Office of Site Remediation 

Enforcement (2271A) March 2006 

Washington, DC 20460 Issue #25 

Sealand Restoration 2 

Harbor Island Cleanup 

3 

North Ridge Settlement 

Triad Cleanup 4 

In The Courts 5 

International Hazardous Waste Case 

ASARCO 

Tidbits 6 

Earth Day 2006 

FRTR Factsheet 

Escambia Cleanup Plan 

Calendar 7 

Glossary 

CleanupNews is a monthly 

newsletter highlighting hazardous 

waste cleanup cases, policies, 

settlements and technologies. 

inside 

Changes to Financial Test 

Vaandering Sentence 

Local Redevelopment Authorities 

cleanupnews 

EPA Proposes 

Agreement for ChemWood Treatment 

EPA is proposing to enter into a Prospective Purchaser Agreement (PPA) with Kanani, L.L.C. for the purchase of the ChemWood Treatment Company facility in Campbell Industrial Park, 

Ewa Beach, Hawaii. The property is a RCRA Corrective Action site, and 

the agreement includes covenants not to sue under both RCRA and 

CERCLA. EPA believes this agreement represents a substantial benefit to EPA and the local community because the current and previous 

owners are out of business and financially unable to address contamination at the site. Kanani plans to use the 2.6-acre site on Oahu Island 

for supplies and vehicle storage. The agreement will not be finalized 

until after a 30-day public comment period and EPA’s consideration of 

any comments received. 

Under the agreement, Kanani will implement all cleanup actions including capping contaminated soils and monitoring the natural attenuation of groundwater contamination. Kanani will also record use restrictions and other institutional controls to help ensure that future use 

of the site does not compromise the integrity of the protective cap and 

other corrective actions. Improved site security will also alleviate concerns of unauthorized public access to the site. All of Kanani’s actions 

continued on page 4 

Los Angeles Man

Sentenced for Dry 

Cleaning Waste 

Scheme 

On January 25, 2006, Behzad Kahoolyzadeh was sentenced in 

district court to 37 months in jail and ordered to pay $1.29 

million in cleanup costs for his involvement in the illegal transport and storage of dry cleaning chemicals. Kahoolyzadeh, who is also 

known as Behzad Cohen and David Cohen, pleaded guilty on March 4, 

2004 to five felony counts: 1) unlawful storage of hazardous wastes in 

violation of a permit; 2) unlawful storage of hazardous wastes without a 

permit; 3) unlawful transportation of hazardous wastes to an unper 

continued on page 5 

Printed on recycled paper 
Highlights

Construction Completed at Sealand 

Restoration Superfund Site 

Agroup of responsible parties has completed con 

struction of a subsurface 

barrier system that will treat ground 

water contamination at the Sealand 

Restoration Superfund site near 

Lisbon, New York. This marks the end 

of the major work to be done at the 

site to address volatile organic compound (VOC) ground water contamination. 

Sealand Restoration, Inc. was issued a permit by the New York Department of Environmental Conservation (NYSDEC) to landfill petroleum 

wastes on the site in 1979. NYSDEC 

discovered that Sealand Restoration 

was accepting waste not included in 

the permit and ordered the company 

to stop operations. NYSDEC shut 

down the landfill in 1980 after nearby 

wells showed low levels of cadmium 

contamination. Additional sampling 

from on-site monitoring wells revealed 

ground water contamination from 

heavy metals and VOCs, including 

The biopolymer slurry is pumped via 

a hose into the trench during 

excavation. 

benzene, trichloroethene, 1,1,1-

trichloroethane, toluene, and acetone. 

The State of New York and St. 

Lawrence County removed drums and 

excavated contaminated soil, and the 

area was filled with clean fill and 

capped. The site was added to the NPL 

in August 1990. 

A remedial investigation and feasibility study to determine the nature 

and extent of on-site ground water, 

surface water, and sediment contamination and to evaluate remedial alternatives was completed by the responsible parties in August 1995. A 

remedy calling for ground water extraction and treatment was selected by 

EPA in September 1995. In 2001, 

EPA modified its original plan for 

ground water remediation after further 

testing showed that the original remedy would not satisfactorily address 

the contamination. Instead, EPA 

chose a permeable reactive barrier 

which will remove contaminants from 

the water as it flows through the barrier. Under the modified plan, some 

contamination will be allowed to attenuate naturally, as well. Although 

the major work is completed, EPA will 

continue to oversee the cleanup to 

make sure that the responsible parties maintain the system properly. 

For additional information, contact 

Robert Nunes, EPA Region 2, (212) 637- 

4254. 

On January 31, 2006, RSR Corporation and its subsidiaries 

Quemetco, Inc. and QRI, Inc. (RSR) agreed to pay $8.5 million for 

lead contamination at the Harbor Island Superfund site in Seattle, Washington. The settlement will 

resolve RSR’s liability. In a 1996 consent decree, other businesses that contributed to the contamination of 

Harbor Island agreed to complete cleanup work worth approximately $32 million. RSR Corporation was not a 

party to the consent decree, and the U.S. brought a lawsuit against RSR to recover costs not included in the earlier 

settlement. 

Harbor Island, located at the mouth of the Duwamish River near downtown Seattle, is a man-made island that 

has been used by various industries for over a century. RSR operated a lead smelting operation on the island from 

1972 to 1983. Lead in air emissions and fugitive lead dust emissions from its smelting operation contaminated 

surface soils. In addition to the soil contamination resulting from RSR’s operations, marine sediments and 

ground water were contaminated with heavy metals, volatile organic compounds (VOCs), pesticides, and other 

contaminants from other industrial processes. Surface cleanup has been completed, but some subsurface areas 

and the groundwater still require cleanup and further investigation. 

The public comment period for the proposed consent decree ended March 10, 2006. 

For additional information, contact Bob Hartman, ORC, (206) 553-0029, hartman.bob@epa.gov; Neil Thompson, 

EPA Region 10, (206) 553-7177; or Cynthia Magnuson, USDOJ, (202) 514-2007, cynthia.magnuson@usdoj.gov. 

Settlement Reached for Harbor Island 

2 cleanupnews
 
Advisory Board Recommends ecommends

Changes to Financial es to Financial es to Financial Test

by Greg Madden, OSRE 

The Environmental Financial 

Advisory Board (EFAB or 

Board)—which advises EPA 

on financial matters—has been 

charged with addressing a number of 

issues related to financial assurance 

for closure and cleanup liabilities. The 

first issue EFAB took up was the use 

of the “financial test” mechanism as 

financial assurance for an entity’s closure and/or cleanup obligations. The 

financial test mechanism assesses the 

regulated entity’s present financial viability. The financial test is used by 

many entities to provide financial assurance. 

EFAB has held discussions about 

the financial test in the RCRA closure/ 

post-closure financial assurance regulations over the past year and a half. 

EPA uses these regulations as guidance on financial assurance for 

CERCLA cleanups and RCRA corrective action activities. The Board completed their review of the regulations 

and provided their recommendations 

for changes to the financial test in a 

January 11, 2006 letter to Administrator Johnson. 

One key element of the recommendation was EFAB’s belief that “the 

Agency and its State counterparts 

should view themselves as potential 

creditors with respect to the financial 

assurance requirements.” (emphasis 

added). Another key element of the 

EFAB recommendation was recognition 

that the financial test mechanism 

needed to consider the “limited capacity” of EPA and State environmental 

agencies to undertake “extensive credit 

analysis” in implementing a financial 

test regulation. 

The Board found that credit rating 

agencies methodologies provide reliable 

credit quality assessments. In its current form the RCRA closure/post-closure requirements have two financial 

test alternatives, only one of which requires independent third party credit 

analysis (i.e., credit ratings). EFAB expressed concern that this alternative 

“does not provide the same level of scrutiny offered by a credit rating.” 

In light of the belief that environmental regulatory agencies should consider 

themselves “potential creditor,” along 

with concerns about those agency’s limited financial analysis capacity and the 

reliability of credit rating agency methodologies, the Board recommended: 

“the Agency consider that all companies using the Alternative I test to 

meet their obligations receive an independent third party assessment of 

their credit position using methodologies currently employed by the credit 

rating services and other financial institutions.” 

EPA has already responded to the 

EFAB letter with a February 21, 2006 

letter from Office of Solid Waste and 

Emergency Response, Assistant Administrator Susan Bodine. In its response, explained that the recommendations would be considered in any 

actions taken to upgrade financial assurance requirements. EPA noted 

that the Agency was “particularly interested in the Board’s advice that 

EPA and the States should consider 

the financial assurance requirements 

from the view of a potential creditor 

when evaluating financial assurance.” 

EFAB will continue its work by next 

taking up the issue of “captive insurance” as a financial assurance mechanism. 

For additional information, contact 

Greg Madden, OSRE, (202) 564-4229. 

In the Spotlight

$11 Million Settlement Reached for
 

North Ridge Estates Superfund Site
 

On January 20, 2006, EPA 

and the Department of 

Justice announced that a 

settlement has been reached resolving a dispute over an asbestos contaminated property known as the 

North Ridge Estates Superfund Site 

in Klamath Falls, Oregon. In a related lawsuit filed in early 2003, 13 of 

the 22 homeowners who purchased 

homes in the North Ridge Subdivision 

argued that the real estate developers 

known as MBK Partnership contaminated the property by illegally spreading and burying asbestos containing 

materials (ACM). According to the consent decree, MBK and other parties associated with MBK agreed to pay $11 

million to reimburse EPA for costs and 

to compensate affected families and 

help them move into new homes. 

EPA’s costs included paying to relocate homeowners during the summer 

of 2005 due to dry conditions and the 

danger of exposure to friable asbestos material.

 continued on page 6 

cleanupnews 3 
Triad Speeds Cleanup of Lead-
 

Contaminated Firing Range Soil
 by Deana Crumbling, OSRTI

OSWER News

The former Evergreen Infiltration Range is part of 

Fort Lewis in Washington 

state. The area was target for cleanup 

to allow fast-track construction of 

additional base housing. The impact 

berm (300 feet long and 40 feet high) 

still contained lead fragments from 

slugs and some soil was contaminated 

with high lead concentrations. The Fort 

Lewis Directorate of Public Works and 

the U.S. Army Corps of Engineers 

worked together to 

control measures and used software 

to visually display concentration 

patterns in real-time. 

Approximately 5,000 cubic yards 

of soil were removed. Lead fragments were screened out and sent 

to a recycling facility. If treated with 

phosphate amendments, the RCRA 

regulator allowed the remaining soil 

to be reused to build new berms on 

an active range. Reuse had several 

benefits. 1) The costs of landfill disimplement the Triad 

approach (intensive 

systematic planning, 

adaptive decisionmaking, and tools 

supporting real-time 

decision-making; see 

www.triadcentral.org) 

in spring 2003 to meet 

the aggressive time 

schedule and conserve 

restoration resources. 

Remediation to 

Washington state 

clean-up levels for un- View of the impact berm and sampling. Berm 

restricted (residential) vegetation had been growing undisturbed for 41 

use was required. Dur- years. 

ing systematic planning an interdisciplinary project team developed the 

decision logic that guided real-time 

field work. A field-portable X-ray fluorescence (XRF) instrument (see http:/ 

/fate.cluin.org/xrf.asp?techtypeid=49) 

reported quantitative soil lead concentrations within 5-10 minutes of obtaining the sample. Lead contamination was present in highly heterogeneous patterns which could cause misleading data results; however, realtime, adaptive, high-density sampling 

and analysis monitored and managed 

the effects of heterogeneity and 

avoided erroneous decisions. The 

project team designed strict quality 

4 cleanupnews
 

posal for the old berms were not incurred. 2) Slugs fired into the new 

berms would be “treated” upon deposition. 3) Creation of new volumes 

of contaminated soil requiring treatment and disposal in the future was 

avoided by not using clean soil to 

construct the new berms. Compared 

to a more standard dig and haul, 

time savings were estimated at several months and cost savings at approximately $1 million. 

For additional information, contact Kym Takasaki, US Army Corps 

of Engineers, (206) 764-3322, 

kymberly.c.takasaki@usace.army.mil. 

PPA, continued from page 1 

will help prevent contamination from 

migrating offsite. 

From 1973 to 1988, Chem-Wood 

Treatment Co. ran a wood treatment 

facility on the site. Post-treatment 

dripping, accidents and mismanagement of waste allowed the treatment 

mixture, which included formulations of pentachlorophenol diluted 

with mineral spirits and containing 

dioxin, to contaminate the soil and 

groundwater. In response to a RCRA 

Section 3008(h) Corrective Action 

Order issued by EPA in 1988, ChemWood halted its wood treatment activities at the site and began to address the soil and groundwater contamination. Chem-Wood capped 

most of the property and created a 

Corrective Action Trust Fund which 

currently contains $292,000. In return for an unpaid loan, ownership of 

the site was transferred from ChemWood Treatment Co. to the now bankrupt SOGO Hawaii, Inc. 

Kanani estimates that it will cost 

over $1.6 million to complete the corrective actions outlined by the PPA, 

which is more than the $1.3 million 

the the property is worth. After factoring in the Corrective Action Trust 

Fund set up by Chem-Wood, Kanani 

expects to spend $90,000 in cleanup 

costs above the site’s property value. 

This agreement and EPA’s covenant not to sue only cover existing 

contamination at the time of sale. In 

order to maintain EPA’s covenant, 

Kanani must take care not to worsen 

existing contamination and must not 

cause additional contamination at 

the site. 

For additional information, contact 

Helen Keplinger, Attorney-Advisor, 

OECA/OSRE/RSD, (301) 229-5526. 
Michigan Man 

Pleads Guilty to 

Abandoning 

Chemicals 

On December 19, 2005, James A. 

Vaandering, who pleaded guilty to 

abandoning chemicals at an electroplating facility, was sentenced to 13 

months in prison, 300 hours of community service, and 3 years of supervised release by the District Court for 

the Western District of Michigan. 

Vaandering was also ordered to pay 

$1,000 in fines and $151,000 to EPA 

for cleanup costs. 

Vaandering was a supervisor at 

Sealmore Corporation in Muskegon, 

Michigan, which was condemned in 

late 2000. Among the chemicals left 

at the facility were acid solutions containing hexavalent chromium and hydrofluoric acid. Hexavalent chromium 

and hydrofluoric acid are chemicals 

that can cause serious health problems if individuals are 

improperly exposed to them. 

For additional information contact 

Peter Rosenberg, Office of Criminal 

Enforcement, Forensics and Training, 

(202) 564-2611. 

Defendants 

Sentenced in 

International 

Hazardous Waste 

Prosecution 

On February 14, 2006, U.S. District 

Court Judge Bruce W. Kauffman, Eastern District of Pennsylvania, sentenced three defendants for mishandling hazardous waste stored at a 

warehouse in Pottstown, Pennsylvania between 1998 and 2000 and 

transported in 2000 to the port of 

Rotterdam, the Netherlands. The defendants—Joel D. Udell, 65, and his 

two companies, Pyramid Chemical 

Sales Co. and Nittany Warehouse 

LP—ran a chemical brokerage business in Pottstown and Ambler in Pennsylvania. They had previously pleaded 

guilty to unpermitted hazardous waste 

storage, transportation of hazardous 

waste without manifests and to unpermitted facilities, and exporting hazardous waste outside the United 

States without the consent of the receiving county. The defendants collectively must pay more approximately $ 

1.8 million in restitution to the Dutch 

government, Rotterdam port operator 

and EPA for disposal, storage and 

clean up costs, and pay $200,000 in 

fines. Udell, who now lives in Boca 

Raton, Florida, was also sentenced to 

home confinement for six months back 

in Montgomery County, Pennsylvania 

where Pottstown and Ambler are located and to perform 500 hours of community service in Pottstown. The defendants will also serve five years of 

probation. 

In May 1998, Pottstown officials attempted to get Udell to improve hazardous waste handling and storage at 

the Nittany Warehouse in Pottstown 

where he stored his chemicals awaiting sale. When Udell failed to comply, 

Pottstown sued in state court and obtained a clean up order in April, 2000. 

EPA required the defendants to perform a Superfund cleanup at the warehouse beginning in July 2000. Around 

that same time, the defendants 

shipped 29 forty-foot containers of 

chemicals, including hazardous waste, 

to Rotterdam. The wastes remained 

for three years in Rotterdam despite 

Dutch and EPA orders to the defendants to return the chemicals to the 

U.S. or dispose of them. Eventually 

the Dutch government paid to have the 

nearly 300 tons of waste incinerated. 

For additional information, contact 

Martin Harrell, EPA Region 3, (215) 

814-2638. 

District Court 

Finds ASARCO 

Does Not Have 

Contribution 

Rights 

On January 24, 2006, the District 

Court for the District of Arizona ruled 

that ASARCO could not claim contribution rights under CERCLA Section 

113. ASARCO had entered into a 

settlement with the State of Nebraska 

through which it agreed to voluntarily 

clean up a 22-acre parcel in Omaha, 

Nebraska. After incurring cleanup 

costs, ASARCO claimed contribution 

rights under Section 113 and sought 

$30 million in costs from Union Pacific. 

The Court found that the Memorandum of Agreement (MOA) ASARCO 

entered into with the State of Nebraska 

did not resolve ASARCO’s CERCLA 

liability under Section 113(f)(3)(B). 

The state settlement was not authorized by EPA, and there was no agreecontinued on page 7 

LA Man, continued from page 1 

mitted facility; 4) unlawful transportation of hazardous wastes without a 

manifest; and 5) conspiracy to commit 

those offenses. 

Kahoolyzadeh was connected with a 

dry cleaning waste handler—AAD Distribution and Dry Cleaning Services, 

Inc. of Vernon, California—which collected, treated, and managed the disposal of perchloroethylene (PERC). 

Kahoolyzadeh and others hid drums 

on trucks prior to inspections so that 

permit violations would not be identified; the drums were then shipped offsite and stored at an unpermitted facility. 

For additional information, contact 

Erica Martin, ORC, (626) 583-6746; 

William W. Carter, United States 

Attorney’s Office for the Central District 

of California, (213) 894-3547, 

william.carter@usdoj.gov; or David P. 

Kehoe, DOJ, Environmental Crimes 

Section, david.kehoe@usdoj.gov. 

cleanupnews 5 

In The Courts 
Tidbits

Earth Day 2006 is

April 22 

EPA and other federal agencies, 

state and local governments, and organizations are gearing up for Earth 

Day 2006. The federal government’s 

Earth Day Web site at: http:// 

www.earthday.gov provides a wealth 

of information about environmentally-friendly practices for work and 

home. There is also a link to the Earth 

Day Network, which provides a list of 

international and U.S. Earth Day activities and volunteer opportunities. 

EPA Region 2 will celebrate Earth 

Day by presenting its annual Environmental Quality Awards; details are 

provided on the award Web site at: 

http://www.epa.gov/region2/eqa/. The 

District of Columbia is planning 

Green DC Week (April 17-23, 2006) 

with educational activities scheduled 

around the city. For additional information, see the Green DC Week Web 

site at: http://www.greendcweek.net. 

Remediation 

Technology 

Assessment 

Reports: Summary 

of Selected 

Documents 

This new factsheet, published by the 

Federal Remediation Technologies 

Roundtable (FRTR), identifies and 

summarizes selected reports prepared by federal and state agencies 

to assist project managers in selecting and designing remediation technologies. Remediation Technology 

Assessment Reports are based on 

practical field experience with either 

specific technologies (such as permeable reactive barriers) or, in a few instances, specific contaminants (such 

as arsenic). As of February 2006, the 

6 cleanupnews 

website http://costperformance.org/ 

remediation provides access to 70 of 

these reports. The new factsheet highlights the Remediation Technology Assessment Reports that may be among 

the most useful to project managers. 

For additional information, contact 

Marti Otto, OSRTI, 

otto.martha@epa.gov, (703) 603-8853. 

DOD Announces 

Local 

Redevelopment

Authorities 

On February 7, 2006, the DOD’s Office of Economic Adjustment (OEA) 

published a Federal Register notice 

(71 FR 6274) that includes a listing of 

recognized Local Redevelopment Authorities (LRAs), their contact information and associated military installations that are closing or realigning 

as a result of the 2005 Defense Base 

Closure and Realignment (BRAC) report. Anyone interested in redevelopment activities at the installations 

listed should contact the LRA point of 

contact for information. Additional 

LRAs will be announced in the Federal Register when they are officially 

recognized by the DoD. 

For additional information, contact 

Tracey Seymour, FFRRO, (703) 603- 

8712. 

North Ridge, continued from page 3 

The North Ridge Estates site was 

purchased in 1977 by Melvin Stewart, 

Maurice Bercot, and Kenneth Tuttle, 

the original MBK partners. Prior to 

the MBK purchase, the site had served 

as the campus of the Oregon Technical 

Institute. The existing buildings dated 

back to the 1940s and were constructed 

with asbestos containing materials. 

Although MBK responded to a 1979 

EPA administrative order by removing some ACM from the site, the partnership did not record a restriction on 

using the land for residential development. In 1993, the site was developed 

for private housing. 

For additional information, contact 

Cliff Villa, EPA Region 10, (206) 553- 

1185. 

Escambia Final 

Cleanup Plan 

Approved 

EPA has signed the Record of Decision outlining the cleanup strategy for 

soil contamination at Escambia Wood 

Treating Company Superfund Site in 

Pensacola, Florida. The cleanup plan 

includes excavating both on-site and 

off-site soils; permanently relocating 

residents in the Clarinda triangle 

neighborhood; soil containment and 

capping; and institutional controls. 

EPA modified the initial cleanup plan 

based on a re-evaluation of the original remedy and community concerns. 

The Escambia Wood Treating Company treated utility poles, foundation 

pilings, and lumber on the site from 

1942 to 1982. To date, EPA has excavated and covered 255,000 cubic yards 

of contaminated material on-site and 

permanently relocated 358 households. 

For additional information, contact 

Laura Niles, EPA Region 4, (404) 562- 

8353, niles.laura@epa.gov. 

ASARCO, continued from page 5 

ment between EPA and the state 

that the settlement would resolve 

ASARCO’s CERCLA liability. In fact, 

the MOA did not mention federal authority, EPA, or CERCLA. The MOA 

also did not contain a covenant not to 

sue; CERCLA Section 122(c)(1) requires that agreements contain covenants not to sue in order for there to 

be a resolution of liability. 

For additional information, contact 

Josh Epstein, OSRE, (202) 564-6009. 
March 29-31, 2006 

Conference on Contaminated 

Property Transactions: Deal 

Making and Redevelopments 

Washington, DC 

http://www.rtmcomm.com/ 

rtmcomm/ 

conference_detail.php?ConfID=20 

April 4-6, 2006 

WasteExpo 

Las Vegas, NV 

http://www.wasteexpo.com/ 

May 15-19, 2006 

IT3 Conference 

Savannah, GA 

http://www.awma.org/events/it3/ 

2006/ConferenceInfo.asp 

May 16-17, 2006 

Restoration 2006 

New Orleans, LA 

http://www.restoration2006.org/ 

en/index.aspx 

June 20-23, 2006 

A&WMA’s 2006 Annual 

Conference & Exhibition 

New Orleans, LA 

http://www.awma.org/ACE2006/ 

June 21-23, 2006 

Waste Management 2006 

Malta 

http://www.wessex.ac.uk/ 

conferences/2006/waste06/ 

August 19-22, 2006 

2nd International Conference on 

Environmental Science and 

Technology 

Houston, TX 

http://www.aasci.org/ 

conference/env/2006/index.html 

Calendar

Glossary 

ACM Asbestos containing material 

BRAC Base Closure and Realignment 

CD Consent decree 

CERCLA Comprehensive Environmental 

Response, Compensation, and 

Liability Act 

EFAB Environmental Financial Advisory 

Board 

EPA Environmental Protection Agency 

LRAs Local Redevelopment Authorities 

MOA Memorandum of Agreement 

NPL National Priorities List 

NYSDEC New York State Department of 

Environmental Conservation 

OECA Office of Enforcement Compliance 

and Assurance 

OSRE Office of Site Remediation 

Enforcement 

OSRTI Office of Superfund Remediation 

Technology Innovations 

OSWER Office of Solid Waste and Emergency 

Response 

PPA Prospective purchaser agreement 

RCRA Resource Conservation and Recovery Act 

VOC Volatile organic compounds 

XRF X-ray fluorescence 

cleanupnews

CleanupNews is a monthly publication of EPA’s 

Office of Site Remediation Enforcement, in 

cooperation with the Office of Superfund 

Remediation and Technology Innovation, Office 

of Underground Storage Tanks, and Office of 

Emergency Prevention, Preparedness and 

Response. Past issues of CleanupNews can 

be found at http://www.epa.gov/compliance/ 

resources/newsletters/cleanup 

cleanupnews.html 

To comment on the newsletter contact Richard W. Popino, PhD REM, at MC-2271A, U.S. EPA, 1200 Pennsylvania Ave., NW, Washington, DC 20460, email:popino.rick@epa.gov. 

To be added or deleted from the subscriber list, contact Christine Rueter at: christine.rueter@dpra.com 

To receive CleanupNews by email, subscribe at http://www.epa.gov/compliance/resources/listserv/

cleanup.html.

Richard W. Popino, PhD REM, editor-in-chief 

EPA Review Board; Diane Bartosh, Sandra 

Connors, Karen Ellenberger, Elliott Gilberg, Jeff 

Heimerman, Kenneth Patterson, Neilima Senjalia, 

Suzanne Wells 

Cheryl Mueller and Christine Rueter 

DPRA Inc., writers 

Mary Spencer 

DPRA Inc., designer 

http://www.epa.gov/compliance/about/offices/osre.html