| **	Enforcement Schedule Update

v NoV	Beede Waste Oil Superfund Site - April 2002

EPA is distributing this enforcement schedule update to potentially responsible parties (PRPs) to provide
information on upcoming settlement opportunities and other ongoing Beede activities.

Second De Minimis Settlement In February 2002, EPA announced its intention to offer a second de
minimis settlement opportunity to a second group of de minimis Beede PRPs this spring. The second
group will consist of parties that sent up to 5.000 gallons of waste oil to the site. EPA now expects such
a settlement to be offered on or around June 1, 2002. Although specific details are still under
consideration, the settlement likely will be structured like the first Beede de minimis settlement. That
first settlement, completed in November 2001 with 496 Beede PRPs, included payment of a non-
negotiable cash-out sum in exchange for a broad Superfund liability release from EPA. In addition to an
EPA release, the second settlement may also include a release from the State of New Hampshire for its
past costs incurred at Beede. Through the settlement, EPA intends to provide de minimis PRPs with an
opportunity to resolve liability without incurring the transaction costs associated with forming PRP
groups and conducting complicated settlement discussions. Note that all monies collected from the
second de minimis settlement will go into the Beede Special Account to be used for the Site, either for
cleanup or past costs, as decided in future negotiations.

PRP Waste Quantity Reviews EPA has completed numerous waste quantity reviews for those PRPs
who questioned their volumetric calculation and submitted a request to EPA in 2001. Where appropriate,
based on the facts and evidence, EPA adjusted volumetric information impacting PRP status. EPA plans
to communicate the results of the waste quantity reviews to those PRPs who requested them before EPA
issues the second de minimis settlement offer. A revised volumetric ranking report also will be placed on
the Beede Web Site. Note that EPA is deferring consideration of waste quantity review claims submitted
after December 2001, along with consideration of claims for review requiring legal determinations, until
later in the settlement process.

Proposed Cleanup Plan EPA is nearing completion of the proposed remedial action plan, which will
document the details, rationale and costs of a preferred cleanup alternative for the Beede Site. Issuance
of the plan will trigger a public review and comment period. EPA hopes to issue the proposed plan in or
around early June.

Meetings with EPA A number of PRPs and PRP groups have expressed interest in meeting directly
with EPA. At this point, such meetings are premature since EPA must treat parties fairly and cannot
meet with one PRP or PRP group without also providing other PRPs with access to EPA. When it is
appropriate to begin meeting with PRPs, EPA will provide equal direct access to all PRP groups,
including those that may be represented by a superfund company, such as TRC Companies, Inc. Note
that, at this time, EPA has not yet begun substantive negotiations with any parties or PRP groups. At
present, EPA's efforts are focused on issuing the second de minimis settlement offers and the proposed
plan. Once EPA has described the proposed cleanup activities and their expected costs through the
release of the proposed plan and has considered comments to that plan, meaningful settlement
discussions with PRP representatives can occur. Parties interested in negotiating with EPA directly will
need to form into PRP groups to facilitate participation in these future settlement discussions. EPA
expects to begin considering PRP requests for meeting(s) with EPA in the summer of 2002.

Additional Information EPA plans to issue a Beede Newsletter to all PRPs and other interested parties
very soon. For more information, please call the toll-free Beede Hotline at 1-888-294-6980 or visit our
web site at www, epa. gov/regionO 1 /supefiind/sites/beede.


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