estimated $1.5 million cleanup project. In January 2004, EPA and Xcel Energy signed an administrative order on consent to implement the investigation and cleanup of the Poudre River. Through the collabo- rative efforts of EPA, Xcel, and the City of Fort Collins, the work be- gan the week of January 26, 2004. The investigation and cleanup in- volves diverting a portion of the river through pipes to avoid contact with contaminated sediments and replacing removed sediments. To help determine the source of the contamination, new monitoring wells will be installed, and a trench will be dug to the bedrock. During the project, temporary fenc- ing will be in place, and air and water monitoring will be performed to en- sure public health and safety. Also, a portion of the Poudre River Trail will be re-routed, and one of the parking lots for the Gustav Swanson Natural Area will be closed. The Aztlan Com- munity Center, United Way facility. and skate park located near the worksite will not be affected. Fortu- nately, the drinking water intakes for the cities of Fort Collins and Greeley are located upstream from the con- tamination, and it does not appear that anyone is using the groundwater at or around the worksite. The work, including re-vegetation. will be completed by May 2004. For additional information, contact Jennifer Lane, EPA Region 8, lane.iennifer&eva.zov. O'Brien Machinery Project: Enforcement Working to Redevelop Property byJocelyn Scott, Office of Site Remediation Enforcement ain Street Village—an exciting new townhome community in Downington. Pennsylvania—is a far cry from the contaminated industrial site that was once owned by O'Brien Machin- ery Company. The 10.6-acre parcel is now the site of a recently developed 160-unit housing development with a beautiful creek and newly land- scaped surroundings. EPA's Superfund enforcement program rec- ognized the benefits of this project to human health and the environment. and made significant efforts that helped bring redevelopment of this site to fruition. During the 1980s, the O'Brien Machinery Co. operated a manu- facturing plant that built and re- paired large electrical generators used in industrial processes. The site was abandoned after the owner of the property went bankrupt ow- ing over $1 million in unpaid back taxes. The site turned from a pro- ductive facility into an abandoned contaminated property riddled with drug dealers and dilapidated buildings. When EPA discovered the site in 1992, it found transform- ers leaking PCB-containing fluids onto the site and subsequently con- ducted removal activities. The Agency attached a $1.5 million CERCLA hen against the property for costs it incurred in performing these removal activities at the site. Al- though EPA's cleanup efforts were sufficient to prevent an endangerment posed by high levels of PCBs, further cleanupnews ------- EPA Details Resource Conservation Challenge Accomplishments EPA recently published the first annual report on the Resource Conservation Challenge, a major cross-Agency ini- tiative that identifies and uses inno- vative, flexible, and protec- tive ways to conserve natu- ral resources and energy. RCC works to (1) prevent pollution and promote recy- cling and reuse of material; (2) reduce the use of toxic chemicals; and (3) conserve energy and materials through partnerships and programs that protect hu- man health and the environment; save energy and reduce greenhouse gases; create jobs; and grow the economy. The report outlines major RCC achievements, including measurable environmental benefits and an in- crease in the number of new partner- ships. Nearly all the RCC environmen- tal benefits result from voluntary pub- lic-private partnerships. In 2003, ex- isting RCC partnerships with federal and state governments, tribes, and industry grew, and new ones were formed. The Agency's long-standing partnership, Waste Wise, grew to over 1,300 members, and new partner- ships like the National Waste Mini- mization Partnership Program, the Coal Combustion Products Partner- ship, Plug-In to eCycling, and the "This report shows us that the old ways of doing business are too slow and discouraging, and that the RCC is a successful, collaborative tool for achieving future progress on the environment." -Marianne Horinko, EPA Assistant Administrator for the Office of Solid Waste and Emergency Response GreenScapes Alliance grew from the ground up. RCC's partners identified environmentally beneficial solutions to specific problems and implemented them. For example: •A Waste Minimization Partner in Texas is working to reduce polycyclic aromatic hydrocarbons (PAHs) in tank bottom wastes by 32,000 pounds and benzene by 70,000 pounds. • Plug-In to eCycling partners safely recycled 26.4 million pounds of elec- tronic equipment in 2003. • The tire partnership is committed to reduce, recycle, or otherwise recover 85 percent of newly generated scrap tires and to reduce the number of tires in existing stockpiles by 55 percent within four years. •In 2002, Waste Wise partners col- lectively reduced greenhouse gas emis- sions by 2.4 million tons. "I'm thrilled at the energy and enthusi- asm surrounding the RCC-and the real sense of ownership by EPA nationwide," said Marianne Horinko. EPA Assistant Administrator for the Office of Solid Waste and Emergency Response. "It's a true collaboration among diverse stakeholders. We'll ac- complish more in less time than years of regulatory development and litiga- tion could ever do." The RCC annual report is available at: http://www.epa.gov/epaoswer/osw/ conserve/resources/rcc-rptl.pdf. Com- plete information about the Resource Conservation Challenge is also on the Web at: http://www.epa.gov/rcc. For additional information, contact Diane Bartosh, Office of Solid Waste, (703) 308- 7895. Want to join us in conserving paper? It's fast and simple. Go to the CleanupNews page at: , enter your email address, and click "Submit." When a new issue of CleanupNews comes out, you'll receive it in HTML—right to your desktop! Note: Signing up for electronic issues does not automatically cancel your hard copy subscription. Send hard copy subscription change requests to cleanupnews 5 ------- (ft •c o o 0) S Cooper, continued from page 1 case over for oral argument until Oc- tober 2004. Background: Cooper Industries ("Cooper") oper- ated an aircraft maintenance business that contaminated the property with hazardous substances. In 1981, Aviall Services ("Aviall") purchased Cooper's business and its operation. Aviall's operation of the business also resulted in the deposition of hazardous mate- rials. When Aviall found hazardous substance contamination, it notified Texas authorities, and cleaned up the property without an order from state or federal authorities. Aviall subse- quently sought contribution from Coo- per under section 113(f) of CERCLA, which allows parties to seek contribu- tion from other parties responsible for the contamination of the site. The district court rejected Aviall's claim holding that Aviall voluntarily cleaned up the site and that CERCLA 113(f) only applies where a cleanup action occurs pursuant to a lawsuit or settlement involving the federal or state government. Aviall appealed the district court's decision to the United States Court of Appeals for the Fifth Circuit. In November 2002, the Fifth Circuit reversed the lower court's de- cision and found that Aviall could seek contribution from Cooper under CERCLA Section 113(f) even though Aviall cleaned up the site voluntarily. In December 2003, Cooper filed a pe- tition for certiorari asking the Supreme Court to review the case. The Supreme Court invited the United States to file an Amicus brief on whether the Su- preme Court should grant certiorari and hear the case. On December 12. 2003, the United States filed an Am- icus brief recommending that the Court review the case. On January 9. 2004, the Supreme Court decided to review this case. The United States filed an Amicus brief on the merits of the case on February 23, 2004. For additional information, contact Clarence Featherson, OSRE, (202) 564- 4234. Bunker Hill Superfund Site Notice of Appeal Filed In two court decisions issued on Sep- tember 3, 2001 and November 18. 2003, the U.S. District Court for the District of Idaho awarded a $7 million reduction in remaining financial re- sponsibilities of a 1994 consent decree at the Bunker Hill Mining and Metal- lurgical Site to the defendants, Asarco. Inc. and Hecla Mining Company. The court determined the modification of the agreement was appropriate be- cause factual circumstances had changed since the lodging of the 1994 decree. From the late 1800s to the 1970s, mining activities upstream and a lead smelter in the Coeur d'Alene Basin contaminated the groundwater, soil. air, and Coeur d'Alene River with lead. arsenic, zinc, and cadmium. The af- fected area is divided into three cleanup projects. Operable unit 1 (OU1) and OU2 are within the "Box," a 21-square-mile area within the Coeur d'Alene Basin comprised of his- toric smelter and mining areas as well as residential areas containing 5,000- 6,000 residents. OU3 is the "Basin," which runs along the Coeur d'Alene River through Lake Coeur d'Alene and into the Spokane River. Since 1994. over 2,200 residential and community areas have been cleaned up and blood lead levels in children have been re- duced significantly through the ef- forts of EPA and Upstream Min- ing Group, a syndicate of mining companies including Asarco and Hecla. The Box was the area of focus for remediation pursuant to the 1994 decree. The court found that EPA's recent decision to use CERCLA remedial authorities to deal with environmental issues outside of the Box but inside the Coeur d'Alene Basin represented a departure from EPA's previ- ously announced plans and an in- crease in the total potential finan- cial exposure of the movants. Ac- cording to the court, EPA made it more difficult for the defendants to obtain credit backing to meet the financial requirements of the 1994 agreement by permitting cleanup efforts on the mining wastes outside of the Box. To com- ply with the court order, EPA and the State of Idaho will confer with the defendants about the most efficient way to accomplish a $7 million cut in financial obliga- tions. Within the 1994 decree, EPA reserved their authorities for any contamination outside of the Box while allowing a covenant not to sue for OU2. EPA and the Depart- ment of Justice are considering an appeal. In the meantime, they have filed a notice of appeal, pre- serving the right to lodge an ap- peal in the future. The U.S. District court ruled in favor of EPA in a similar suit for cleanup costs in OU3. In that rul- ing, Hecla and Asarco were held liable for 31% and 22% of the cost, respectively. For additional information, please contact Ted Yackulic, Region 10, (206) 553-1218. cleanupnews ------- O 'Brien, continued from page 3 remediation of remaining contamina- tion was necessary to make the site viable for redevelopment and reuse. Fortunately, Gary Silversmith. President of SERENA, Inc. was will- ing to tackle such an undesirable site and approached the Borough of Downington with a plan to acquire the O'Brien site and redevelop it into a townhouse neighborhood after remediation. The plan required that EPA coordinate closely with Pennsylvania's Department of Envi- ronmental Protection, Chester County, the Borough, and SERENA. Their willingness to work together and invest resources into this project al- lowed several activities to occur, in- cluding: (1) a $1 million grant from Pennsylvania's Industrial Sites Reuse Fund; (2) a prospective purchaser agreement (PPA) between EPA and SERENA for the additional cleanup activities including the remediation of residual PCB contamination to resi- dential levels and a controlled demo- lition of existing structures; and (3) proper remediation of the site that was protective of human health and the environment. In addition to negotiat- ing the PPA, EPA's enforcement pro- gram worked hard to arrange a way to resolve its CERCLA lien against the O'Brien site to allow this project to move forward. Without these collabo- rative efforts, the site would have re- mained a contaminated unused piece ofproperty. In 2001, SERENA completed the redevelopment of the O'Brien Machin- ery site into an attractive upscale townhome community. While there were several major hurdles along the way, the property was remediated and returned to productive reuse for the community. This project is evidence of the great work EPA's Superfund en- forcement program has been perform- ing to ensure the revitalization of brownfield properties. It is also an excellent example of how a sound re- development plan and strong partner- ship between federal, state, local and private entities can transform a site from a brownfield to a redevelopment success. For additional information, contact Jocelyn Scott, OSRE, (202) 564-4795. House Bill Seeks Service Station Liability Limits House Resolution 3543, introduced by Rep. Michael Capuano (D-MA) this past November, seeks to limit liabil- ity under the Comprehensive Environ- mental Response, Compensation, and Liability Act of 1980 (CERCLA) for service station dealers with respect to the release or threatened release of recycled oil. The bill would amend CERCLA Section 114(c) to add a new paragraph. The new paragraph would explain that response costs or dam- ages may not be recovered from ser- vice station dealers that properly managed and disposed of recycled oil in the period between November 8. 1986 and the effective dates of regu- lations and standards promulgated under Section 3014 of the Solid Waste Disposal Act. Currently, CERCLA Section 114(c) allows certain liability exemptions for service station dealers meeting spe- cific requirements. The exemptions are intended to promote the collection of used motor oil from do-it-yourselfer recyclers (e.g., individuals changing oil in personal-use vehicles). To be eli- gible for an exemption, a service sta- tion dealer (SSD) must meet three cri- teria: the dealer meets the definition of a service station dealer as defined in CERCLA Section 101(37); the col- lected used oil has not been mixed with a CERCLA hazardous substance; and the used oil has been "managed in compliance with the regulations and standards promulgated pursuant to Section 3014 and other applicable au- thorities." The bill seeks to expand the third requirement for exemption by amend- ing the exemption period to include management and disposal activities occurring on or after the effective start date of the Superfund Amendments and Reauthorization Act of 1986 (SARA). The used oil management standards included in SARA were not codified (as 40 CFR Part 279) until 1992. The effective date for these stan- dards under RCRA is March 8, 1993. Thus, an SSD can still be liable under CERCLAfor actions taken prior to 1993. The bill, which has gained a number of co-sponsors, has been referred to the House Committee on Transportation and Infrastructure and the House Committee on Energy and Commerce. For additional information, contact Susan Boushell, OSRE, boushell.susan(S)epa.gov. OSRE Completes Second Printing of PRP Search Manual The Office of Site Remediation En- forcement (OSRE) has done a second printing of the September 2003 PRP Search Manual. The purpose was to provide copies to State and Tribal staff who perform potentially responsible party (PRP) search activities and to give extra copies to Regional staff who requested them. As previously announced, the manual is also available online at http://www.epa.gov/compliance/re- sources/publications/cleanup/ superfund/prpmanual/index.html. If you have any questions, please contact Nancy Deck, OSRE, (202) 564-6039. deanupnews 7 ------- April 27, 2004 1:30-3:30pm National Notable Achievement Awards Ceremony Sheraton, Crystal City, VA Contact: Ann Eleanor, eleanor,ann@eDa,QOv April 28-29, 2004 2004 ASTSWMO Mid-Year Meeting Savannah, GA Contact: Jocelyn Scott (202) 564-4795 http ://www,astswmo org May 11-12, 2004 2004 National Corrective Action Conference Orlando, FL Contact: Lael Butler (404) 562-8453 or Karen Tomimatsu (703) 605-0698 http ://www, national caconf, corn/ default, htrnl July 12-14, 2004 ASTSWMO 2004 State Hazardous Waste Managers Conference Washington, DC Contact: Jocelyn Scott (202) 564-4795 http: //www, astswmo org September 20-22, 2004 Brownfields 2004: "Gateway to Revitalization" St. Louis, MO httn://www bfownfields2004 org Glossary CERCLA Comprehensive Environmental Response, CFR EOC EPA OSRE OSWER OU Compensation, and Liability Act Code of Federal Regulations Emergency Operations Center Environmental Protection Agency Office of Site Remediation Enforcement Office of Solid Waste and Emergency Response Operable unit PAHs PCBs PPA RCC RCRA SARA cleanup CleanupNews is a quarterly publication of EPA's Office of Site Remediation Enforce- ment, 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.aov/compliance/resources/ newsletters/cleanup cleaiuipnews.html Polycyclic aromatic hydrocarbons Polychlorinated biphenyls Prospective purchaser agreement Resource Conservation Challenge Resource Conservation and Recovery Act Superfund Amendments and Reauthorization Act Richard W. Popino, PhD REM, editor EPA Review Board; Diane Bartosh, Paul Connor, Karen Ellenberger, Jeff Heimerman, Kathleen Johnson, Kenneth Patterson, Neilima Senjalia, Suzanne Wells Christine Rueter, DPRAInc., senior writer Betsy Anderson, DPRA Inc., writer Sarah Heberling, DPRA Inc., writer Ruth Colville, DPRAInc., senior designer Lauren Grantham, DPRA Inc., designer To comment on the newsletter contact Dr. Richard W. Popino, at MC-2271A, U.S. EPA, 1200 Pennsylvania Ave., NW, Washington, DC 20460, emaihpopino.rick@epa.gov. To be added or deleted from the mailing list, contact Christine Rueter, DPRA Inc., 1300 North 17th Street, Suite 950, Arlington, Virginia 22209, Fax: (703) 524-9415, emaihchristine.rueter@dpra.com Suite 9! 008$ ^uATj^ joj jfyjuua^ ssauisng T.EIOTJJQ 9E-9'ON Ill/\iy3d VcB aiVdS33d1S39VlSOd ssvioisyid 09tOS OQ ' (VILLZ) AoueSy uoi ------- |