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UPCOMING SITESGrand Calumet River/Indiana Harbor
The Grand Calumet River, originating in the east end of Gary, Indiana, flows 13 miles (21 km) through the heavily industrialized cities of Gary, East Chicago and Hammond. The majority of the river's flow drains into Lake Michigan via the Indiana Harbor and Ship Canal, sending about 500 million gallons of water into the lake per day. The AOC begins 15 miles (24 km) south of downtown Chicago and includes the east branch of the river, a small segment of the west branch and the Indiana Harbor and Ship Canal. Today, 90% of the river's flow originates as municipal and industrial effluent, cooling and process water and storm water overflows. Although discharges have been reduced, a number of contaminants continue to impair the AOC. Background The Grand Calumet River and Indiana Harbor and Ship Canal contain 5 to 10 million yds3 of contaminated sediment up to 20 feet (6 m) deep. Contaminants include toxic compounds (e.g., PAHs, PCBs, and heavy metals), and conventional pollutants (e.g., phosphorus, nitrogen, iron, magnesium, volatile solids, oil, and grease). Project Status The Indiana Department of Environmental Management (IDEM) and USEPA are actively working on cleanup projects pursuant to these agreements, as well as developing new major agreements through voluntary cooperation and legal action. The major parties to cleanup agreements on the waterway include:
Additionally, as part of the phase II RAP development for the Grand Calumet River/Indiana Harbor Canal AOC, the State of Indiana Department of Environmental Management (IDEM) requested assistance from the USACE to develop potential methods of sediment cleanup and habitat restoration in the GCR in Lake County, Indiana. The report, "Grand Calumet River - Indiana Harbor Canal Sediment Cleanup and Restoration Alternatives Project", is intended to provide stakeholders with the information necessary to begin development of sediment cleanup alternatives. This document presents a methodology for analyzing sediment cleanup and habitat restoration options for the river. The intent is not to recommend a single best approach but rather to make the reader aware of the range of considerations and options available for sediment cleanup and habitat restoration. Copies of this document are available by contacting:
Kalamazoo River - Allied Paper
Location The Kalamazoo River flows across the southwestern portion of the lower peninsula of Michigan. The river flows in a westerly direction and discharges into Lake Michigan near the town of Saugatuck. The lower eighty miles of the Kalamazoo River have been identified as an AOC, due to historic releases of PCBs from de-inking operations at local paper mills. The Allied Paper, Inc./Portage Creek/Kalamazoo River Site involves PCB contamination of: (1) an Allied Paper, Inc., property in Kalamazoo, Kalamazoo County, Michigan, (2) a 3-mile stretch of Portage Creek from Kalamazoo to where the creek meets the Kalamazoo River and (3) a 35-mile stretch of the Kalamazoo River. Background Allied Paper, Inc., a subsidiary of SCM Corporation, has operated paper mills on a 80-acre property at 2030 Portage Road in Kalamazoo since 1925. From 1957 to 1971, the company recycled and de-inked paper, including carbonless copy papers, which contained 3.4 percent PCBs by weight. In 1986, MDNR detected PCBs in several places in the 80-mile stretch of the Kalamazoo River between Kalamazoo and Lake Michigan. Contamination is primarily in the sediments, although the water column and fish are also affected. According to MDNR, the contamination begins at the point were Allied's Bryant Mill Pond discharges to Portage Creek. Administrative History Since the PCB contamination was identified as a problem in 1971, several actions have been taken to improve conditions. The discharge of PCBs has been substantially reduced due to the ban on PCB production, and other regulatory point source controls, such as the NPDES permit program. However, contaminated sediments in the upstream areas still serve as a source of PCBs to the Kalamazoo River. On December 2, 1987, the State filed a complaint under CERCLA Sections 107 and 113, the Resource Conservation and Recovery Act, the Federal Water Pollution Control Act, the Toxic Substances Control Act and three Michigan laws. The complaint called for Allied Paper and SCM Corporation to stop the release of hazardous substances into the environment and pay cleanup costs. In response, the companies have undertaken studies of the extent of the PCB contamination, the quantities of PCBs in Bryant Mill Pond, and possible remedial actions. In August 1990, the Allied Paper, Inc./Portage Creek/ Kalamazoo River Superfund site was included on the National Priority List pursuant to CERCLA. The site includes Portage Creek, from Cork Street just above the Bryant Mill Pond to its confluence with the Kalamazoo River; and the Kalamazoo River from this confluence downstream to the Allegan City Dam. The area listed includes a three mile stretch of Portage Creek and a 35 mile stretch of the Kalamazoo River. However, because the data indicate the PCBs have migrated downstream, the Superfund remedial investigation includes the area from Morrow Dam to the mouth of the Kalamazoo River. Amount of Contaminated Sediments
Project Status MDEQ is currently considering various remediation alternatives for the site. The parties involved are working on finalizing the terms of an agreement. Pine River - Velsicol Chemical
Location This site is located at North Avenue and Watson Street in St. Louis, Michigan. St. Louis is in the central part of the lower peninsula of Michigan. The Pine River flows along the site on both the eastern and northern sections of the site. Background This was the former location of the Vesicol Chemical Company Plant, which manufactured chemicals including DDT, hexabromobenzene (HBB) and polybrominated biphenyl (PBB). DDT was produced on site until 1959. HBBs and PBBs were produced until the mid 1970's. Sampling of the Pine River Reservoir in the early 1980's indicated high levels of these chemicals present in the sediments. Further sampling in 1996 showed that contaminant levels are decreasing, but still very high. In 1974, a no consumption advisory for all species of fish in the Pine River from the St. Louis Impoundment to its confluence with the Chippewa River was issued and continues to remain in effect today. Administrative History This remediation project is being completed under Superfund. There has been no ROD as of yet, as the project is still in the investigation stage. Amount of Contaminated Sediments
Project Status USEPA and MDEQ are working together in order to collect more data and sediment samples from the St. Louis Impoundment. Sampling using USEPA's R/V Mudpuppy was completed on July 25, 1997. A human health risk assessment from fish consumption is currently in draft form. Also, an ecological assessment of estimated impacts to wildlife from contaminated sediments is being developed. USEPA and MDEQ will begin the process of choosing the most cost-effective and timely option for remediation once the data collection is completed. Saginaw River
Location The Saginaw River discharges into Saginaw Bay, which is a southwestern extension of Lake Huron located in the east central portion of Michigan's lower peninsula. This AOC watershed encompasses 8,709 square miles in 22 counties and includes all of Saginaw Bay (1,143 square miles) out to its interface with open Lake Huron at an imaginary line drawn between Au Sable Point and Point Aux Barques. Background Environmental problems in the Saginaw AOC are caused by eutrophication (nutrients), toxic substances (PCBs, dioxin and heavy metals), bacterial contamination, sedimentation and commercial/residential development. Much of this ecosystem degradation results from poor land use practices. The sources that continue to contribute contaminants to the Saginaw River and Saginaw Bay include industrial and municipal discharges, combined sewer overflows (CSOs), contaminated sediments in the river and bay bottom, urban stormwater runoff, agricultural nonpoint sources, old waste disposal sites and the atmosphere. Administrative History As part of a 1997 natural resource damage settlement, General Motors and the cities of Bay City and Saginaw have agreed to provide funds for the dredging and disposal of PCB contaminated sediments in the lower river. Amount of Contaminated Sediments
Project Status Dredging is expected to begin during the summer of 1998. Total Cost The estimated cost for the remediation project is $5,000,000. South Branch of the Black River
Location This site is located at the north end of the village of Bangor. It is a former mill pond which was formed by a dam on the Black River at County Road 681. The dam was removed for safety reasons and has not been replaced to date. Background Sediments in the former mill pond were contaminated by discharges from a nearby facility, Du-Wel, Bangor. The Du-Wel, Bangor facility discharged treated wastewater under a NPDES permit issued by the Surface Water Quality Division (SWQD) of the MDEQ. PCBs and various metals, including chromium, are present in sediments at levels of concern. Historical, non-permitted releases have contributed to the documented fish kills and Fish Consumption Advisories issued for the Black River at the site. Administrative History This is a state lead site. A Remedial Investigation and Feasibility Study have been completed by Du-Wel. Negotiations are currently underway with the potentially liable party to fund an escrow account that would cover at least part of the clean-up. The village of Bangor would like to refill the mill pond to create recreational opportunities at the site. If this action is funded, the site should be remediated by December, 1998. Amount of Contaminated Sediments
Project Status Sediment removal will be started and completed within 1998. Total Cost It is unlikely that proposed escrowed funds will cover the cost of remedial activities at the site. $1,000,000 in state funds may be needed to complete remedial activities, including excavation, transportation, disposal of contaminated sediments and confirmatory sampling for future site closure. St. Mary's River - Cannelton Industries
Location The St. Mary's River is the 70 mile connecting channel between lakes Superior and Huron. The Area of Concern extends from the head of the river at Whitefish Bay (Point Iroquois) downstream through St. Joseph Channel to Humbug Point on the Ontario side and to the outlet of Lake Munuscong at Point aux Frenes on the Michigan side. The Cannelton Industries, Inc., site covers 75 acres along the south bank of the St. Mary's River about 1.5 miles west of the downtown area of Sault Sainte Marie, Chippewa County, Michigan. Background Starting in 1900, the Northwestern Leather Company manufactured leather products on the site, dumping tannery wastes on 5 acres located in the 100-year floodplain of the St. Mary's River. The waste was disposed of to a depth of 6 to 8 feet and left uncovered. An estimated 10,000 yds3 were disposed of, as observed from the depth of wastes along the bank and the area void of vegetation. In 1954-55, Fibron Limestone Co. (a subsidiary of Algoma Steel Corp., Ltd., of Canada) purchased the 75 acres. Subsequently, the property was transferred to Cannelton Industries, Inc., another Algoma subsidiary. The property was intended for construction of a manufacturing plant that was never built. Algoma dismantled various structures that were considered hazardous. The site is now idle. The Algoma Slip sediments are contaminated mostly with metals and PAHs. In addition, sediments are contaminated with various heavy metals, oil and grease, PCBs, and PAHs in local areas along the Ontario shoreline, the north shore of Sugar Island, in Little Lake George and in Lake George, all downstream of Ontario point source discharges. Communities of benthic organisms are impaired along the Ontario shoreline downstream of industrial and municipal discharges. Administrative History In 1986, Algoma Steel agreed informally with the State to construct (1) a wall along the shore of the St. Mary's River to prevent wave and ice action from removing solid material from the site and (2) an impermeable clay cap to prevent erosion and prohibit rainwater from infiltrating the site. In the spring of 1989, under a Consent Order with U.S. EPA, Algoma Steel installed a sprinkler system as a temporary measure in a 2-acre barren zone with a history of fires. In November 1989, Algoma Steel completed a wall to control erosion along the shoreline of the barren zone. The remediation efforts are now being conducted under a Superfund Emergency Removal Action. In 1992, a ROD was signed which called for the excavation and dredging of tannery waste, contaminated soils and sediments. Project Status New information collected in the pre-design studies indicate that the measures called for in the 1992 ROD are not necessary. Soil leaching has been minimized and sediment toxicity and bioaccumulation studies do not show contaminated levels high enough to threaten aquatic organisms. USEPA and MDEQ have agreed that the majority of sediments can be managed in place, which will limit dredging and lower costs. Cost The entire remediaton project for both the land based and sediment activities for the new plan will cost about $5,500,000. Trenton Channel
Location The Detroit River AOC is part of the international boundary between the United States and Canada. This 32 mile long channel conveys the flow from Lake Saint Clair and the upper Great Lakes to Lake Erie. Over 700 square miles of land in both Michigan and Ontario drains directly to the Detroit River or one of its tributaries. The Rouge River, a Michigan tributary to the Detroit River, is listed as a separate AOC. Background The known causes of the impairments to the channel include urban and industrial development in the watershed, which has led to the destruction of over 95% of the Detroit River's wetland habitat since the early 1900's. CSOs and municipal and industrial discharges continue to be point sources of contaminants within the AOC. Storm water run off, the tributaries, and upstream inputs from Lake Saint Clair are also contaminant sources. The magnitude of the contributions from air deposition and the resuspension of contaminated sediments are currently under study. Project Status The Trenton Channel Project has been initiated to characterize the sediments in the Trenton Channel, develop a fate and transport model for mercury and PCBs and evaluate remedial technologies for Trenton Channel sediments. The project is funded by the USEPA and MDEQ. Public comment is currently being sought on a proposed remediation of contaminated sediments at the Black Lagoon site along the Trenton Channel. The Black Lagoon project is slated for completion in late 1998. Amount of Contaminated Sediment
St. Louis River - Interlake Duluth Tar Site
Location The Interlake Duluth Tar Site is within the St. Louis River AOC. The St. Louis River flows from Minnesota into Lake Superior, with its last 23 miles forming part of the Minnesota and Wisconsin border. Background Historically, industrial facilities and development have been located along the river, in particular steel manufacturing, iron manufacturing and coal tar refining. The PRP involved with the site is Beazer East, Inc. Site investigations found VOCs, heavy metals, iron and mercury of concern in the Interlake sediments. Project Status The Minnesota Pollution Control Agency (MPCA) expects to choose a remedial option during the Spring of 1998 and begin remediation work in 1999. Iroquois Gas and Westwood Pharmaceutical
Location The Iroquois Gas - Westwood Pharmaceutical Hazardous Waste Site is located in Erie County, in the City of Buffalo, New York. The site is bounded by Dart Street on the east, Buffalo Structural Steel on the north, Scajaquada Creek on the west and a residential area to the south. Scajaquada Creek flows into the Niagara River just north of Lake Erie. Background This site was used for approximately the first half of the century to manufacture gas. Iroquois, which became National Fuel Gas Distribution Corporation, used the site for gas production and storage from 1925 until the 1960's. The area was sold to Westwood Pharmaceuticals, Inc. in 1972. Westwood began to build a warehouse in the southwest corner of the property in 1985. During construction, water and soil contamination was discovered. The Remedial Investigation determined that the site soil was contaminated with PAHs, BTEX chemicals (benzene, toluene, ethylbenzene and xylene), lead and cyanide. The ground water, which flows towards Scajaquada Creek, is mainly contaminated with PAHs and BTEX. The RI also concluded that 7,350 gallons per day of ground water was discharging into the creek and estimated amount of non-aqueous phase liquids entering the creek was 440 lbs/year. The creek sediments are contaminated with the same pollutants as found in the soil and ground water at the site. Administrative History Under a State Consent Order, the RI was completed in June 1993. In March of 1994, NYSDEC issued a ROD which described the remedial actions. In addition to the remediation of the land based site, the ROD also outlined a plan to excavate the contaminated sediments in Scajaquada Creek and to restore the creek channel to background conditions. Amount of Contaminated Sediments
Project Status For the remediation process, Westwood is responsible for the main plant area and National Fuel Gas Distribution Corporation is responsible for Scajaquada Creek. The main plant area is expected to be completed by September 1997. The creek remediation is currently in the design stage and should be completed by the end of the calendar year. Dredging will be done in 1998. Total Cost The entire remediation project has cost $2,100,000 to date and is expected to incur costs of approximately $5,150,000 in the future. Of the total amount, $250,000 was or will be provided by the state. St. Lawrence River - Reynolds Metals Site
Location Reynolds Metals Company (RMC) owns and operates an aluminum reduction plant in the Town of Massena, New York. The facility is located on 112 acres of land near the St. Lawrence River within the Massena AOC. Background The Reynolds facility manufacturers aluminum ingots. Waste materials were historically land filled, spilled, leaked, and otherwise released into the area contaminating the soils, sediments, groundwater, surface water and air. The major pollutant of concern has been PCBs, although there were also cyanides, fluorides, and dioxin/di-benzofurans released. Contaminated areas on the site relating to sediments include:
Administrative History Although this site is not on the National Priorities list, USEPA is responsible for the cleanup of the St. Lawrence River portion of the contamination. NYSDEC is the lead agency on the soil remediation. The river cleanup ROD was signed in September of 1993. This ROD calls for excavating 7 acres of sediments from wetlands and 1.5 acres of sediments from potliner storage pad. The contaminated material will be shipped off site for disposal. Amount of Contaminated Sediments
Project Status Dredging of the contaminated sediments is expected to occur in 1998. Total Cost The estimated cost for the St. Lawrence River sediment remediation is $57,000,000. This does not include the costs of the land-based portion of the project. Ashtabula River and Harbor
Location The Ashtabula River flows through northeastern Ohio and empties into Lake Erie at Ashtabula Harbor in the city of Ashtabula. Ashtabula is located between Cleveland, Ohio and Erie, Pennsylvania. The Ashtabula River has been declared an AOC by the IJC. The AOC area consists of the lower 2 miles of the river, Fields Brook and the nearshore Lake Erie areas. The Lower River and Harbor are being addressed via a comprehensive public and private partnership with USEPA, OEPA, USACE, USFWS, industry and the public. However, The Fields Brook Site is being remediated separately under a Superfund Action. Background Various point and nonpoint industrial sources are believed to have contaminated sediments in the river with a variety of organic and heavy metal pollutants, with the main contaminate of concern being PCBs. Sediment contaminants have transferred to fish, affected habitat quality and restricted lower Ashtabula River commercial and industrial use. A fish advisory is in effect resulting from mercury and PCB contamination. Amount of Contaminated Sediments
Project Status The Partnership's proposed plan and Environmental Impact Statement for lower river and harbor sediment remediation project is currently in draft form and is scheduled for release by the end of 1997. The EIS includes various remediation alternatives, selected sites for the CDF, estimated costs and potential cost distribution between industry and government. Site remediation is expected to begin in 2000 or 2001. Ashtabula Fields Brook Superfund Site
Location The industrial development on Fields Brook is approximately 1.5 miles upstream of the confluence with the Ashtabula River. The Fields Brook site is part of the Ashtabula Area of Concern. The Fields Brook remediation project is separate from the Ashtabula River and Harbor remediation project. Fields Brook drains a 6-square-mile area in the city, township and county of Ashtabula, in northeastern Ohio. The main channel is 3.9 miles long and begins at Cook Road, just south of the Penn Central Railroad tracks. From this point, Fields Brook flows northwest to Middle Road, then west to its confluence with the Ashtabula River. From Cook Road downstream to State Highway 11, Fields Brook flows through an industrialized area. Background Analysis of fish tissue caught in Fields Brook and the Ashtabula River prior to 1982 indicated the presence of chlorinated organic compounds. A health advisory was issued on March 1, 1983, recommending that people not eat fish in a 2-mile reach of the Ashtabula River. Due to the possibility of direct contact with the sediment, movement of the contaminated sediment into the Ashtabula River and the possibility of uncontrolled releases of hazardous materials from the sediment entering the water supply of the City of Ashtabula, Fields Brook was added to the NPL by USEPA in August, 1983. Current Status The Fields Brook Superfund remediation project is still in the planning stage. Because the Fields Brook site is so large, USEPA divided the site into four work units, three of which are called "Operable Units."
Design remediation work for Fields Brook is expected to continue through 1998. It is anticipated that remediation work and construction of an on site landfill will begin in 1999. The final unit is the Ashtabula Public/Private Partnership, which is examining remediation work in the Ashtabula AOC, as described in the prior section. Total Cost The tributary remediation project is expected to cost between $5,000,000 to $6,000,000. Fox River
Location The Fox River is one of the IJC designated Areas of Concern. The study area is a 39-mile stretch of the Fox River extending from Lake Winnebago to Green Bay. The flow from the Fox River is a contributing source to the Green Bay Estuary in Lake Michigan, Green Bay, Wisconsin. Background USEPA, WDNR and other governmental and private agencies conducted studies of the Fox River from 1989 to 1992. These studies concluded that the principal contaminants of concern within the Fox River are PCBs and mercury. Of the potentially 34 contaminated sites along the river, the most detailed sediment sampling and contamination delineation has been conducted at Deposit POG and Deposit N. Additional detailed sampling and contamination delineation is currently underway at a third location, Hot Spot 56/57. Administrative History The USEPA is considering proposing the Fox River for Superfund NPL listing. The U.S. Fish and Wildlife Service is conducting a Natural Resource Damage Assessment on the river and bay and the WDNR is working to implement a cooperative agreement with the Fox River PRPs. Amount of Contaminated Sediments
Project Status Several industries have agreed to voluntarily conduct a demonstration project in the lower part of the river (Hot Spot 56/57) and Wisconsin has taken the lead on the upper river site (Deposit N). Both remediation projects are expected to be completed in 1998. The Deposit N remediation project is expected to cost between $2-3,000,000. Manitowoc River Basin - Hayton Mill Pond
Location Hayton Mill Pond is located in the northeast section of the City of New Holstein, Wisconsin. Background WDNR completed a remedial investigation over the past five years of this site. Results of the investigation indicate that the primary source area is a system of drainage ditches in the Northeast Section of the City of New Holstein. Water flows from the drainage ditches through Pine and Jordan creeks to Hayton Mill Pond, a man-made pond formed by the construction of the Hayton Mill Pond Dam. PCB contamination has migrated from the drainage ditches downstream to Hayton Mill Pond which serves as a sedimentation basin for the contaminated sediments. PCB concentrations in the Mill Pond average approximately 2-3 ppm. Fish tissue PCB concentrations in Mill Pond have exceeded 75 ppm. Tecumseh Products, Inc., is voluntarily participating in an investigation of the site. Amount of Contaminated Sediments
Project Status The WDNR is attempting to build relationships between local, state, and federal partners to undertake an estimated $800,000 remediation of the drainage ditch sediment. Local partners have provided small amounts of funding to date to finance the remedial investigation. GLNPO has agreed to provide $250,000 in grant funding for the remediation provided that an agreement can be reached the PRPs to provide the additional funding. WDNR is pursuing a cooperative rather than an enforcement-oriented approach in hopes of completing the remediation in a more timely and cost effective manner. Total Cost Total site remediation costs are estimated at $10,000,000. Little Menomonee River - Moss-American Site
Location The Moss-American site includes the former location of the Moss-American creosoteing facility, approximately 100-150 yards west of the Little Menomonee River, approximately .5 miles of the Little Menomonee River downstream from the facility, and the adjacent floodplain soils. It is located in the northwestern section of the city of Milwaukee, Wisconsin. The Little Menomonee River is a tributary to the Menomonee River and its waters eventually flow through the Milwaukee AOC. Background From 1921 until 1967, the wood preserving facility on this site used creosote in their processes. The facility discharged their wastes to settling ponds that ultimately released into the Little Menomonee River. The soils and sediments in the settling ponds and river were contaminated with creosote during this time. The original facility was purchased by Kerr-McGee in 1963 and became Moss-American. The site was renamed in 1974 to Kerr-McGee Chemical CorporationForest Products Division. Administrative History In 1971, Moss-American diverted its process water discharge from the river to the Milwaukee sanitary sewerage system. Also in 1971, WDNR ordered Kerr-McGee to clean eight settling ponds and dredge 1,700 feet of the river after creosote contamination was discovered. The settling ponds were filled with clean soil, the discharge pipe to the river was removed and a twelve foot deep underground clay retaining wall constructed between the ponds and the river. In 1973, USEPA financed the dredging of approximately 5,000 feet of the river, storing most of the creosote contaminated sediments in an onsite landfill. The facility closed in 1976. Milwaukee County reached a settlement with Kerr-McGee after the facility closed in which the county received a major portion of the property as payment for the dredging of the river. This land was converted into a park corridor along the river. However, sampling in the 1970's and 1980's by USEPA and other agencies indicated high levels of creosote contamination remaining in the soils and sediments. Contaminants detected in the sediments were primarily carcinogenic polynuclear aromatic hydrocarbons (CPAHs), similar to the contamination found in the soils. Sediment contamination was on average 18 ppm CPAHs. These sediments were found distributed throughout the five mile reach of the river between the site and its confluence with the Menomonee River. The site was placed on the NPL list pursuant to CERCLA. The RI/FS was therefore funded by the Superfund program and was completed in May 1990. The ROD for the site was signed on September 27, 1990. Amount of Contaminated Sediments
Project Status Pre-design study conducted in 1994 indicated the presence of extractable quantities of free- product creosote at a depth of approximately 10 feet below ground surface under one acre of the site. In 1995, following design approval by USEPA, remedial actions began with the start-up of a free-product recovery system. To date, approximately 4,100 gallons of free- product creosote have been recovered. Over the past several months, Kerr-McGee, WDNR and USEPA have engaged in discussions concerning whether it would be desirable to make certain changes in the way the remedy is undertaken. In April 1997, the agencies concurred on an Explanation of Significant Differences that would allow Kerr-McGee a trial period to conduct groundwater remediation by an in-situ funnel and gate approach. The parties have also discussed whether it might be advantageous to allow wet dredging and/or dry excavation approaches to sediment management options which could be selected in addition to the original approach of river reroute. If such an approach may have merit, USEPA would prepare a ROD amendment concerning this topic and solicit public comment beginning in early 1998. Total Cost Remediation was estimated to exceed $25,000,000. Contributors
For additional copies of this document, please contact:
Mr. Lawrence Brail, ADS [contractor] |
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