An Analysis of State Superfund Programs

Total Page:16

File Type:pdf, Size:1020Kb

An Analysis of State Superfund Programs ENVIRONMENTAL LAW INSTITUTE AN ANALYSIS OF STATE SUPERFUND PROGRAMS 50-State Study, 2001 Update November 2002 AN ANALYSIS OF STATE SUPERFUND PROGRAMS 50-State Study, 2001 Update Environmental Law Institute® Copyright© 2002 An Analysis of State Superfund Programs: 50-State Study, 2001 Update Copyright© 2002 Environmental Law Instititute®, Washington, DC. All rights reserved. ISBN No. 1-58576-049-8. ELI Project No. 981621 An electronic retrievable copy (PDF file) may be obtained for no cost from the Environmental Law Institute Web site <www.eli.org>, click on “Publications” then “2002 Research Reports” to locate the file. [Note: ELI Terms of Use will apply and are available on site.] (Environmental Law Institute®, The Environmental Forum®, and ELR® —the Environmental Law Reporter® are registered trademarks of the Environmental Law Institute.) ACKNOWLEDGEMENTS This report was prepared by the Environmental Law Institute (ELI) with funding from the U.S. Environmental Protection Agency (U.S. EPA) under Assistance Agreement ID No. CR-822795-01. It does not represent the views of the U.S. EPA and no official endorsement should be inferred. Environmental Law Institute staff contributing to this report were Margaret Filbey, Dorigen Fried, Samantha Klein, James McElfish, Kelly Mott, John Pendergrass, Kapena Pflum, and Elizabeth Seeger. Michael Bellot and Susan Sladek from U.S. EPA also contributed to this report. The assistance of state program officials was essential to this report and is gratefully acknowledged. This report is the seventh in a series of ELI studies of state superfund programs beginning in 1989, the first four of which were published by U.S. EPA. TABLE OF CONTENTS Executive Summary.....................................................................................................7 Acronyms..............................................................................................................................10 . Chapter I: Introduction...............................................................................................................................11 Chapter II: State “Superfund” Programs................................................................................................13 A. Overview of Cleanup Activities and Capabilities.....................................................................13 B. Statutory Authorities..................................................................................................................14 C. Hazardous Substances Sites..........................................................................................................15 D. Program Organization.................................................................................................................17 E. Funds.....................................................................................................................................19 F. Cleanup Policies..........................................................................................................28 G. Public Participation.................................................................................................................30 H. Enforcement................................................................................................................................32 I. Voluntary Cleanup Programs.........................................................................................................37 J. Brownfields............................................................................................................................41 Chapter III: Long-term Stewardship............................................................................................................45 A. Staffing and Funding.................................................................................................................45 B. Institutional Controls...................................................................................................................46 C. Reopeners....................................................................................................................................48 D. Summary.....................................................................................................................................49 Chapter IV: State Program Tables................................................................................................................51 Table IV-1: Overview of State Programs............................................................................................51 Table IV-2: Statutory Authorities and Provisions.............................................................................54 Table IV-3: Hazardous Sites.........................................................................................................60 Table IV-4: Actions Taken at Non-NPL Sites..................................................................................63 Table IV-5: Program Organization..................................................................................................66 Table IV-6: Program Administration and Staff Funding Sources...................................................71 Table IV-7: Program Administration and Staff Funding Sources VCP/Brownfields Program...........................................................................................74 Table IV-8: State Cleanup Funds.................................................................................................77 Table IV-9: Expenditures and Obligations from State Cleanup Funds...............................................82 Table IV-10: Sources of State Cleanup Funds...................................................................................87 Table IV-11: Uses of State Cleanup Funds.........................................................................................92 Table IV-12: State Cleanup Policies and Criteria..............................................................................97 Table IV-13: Public Participation..................................................................................................100 Table IV-14: Liability Standards................................................................................................103 Table IV-15: Penalities and Damages Available Under State Superfund Statutes..............................106 Table IV-16: Voluntary Cleanup Programs.....................................................................................109 Table IV-17: Brownfields Programs............................................................................................115 Table IV-18: Brownfields Sites......................................................................................................119 Table IV-19: Long-term Stewardship Programs.........................................................................122 Table IV-20: Long-term Stewardship Staffing and Tracking..........................................................125 Table IV-21: Institutional Controls...........................................................................................128 6 SUPERFUND Chapter V: State Summaries....................................................................................................................133 Region 1.............................................................................................................................133 Region 2.................................................................................................................................150 Region 3.................................................................................................................................159 Region 4...................................................................................................................................175 Region 5.........................................................................................................................................197 Region 6.......................................................................................................................................215 Region 7........................................................................................................................................231 Region 8.........................................................................................................................................241 Region 9.........................................................................................................................................257 Region 10.......................................................................................................................................269 Appendix:.........................................................................................................................280 Executive Summary 7 EXECUTIVE SUMMARY tates are in the process of cleaning up thousands of sites that are not on the National Priorities List (NPL) but are contaminated with hazardous substances. Because these sites are not on the NPL, they are not eligible for Scleanup funding under the federal Superfund program. These non-NPL cleanups are either paid for by the states, by responsible parties, or by volunteers such as developers or prospective purchasers who want to put the site to a new use. In fiscal year 2000 (FY00), states completed cleanups at more than 4,500 non-NPL sites, with slightly fewer than half of those being completed under
Recommended publications
  • RESPONSE to ENVIRONMENTAL CONCERNS PERTAINING to the HOUGHTON TRANSFER STATION and HOUGHTON CLOSED LANDFILL KING COUNTY SOLID WASTE DIVISION July 2021
    RESPONSE TO ENVIRONMENTAL CONCERNS PERTAINING TO THE HOUGHTON TRANSFER STATION AND HOUGHTON CLOSED LANDFILL KING COUNTY SOLID WASTE DIVISION July 2021 1. Concern: The Houghton Closed Landfill and Houghton Transfer Station are “Superfund sites.” Response: Neither site is designated as a Superfund site. A May 14, 2021 email from Calvin J. Terada, Director of the Superfund and Emergency Management Division of the U.S. Environmental Protection Agency – Region 10 to Christie True, Director of the King County Natural Resources and Parks Department, confirmed that neither facility is a Superfund site: From: Terada, Calvin Sent: Friday, May 14, 2021 8:44 AM To: True, Christie Cc: Opalski, Dan Subject: RE: ECHO report for Houghton Transfer Station Ms. True, My name is Calvin Terada and I am the Director of the Superfund and Emergency Management Division and Dan’s colleague at EPA Region 10 in the Seattle Regional Office. Dan forwarded me your message and asked me to see if there is anything that I can do to assist you with you with your research effort. After receiving the forwarded message, I checked EPA’s publicly available database called Superfund Enterprise Management System (SEMS) in Envirofacts https://enviro.epa.gov/ and also asked our data coordinator to confirm my findings. As you have requested, we can confirm that the below site is not a site on EPA’s National Priorities List (NPL), aka Superfund site. We also could not find any information related to the Houghton Landfill and so we can assume that this site is also not on the NPL. We did find information about an EPA action that took place at the site and listed the below information for your reference.
    [Show full text]
  • National Historic Preservation Act Section 106 Review Under the Comprehensive Environmental Response, Compensation, and Liability Act
    National Historic Preservation Act Section 106 Review Under the Comprehensive Environmental Response, Compensation, and Liability Act Earl Liverman, US EPA R10 On-Scene Coordinator (Ret.) 1-1 Overview ♦ Course provides participants with an overview of the National Historic Preservation Act (NHPA) and Section 106 requirements under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) ♦ Topics covered: o Overview of the NHPA o NHPA under CERCLA o Pre-Incident Planning and Emergency Response Under Section 106 o Comparison of Key Elements of the Section 106 Process under NHPA and CERCLA o Section 106 Process: Case Studies Under CERCLA o Summary: Compliance with Section 106 Under CERCLA 1-2 I. Overview of the National Historic Preservation Act 1-3 National Historic Preservation Act ♦ Environmental review process initiated with passage of the 1966 National Historic Preservation Act (NHPA), as amended (P.L. 89-665; 80 Stat. 915; 16 U.S.C. 470) ♦ Section 106 requires federal agencies to: » Take into account effects of undertakings on historic properties » Provide the Advisory Council on Historic Preservation (ACHP) with a reasonable opportunity to comment » Consult with State Historic Preservation and Tribal Historic Preservation Offices, Indian tribes, and Native Hawaiian Organizations 1-4 Overview of the Section 106 Review Process NHPA applies to your project if your project constitutes an undertaking and will have a potential effect on a property that is eligible for or included in the National Register of Historic Places Initiation of Section 106 Process 36 CFR § 800.3 Identification of Historic Properties 36 CFR § 800.4 Assessment of Adverse Effects 36 CFR § 800.5 Resolution of Adverse Effects 36 CFR § 800.6 1-5 Responsibility for Compliance with Section 106 ♦ Responsibility for Section 106 compliance lies with the federal agency funding the project or action [36 C.F.R.
    [Show full text]
  • This Is Superfund
    This is Superfund A Community Guide to EPA’s Superfund Program IF THERE IS A SUPERFUND SITE in your neighborhood, you are probably wondering, “what will happen?” and, “what can I do?” This brochure will give you a better understanding of the Superfund process and ways you and your community can be involved, including important topics such as: ► What is Superfund? ► Discovering Superfund Sites ► Taking Action to Clean Up Polluted Sites ► Responsibility for Superfund Site Cleanup ► Getting Involved: You and Your Community ► The Superfund Process ► Making each Superfund Cleanup “Greener” ► Maintaining the Site Cleanup Over the Long­Term ► Deleting a Site from the National Priorities List Valley of the Drums, KY 1979 Love Canal, NY 1978 2 What is Superfund? For a variety of reasons, hazardous commercial and industrial wastes have been mismanaged and may pose unacceptable risks to human health and the environment. This waste was dumped on the ground or in waterways, left out in the open, or otherwise improperly managed. As a result, thousands of hazardous waste sites were created throughout the United States. These hazardous waste sites commonly include manufacturing facilities, processing plants, landfills and mining sites. In 1980, Congress established the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended, in response to growing concerns over the health and environmental risks posed by hazardous waste sites. This law was enacted in the wake of the discovery of toxic waste dumps such as Love Canal and Valley of the Drums in the 1970s. CERCLA is informally called Superfund. The Superfund program is administered by EPA in cooperation with state and tribal governments.
    [Show full text]
  • A Citizen's Guide to Using Federal Environmental Laws to Secure
    A Citizen’s Guide to Using Federal Environmental Laws to Secure Environmental Justice Copyright © 2002 Environmental Law Institute®, Washington, DC. All rights reserved. ISBN No. 1-58576-033-1. ELI Project No. 981624. An electronically retrievable copy (PDF file) of this report may be obtained for no cost from the Environmental Law Institute web site <www.eli.org>, click on “Publications” then “2002 Research Reports” to locate the file. [Note: ELI Terms of Use will apply and are available on site.] (Environmental Law Institute®, The Environmental Forum®, and ELR® – The Environmental Law Reporter® are registered trademarks of the Environmental Law Institute.) acknowledgement This project was supported by the Office of Environmental Justice of the U.S. Environmental Protection Agency under Assistance Agreement No. CR82675501. The views expressed herein should not be attributed to EPA nor should any official endorsement be inferred. table of contents Chapter 1. Introduction to Environmental Laws and Available Resources ...............................35 Environmental Justice Funding and Other Assistance for Public Participation. ..35 Other Grants . ......................... ......36 Introduction to Environmental Justice Issues.............1 Program Funding ..............................36 How Environmental Laws Can Help You to Protect Your Community ...............................3 How This Handbook Can Help You to Use Appendix A - Summary Descriptions of Selected Environmental Laws to Your Advantage...............4 Environmental Statutes..........................39 How This Handbook Is Organized, and What It Covers . 5 What This Handbook Does Not Cover.................6 Appendix B - Overview of Additional U.S. EPA Community Grant Programs .....................83 Chapter 2. Understanding the Players and the Laws Appendix C - Selected Other Environmental Justice Resources ...............................87 Identifying the Players..............................9 The U.S.
    [Show full text]
  • Superfund: It's Time for Repeal After a Decade of Failure
    UCLA UCLA Journal of Environmental Law and Policy Title Superfund: It's Time for Repeal after a Decade of Failure Permalink https://escholarship.org/uc/item/8jg867n2 Journal UCLA Journal of Environmental Law and Policy, 12(1) Author McGee, Robert W. Publication Date 1993 DOI 10.5070/L5121018815 Peer reviewed eScholarship.org Powered by the California Digital Library University of California Superfund: It's Time for Repeal After a Decade of Failure Robert W. McGee* I. INTRODUCTION The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA),1 also known as Superfund, was passed more than a decade ago.2 After that much time, there is more than enough evidence to evaluate whether Superfund has been effective in achieving its purpose: cleaning the environment.3 The evidence suggests that Superfund not only did not accomplish its task but it also might have made things worse in a number of ways. This Essay, in part II, enumer- ates the problems associated with Superfund. Part III argues that Superfund is beyond repair and should be repealed - the sooner the better. It then continues by suggesting what should replace Superfund. * Robert W. McGee is a professor at the W. Paul Stillman School of Business, Seton Hall University in South Orange, New Jersey. He has authored more than 300 articles and reviews and has written or edited more than 30 books and monographs. The author would like to thank Joseph Wu and Vivian Lugo for their research assistance. 1. Pub. L. No. 96-510, 94 Stat. 2767 (1980) (codified at 42 U.S.C.
    [Show full text]
  • Hello APES Students, I Look Forward to Meeting You All in September!! In
    Hello APES students, I look forward to meeting you all in September!! In the meantime, I have put together a few things for you to help you prepare for our class and most of all, to get you out into the environment and explore. Your summer work will make up your first project grade and quiz grade for the semester and will be due on the first Friday of school (even if we don’t have class)! Feel free to email me with any questions at [email protected] Mrs. Mullane Assessment: (25 points) On the second day of class (Thursday or Friday) we are back at school, there will be a quiz covering part 2, environmental Laws. Part I: Ecology Field Journal (50 points) In a composition notebook (you will use this for notes throughout the year) complete 10 journal entries. Each entry must follow the format below and you must include the following topics: Each of the 10 entries must (have): Fill at least one page of your notebook All information and pictures should be at least 1 inch away from the edge of the paper A minimum of one paragraph (5 sentence) description of what you observed One hand drawn and colored picture of what you observed, drawn on unlined paper and glued into the notebook I am not the best artist so I usually need to make notes on my pictures to make it more clear Quantitative data recorded: Date Time Location Name of topic covered (use descriptions from below) Weather (temp/ cloud cover/ precipitation) Length or relative size of drawing Topics to Cover: Humans interacting with nature (3 entries) Naturally occurring abiotic (non-living) object (2 entries) Producer (2 entries) Consumer (3 entries) non-human Part II: Laws (31 points) Review the information provided about some major environmental laws.
    [Show full text]
  • Superfund Laws
    Chapter VIII SUPERFUND LAWS In the aftermath of Love Canal and other revelations of the improper disposal of hazardous substances, the federal and state governments enacted the “Superfund” laws to address these problems. Generally these laws address remediation of spills and dumps, rather than regulation of current conduct, and hold parties liable to cleanup contamination resulting from activities that may have been legal. They have resulted in extensive litigation, widespread concerns about environmental liabilities, and expensive cleanups. A. CERCLA The federal Superfund law is entitled the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (“CERCLA”), 42 U.S.C. §9601, et seq. It was extensively amended by the Superfund Amendments and Reauthorization Act of 1986 (“SARA”), and further amendments were made in 2002 by the Small Business Liability Relief and Brownfields Revitalization Act. 1. Basic Scheme CERCLA provides a framework for the cleanup of the “release” or threatened release” of hazardous substances into the environment. EPA can take action to clean up hazardous substances using funds from the multi-billion dollar “Superfund” (raised by excise taxes on certain chemical feedstocks and crude oil), and then seek reimbursement from “responsible parties.” Alternatively, it can require responsible parties to clean up a site. “Hazardous substances” are defined to include hazardous wastes under RCRA, hazardous substances and toxic pollutants under Clean Water Act §§311(b)(2)(A) and 307(a), 33 U.S.C. 23 §§1321(b)(2)(A) and 1317(a), hazardous air pollutants under Clean Air Act §112, 42 U.S.C. §7412(a), any “imminently hazardous chemical substance or mixture” designated under Toxic Substances Control Act §7, 15 U.S.C.
    [Show full text]
  • A Community Guide to EPA's Superfund Program
    This is Superfund A Community Guide to EPA’s Superfund Program IF THERE IS A SUPERFUND SITE in your neighborhood, you are probably wondering, “what will happen?” and, “what can I do?” This brochure will give you a better understanding of the Superfund process and ways you and your community can be involved, including important topics such as: ► What is Superfund? ► Discovering Superfund Sites ► Taking Action to Clean Up Polluted Sites ► Responsibility for Superfund Site Cleanup ► Getting Involved: You and Your Community ► The Superfund Process ► Making each Superfund Cleanup “Greener” ► Maintaining the Site Cleanup Over the Long-Term ► Deleting a Site from the National Priorities List Valley of the Drums, KY 1979 Love Canal, NY 1978 2 What is Superfund? For a variety of reasons, hazardous commercial and industrial wastes have been mismanaged and may pose unacceptable risks to human health and the environment. This waste was dumped on the ground or in waterways, left out in the open, or otherwise improperly managed. As a result, thousands of hazardous waste sites were created throughout the United States. These hazardous waste sites commonly include manufacturing facilities, processing plants, landfills and mining sites. In 1980, Congress established the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended, in response to growing concerns over the health and environmental risks posed by hazardous waste sites. This law was enacted in the wake of the discovery of toxic waste dumps such as Love Canal and Valley of the Drums in the 1970s. CERCLA is informally called Superfund. The Superfund program is administered by EPA in cooperation with state and tribal governments.
    [Show full text]
  • GAO-21-555T, SUPERFUND: EPA Should Take Additional Actions To
    United States Government Accountability Office Testimony Before the Subcommittee on Environment and Climate Change, Committee on Energy and Commerce, House of Representatives For Release on Delivery Expected at 10:30 a.m. ET Thursday, May 13, 2021 SUPERFUND EPA Should Take Additional Actions to Manage Risks from Climate Change Effects Statement of J. Alfredo Gómez, Director, Natural Resources and Environment GAO-21-555T May 2021 SUPERFUND EPA Should Take Additional Actions to Manage Risks from Climate Change Effects Highlights of GAO-21-555T, a testimony before the Subcommittee on Environment and Climate Change, Committee on Energy and Commerce, House of Representatives Why GAO Did This Study What GAO Found Superfund is the principal federal In October 2019, GAO reported that available federal data on flooding, storm program for addressing sites surge, wildfires, and sea level rise suggested that about 60 percent (945 of contaminated with hazardous 1,571) of all nonfederal Superfund National Priorities List (NPL) sites—which substances. EPA administers the have serious hazardous contamination--are located in areas that may be program and lists some of the most impacted by these potential climate change effects (see figure). In 2019, GAO seriously contaminated sites—most of released an interactive map and dataset, available with its report (GAO-20-73). which are nonfederal—on the NPL. At those sites, EPA has recorded over Nonfederal NPL Sites Located in Areas That May Be Impacted by Flooding, Storm Surge, 500 contaminants, including arsenic Wildfires, or Sea Level Rise, as of 2019 and lead. Climate change may make some natural disasters more frequent or more intense, which may damage NPL sites and potentially release contaminants, according to the Fourth National Climate Assessment.
    [Show full text]
  • Scott Pruitt's Toxic Superfund Shell
    Scott Pruitt’s Toxic Superfund Shell Game How cronyism, budget cuts and secrecy threaten the health of millions of Americans More than 50 million Americans live within 3 miles of sites contaminated with toxic waste that has been dumped, left out in the open, or otherwise improperly managed. Living near these dangerous places has been linked to higher rates of cancer, birth defects, and rare diseases. Contamination can leech into the soil and seep into plumbing systems and waterways. Winds can carry contaminated dust particles into nearby neighborhoods. EPA’s Superfund program works to clean up the dangerous chemicals and compounds at these sites. EPA Administrator Scott Pruitt has promised to focus on Superfund, but he’s hobbling it instead. Addressing the Most Toxic Health Risks More than 1,300 “Superfund” sites are on a list of the most highly polluted properties in the nation - exposing millions of Americans to toxic chemicals. Sites include former industrial facilities, mines, landfills and dumps, dry cleaners and other locations contaminated by heavy metals like arsenic, lead and mercury, chemicals like benzene and asbestos, as well as radiation. Superfund sites also include places where disasters like oil and mercury spills and factory fires occurred. These areas threaten the public health, since more than 50 million Americans live within 3 miles of a Superfund site. Living close to a Superfund site has been linked to residents having higher rates of: cancer, birth defects, and rare disease. Communities beyond the sites can also be exposed when site hazards spread. o Polluted water can contaminate local waterways and utility systems o Contaminated soil can leech chemicals into drinking water and sediment o Hazardous dust particles can be carried by winds and spread toxics into air, land and water There are Superfund-affected communities who can no longer use local tap water for drinking or bathing.
    [Show full text]
  • Superfund Activities in the Environment and Natural Resources Division for Fiscal Years 2004 and 2005
    SUPERFUND ACTIVITIES IN THE ENVIRONMENT AND NATURAL RESOURCES DIVISION FOR FISCAL YEARS 2004 AND 2005 U.S. Department of Justice Office of the Inspector General Audit Division Audit Report 07-43 September 2007 SUPERFUND ACTIVITIES IN THE ENVIRONMENT AND NATURAL RESOURCES DIVISION FOR FISCAL YEARS 2004 AND 2005 EXECUTIVE SUMMARY The Comprehensive Environmental Response, Compensation and Liability Act of 1980 (known as CERCLA or Superfund), which was expanded by the Superfund Amendments and Reauthorization Act of 1986, established the Superfund program to clean up the nation’s worst hazardous waste sites.1 CERCLA seeks to make those responsible for the improper disposal of hazardous waste bear the costs for their actions. It also established the Hazardous Substance Superfund Trust Fund (Trust Fund) to finance clean up actions where a liable party cannot be found or the third party is incapable of paying clean up costs. The Trust Fund also pays for the Environmental Protection Agency’s (EPA) enforcement, management activities, and research and development. Executive Order 12580, issued January 23, 1987, gives the Attorney General responsibility for all Superfund litigation. Within the Department of Justice (DOJ), the Environment and Natural Resources Division (ENRD) was assigned to administer cases against those who violate CERCLA’s civil and criminal pollution-control laws. In fiscal year (FY) 1987, EPA entered into interagency agreements with ENRD and began reimbursing ENRD for its litigation costs. EPA authorized reimbursements to ENRD of $27.9 million for FY 2004 and $26.9 million for FY 2005 in accordance with EPA Interagency Agreements DW-15-93796801 and DW-15-92194601, respectively.
    [Show full text]
  • COURSE Risk Assessment Guidance for Superfund (RAGS) MODULE Orientation and Introduction TIME LIMIT 30 Minutes
    COURSE Risk Assessment Guidance for Superfund (RAGS) MODULE Orientation and Introduction TIME LIMIT 30 minutes MODULE GOALS At the completion of this module, students will be able to describe applicable legislation for U.S. EPA Superfund risk assessments, the development of specific guidance, and the risk assessment process. STUDENT PERFORMANCE OBJECTIVES (SPOs) 1. Describe the student requirements for the successful completion of this course. 2. Identify the goals and objectives for this course. ALSO APPLIES TO OTHER REMEDIATION SITES SUCH AS BROWNSFIELDS S-4 ERAGS Process STATE: Here is the 8-step process of the Ecological Risk Assessment Guidance for Superfund or ERAGS again. CLICK [Steps 1 and 2 are highlighted] STATE: Let’s start with the first two steps of ERAGS, Steps 1 and 2 which make up the Screening Level Ecological Risk Assessment or SLERA STATE: Steps 1 & 2 are represent an abbreviated consideration of each step of the complete Ecological Risk Assessment Framework. A SLERA is a simplified risk assessment that is conducted with limited data by assuming values for parameters for which data are lacking. Conservative assumptions regarding the receptors and the contaminants must be as protective as possible. A high degree of conservatism helps to reduce the likelihood that potentially significant risk is overlooked before an in depth evaluation is conducted. S-41 2. Briefly review the RI/FS process using slide a. Development of preliminary remedial goals/conceptual model, b. Conduct baseline risk assessment, c. Define PRGs based on risk assessment and ARARs, and d. Conduct risk evaluation of remedial activities. [click] State: Note that HHRA and ERA play equal roles in providing information in the baseline risk assessment.
    [Show full text]