NCD980602163_19981201_Warren County PCB Landfill_SERB C_USEPA - Warren County PCB Landfill_SERB C_US-EPA EJ Quarterly - Summer Fall 1998-OCR

&EPA
IN THIS ISSUE:
State and Tribal Grants
Program ... 1
Title VI Case
Dlsmlssal ... 3
Oregon's Lead Based
Paint Program ..... 4
Grant Availability .. 4
NEJAC Subcommittee
Membership Llsts ....... 5
The South Africa
Report ..... 7
United States
Environmental Protection
Agency
Enforcemen t and
Compliance Assurance
Mail Code 22O1A
EPA-300 N-98-001
SUMMER -FALL 1998
EJ ttu-.rterly
An Environmental Justice Bulletin
State and Tribal Environmental Justice Grants Program
Fiscal Year 1998 Grantees
The State and Tribal Environmental Justice
(STEJ) Grants Program, sponsored by the U.S.
Environmental Protection Agency, Office of
EnvironmentalJustice,isintended tohelpStates
and Tribes effectively comply with Title VI of
the Civil Rights Act of 1964 and provide for
environmental justice in the development and
implementaion of their environmental
programs. For fiscal year 1998, EPA awarded
five grants, at$100,000each, to (4)Statesand (1)
Tribe. These are listed on page 2.
The specific objective of the STEJ Grants
Programs is to accomplish the following
environmental justice goals and objectives: 1)
enhance the state or tribal government's
effectiveness in complying with Title VI of the
Civil Rights Act of 1964, 2) reduce or prevent
disproportionately high and adverse human
health or environmental effects on low-
income communities and minority
communities, 3) integrate environmental
justice goals into a state's or tribe's policies,
programs and activities, 4) provide financial
and technical resources to develop an enabling
infrastructure at the state/local community
level and tribal/ tribal community level, 5) set
up model programs to address enforcement
and compliance issues in affected EJ
communities, 6) integrate measurable EJ goals
within the annual Performance
Partnership Agreements (PPAs) and
Memorandums of Understandings(MOUs)
between a state and EPA, or integrate
measurable EJ goals within the Tribal
Environmental Agreements (TEAs), and 7)
improve public participation in the decision-
making processeses (e.g. permitting processes,
development of regulations and policies).
UPCOMING NEJAC MEETING IN BATON ROUGE, LA
The next meeting of the full National
Enviornmental Justice Advisory Council
(NEJAC) will be held December 7 -10, 1998 at the
Baton Rouge Hilton, 5500 Hilton A venue, Baton
Rouge, Louisiana. The NEJAC was established
to ensure that EPA receives the viewpoints of
affected stakeholders on issues related to
environmental justice. The NEJAC consists of 25
members representing environmental justice
groups; industry; and state, local and tribal
governments and both government and non-
government organizations. It has six
subcommittees that focus on issues related to
enforcement, health and research, indigenous
peoples, international issues, public participation
and accountability, and waste and facility siting.
In addition to the 25 NEJAC members, each of
who sits on a subcommittee, 39 individuals
serve as members of various subcommittees.
See agenda on p.6
Page2
EJ Quarterly/Summer-Fall 1998
State and Tribal Environmental Justice Grants Program
Fiscal Year 1998 Grantees
STEJ -01 Vermont Agency of Natural
Resources, Department of Environmental
Conservation
This project will work to achieve both compliance
with environmental standards and remediation
of adverse environmental conditions at mobile home
parks while meeting the affordable housing needs
of thousands of low-income Vermonters. The two
specific goals of the project are: 1) obtain compliance
and reduce or prevent disproportionate adverse
environmental and health effects on mobile home
park residents, and 2) develop enabling
infrastructure at the state and local level with
technical and legal resources available to assist
mobile home park residents. This project seeks to
address the unique environmental and public health
concerns which impact mobile home park
residences. Fivestateagencieshaveformedamobile
home park compliance group to share information,
expertise, and authority to develop and implement
solutions for mobile home park problems that
previously seemed unsolvable from
an individual agency perspective.
STEJ -03 New Jersey Deparbnent of
Environmental Protection
The purpose of this project is to allow the New
Jersey Department of Environmental Protection
(DEP) to establish and incorporate an
"Environmental Justice (EJ) Screening Process" for
evaluating EJ issues of affected communities with
respect to Air, Water, and/or Federal Hazardous
Waste facility permits. Based upon the results from
the EJ Screening Process, the DEP would establish
an Environmental Equity Community Partnership
(EECP) Program in those minority and/ or low-
income communities that may be experiencing a
cumulative environmental burden .
STEJ -09 State of Tennessee Environmental Policy
Office
This project will include the development of a
strategic plan to ensure environmental justice the
Department's programs. The State will create a
strategic plan with significant community
involvement that will guide all environmental justice
activities of the Tennessee Department of
Environment and Conservation (IDEC) and serve
as a state and national model. The grantee will
address environmental justice through three major
components: 1) achieving an integrated system of
meaningful community involvement and
participation through networks, such as Tennesse's
regional Minority Health Coalitions
and other organizations, 2) integrating
environmental justice strategies with a major
ongoing initiative to re-engineer the Department's
environmental regulatory programs, and 3)
Developing and strengthening partnerships with
other state and federal agencies.
STEJ -14 Texas Natural Resource Conservation
Commission(TNRCC)
This project seeks to further1NRCC'scompliance
with Title VI of the Civil Rights Act of 1964,
through the creation and guidance of stakeholder
advisory panel. The project goals were developed
with input from various communities that have
filed Title VI complaints against the TNRCC or
which have raised issues of environmental justice
with the agency in order to determine the best
course of action to reduce the possibility for
future complaints. The advisory panel, made up
of thepartneringcommunityrepresentativesfrom
Beaumont, Corpus Christi, Houston, and Wichita
Falls--along with the TNRCC Chairman or his
appointee, Public Interest Counsel, Office of Legal
Services-Supplemental Environmental Projects,
and a representative from a Regional Field Office,
will help develop model programs to be piloted
in their respective areas to address enforcement
and compliance concerns. Furthermore, the panel
will provide vital input to enhance the agency's
environmental equity efforts.
STEJ -26 Kalispel Tribe of Indians
The Kalispel Tribe proposes to develop and
implement an ISO 14001 conforming
Environmental Management System (EMS) that
integrates EJ goals with environmental
performance objectives for the Kalispel
reservation. The Kalispel Tribe developed the
proposal with the support and advice of grassroots
organizations, the Director of the Washington
Department of Ecology and his staff, Pend Oreille
County, and the Coeur D'Alene, Colville and
Spokane Tribes. The ISO 14001 standard,
establishes an internationally accepted framework
forEMSswhichcanserveasasustainableprogram
that: 1) allow meaningful involvement of all
members of the Tribe in the development of goals
for an environmental program, 2) prevents
impacts from being disproportionately borne by
subgroups within the Tribe, 3) goes above and
beyond compliance with environmental laws, 4)
reduces pollution and pro-actively prevents
pollution, and 5) ensures fair treatment.
EJ Quarterly/Summer-Fall 1998
Supreme Court Dismisses as Moot an EJ Case Filed
under Title VI of the Civil Rights Act over State Permit
On August 17, 1998, the Supreme Court dismissed
as moot Seif v. Chester Residents Concerned For
Quality Living, 1998 WL 477242, an important
environmental justice case filed in federal district
court under Title VI of the Civil Rights Act.
The dismissal came at the request of the plaintiffs,
a group of residents in Chester, Pennsylvania.
They had sued the State's environmental agency
over a permit for a solid waste facility in the city of
Chester, which is a predominantly African-
American community. In their lawsuit, the
plaintiffs alleged that the permit violated EPA's
Title VI regulations because it would have racially
discriminatory human health, environmental, and
other effects on members of their community,
which already is overburdened by polluting
facilities. Unexpectedly, they asked the Supreme
Court to end the case after learning that the State
agency recently had revoked the permit for the
proposed facility at the request of the permittee.
The issue before the Court was whether the
plaintiffs had the right to bring their lawsuit under
Title VI without alleging intentional discrimination.
Title VI prohibits recipients of federal funds from
discriminating on the basis ofrace, color, or national
origin in their programs and activities. While the
statute itself bans intentional discrimination only,
it allows federal agencies to adopt implementing
regulations that also ban unintentional
discriminatory effects. It is well settled that Title
VI creates an implied right for a private party to
sue a recipient for intentional discrimination.
However, the Supreme Court has not squarely
addressed the question of whether a private party
may sue to enforce an agency's Title VI regulation
that prohibits discriminatory effects-a
proposition that is widely accepted among the
federal courts of appeals.
As a recipient of EPA grant funds, the State's
environmental agency is subject to the
requirements of Title VI and EPA' s implementing
regulations. In lieu of filing an administrative
complaint with EPA' s Office of Civil Rights, the
plaintiffs brought their complaint in federal district
court alleging that the permit at issue violated
EPA' s Title VI regulation that bans discriminatory
effects. The district court granted the State agency's
motion to dismiss the complaint. It ruled that,
unlike intentional discrimination claims under
Title VI itself, there is no private right of action
to enforce EPA' s regulation. The district court's
dismissal of the case was reversed on appeal by
the Third Circuit Court of Appeals.
As a result, the State agency petitioned the
Supreme Court to review the case, which the
Court accepted for review in early June.
In their last filing, the plaintiffs requested that
the Court dismiss the case as moot and suspend
the briefing schedule while it considered the
mootness question. They also argued that, if the
Court dismissed the case, it should not vacate
the appeals court's decision because the case
became moot after that decision but before the
Court had accepted the case for review. One
day before the State agency's opening brief was
due, the Court suspended the briefing schedule.
Less than two weeks later, it summarily
dismissed the case as moot and remanded it to
the appeals court with instructions for its
dismissal. In doing so, the Court followed its
usual practice of vacating the judgment below
to preserve the rights of the parties in future
litigation.
Barry Hill Selected as
Director, OEJ
On November 16, 1998,AssistantAdminstrator
Steven A. Herman announced that Barry Hill
had been appointed as the Director of EPA's
Office of Environmental Justice. Mr. Herman
stated that Mr. Hill comes to EPA with
impressive qualifications and background,
including experience as a governmental
manager at the Department of the Interior, as a
teacher of environmental justice at law
institutions, a member of the Executive
Committee of the Board of Directors of the
Environmental Law Institute and as counsel
with an international law firm. Mr. Herman
also stated that as demonstrated by his
successful work experiences with diverse
groups, Mr. Hill will bring to EPA interpersonal
and leadership skills as well as sensitivity to
environmental issues.
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Page3
EJ Quarterly/Summer-Fall 1998
EPA AUTHORIZES OREGON'S LEAD-
BASED PAINT PROGRAM
On September 3, 1998, the U.S. Environmental Protection Agency
(EPA) Region 10 authorized Oregon to administer and enforce a
Lead-based Paint Activities Program. Oregon is the first state in
Region 10 and one of the few states in the country to receive
approval for a state Lead Program.
On March 31, 1998, Oregon applied to EPA for authorization to
administer and enforce a StateLead-based Paint Program. The
Lead Program will be administered by the Oregon Health
Division. This agency will share responsibilities for certification
and enforcement with the Oregon Construction Contractors
Board.
Under the Toxic Substances Control Act (TSCA), Congress
mandated that EPA develop and implement a nationwide lead-
based paint hazard reduction program. State and Tribal
governments, however, may apply to EPA for authorization to
administer their own programs in lieu of this Federal Program.
To become authorized by EPA, State and Tribal programs must
be as protective as the federal program and adequately enforced.
The program is designed to protect families from exposure to
lead in paint, dust, and soil by protecting them from the hazards
of improperly conducted lead-based paint activities. The lead
program ensures that contractors are qualified through training
and certification to inspect, assess or remove lead-based paint,
dust or soil are well qualified to conduct these activities.
Trainingand certification is required to ensure the proficiency of
contractors who conduct lead-based paint inspection, risk
assessment and abatement services in residences and day
carecenters. Trainer accreditation is required to ensure that
training programs provide quality instruction in current and
effective work practices.
Oregon State Rules for the Certification of Individuals and Firms
engaged in Lead-based PaintActivities were promulgated on
May 1, 1997. These rules describe the requirements for certification
of individuals and firms providing lead-based paint services.
According to the -rules, no person or firm may perform lead-
based paint services in target housing or childoccupied facilities
without first receiving certification. Lead-based paint services
include leadpaint inspections and risk assessments, and the
design and application oflead paint hazard reduction (abatement)
operations. For further information, please contact Barbara Ross
at [phone].
Page4
COTTONWOOD FOUNDATION
ANNOUNCES GRANT
AVAILABILITY
Approximately 25 grants of up to $1,000 will be awarded
in 1999 by Cottonwood Foundation, a small foundation
that provides grants to grassroots organizations
intemationallythatcombineactivitiesinallof thefollowing
four areas: protectging the environment, promoting
cultural diversity, empowering people to meet their basic
needs, and relying on volunteer efforts.
If you are interested in applying for one oft hese grants or
would like to nominate another group for consideration,
please visit the web site at http:/ /www.pressenter.com/
~cottonwd/ for application instructions or contact:
Cottonwood Foundation
Box 10803
White Bear Lake, MN 55110 USA
e-mail: [e-mail]
Completed applications are due on February 12, 1999 for
consideration in Spring 1999 or August 12, 1999 for
consideration in Fall 1999.
~ ~ I.Ji EPA NATIONAL ENVIRONMENTAL JUSTICE ADVISORY COUNCIL SUBCOMMITTEE MEMBERSHIP 1998 -99 STAKEHOLDER BREAKDOWN • Denotes NEJAC Council Member AC = Academia CG= Community Group SL = State/Local Govt. TR= Tribal • • NEJAC Proxy Chair EV = Environmental Group NG= Non-governmental Organization IN = Industry Air/Water Subcommittee -10 Members (2 NEJAC) NG Damon Whitehead* (2) Lawyers' Com. for Civil Rights NG Dan Greenbaum (3) Health Effects Institute SL Mariaime Yamaguchi (2) Santa Monica Bay Restoration Project IN Leonard Robinson (2) TAMCO IN Clydia Cuykendall (2) Star Enterprise AC Michel Gelobter• (3), Proxy Chair Rutgers University AC Bunyan Bryant (2) University of Michigan CG Daisy Carter (3) Project A WAKE CG Elaine Barron (3) Paso del Not1e Air Quality Task Force AC Kathleen Hill ( 1) Humboldt State University Enforcement Subcommittee --10 SL Lillian Mood, R.N. (2) members ( 4 NEJAC) AC Gerald Torres* (2), IN Leslie Beckoff * (I) EV Savi Horne(3) CG Rita Harris (2) NG Lamont Byrd (I) NG Luke Cole• (1) Proxy Chair NG Richard T. Drury (I) CG Zulene Mayfield (3) TR Lillian Wilmore (I) South Carolina Dept. of Health University of Texas Law School DuPont Speciality Chemicals Land Loss Prevention Project Mid-South Peace & Justice Center Teamsters CA Rural Legal Assistance Foundation Communities for a Better Environ. Chester Residents Con. for Q. Living Native Ecology Initiative (Kiowa Tribe) Health and Research Subcommittee --10 members (7 NEJAC) CG Margaret Williams* (I) Citizens Against Toxic Exposure CG Rose Augustine* (3) Tucsonans for a Clean Environment AC Marinelle Payton• (1), Proxy Chair Han•ard Medical School EV Carlos Porras (2) Communities for a Cleaner Environment IN Philip Lewis (3) Rolllll and Haas Company NG Jim Sessions * (3) Highlander Research & Education Center SL Rosa Franklin * (I) Washington State Senate SL Jane Stahl* (3) State of Connecticut SL Michael DiBartolomeis (2) California EPA TR Don Aragon* (2) Shoshone and Northern Arapaho Tribes International --8 members (2 NEJAC) NG Fernando Cuevas* (3) NG Janet Phoenix (I) SL Beth Hailstock (2) AC Maria Carmen Libran (2) CG A. Caroline Hotaling(3) NG Alberto Saldamando(3) EV Arnoldo Garcia • (1), Proxy Chair IN Albert P. Adams (3) Farm Labor Organizing Committee Not1heast EJ Network Cinci1mati Health Department University of Puerto Rico-Mayaguez Border Ecology Project International Indian Treaty Council Urban Habitat Program Piquniq Management Corporation Indigenous Peoples --11 members (4 NEJAC) EV Tom Goldtooth • (1), Proxy Chair Indigenous Environmental Network TR Je1mifer Hill-Kelly* (3) Oneida Enviromnental Health & Safety TR Dwayne Beavers * (I) Cherokee Nation TR Moses Squeochs (3) Yakama Nation TR Sarah James (2) Athabascan Tribal Government AC George Godfrey ( 1) Haskell Nations University AC Dean Suagee(3) Vennont Law School SL Brad Hamilton (2) State of Kansas SL Nancy Draper (I) Newport News Wate1works IN Gerald R. Prout * (I) FMC Corporation NG Charles Miller (2) Charles Miller Law Offices Public Participation and Accountability-7 members (3 NEJAC) NG Haywood Tu1Tentine** ( 1) Laborers' District Council of Education NG Lawrence Dark (3) Urban League of Portland CG Delbert Dubois (2) Four Mile Hibberian Community Ass., Inc. AC Robet1 Holmes (2) Clark Atlanta University SL Annabelle Jaramillo* (2) Office of the Governor, State of Oregon IN Denise Feiher (3) QST Enviro1U11ental Inc. CG Rosa Ramos• (I), Chair Community of Cantaflo, Puerto Rico Waste and Facility Siting Subcommittee CG Lo1rnine L. Granado (3) CG Cynthia Jennings *(2) SL David Moore * (3) SL Jerald White (2) IN Sue Briggum *(I) IN Mike Taylor (3) NG Mathy Stanislaus (I) NG Brenda Lee Richardson (2) AC Johnny Wilson (2) AC Michael K. Holmes (2) EV Ricardo Soto-Lopez (I) EV Neftali Garcia Martinez (3) EV Vernice Miller • (2), Proxy Chair TR Mervyn Tano (3) {l)--Tern1 expires 12/31/1999 --14 members (4 NEJAC) Cross Community Coalition ONE/CHANE Mayor, City of Beaumont, TX New Orleans Mayor's Office of Env. Affrs WMX Vita Nuova Enviro-Sciences, Inc. Women Like Us Clark Atlanta University St. Louis Community College Pue110 Rico-Northeast EJ Network Scientific and Technical Services Natural Resources Defense Council Int'! Institute for Indigenous Res. Mgmt. (2)--Term expires 12/31/2000 (3)--Te1m expires -12/31/2001 December I, 1998 (12:36PM) m c_ 0 C PJ ~ ...... ~ (/) C 3 3 (t) ...... I "Tl PJ __._ <.O <.O CX)
EJ Quarterly/Summer-Fall1998
NATIONAL ENVIRONMENTAL JUSTICE ADVISORY COUNCIL MEETING
AGENDA
Baton Rouge Hilton, 5500 Hilton Avenue, Baton Rouge, Louisiana
December 7-10, 1998
MONDAY, DECEMBER 7
5:00 p.m. Registration Begins
6:45 p.m. NEJAC Meeting Convenes for Public Comment
Period
7:00 p.m. Public Comment Period Begins
9:00 p.m. NEJAC Adjourns for the Evening
TUESDAY, DECEMBER 8
8:00 a.m. COFFEE/REGISTRATION BEGINS
9:00 a.m. NEJAC Meeting Convenes
Welcome and Opening Remarks
-Senior Manager, Environmental Protection Agency
-Senior Manger, EPA Office of Enforcement and
Compliance Assurance (OECA)
-Gregg Cooke, Regional Administrator, Region VI
-Tom Goldtooth, Acting Chair of NEJAC
10:00 a.m. Review of the Agenda
Discussion with Barry Hill, Director, OEJ
10:30 a.m. Title VI Workgroup Update
Anne Goode, Director, OCR
11:00 a.m. Report on the Waste Transfer Station
Fact Finding Meeting, Brooklyn, NY
12:00 p.m. Lunch Break
1:30 p.m. NEJAC Meeting Reconvenes
Discussion of new business continued
Science Advisory Board Committee Report
Dr. Maria Morandi, Univ. of Texas
2:30 p.m. Report on the White House EJ Listening
Sessions, Brad Campbell, Director, CEQ
3:30 p.m. Discussion of the NEJAC Assessment
WorkGroup, Charles Lee, Chair
5:30 p.m. NEJAC Adjourns for the Evening
WEDNESDAY, DECEMBER 9
8:00 a.m. COFFEE/REGISTRATION
8:30 a.m. NEJAC Subcommittee Meeting Convene
5:00 p.m. NEJAC Subcommittees Adjourn
6:45 p.m. NEJAC Meeting Reconvenes for Public Comment
Period
-Remarks from Haywood Turrentine, Chair of NEJAC
7:00 Public Comment Period Begins
9:00 NEJAC Adjourns for the Evening
THURSDAY,DECEMBER10
8:00 a.m. COFFEE/REGISTRATION
9:00 a.m. NEJAC General Session Reconvenes
Acknowledgment of the Air /Water Subcommittee
Dana Minerva, Deputy Assistant Administrator,
EPA Office of Watert
Robert Brenner, Acting Deputy Assistant Administrator,
EPA Office of Air and Radiation
10:30 a.rn. Business Requiring Executive Council
Action
-Subcommittees' reports, findings and
recommendation
12:00 p.rn. Lunch Break
1:00 p.rn. NEJAC General Session continues
-Council resolutions
3:00p.m. Afternoon Break
3:15 p.rn. Business Requiring Executive Council Action
continued
5:00 p.rn .. NEJAC Meeting Adjourns
Page6
EJ Quarterly/Summer-Fall 1998
South Africa Report
On November 16, NEJAC Chairman Haywood Turrentine
submitted to the EPA Administrator ,the South Africa Report,
which was prepared by the International Subcommittee's
Workgroup on South Africa. The report contains
recommendations from the community leaders. The
recommendations were give to the South Africa Workgroup
representatives during their personally financed, ten day, fact
finding trip.
The recommendations for consideration and the Executive
Summary are printed below.
EXECUTIVE SUMMARY
Representatives of the South Africa Working Group of the
National Environmental Justice Advisory Council's (NEJAC)
International Subcommittee visited South Africa in February
1998 during the meeting of the Gore-Mbeki Binational
Commission (BNC). The purpose of the visit was to participate
in activities associated with the BNC and to meet with
communities and environmental justice organizations in an
effort to identify possible areas of work and collaboration.
The South Africa Report provides a narrative that includes
general observations, summaries of meetings and tours and
the recommendations from the community and environmental
leaders in South Africa to NEJAC, its International
Subcommittee and the Office of International Activity (OIA).
This executive summary presents the recommendations
outlined in section seven of the report.
RECOMMENDATIONS
The following recommendations represent the thinking of the
communities we met with in South Africa not the authors of
this report. The recommendations are:
-Establish consistent communication between environmental
justice networks with a point of contact in South Africa and the
U.S.
-Develop an exchange program of information and trainings
"community based organization to community based
organization"
-Bring U.S. study tour of environmental justice groups
working wtih EPA/NEJAC to South Africa
-Maintain environmental justice observer at Binational
Committee (BNC) meetings both from South Africa and
fromthe U.S.
-Link Environmental Justice groups in U.S. with South Africa
groups who are addressing similar issues
Pagel
-Establish link between South African Environmental Justice
Network, Grantees of the small grants program (South African
Development Initiative for the Environment) and the South
Africa Working Group of the International Subcommittee of
NEJAC
-Develop a community based technical assistance center in
South Africa that houses environmental justice experiences and
trainings on various environmental issues
-Invite the participation of the South African Environmental
Justice Network Forum in the Environmental Management and
Pollution Working Group of the Binational Commission
-Conduct official study tour to South Africa for the South Africa
Working Group
-Request U.S. EPA toofacilitate the participation ofthe South
Africa Working Group in the Environmental Management and
Pollution Working Group of the BNC
Specific Recommendations to EPA/OJA
-Leadership Teams/Facilitation Teams/Training Teams from
EPA to South Africa should have People of Color Participants
-Integrate community based experience into the Environmental
Impact Assessment trainings for South Africa (being provided
byEPA/OIA)
-Build networks between the Bush Colleges in South Africa and
the historical Black Colleges and Universities in the U.S.
(coordinate efforts)
The following represents an immediate and specific request:
-Provide to the Environmental Justice Network Forum in South
Africa the following:
A. Education/training materials
B. "How to" guides on environmental issues
C. Instruction on how the environmental justice community
developed NEJAC with EPA
The NEJAC is requested to approve and implement the listed
recommendations. The Council is also requested to work with
the International Subcommittee in developing a plan of action
and its concomitant time frame and budget.
For further information on the South Africa Report, contact
Marva King, OEJ, [phone].
&EPA
U.S. Environmental Protection
Agency -2201 A
Washington, DC 20460
Official Business
Penalty for Private Use •
$300
Jack Butler
Superfund Section Chief
NCDEHNR-DWM
P.O. Box 27687
Raleigh , NC 27611-7687
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