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OFFICE OF INSPECTOR GENERAL
Catalyst for Improving the Environment
Pubiic Liaison Report
Environmental Justice Concerns
and Communication Problems
Complicated Cleaning Up
Ringwood Mines/Landfill Site
Report 2007-P-00016
April 2, 2007
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Report Contributors:
Paul McKechnie
Dan Cox
Tom Reilly
Christine Baughman
Abbreviations
Borough Borough of Ringwood, New Jersey
CIC Community Involvement Coordinator
CRP Community Relations Plan
EPA U.S. Environmental Protection Agency
Ford Ford Motor Company
NJDEP New Jersey Department of Environmental Protection
NPL Superfund National Priorities List
OIG Office of Inspector General
PRP Potentially Responsible Party
RPM Remedial Project Manager
Cover photo: Warning signs at one of the sludge removal areas at the site
(taken by OIG staff in August 2006).
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tftD STA^
s U.S. Environmental Protection Agency 2007-P-00016
% WBL, \ Office of Inspector General Apnl 2 2007
/ fi
%; At a Glance
Catalyst for Improving the Environment
Why We Did This Review
Three members of the
New Jersey congressional
delegation requested that the
Office of Inspector General
"conduct an investigation into
the history and continued
inadequate characterization
and remediation of the
Ringwood Mines/Landfill
Superfund site." This report
addresses whether environ-
mental injustice exists and if
EPA employed effective
community relations. Envi-
ronmental justice is fair treat-
ment and meaningful involve-
ment of all people in imple-
menting environmental laws.
Background
About 500 acres around the
Ringwood mines became a
Superfund site in 1983
because of dumped hazardous
paint sludge. Paint sludge was
removed several times, and
the water was being
monitored, so EPA deleted it
from the list of such sites in
1994. Cleanup activities at the
site resumed after residents
reported finding more paint
sludge in 2004.
For further information,
contact our Office of
Congressional and Public
Liaison at (202) 566-2391.
To view the full report,
click on the following link:
www.epa.qov/oiq/reports/2007/
20070402-2007-P-00016.pdf
Environmental Justice Concerns and
Communication Problems Complicated
Cleaning Up Ringwood Mines/Landfill Site
What We Found
We did not find evidence to indicate that the U.S. Environmental Protection
Agency's (EPA's) actions or decisionmaking to investigate or remediate
environmental conditions at the Ringwood Mines/Landfill site were affected by
the area's racial, cultural, or socioeconomic status. However, residents living near
the site continue to believe they were unfairly treated because of their racial
makeup and socioeconomic status. Several residents believe their health was
adversely affected by exposure to site contamination. Ringwood residents said
that multiple cleanups at the site beginning in 1987, and a lack of effective
communication with EPA Region 2, contributed to this perception. Additionally,
residents believe that EPA is pursuing the current activity because of outside
pressures. Region 2 plans to address environmental justice concerns by cleaning
up the site.
Problems with communications and relationships impeded effective cooperation
between EPA and residents. Although Region 2 has increased its community
relations efforts at the site, the new community relations plan being prepared must
address these impediments.
What We Recommend
We recommend that the Regional Administrator, Region 2:
Address the Ringwood community's perception of unfair treatment and
concerns regarding completely cleaning up the site by ensuring that the new
Record of Decision includes a detailed comparison of current and prior site
investigations and cleanups.
Prepare and implement a new community involvement plan for the Ringwood
site.
Help the community correct the deficiencies in the Community Advisory
Group so its meetings are regularly held and productive.
Increase communication with the community about Region 2 efforts to ensure
that the Ford Motor Company properly performs the correct work at the site.
Region 2 concurred with our recommendations.
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I A \
OFFICE OF
INSPECTOR GENERAL
April 2, 2007
MEMORANDUM
SUBJECT: Environmental Justice Concerns and Communication Problems
Complicated Cleaning Up Ringwood Mines/Landfill Site
Report No. 2007-P-00016
FROM: Eileen McMahon ' ' 'C11' ? 1
Assistant Inspector General for Congressional and Public Liaison
TO: Alan J. Steinberg
Regional Administrator
Region 2
This is our final report on the subject review conducted by the Office of Inspector General (OIG)
of the U.S. Environmental Protection Agency (EPA). Congressman Frank Pallone, and Senators
Frank Lautenberg and Robert Menendez of New Jersey requested in March 2006 that we conduct
the review. This report contains findings that describe the problems the OIG has identified and
corrective actions the OIG recommends. This report represents the opinion of the OIG and the
findings contained in this report do not necessarily represent the final EPA position. Final
determinations on matters in this report will be made by EPA managers in accordance with
established resolution procedures.
The findings in this report are not binding in any enforcement proceeding brought by EPA or the
Department of Justice under the Comprehensive Environmental Response, Compensation, and
Liability Act to recover costs incurred not inconsistent with the National Contingency Plan.
The estimated cost of this report - calculated by multiplying the project's staff days by the
applicable daily full cost billing rates in effect at the time - is $254,713.
Action Required
In accordance with EPA Manual 2750, you are required to provide this office with a
written response within 90 days of the date of this report. You should include a
corrective action plan for agreed-upon actions, including milestone dates. We have no
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
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objections to the further release of this report to the public. This report will be available
at http://www.epa.gov/oig.
If you or your staff have any questions, please contact me at 202-566-2391; or Paul McKechnie,
Product Line Director for Public Liaison, at 617-918-1471 or mckechnie.paul@epa.gov.
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Environmental Justice Concerns and Communication Problems
Complicated Cleaning Up Ringwood Mines/Landfill Site
Table of C
Chapters
1 Introduction 1
Purpose 1
Background 1
Scope and Methodology 3
2 Ringwood Residents Have Environmental Justice Concerns 5
No Evidence of Discrimination 5
Region 2 Actions Contributed to Perception of Unfair Treatment 6
Site Residents Believe Health Was Adversely Affected 7
Region 2 Plans to Address Concerns by Cleaning Up the Site 8
Recommendation 9
Agency Response and OIG Comments 9
3 Region 2 Must Overcome Impediments to Good Community Relations 11
Region 2 Did Not Promptly Establish Community Relations 11
Community Relations Plan Did Not Change with the Situation 13
EPA's Relationship with Ford Is Perceived As Inappropriate 14
Other Legal Considerations Complicate Communication 15
Continued Improvement in Communication Is Needed 16
Recommendations 19
Agency Response and OIG Comments 19
Status of Recommendations and Potential Monetary Benefits 21
Appendices
A Agency Response to Draft Report 22
B Distribution 26
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Chapter 1
Introduction
Purpose
We conducted this review in response to a request dated March 3, 2006, from
three members of the New Jersey congressional delegation: Congressman Pallone,
Senator Lautenberg, and Senator Menendez. They requested that the Office of
Inspector General (OIG) review various issues concerning the actions of the U.S.
Environmental Protection Agency (EPA) at the Ringwood Mines/Landfill
Superfund site in Ringwood, New Jersey. This review addresses the following
two objectives.
Did racial, cultural, or socioeconomic factors at Ringwood have any bearing
on timely investigating and remediating environmental concerns at the
Ringwood site?
How effective were Region 2's community relations activities at the
Ringwood site?
The OIG (Office of Program Evaluation) will issue a separate report on EPA
oversight of site cleanup efforts, remedy selection, and conditions which resulted
in relisting the site on the Superfund National Priorities List (NPL).
Background
From 1967 into 1971, waste material from the Mahwah, New Jersey, factory of
the Ford Motor Company (Ford) was deposited in the Borough of Ringwood,
New Jersey, in and around the shafts of abandoned iron ore mines that had
operated from the 1700s through the 1930s. The waste materials included car
parts, solvents, and paint sludge. A subsidiary of Ford had purchased 800 acres of
this land in 1965, with the intention of developing it. However, the development
plans were not approved.
In 1970, Ford donated about 300 acres of the area to the Borough of Ringwood
(Borough), specifically to the Ringwood Solid Waste Management Authority. On
part of this land, the Borough started a municipal landfill in 1972. The landfill
was closed in 1976, at the request of the New Jersey Department of
Environmental Protection (NJDEP).
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Figure 1. Paint sludge around a tree
Source: Photo taken by OIG staff in August 2006.
Testing by NJDEP in 1982 found
that groundwater and surface
water in the area were
contaminated with volatile
organic compounds, lead, and
arsenic. This testing led to EPA
adding the Ringwood
Mines/Landfill site (Ringwood
site or site) to the NPL in 1983.
The NPL is a list of the most
serious hazardous waste sites in
the United States identified for
possible long-term cleanup. The
Ringwood site consists of
approximately 500 acres in a
block of land about one-half mile
wide and one and one-half miles
long. It consists of rugged forest
areas, open areas overgrown with vegetation, abandoned mine shafts and surface
pits, an inactive landfill, an industrial refuse disposal area, a municipal recycling
area, the Ringwood maintenance garage, and about 50 private homes.
EPA has the legal authority to identify potentially responsible parties (PRPs)
linked to the site and negotiate settlements with PRPs for site cleanup work or to
issue administrative orders directing them to do so. In 1984, through EPA
enforcement actions and the oversight of staff from EPA's Region 2, Ford started
investigating the contamination of the Ringwood site as a PRP, and in 1987,
removed 7,000 cubic yards of surficial paint sludge containing lead and arsenic
from four areas. In September 1988, the Acting Regional Administrator for
Region 2 deci ded, via a Record of Decisi on, to require long-term monitoring of
surface water and groundwater at the site, as well as confirmatory soil sampling in
areas where sludge and soil were removed. Additional paint sludge and other
debris were removed in 1990. In 1993, Region 2 concluded the requirements had
been met to delete the site from the NPL. The State of New Jersey concurred
with the decision to delete the site from the NPL. The Ringwood site was deleted
from the NPL in 1994. Ford later removed additional paint sludge from the site in
1995 and 1997, in response to requests from residents and the Borough.
In 2004, the local community alerted EPA to the presence of additional paint
sludge at the Ringwood site. Ford and the Borough are re-investigating the site
under the oversight of an EPA Region 2 Remedial Project Manager (RPM), based
on EPA enforcement actions dated September 2005. Ford is identified as the
performing party. Thus, Ford is also removing additional paint sludge from
several locations at the site. Some of these locations were next to the sites of
earlier removal actions. As of July 2006, 16,000 tons of paint sludge and soil had
been removed. In addition, New Jersey agencies are overseeing the possible
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remediation of residential properties or the relocation of residents related to the
Ringwood site. Effective October 2006, the Ringwood site was again added to
the NPL.
Scope and Methodology
We performed this review in accordance with Government Auditing Standards,
issued by the Comptroller General of the United States, except that we limited our
review of management controls and compliance to those directly relating to the
issues identified in the congressional request.
We performed our work from June 2006 through November 2006. As part of our
work, we interviewed EPA employees in the Region 2 Office of Regional
Administrator, the Public Affairs Division, and the Emergency and Remedial
Response Division; NJDEP employees of the Environmental Justice Program;
eight current or former residents who lived on or near the Ringwood site (site
residents); several consultants for the residents; and officials of the Borough. To
perform this review in a timely manner and still comply with the requirements of
the Paperwork Reduction Act, we limited the number of interviews conducted.
However, to offset this limitation, we held two open meetings in Ringwood
during October 2006, to obtain more information from the community about
community relations and environmental justice. Approximately 55 people came
to these meetings, and 30 people spoke during the sessions. Those who attended
included site residents, consultants for the site residents, residents living
elsewhere in the Borough (Borough residents), Borough officials, other elected
officials, a representative of an environmental organization, and residents of
nearby communities.
Besides talking to people, we toured the Ringwood site with staff from Region 2
and other organizations. We also reviewed documents provided by those who
spoke to us, documents from Region 2's site files for the Ringwood site,
documents in the Ringwood site information repository at the Ringwood Public
Library, and information obtained through the Internet, particularly the Websites
of EPA and the Websites specifically for the Ringwood site. In a few cases, we
relied on information obtained by the other OIG team working on the Ringwood
congressional request. Finally, we obtained information related to the Ringwood
site from EPA's financial management system.
We issued a draft report to the Regional Administrator of Region 2 on
February 12, 2007. The Assistant Regional Administrator for Policy and
Management responded in a memorandum dated March 16, 2007. This
memorandum is attached as Appendix A. The Region 2 official concurred with
all of the recommendations, and cited actions the Region has taken to start
implementing two of the recommendations. The response also provided several
factual corrections and suggested content revisions. We revised the report as we
considered appropriate, and discuss some of these items at the end of Chapters 2
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and 3. In addition, the Region's response requested that we change the title of the
report so it would be neutral, reflecting the subject of the review. We did not do
so because it is OIG procedure that the report title should reflect our position on
the matter under review.
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Chapter 2
Ringwood Residents Have
Environmental Justice Concerns
Contrary to the strong opinions expressed by Ringwood site residents, we found
no evidence that EPA's actions or decisionmaking were affected by the area's
racial, cultural, or socioeconomic status. We did find that in 1984, EPA Region 2
did not take the actions needed to foster a feeling among the residents that EPA
was committed to protecting their health and the environment. Additionally, the
residents believe that outside pressures have caused the latest cleanup initiative.
Region 2's past interactions with Ringwood residents, together with the fact that
EPA is back for the fifth time in 20 years to clean up the site, have contributed to
the residents' feelings of mistrust.
No Evidence of Discrimination
Based on our extensive review of site files and interviews, we did not find
evidence that Region 2 discriminated against Ringwood site residents.
Of the seven people we interviewed who currently live on the site, six indicated
their heritage included American Indian (i.e., the Ramapough Mountain Indians),
African American, or both. These are considered minority populations. Six
indicated their household income could be categorized as lower income.
Information provided by the Borough Manager supported the characterization of
the neighborhood as lower income. He indicated that 560 people are living in 44
homes there, or an average of 12 people per home. Also, the assessed values of
homes in the neighborhood of the site are lower than for the Borough as a whole:
an average of $68,000 versus $180,000.
Racial and socioeconomic factors did not appear to have any bearing on EPA
efforts to clean up the Ringwood site. One Region 2 supervisor involved with the
earlier cleanup efforts at the site said that he was aware some of those living at the
site were members of the Ramapough Mountain Indian community. He said the
fact that they were members of a minority community had no effect on the work
that EPA needed to do at the site. He added that Agency staff did not treat them
differently. He explained that it was EPA's job to clean up the site regardless of
who lived there, and even if no one lived there.
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Region 2 Actions Contributed to Perception of Unfair Treatment
Environmental justice is the fair treatment and meaningful involvement of all
people regardless of race, color, national origin, or income with respect to
developing, implementing, and enforcing environmental laws, regulations, and
policies. Seven individuals, though, who spoke at our public availability session
and included two residents we had previously interviewed, felt that the Ringwood
site would have been cleaned up more timely and effectively if the site had been
located in a nonminority, more affluent neighborhood. Of the current residents
we interviewed or who provided comments at our public availability sessions,
most felt they had not been treated fairly by EPA for varying reasons. First, EPA
performed previous cleanups of the site, but it is still contaminated. Second,
during earlier cleanups of the site, EPA did not communi cate formally with the
residents. Third, residents believe outside pressure is forcing Region 2's current
actions.
Five Cleanup Actions Required
EPA is conducting a fifth cleanup action at the Ringwood site, because all
contamination was not identified and removed during the previous four cleanups.
A brief summary of the prior four cleanup actions follows:
Beginning in October 1987, Ford excavated and removed 7,000 cubic yards of
paint sludge containing lead and arsenic from the surface of four areas of the
site.
Additional paint sludge was discovered at the O'Connor Di sposal Area of the
site in October 1989, and in January 1990, drums of waste material were
discovered there. As a result, 51 drum remnants and 727 tons of additional
paint sludge were
removed. In 1992 and
1993, geophysical
surveys and test pit work
were conducted in the
area, but no additional
barrels or hazardous
substances were
discovered.
In 1995, residents
notified Borough officials
that more paint sludge
was at the site. Ford
removed five cubic yards
of paint sludge from a
residential property.
Figure 2. Removal activity at SR-3 (sludge removal
area 3), just north of the O'Connor Disposal Area.
l
Source: Photo taken by QIG staff in August 2006.
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In December 1997 and January 1998, an additional 30 cubic yards of paint
sludge and soil were removed from the hillside adjacent to the O'Connor
Disposal Area.
Lack of Communication During Original Cleanup
While the Superfund program was relatively new at the time, Region 2 staff were
required to establish an effective dialog with the community during the original
cleanup of the Ringwood site. When the Region did not effectively communicate
with the community, the residents began to mistrust EPA and believed they were
not being treated fairly. We discuss problems regarding EPA communications
and community relations at the Ringwood site further in Chapter 3.
Many Believe Outside Pressure Was Needed for Current EPA Actions
According to many individuals whom we interviewed or who spoke at our public
availability session, not only has EPA not cleaned up the site, but also it is not
voluntarily doing so now. These individuals believed that EPA would not have
taken the current actions without outside pressure. They believed EPA responded
to various sources of pressure, including pressures from elected officials,
residents' lawyers, environmental
Ringwood site residents are sensitive to
the manner in which they are
treated. The Borough covers an area of
more than 25 square miles. Yet several
facilities are concentrated in the same
area around the Ringwood mines. This
includes a landfill (now closed), a
recycling center, the Borough
maintenance garage, and radio and
power line towers. In the 1990s, the
area was a proposed site for a power
plant and a chemical company.
groups, and the media.
Figure 3. Map of Ringwood showing
(in yellow) the approximate size and
location of the Superfund site.
NEW YORK STATE
Site Residents Believe Health Was
Adversely Affected
neighbors, was adversely affected by
exposure to contamination at the site.
For the adults, this exposure has now
Several residents believe their health, or
the health of family members or
Jkuehue] *
I /
BOROUGH OF RINGWOOD
Source: OIG staff.
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lasted 40 years, that is, since 1967. Four people gave us examples of such health
problems.
In May 2006, the New Jersey Department of Health and Senior Services
completed a public health assessment and concluded that the Ringwood site posed
a public health hazard because exposure to paint sludge and soil may continue to
occur at levels of health concern. The report also noted a higher proportion of
children with elevated blood lead levels compared to the rest of the Borough.
However, the overall incidence of cancer was not elevated. The report
recommended that an exposure investigation be conducted because of the
potential for exposure to metals from paint sludge and contaminated soils at the
site. However, in a June 2006 letter, attorneys representing some Ringwood
residents indicated that they had advised their clients not to participate in
interviews or physical exams requested by the Agency for Toxic Substances and
Diseases Registry, due to ongoing litigation regarding the Ringwood site. The
lawyers proposed an alternative method to provide information on their clients'
past and current medical condition.
In May 2006, EPA Region 2 issued a draft environmental justice assessment
which concluded that Ringwood was an adversely impacted area based on a report
issued by the Agency for Toxic Substances and Diseases Registry in 1989. The
report concluded that the Ringwood site posed a potential health concern because
of the risk to human health that could result from possible exposure to hazardous
substances at levels that may result in long term adverse health effects. However,
the Region indicated that because of the current limitation of localized health
information about the community resident population, it could not satisfactorily
distinguish the area from other communities to perform a comparative assessment
to determine if environmental injustice occurred or exists. The Region indicated
that to make such a determination it needed to conduct a refined environmental
justice assessment, including cumulative and risk assessments, when localized
health data on the residents have been collected by the State of New Jersey and a
comparable "reference" community is identified.
Region 2 Plans to Address Concerns by Cleaning Up the Site
Region 2 believes that cleaning up the Ringwood site will be the most effective
way to address any concerns or perceptions regarding environmental injustice.
Regional staff informed Ringwood site residents that they plan to effectively
clean up the site this time. This intention appears to be supported by the
Agency's relisting of the site on the NPL. However, residents doubt the Agency's
abilities to do so, considering EPA's past cleanup efforts at Ringwood. Residents
cited concerns that all sludge and debris may not have been identified; limited
monitoring of streams flowing into the Wanaque Reservoir was occurring; and
there was a lack of testing of local wildlife and plants, some of which are
consumed by site residents.
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Region 2's RPM for the Ringwood site said that testing for waste disposal areas
has been extended to areas not previously surveyed, additional monitoring wells
are being installed, and testing wildlife and plants began in October 2006. On
January 30, 2007, EPA, together with Federal and State health agencies, held a
public information session to discuss results of the EPA's biota study at the
Ringwood site; about 50 people attended the session. On March 9, EPA released
the initial results of its study of deer from the Ringwood site. Recently collected
deer from off the site are being analyzed. According to a Region 2 official,
additional wildlife, including wild turkeys, rabbits, and squirrels, will be collected
and analyzed; they plan to present these findings to the public later this spring.
While the Region plans to address environmental justice concerns by cleaning up
the site, we believe the Region can take additional action to alleviate these
concerns. When the current investigation of the site is completed, Region 2 will
consider options for cleaning up the site. The remedy the Region selects will be
documented in a Record of Decision. According to a Region 2 official, a Record
of Decision routinely includes a summary of prior investigation and cleanup
actions. And any future Record of Decision issued for the Ringwood site will
discuss all prior investigation and cleanup actions implemented at the site and
demonstrate why the selected cleanup action, once implemented, will protect
human health and the environment. We believe the new Record of Decision
should not just summarize the prior actions, but provide a detailed comparison of
the current and prior investigations and cleanup actions. We believe such a
detailed comparison will better address residents' concerns about the scope of the
current cleanup.
Recommendation
We recommend that the Regional Administrator, Region 2:
2-1 Address the Ringwood community's perception of unfair treatment and
concerns regarding completely cleaning up the site by directing his staff to
ensure that the new Record of Decision includes a detailed comparison of
current and prior site investigations and cleanups.
Agency Response and OIG Comments
In the response to the OIG draft report, the Assistant Regional Administrator for
Policy and Management concurred with the above recommendation, and
suggested replacing the description of the recommendation in the "At a Glance"
section of our report with the actual recommendation. We concurred and revised
the final report accordingly.
The Region's response also indicated that although New Jersey health officials
noted that children living near the Ringwood site had higher levels of lead in their
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blood than children in other parts of the borough, only one child in the study had
an elevated level in his/her blood that was possibly related to paint sludge from
the Ringwood site.
According to the New Jersey Public Health Assessment, 909 Ringwood children
were tested for blood lead between July 1999 and October 2005. Of these
children, 45 lived in the Ringwood Mines area ("Focus Area"); 861 lived in other
areas of Ringwood ("non-Focus Area"); and 3 lacked sufficient address
information to determine residential location.
The study noted that although most children had a blood lead level below 10
|ig/dL, there appeared to be slightly higher levels in the distribution of blood lead
levels in the Focus Area children, which could have resulted from the relatively
small sample size or could indicate that the children had slightly more exposure to
lead in the environment than non-Focus Area children.
The Ringwood Health Department followed up on two Focus Area children
whose blood lead levels exceeded 10 |ig/dL and determined that the elevated level
for one child was attributed to potential exposure to lead in paint sludge, while for
the other child the likely cause was lead paint during home renovation. However,
the New Jersey Public Health Assessment also noted that if 1,000 children had
been tested, the rate of elevated blood level for non-Focus Area children was 8
children per 1.000. while the rate for Focus Area children was 44 children per
1.000.
The Region's response also indicated that Upper Ringwood was an adversely
impacted area solely as a result of it being part of a Superfund site. However, as
noted on pages 8 and 9 of this report, the Region's environmental justice
assessment concluded that the site exhibited an adverse health effect on the
Ringwood Mines community based on a report issued by the Agency for Toxic
Substances and Diseases Registry in 1989. This report concluded that the
Ringwood site posed a potential health concern because of the risk to human
health that could result from possible exposure to hazardous substances at levels
that may result in long term adverse health effects.
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Chapter 3
Region 2 Must Overcome Impediments
to Good Community Relations
Despite recent efforts by Region 2 staff to increase communications with
residents, three factors impede good relations. First, during earlier cleanups of the
Ringwood site, Region 2 staff missed opportunities to establish a good
relationship with the community by not promptly developing a community
relations plan in 1984, and then not updating it in the early 1990s to reflect
changes in the situation. Second, there
are concerns about EPA's relationship
with Ford, the performing potentially
responsible party (PRP) for the site.
Third, other legal concerns are also
impacting communications.
Specifically, the site residents' lawyers
want communications with some site residents to go through them, and the
Borough's status as a PRP complicates communications with Borough officials.
For an effective working relationship with the community, the new community
relations plan for the Ringwood site must address the current impediments.
Region 2 Did Not Promptly Establish Community Relations
Despite requirements to the contrary, the Region 2 community relations staff did
not become involved in site activities until 1988 - 5 years after the site was listed
on the NPL and shortly before the remedy was selected for the site. Earlier dialog
with community members might have laid a foundation for good relations,
perhaps leading to locating and removing more contamination during the original
site cleanup; according to one of the site residents, they have pointed out half of
the areas that are now being cleaned up.
In September 1983, EPA added the Ringwood site to the NPL. According to
EPA's May 1983 Superfund Community Relations Policy, the objectives of the
Superfund community relations program are to:
gather information about the community in which a site or incident is located,
inform the public of planned and ongoing actions,
give the public the opportunity to be involved in decisionmaking, and
focus and resolve controversy.
At most sites, the success of community
involvement has a direct impact on the
success of the overall cleanup.
Source: April 2002 Superfund
Community Involvement Handbook
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For all Superfund-financed cleanup actions, the policy stated EPA regional offices
must develop a community relations plan (CRP). The CRP is a management and
planning tool which outlines the specific
communications activities to be used
during a Superfund response and the
integration of these activities with the
technical work at a site. The Remedial
Action Master Plan for a site must include
a community relations assessment with
steps needed to prepare the CRP.
EPA drafted a Remedial Action Master
Plan for the Ringwood site in August
1983. It included the required community
relations assessment. The first item in the
assessment was to identify community concerns by interviewing local officials
and community members. It did not include the required schedule for completing
the community relations plan.
Seven months after the Remedial Action Master Plan was prepared, Ford became
responsible for cleaning up the site. Since the cleanup was led by the PRP, it was
no longer a Superfund-financed action. Consequently, EPA's 1983 policy did not
apply, so the Region 2 staff may have considered a CRP unnecessary. Effective
February 1986, the requirements changed; for cleanup actions at NPL sites,
including enforcement actions, a CRP must be implemented before field activities
start. However, the Region 2 staff did not immediately start preparing the CRP
for the Ringwood site.
The interviews needed to prepare the CRP were performed in early 1988. They
were conducted by a member of the Region 2 Office of External Affairs and an
EPA contractor. In Region 2, the community relations staff are not part of the
Superfund program division. The CRP for the Ringwood site was issued in July
1988. The delay from 1983 to 1988 in preparing the CRP was not explained in
the site files, although we found documents dated 1985 and 1986, informing
Region 2 staff of potential community relations problems at the site and urging
them to prepare a CRP. These documents came from staff in the New Jersey
Department of Environmental Protection.
Although community relations staff were not involved until 1988, Region 2
technical staff were involved. There was little evidence that the Region 2
technical staff informed the community about site activities. We found two
handouts about site activities dated before the July 1988 CRP: February 1984 and
October 1987. The latter announced the start of excavating and removing paint
sludge. It was mailed to residents by local officials. The first public meeting with
residents during that period was in August 1988, to discuss the options for
The RPM is the overall project manager with
responsibility for everything that occurs at the site. The
Community Involvement Coordinator is responsible for
advising the project manager on required community
involvement activities and recommending activities that
will ensure the community has every opportunity to be
involved. Involvement by all members of the Site Team
in community involvement planning and implementation
activities ensures integration of community involvement
in the cleanup process and furthers public participation.
Source: April 2002 Superfund Community Involvement
Handbook
12
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cleaning up the site. There was no evidence in Region 2's site files of any other
meetings with residents.
The lack of evidence concerning communication with the community during the
original cleanup was consistent with what community members told us. We
interviewed eight people who were adults living in Ringwood at that time. Six of
these individuals lived on or very near the site. None of the eight people recalled
efforts by EPA to inform them about what was going on at the site. Three said
they were unaware of the original cleanup activity. Five site residents said they
did not know about the original cleanup until they saw trucks or workers at the
site.
Community Relations Plan Did Not Change with the Situation
Region 2 staff did not re-evaluate community relations activity in 1992 and 1995
when community members brought additional concerns to their attention. The
community issues and concerns identified in the 1988 Ringwood CRP were
limited. Two local organizations, the Families of the Ringwood Mines and the
Ringwood Neighborhood Action Association, expressed additional concerns
about the site in 1992 and 1995, respectively. Although EPA's 1988 Community
Relations Handbook indicates that a community relations plan should be revised
if community attitudes change, the Region 2 staff have never changed the
Ringwood CRP.
In a letter dated April 1992, a representative of the Families of the Ringwood
Mines told the Region 2 project manager that the citizens living near the
Ringwood mines were concerned about the possible health effects of the
substances dumped at the mines. The letter noted the presence of noxious odors
and vapors. This group apparently started collecting health information from
community members. Because he was concerned about the issue, in June 1992
the Region 2 project manager requested that a fact sheet be prepared. A fact sheet
dated July 1992 was prepared. It summarized the results of monitoring activities
at the site. There was no evidence of other community relations activity
concerning the matter.
In late February 1995, the president of the Ringwood Neighborhood Action
Association informed the Borough Council that paint sludge remained at the
Ringwood site despite two previous removal actions. After visiting the site, the
health officer from the Borough contacted EPA about the sludge. The Region 2
project manager visited the site in April 1995, and promised to investigate further.
There was no evidence of other community relations activity concerning the
matter. These events in 1995 were similar to how the current cleanup actions at
the site started.
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EPA's Relationship with Ford Is Perceived As Inappropriate
Some Borough residents and officials, and others, perceive EPA's relationship
with Ford to be inappropriate. According to them, Ford appears to be making the
decisions about cleaning up the site, not EPA.
Several people, including site residents, their consultants, and Borough officials,
expressed concern about the relationship between EPA and Ford (including
Ford's technical consultant). They characterized the relationship between EPA
and Ford in several ways, or combinations of ways, including that EPA:
Protected or defended Ford, or let Ford off the hook.
Let Ford make the decisions.
Was lax, or not forceful enough, with Ford.
Did not ensure that Ford's technical consultant performed adequately.
Some of these individuals also expressed concern about funding the cleanup if
Ford backs out or goes bankrupt; this concern was cited as a possible reason for
EPA being lax with Ford.
According to several people, the actions of the current Region 2 RPM contributed
to their perception of an inappropriate relationship. Under the current settlement
agreement between EPA and Ford, EPA (i.e., the RPM designated in the
agreement) must approve the plans prepared by Ford, as well as the work
performed. Thus, the RPM must work closely with Ford. At the same time, we
believe the Region 2 staff must demonstrate to the community that they are
directing this work, not Ford or its technical consultant. Some ways they may do
this are as follows:
When meeting with Borough residents, fully answer questions about work at
the site in an open and direct manner, without referring to representatives of
Ford or its consultant. According to a Region 2 official, their representatives
answer the vast majority of questions, and refer questions to Ford or its
consultant on the rare occasions EPA staff are unable to answer a specific
comment. Despite these efforts, several Borough residents and officials
believe the RPM does not fully answer some of the questions he addresses.
Promptly convey testing results to the community, and explain the
implications of these results to them. According to a Region 2 official,
Region 2 releases data after the quality is verified, so it usually takes 21 days
to process a sample. At the public meeting on July 25, 2006, Region 2 staff
explained to the community why it takes longer for EPA to release results
than it takes the site residents' consultant. Once Region 2 has the results,
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though, the community wants them as soon as possible, along with what they
mean.
In the cover letter providing the site residents' representative with the monthly
progress report, clearly explain in detail when and how upcoming site activity
will impact the neighborhood. Although Region 2 staff have expanded
distribution of these progress reports, apparently site residents (and, as
discussed later, Borough officials) are not satisfied with their content. For
example, according to the progress report for August 2006, in September
2006, Ford's consultant anticipated performing site-wide groundwater
sampling. In the letter dated September 19, 2006, that conveyed this progress
report to the community's representative, the RPM noted that Ford's
consultant "will be collecting groundwater samples from all viable monitoring
wells at the Site, starting on Monday, September 25, 2006." The RPM
repeated this information in a letter to the site residents' representative dated
September 21. Starting on October 3, and continuing for several days, a crew
using large equipment that partially blocked a residential street performed
work in the Ringwood site. Site residents were upset about this activity for
several reasons, one of which was they believed no one had warned them
about it in advance. Even with the RPM's notice, they had not connected this
activity with the groundwater sampling.
Inform the community when EPA approves plans for work at the site,
highlighting the review EPA performed and any changes to the plan that EPA
requested.
Other Legal Considerations Complicate Communication
EPA's communications with Borough residents and officials are impacted by two
other issues, which are of a legal nature. First, lawyers representing past and
present residents of the Ringwood site want contacts with the site residents
coordinated through them. This sometimes slows efforts by Region 2 staff to
meet with site residents. Second, site residents sometimes rely on Borough
officials to inform them about site activities. These officials do not always know
about the activities because, since the Borough is also a PRP, Region 2 staff must
follow legal protocols in communicating with them.
Shortly after the RPM's site visit in April 2004, lawyers representing the site
residents contacted the Region 2 staff. They asked Region 2 to keep them
apprised concerning EPA's activities as they affect the residents, and to coordinate
Region 2's contacts with these residents through them. According to the lawyers,
the site residents had sought counsel "in large part due to EPA's 22-year record of
failing to clean the contaminated site on which they reside, failing to protect their
health, and failing even to speak to them." In January 2006, the site residents
filed a lawsuit against Ford.
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The Region 2 staff must take the lawyers' requests into account when dealing
with site residents. According to a Region 2 official, they try to communicate
with site residents as directly as possible while accommodating their needs for
legal representation. However, accommodating the lawyers' requests sometimes
delays meetings between the Region 2 staff and site residents. For example,
according to the Community Involvement Coordinator (CIC) for the Ringwood
site, she tried to set up a meeting with the site residents (and their lawyers) in
March 2005. The meeting was not held until May 2005.
There is a communication network for the PRPs. It includes the Borough because
in 1990, EPA formally notified the Borough that it was a PRP. A single person
was identified in the enforcement orders to serve as the official contact for the
PRPs related to the Ringwood site. The official contact is a Ford official. All
technical matters must go through this person. Ford, therefore, is responsible for
keeping the Borough informed about what is going on at the site on a day-to-day
basis, not EPA. Each month, Ford's technical consultant prepares a summary on
site activity. The Borough Manager receives these monthly reports. Thus, the
Borough is regularly informed about site activity.
The Borough officials with whom we spoke believed they were not receiving
enough information about site activities. When unexpected activity occurs at the
site, some site residents contact Borough officials. The Borough officials do not
always have information about the activity in question. The Region 2 RPM is
aware of the concern about communication among the PRPs, and is working with
Borough officials to resolve it. In addition, according to him, Region 2 sends a
copy of all correspondence with residents to the Borough.
Continued Improvement in Communication Is Needed
The Region 2 community relations staff have increased interaction with site and
Borough residents. Because of these efforts, some site residents believe
communication has improved regarding their involvement in site activities. The
new CRP being prepared for the Ringwood site must further a good relationship
with site and Borough residents.
Since April 2004, when the Region 2 employee who later became the RPM for
the Ringwood site toured the area with site residents, the Region 2 community
relations staff have spent more time each year on community relations activities
for the Ringwood site. In fiscal 2004, they spent 83 hours, in 2005 almost 360
hours, and in 2006 almost 450 hours. Most of the time in 2006 was performed by
the CIC for the site. Of her time working on various Region 2 Superfund sites
during 2006, she spent over a quarter on Ringwood.
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The increased effort on community
relations activities is reflected by the
number of contacts with site and
Borough residents. Besides several
meetings in 2004 and 2005, with
just site residents and their lawyers,
the Region 2 staff:
held four larger-scale public
information meetings with
those interested in the site;
helped site residents create a
Ringwood Community
Advisory Group (CAG),
which then met four times;
arranged for the Regional Administrator for Region 2 to visit Ringwood in
October 2005 and January 2006;
prepared six handouts about activities at the site; and
established a Website for the Ringwood site in addition to the EPA Website
and a Website maintained by Ford.
Some of the site residents who spoke to us believed EPA is now doing a better job
keeping them informed and involved.
Several setbacks have occurred in the recent relations between the EPA staff and
the residents. For example, although the CAG started off with monthly meetings,
none were held since March 2006, and the reason they were discontinued is in
dispute. One resident said the EPA staff no longer wanted them; the EPA staff
contend a community lawyer requested the CAG meetings stop. Also, several
people who attended community or CAG meetings told us some of the meetings
degenerated because of conflicts between participants. Despite the improved
communications, some site residents told us they believe the EPA staff are not
always open, frank, or timely in letting them know about site activities.
Changes Needed to Community Advisory Group
As noted earlier, the Region 2 staff helped the site residents form a CAG. A CAG
is intended to be a public forum for community members to present and discuss
Figure 4. Time Spent by Region 2 on Community Relations
Recently Increased
Hours of Community Relations Activity
446.0
450.0
400.0
350.0
300.0
250.0
200.0
150.0
100.0
50.0
0.0
83.tr
358.5
2004
2005
Fiscal Year
2006
Source: OCFO Reporting and Business Intelligence Tool
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their needs and concerns
related to the Superfund
decisionmaking process.
Thus, a CAG seems
appropriate for the
Ringwood site.
However, the CAG
meetings, and some of the other Ringwood site meetings, were variously
described in interviews as degenerating or deteriorating, out of control, shouting
matches between EPA staff and residents, awful dynamics, and the community
was hostile. This must be reversed if the CAG is to be a successful forum.
When the Ringwood CAG was established, it was not given enough form to
function effectively. According to EPA guidance, each CAG should develop a
mission statement describing the CAG's specific purpose, scope, goals, and
objectives. Each CAG also should develop a set of procedures to guide day-to-
day operations. CAG members may select a chairperson from within their ranks
and determine an appropriate term of office. The primary functions of the CAG
chairperson are to conduct CAG meetings in a manner that encourages open and
constructive participation by all members; to ensure that all pertinent community
concerns are raised for consideration and discussion; and to attempt, whenever
possible, to achieve consensus among CAG members. If meeting facilitation is
needed, it is preferable to use someone from the community with facilitation
experience or a professional meeting facilitator. A neutral facilitator is
particularly effective at sites where some controversy is anticipated.
The Ringwood CAG was missing several of the above attributes. It does not have
a mission statement or operating procedures. The duties of a chairperson were not
defined, nor was a chairperson selected. Also, given the poor relationships of
those involved, a meeting facilitator is needed. These deficiencies should be
corrected.
A New Community Relations Plan Is Being Prepared
According to the CIC for the Ringwood site, Region 2 plans to prepare a new
CRP for the site. Under EPA's current guidance, the April 2002 Superfund
Community Involvement Handbook, such plans are now called community
involvement plans. One must be prepared after a site is listed on the NPL. The
community involvement plan should identify the community's issues, needs, and
concerns, and identify specific activities, outreach products, or programs EPA
will use to address the community's concerns. The Handbook identifies a variety
of communication strategies and techniques that can be used by the RPM and CIC
to ensure the community is informed about, and involved in, site activities. For
example, it states:
A community with a high level of interest and concern
about remedial activities or significant environmental
justice concerns related to the site should be a strong
candidate for a CAG.
Source: April 2002 Superfund Community Involvement
Handbook
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Person-to-person interaction is necessary for the community to get
to know Site Team members and vice versa. Personal interactions,
either by telephone or in person, contribute more to the
development of trust and cooperative working relationships than
any other form of outreach. Availability sessions, public meetings,
workshops, and TV or radio appearances work well.
As noted earlier, the Region 2 staff have initiated personal interaction at the
Ringwood site. Much more such interaction will be needed because many site
residents believe the Region 2 staff are not open and frank with them about site
activities. They based this belief on a variety of incidents in which the Region 2
staff seemed to evade questions, or did not provide information in a timely
manner. In fact, a few site residents do not acknowledge that communications
have recently improved.
The community involvement plan for the Ringwood site should be promptly
drafted, thoroughly discussed with residents and Borough officials, and quickly
implemented. We believe it should include multiple avenues of communication,
especially personal interaction. According to a Region 2 official, they plan to
address re-establishing the CAG in the new community involvement plan, and
they have already begun work on this plan.
Recommendations
We recommend that the Regional Administrator, Region 2, direct his staff to:
3-1 Prepare and implement a new community involvement plan for the
Ringwood site.
3-2 Help the community correct the deficiencies in the Community Advisory
Group so its meetings are regularly held and productive.
3-3 Increase communication with the community about Region 2 efforts to
ensure that Ford properly performs the correct work at the site.
Agency Response and OIG Comments
In the response to the OIG draft report, the Assistant Regional Administrator
concurred with the above recommendations. Concerning the factual corrections
and revisions requested, we generally agreed and changed the report accordingly.
One comment was about a statement in the OIG draft report that the April 1992
letter from the Family of the Ringwood Mines mentioned that State authorities
had determined that the residents' drinking water was contaminated. Although
the statement was correct, we deleted it because the 1988 Record of Decision
confirmed that the residents receive water from a municipal water supply.
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Regarding EPA's relationship with the PRP, Region 2 indicated in its response to
our draft report that regional staff have interacted with Ford and its contractors
according to all EPA regulations and guidance for dealing with a PRP at a
Superfund site. The Region added that while there are variations in the Region's
relationships with PRPs from site to site, the Region's relationship with Ford at
Ringwood is typical for a Superfund site of this complexity.
Regarding the CAG, the Region's response noted that the Region had secured the
services of a professional facilitator for the CAG.
Regarding the community involvement plan, Region 2 indicated in its response
that regional staff conducted several interviews for the new plan on March 2 and
March 13, 2007.
Regarding the Agency's oversight of the PRP, Region 2's response noted that
since 1983, EPA issued five administrative orders to Ford, requiring Ford to
perform various investigatory and cleanup actions at the site.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
Page
No.
3-1
3-2
3-3
Subject
Status1
Action Official
Planned
Completion
Date
Claimed
Amount
Agreed To
Amount
2-1 9 Address the Ringwood community's perception of
unfair treatment and concerns regarding
completely cleaning up the site by directing his staff
to ensure that the new Record of Decision includes
a detailed comparison of current and prior site
investigations and cleanups.
19 Prepare and implement a new community
involvement plan for the Ringwood site.
19 Help the community correct the deficiencies in the
Community Advisory Group so its meetings are
regularly held and productive.
19 Increase communication with the community about
Region 2 efforts to ensure that Ford properly
performs the correct work at the site.
Regional Administrator,
Region 2
Regional Administrator,
Region 2
Regional Administrator,
Region 2
Regional Administrator,
Region 2
1 0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is undecided with resolution efforts in progress
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Appendix A
Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 2
DATE: March 16, 2007
SUBJECT: Region 2 Comments on OIG Draft Report - Ringwood Mines
FROM: Donna J. Vizian
Assistant Regional Administrator for Policy and Management
TO: Paul McKechnie
Office of Inspector General
EPA Region 2 welcomes the opportunity to comment on the Office of the Inspector General's draft
report on the Ringwood Mines/Landfill Superfund site.
Region 2's responses to each recommendation in the draft report are as follows:
OIG Recommendation #2-1
"We recommend that the Regional Administrator, Region 2, address the Ringwood community's
perception of unfair treatment and concerns regarding completely cleaning up the site, by directing
his staff to ensure that the Record of Decision includes a detailed comparison of current and prior
site investigations and cleanups to demonstrate how the current investigation and cleanup will differ
from those conducted in the past."
Region 2 Response
Region 2 concurs. Any future Record of Decision issued for the Ringwood Mines site will discuss
all prior investigation and cleanup action implemented at the site, and provide a comparison of the
current and prior investigations and cleanup actions.
OIG Recommendation #3-1
"We recommend that the Regional Administrator, Region 2, direct his staff to prepare and
implement a new community involvement plan for the Ringwood site."
Region 2 Response
Region 2 concurs. For additional information, please see the below section entitled "Update on
Community Involvement Work."
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OIG Recommendation #3-2
"We recommend that the Regional Administrator, Region 2, direct his staff to help the community
correct the deficiencies in the Community Advisory Group so its meetings are regularly held and
productive."
Region 2 Response
Region 2 concurs. Again, for additional information, please see the below section entitled "Update
on Community Involvement Work."
OIG Recommendation #3-3
"We recommend that the Regional Administrator, Region 2, direct his staff to increase
communication with the community about Region 2 efforts to ensure that Ford properly performs the
correct work at the site."
Region 2 Response
Region 2 concurs.
Additionally, we are providing several factual corrections and suggested content revisions that we
would like to see incorporated into the final version of the report.
Title of report draws an inaccurate conclusion
The title of the OIG's draft report, "Environmental Justice Concerns and Communication Problems
Complicated Cleaning Up Ringwood Mines/Landfill Site," suggests that EPA's cleanup work at the
Ringwood site has been affected by environmental justice or communication issues. The report,
however, does not present any findings that EPA's daily cleanup efforts have been impacted by these
issues. In addition, the title is a statement of a conclusion rather than a statement that conveys the
subject of the report. We request that
the OIG consider a new title for the report that more accurately represents its content. For example
"A Review of Environmental Justice and Communications Efforts at the Ringwood Mines/Landfill
Site," would more accurately describe the content of the report.
Record of Decision (ROD) recommendation
The OIG's recommendation for the new ROD in Chapter 2 (currently at the bottom of page 8)
should replace the description of that recommendation in the "At a Glance" section as the language
in Chapter 2 is more complete.
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EPA's relationship with Ford
We agree with the OIG that EPA's relationship with Ford as a potentially responsible party (PRP) is
an important issue at the Ringwood site. However, Chapter 3's presentation of EPA's relationship
with Ford, which is based solely on perceptions of interviewees, does not reflect the reality of this
relationship. Region 2 staff have interacted with Ford and its contractors according to all agency
regulations and guidance for dealing with a PRP at a Superfund site, and it is imperative that the
final report reflect this. Although there are variations in our relationship with PRPs from site to site,
our relationship with Ford at Ringwood is typical for a Superfund site of this complexity.
It should be noted that since 1983, EPA has issued five administrative orders to Ford, which require
Ford's performance of investigatory and cleanup actions at the site. In fact, investigations are
currently being conducted at the site by Ford's contractor pursuant to the requirements of a
September 2005 administrative order. Furthermore, all work plans developed by Ford's contractor
are subject to review and approval by EPA. To ensure compliance with the approved work plans, all
fieldwork is overseen by the U.S. Army Corps of Engineers for EPA.
Update on community involvement work
EPA and federal and state health agencies held a public information session on January 30, 2007 to
discuss results of the agency's biota study at the Ringwood site, which was attended by about 50
people. At that meeting, EPA also announced plans to conduct community interviews as part of its
revised community involvement plan (CIP). Several interviews took place on March 2 and March
13 (please note, however, that as of today, none of the Upper Ringwood residents has agreed to be
interviewed for the revised CIP). EPA has secured the services of a professional facilitator for the
community advisory group. EPA also released the initial results of its deer study at Ringwood site
on March 9 and is analyzing recently-collected deer from off of the site. Additional wildlife,
including wild turkeys, rabbits and squirrels, will be continued to be collected and analyzed. We
will likely present our findings to the public later this spring.
Factual corrections for the final report
In the "At a Glance" section, the first item in the left column should specify that three
members of the New Jersey congressional delegation asked the OIG to conduct this
investigation.
On page 2 of the draft, the second paragraph should be revised to reflect that in 1987, 7,000
cubic yards of superficial paint sludge and soil were removed from four areas of the site.
On the same page, the OIG notes that Region 2 concluded the requirements had been met to
delete the site from the NPL in 1993. The report should reflect that the New Jersey
Department of Environmental Protection concurred with our findings.
The photograph on page 5 is from the SR-3 removal area, not the O'Connor Disposal
Area.
The third paragraph on page 7 discusses a 2006 study by New Jersey health officials that
noted children living near the Ringwood site had higher levels of lead in their blood than in
other parts of the borough. Please note that only one child in the study had an elevated level
in their blood that was possibly related to paint sludge from the Ringwood site.
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The last sentence in this paragraph notes that ATSDR recommended an exposure
investigation be conducted. Please note that attorneys representing some Ringwood residents
subsequently indicated in a June 2, 2006 letter that they had advised their clients not to
participate in physical exams being coordinated by ATSDR, due to litigation concerns.
The last paragraph on page 7 of the draft should mention that Region 2 concluded that Upper
Ringwood was an adversely impacted area solely as a result of it being part of a Superfund
site.
The third full paragraph on page 11 mentions a 1992 letter where New Jersey state
authorities determined Ringwood residents' drinking water to be contaminated. However, it
is EPA's understanding that Upper Ringwood residents were connected to the municipal
water supply during the 1980s, which was not contaminated.
The report should discuss, perhaps in the "Other Legal Considerations Complicate
Communication" section in Chapter 3, that New Jersey agencies are overseeing the possible
remediation of residential properties or relocation of residents related to the Ringwood site.
If you have any questions, please let me know or contact John Svec at (212) 637-3699.
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Appendix B
Distribution
Office of the Administrator
Assistant Administrator for Solid Waste and Emergency Response
Regional Administrator, Region 2
Audit Followup Coordinator, Region 2
Director, Public Affairs Division, Region 2
Director, Emergency and Remedial Response Division, Region 2
Audit Followup Coordinator, Office of Solid Waste and Emergency Response
General Counsel
Agency Followup Official (the CFO)
Agency Followup Coordinator
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Director, Office of Regional Operations
Acting Inspector General
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