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Gowanus Canal CAG Meeting
Tuesday, January 22, 2019
Mary Star of the Sea Senior Apartments, 41 1st Street


Doug Sarno opened the meeting at 6:35 p.m.

October meeting summary was approved. September summary still awaiting revisions from Marlene.

Project Updates

Christos Tsiamis, EPA Gowanus Canal Project Manager, presented the updates.

Happy to be here with you – there will be good tidings in terms of progress.

We have completed the 4th Street Basin pilot study, drawn the conclusions on how to proceed – which methods will be used to clean up the canal. Second, 95% design of the Fulton IRM Barrier – the barrier wall from the top of the canal to Union Street to prevent coal tar from coming into the canal and harming it. Completed the design and anticipate receiving 95% design by year end for 1st Street Turning Basin excavation. Right now from technical point of view by spring, we will be able to start the countdown of the clean up in months, not years.

The 4th Street Basin pilot project is complete and it is the first time in 150 years a portion of the canal has a clean bottom.

Two more things:

  • The New York City Department of Design and Construction is about to grant approval to proceed with two larger-than-present storm water basins at 9th Street within days or weeks, and those would alleviate flooding, and at point of discharge, the water into the canal there would be treated.
  • Happy to say all these objects that we fished out of the 4th Street Basin will be brought to Public Place – if they’re not already there – and from archaeologist reports, most of the materials are not of archaeological importance on a national level and not preservable for Superfund, but in conversing with the CAG, there is an interest in preserving it as an interest of the community. Tentatively, week of December 10 there will be a viewing by interested members of the CAG for those objects. Arrangements will have to be made by groups interested in obtaining or possessing those objects. Somewhere until the middle or end of January, they will be stored there and then have to be taken.

Brian Carr, EPA Site Attorney, noted that within the last month, the city has acquired the properties at the head of canal for the CSO storage tank. The design of a tank for the park is no longer required. The design for the clean up of the park is going to proceed. There should be schedules in the coming six months detailing how long the process will take, including the process and design of the temporary pool or pools. One of the benefits of the fact that the tank will not be in the park is that park clean up will happen faster, and happen in sections, so in the long run, the park will be out of commission for a shorter period of time, and the clean up of the park is a slightly secondary part to getting the Fulton Barrier wall constructed.

EPA Regional Administrator Pete Lopez

Pete Lopez is the Regional Administrator for EPA Region II, which includes New York, New Jersey, and Puerto Rico, and eight federally recognized Indian reservations. There is a team of dedicated folks to try to find the best response to legacy contamination as well as clean up CSOs.

[Full video of Administrator Lopez’s discussion with the CAG is available here.]

Administrator Lopez thanked the EPA Gowanus staff present: Natalie, Christos, Brian, Doug in Superfund, Elias, Chris Lyons, and Walter Mugdan, who has spent much of his life on sites like this in Region II. I forget the other location of where I have been here with Congresswoman Velázquez [that location was Wyckoff Gardens 11/16/2017]. Gratitude for the community, not an isolated group here. Acknowledges the city and groups – DCP and DEP – thanks to the PRP National Grid, with the New York State partners DEC and DOH. We are not just dealing with toxic remediation, but also the combined sewer overflows.

Acting EPA Administrator Andrew Wheeler visited the site recently – they witnessed the pilot in progress, he met with young people – saw what was living in there and checked water quality, good to see young people having an interest plus seeing cause and effect – we took note of the pilot. There was some issue with Whole Foods and showing off those banks and we want to make sure those sidewalls are secure as we move forward with the dredging.

Before this meeting, Pete Lopez briefly chatted with CAG members Marlene Donnelly and Linda Mariano about historic preservation, specifically of the Nevins Street façade of the Gowanus Station building. There are a number of options. Some of the recommendations are great and capture the building well. The EPA is not sure if there is a consensus on how to preserve it best, and if this preservation discussion is still open, the EPA wants to know what the CAG thinks, and then we make the recommendation to the city.

Parcels 1, 6, and 7 have been acquired – we put together additional support with Congresswoman Velázquez and Councilmember Levin, so these businesses can maintain contributions to New York City and the community. Recently DEP came to EPA and said they could replace tanks with a tunnel or series of tunnels – that is new on our desk and we’re reviewing it – what does it mean for construction, tunnel vs. tank. The EPA has asked the DEP Commissioner what the benefits of a tunnel over a tank are to the city. The EPA is more interested in hearing from community on this.

Questions and Answers

CAG: I think this is the second time I’ve heard the word tunnel and I’m not sure where it would go, how it would impact the proposed remediation at the end of the canal, are there any design plans submitted to give EPA an idea of what this would be?
EPA: Cursory review, we would look for more detail from them – my assumption is that it would be quite deep and used for water storage. Conceptually – it might give NYC the ability to shift water around and the ability to better manage water. The tunnels are much deeper than the canal. Large constructs capable of holding CSOs. We’re asking for more information from the City.

CAG: How much information on existing flushing tunnels is out there as the city originally planned it?
DEP: Fully reactivated in May 2014 and has been running since, about 215 million gallons from East River to Gowanus Canal.

CAG: The other existing tunnel should be Butler Street tunnel – at about 15 feet wide
DEP: It would be a newly constructed tunnel.

CAG: So late in the game about the container – after all the eminent domain talks – I hope it won’t delay the project.
EPA: As I try to problem-solve I weigh cost and benefits they may be quantitative numbers or more abstract quality-of-life measures. I ask my staff to give me the most objective read. What if any impact does it have on timeline, what if any additional environmental benefit occurs from this construct – the balance between those questions, what the costs and benefits are – not to delay a progression but be as thorough as we can.

CAG: This would be online storage, or would it be treated through the head house?
EPA: My understanding is it would be storage and slowly fed into filtration and then let out.

CAG: Two new 9th Street tunnels and then treatment, please elucidate.
EPA: Anything that discharges into the Canal has to be treated at 9th Street, there will be two points.

CAG: What kind of treatment?
EPA: A high-evel sewer along Third Avenue. Down at 9th Street we’re piloting oil/water separators similar to what is at 1st Street, and on the west side there will be absorption mats.

CAG: And floatables too?
EPA: Our concern was with the chemicals, but we think the separator incorporates everything.

CAG: Treating for bacteriological issues?
EPA: This is for stormwater, so it only has to work with water from the street – for times when they collect large amounts of water and that stormwater is combined with the sewer, that would be for that kind of thing.

CAG: If you don’t have the tanks – that leaves the area for the tanks there, would that be community space?
EPA: For instance, the properties for RH-34 were going to have a tank, and then the head house and the other 2/3rds of that space would be open space – our take is cursory and on a preliminary level. Head house must have pumps, and there would still be something above ground.
CAG: We should keep our eye on the additional space that might exist from that.

CAG: How can a tunnel be more efficient than the tanks – what are we talking about?
DEP: We have conceptually proposed a tunnel to the EPA at RH-34 parcel 6&7. There would be a construction shaft on that site to lower a tunnel boring machine and then through the OH-007 site to likely retrieve the tunnel boring machine. It would be somewhere between 125 to 155 feet below the surface to minimize the impact on property. The storage volume of the tunnel would be more than the two tanks and would have to be further evaluated. It would operate similarly to the tanks, with the two outfalls at RH-34 and OH-007, where it would be treated.
EPA: DEP Commissioner Sapienza said they would be back to discuss this with the CAG.

CAG: How could this not have impact on the clean up process – how could it not delay the clean up?
EPA: This is one of the questions EPA is going to be reviewing. How it would impact the schedule, what are the benefits to improve flood control? The EPA is looking into that, and what is the trade off for tunnel and tank, and what makes sense for this community? I want to understand all the pros and cons – NYC is proceeding with the work they are required to do – they’re no longer doing the parallel design of the park, but everything else is the same as what they are required.

CAG: This is as deep or deeper than the caissons at the feet of the tower of the Brooklyn Bridge – is this as deep as bedrock? You’re going to have groundwater flooding in the area, and a huge amount of earth. Where is that going – at that depth, this tunnel is ambitious – if it is not bedrock, you have muck closing in on people – I wonder at the wisdom of this plan after we’ve been hearing about the tanks for years.
EPA: I allow people to come up with ideas and listen in good faith.

CAG: One thing I point out to visitors to the area is that the path of least resistance is the viaduct and the Subway F/G train over the whole mess.
EPA: This is not bedrock – there would be contamination in some of the sediment.

CAG: Worth noting a CAG member, Jerry Armer, walked under the water tunnel. I want to go away from the tunnel and back to the 4th Street Basin – are we mandating that the debris is removed by barge or by truck?
EPA: Our preference and the community’s is to be done by barge, so we have to see what other work is happening to schedule that. We will keep you informed, we understand the wishes of the community.

CAG: At Thomas Greene Park, will the clean up most likely be by truck?
EPA: Will remove some soil there, but we expect it will largely be solidified in place.

CAG: First Street Basin debris removal will be done by barge?
EPA: There is a change there; NYC DDC says the construction will be done by the PRP group.

CAG: The Red Hook corollary, look to those ball fields – there is a wider view where EPA is involved where there’s an opportunity for synergy.

CAG: The idea of capturing more CSOs is a very good idea, whether that is done with this proposal or with tanks. Would be great to work with DEP.
EPA: Gets back to the gross trade -offs

CAG: Is this part of the future planning with more occupants in 8- to 10-story buildings?
EPA: I was a local elected official – fan of home rule – it is the local government’s authority – the office of City Planning is here, you can talk to them – EPA’s review of tunnel vs. tank – is there an additional environmental benefit – we would not focus on zoning.

CAG: Can DEP share some about their motivation for the tunnel over the tank?
DEP: To be perfectly honest, it came down to cost – we are considering several other tunnels across the city, like Flushing Bay. The costs of the tanks continued to increase, so the tunnels became more attractive, and additional benefits like scalability, construction impacts, etc., but it started with the cost.

CAG: Dr. Jean Holcomb did water analysis; are you aware of this work at NY Technical College?
EPA: We have not but we have been in contact with other academics on this matter.

CAG: One, when will the park timeline be developed? Two, who/how will decontamination happen after the canal? Three, what kind of support will exist for displaced or inconvenienced business?
EPA: 1) The timeline has not been worked out yet, but will be as we fine-tune the Order with National Grid and some with NYC. We don’t have a timeline yet. 2) The objects have been decontaminated in New Jersey, and stored in special containers, and would never put you at risk – rusty but decontaminated. 3) As with the businesses – a number of us were of the belief that there was more we could do to support. The Army Corps provides business support for sites that have to move because of EPA – who could play a role for loans, grants, we worked to put together a robust list of local and state agencies and federal agencies and brought them together, invited those businesses affected, and hoped that economic development interests would overlap, and recognize that no one agency may support or augment the existing process. This would maximize opportunities. Also, with Council Member Levin – SWBIDC, NYCEDC too – the degree to which Army Corps could help – I’m not a pollyanna, I don’t like to go on. We don’t take the relocation for granted, we’re frustrated when it has to happen, so how can we support the mom-and-pops, and give small businesses the ability to succeed? I was raised in the Catskills – there’s no one-way ticket as I saw with the flooding there.

CAG: Originally NYC said build the infrastructure on the acquired property because that would be less expensive. Christos then expressed that putting tanks so close to the bulkheads might create damage.
EPA: There are design issues – in fairness to the City – at RH-34, the Parks Commissioner is concerned that a generation of parks users wouldn’t have access to a park. It is almost certainly the case that the park will be back faster with the tanks not happening on the park site. The city has stated reasons as well, but you’re right, there are design challenges.

CAG: If we take the 1st Street Basin back in time – American Battlefield Protection Program – not just any battlefield site, America’s first battlefield – will you be preserving the battlefield site, and using the mandatory setbacks for battlefields? The exact footprint of the site is where the basin is.
EPA: That has not been addressed at any of our meetings. We want to learn more and would be interested in understanding the parameters – to the extent we do no harm there.
EPA: I put the restoration and preservation of the basin in there – this is happening because of the input of the community. We’re going to take it into account. We’re not going deeper than the original depth of the basin as it already existed. Things going deeper than that will not affect anything.
EPA: Look forward to guidance on that.

CAG: At what point do you have the drop-dead deadline? So at what point does EPA decide tanks or tunnels?
EPA: The relatively near future – whatever will be exacerbated – the City on their own can decide to make other tunnels apart from this.

EPA: What I left out is that in April we’re going to have 95% design of RTA-1 at the head of the canal, and that will start the clean up, so that’s part of the time constraint.

CAG: When will we see a draft of the Memorandum of Agreement (MOA), we haven’t seen one since June?
EPA: We got the State Historic Preservation Office’s feedback – I don’t know if I have the full consensus of the CAG, but I don’t know if there has been any full meeting of the CAG.

CAG: We did have a resolution saying save and preserve 238 Butler Street – specifically the comments to the June meeting. The vision of the MOA called for preserving a portion of the east side, and the whole front façade.
EPA: Would be happy to have a conversation about it.

CAG: Keeping the pieces in place – not moving them around.
EPA: Understood.

CAG: This MOA only treated the tank site – not the head of the canal.
EPA: We are working for the programmatic agreement, and hope to bring it to you ASAP – you’ll have it in a reasonable time.

CAG: We have an archaeology resolution about the 1st Street Basin looking at early industrial/revolutionary, mill times, and industrial times.
EPA: Those standards will be addressed and in the programmatic agreement – point well taken.

CAG: The amount of information being shared tonight is really useful – going forward in the Superfund process, as there is more and more information and things are speeding up, how can we be certain this dialogue continues?
EPA: This is the strength of the community engagement. I try not to pull their staff out of normal hours too often, you tell us the subject you like to talk about, and we’ll assemble a team to discuss it.

CAG: When the onus is on us to identify what we need, it changes what we’re able to discuss, what is best for us is when all the experts are here.
EPA: There has been a hiatus – we meet with folks outside these three hours. I have spent 36 years as a councilman, trustee, I view engagement at the community level as imperative. When I meet with my colleagues, we come from different walks of life and world views with the same goals. Sometimes our meetings last longer than folks might like – try to anticipate impacts and mitigation.
EPA: We have serious deliberation to any level of detail – we have been transparent and will continue the transparency. We’ve brought the PRPs, we’ve brought the city, and will continue in that manner.

CAG: If the whole building [at Nevins] cannot be saved, if there is no tank, moving everything 20 feet south and saving the building would be the preference.

CAG: When you make the decision of deciding whether tank or tunnel – we want to know the parameters and how you came to that conclusion, but we get bigger capacity, we want to know what that is, and I hope you give us the opportunity to review that conclusion in detail.
EPA: I’ve asked for an objective reading. I’ve asked my colleagues with opinions to put those aside. The constructs: time it takes to execute and the environmental benefits. Taxpayers, local officials, CAG – everyone will want to know. We will identify the pros and cons.

CAG: We want to know before that final decision.
EPA: Before a decision is made, we will be listening to you and engage with you and factor it in.

CAG: I want to underscore that we want to have the people from the EPA at our meetings. I really would like to live to see this canal clean. I hope nothing will delay the timeline that Christos has shared with us in the past. I want to know that every PRP is as cooperative as they can be.

CAG: $458 million Red Hook plus $50-odd million for the tunnel at Bergen and Degraw street – it has already been spent – nobody talks about it – we already paid for a huge tunnel under Butler street – why have millions been spent on infrastructure no one is using?
EPA: I don’t know but I’m not afraid to ask the owners of the tunnel – we’re not going to make something up – we’ll research and come back. The city has been a communicative partner – if you want to copy NYS DOH or DEC, you’re welcome to do that – ultimately, we want quality of life, peaceful surroundings, we all want that. We have a history of legacy contamination which was a history of development – growing up I was taught to leave a place better than when you found it. We all want to have this community better than we found it.

CAG: Community engagement – I head up the canoe club – a bunch of people come who are passively aware of this process – is there a way EPA can put up basic signage that says what is happening along the canal?
EPA: That sounds like fun! It doesn’t sound like a costly thing. When EPA pays for the clean up, we put up a sign. Here, the other PRPs are paying – someone else is paying, the participants would have to acknowledge that this is something the community wants – we can’t legally make or compel them, but if they are willing, which they very well could be – we can ask.
EPA: A lot of where we would put the signs would be on private property.

CAG: Beginning in grassroots – this CAG creates a unique body. We don’t have local community government, so we appreciate that this body exists, and that EPA spends time with us. We wish there were more organizations like this. The team has been transparent and open. This is a good working model. Yes, we need the support of someone like Doug to help manage.
EPA: Thanks for reinforcing that. I feel gratified, this is humbling work. I am honored to be here. My sense is my colleagues are happy to be part of this process

CAG: I think Brad’s idea of a stationary sign is terrific. I think a sign, but also what expects to be done and a timeline would be great.
EPA: Interpretive, clear communication, yes.

CAG: Maybe a line – who to contact if you have questions.
CAG: One or two signs, maybe on the Union Street Bridge and maybe on another bridge, I think that is a great idea.
EPA: This can be made to happen- we support it.

CAG: I created buttons and propaganda to help push along and get us nominated – purpose is to get to the community through whatever the purpose may be, so to me the signs are pointless when we as a CAG are supposed to be out there. Katia is not here, but 5,000 people read her blog. I’ve never trusted government, but the Region II team are on the top of my most honest list, as the most transparent group, and we have relied on them greatly.

Reporter: If you move forward with the tunnel, will there still be a need for the head house?
EPA: Yes

Reporter: Would there be any excess land after?
EPA: We only have a cursory understanding – we have to conceptualize – we have to put the tunnels underneath so I couldn’t say it would be wasted, heard one member use.
DEP: Yes, we will need the parcel for the head house.

Community Member: For the last two years we’ve heard so much convincing about how budgets were put in place, and this land and space was important. So at what point was this proposal changed?
EPA: We have heard it was sometime in the summer, but we have no way of monitoring or assessing impact. People are going to be reticent to change a horse midstream unless there was reason to do that. In terms of an engineering and design standpoint.

Community Member: So what’s the point of the CAG, if they aren’t part of that process? That is their whole purpose.
EPA: You can float an idea, but until you have the metes and bounds and help someone understand the translation of it, it doesn’t change anything. We don’t even know if the tunnel is viable or acceptable. Our recommendation is as the project is more viable, to present it to the CAG.

Community Member: We heard tonight one of the reasons was budget – you can’t all of a sudden change that.
EPA: We want a remedy that is going to be effective, we don’t ask what the budget is. The budget is a consequence for the best solution to protect public health and the environment. Tunnel or tank – is there the ability for more effective CSO capturing? What does it mean for effluent in water bodies – that might be worth looking at. For Sal and Lena, the question for property owners – what does it mean for them? Our understanding is that tunnel or tank, it means the same thing.

CAG: Will you present the information [on pros and cons of tunnel or tank]?
EPA: We’ll present it in the way best for the CAG (within reason), and they’ll be presenting to us too.

EPA, Pete Lopez: In closing, and you know this because you have my colleagues, this is an ongoing presentation. Say where the heck is Pete, and I’ll come back.


Committee Updates

Admin Committee

Motion to remove the CAG’s North Gowanus Visioning Group liaison.

There’s a proposal,, in a nutshell, to remove the CAG rep from the North Gowanus Visioning Group. Not a reflection on the community – straddles CAG business, Superfund business, glad there are so many people, it is not any kind of expression of disappointment in Peter Reich. When we met and talked about this, we talked about how it could be a mistake. This group of neighbors, this body gets together, so then that location is the intersection and all the related agencies meet and it’s the Superfund intersection. The last presentation DEP made they went other places – somehow CAG got flown over. Regardless, they made this presentation, and made an impassioned pleas to comment, and Peter said few if any people did, and I realized I was completely ill equipped to say anything about the CAG-related portion of the presentation – we didn’t have the ability to comment. After this business about tunnels and other things going on, I fear in the future, there will be more and more unrepresented things, and we’re doing ourselves a disservice by taking away things listening to our experts.

CB6 Liaison (Hildegaard Link): One of the things it seems like is that CB6 stuff does bypass CAG stuff. What I can do is that anything that comes through CB6 Land Use gets here. They did not share with the Gowanus CAG, so what I can do is make sure that communication comes through so everyone gets the communication. Anyone in the Gowanus area is part of CB6, and we know about it here at the CAG – the first step is to know that anything that happens at CB6 gets back here.

CAG Member: It is a both/and kind of approach – if we had asked weeks ago to have DEP come present things, they probably would have come. I see value when there are other entities. Some overlap or concentric circles – shouldn’t be an either/or, it should be a both/and.

A Community Board meeting is different than a CAG meeting, different than the North Gowanus Visioning, etc., and they often attract different people. This CAG is not as representative of the community as it should be, and there are parts of the clean up, and we’re hearing that and that’s part of our outreach and our responsibility.

We just passed resolutions to have them all here, so these concerns don’t seem as problematic.

At the same time there is a lot of redundancy. When you go to those meetings, there is a lot of overlap and repeats and some of those meetings aren’t accessible to those who work during the day. The Land Use Committee seems to have been absorbed in this. It would be nice that if it is a CAG business.

I don’t think that Peter is set up for a lot of success – it is impossible to represent the CAG and vice versa – whether it is through our representative/liaison we have to figure it out – did not ask him to do the right thing.

For the CB6 DEP meeting, we sent out notices, and maybe they didn’t make it to peoples’ inboxes. I was surprised there weren’t more CAG members at that meeting.

Long ago we decided that none of us speak independently for the CAG.

Peter is there as a liaison, and to keep us informed and let others know what the CAG is working on.

Tonight’s meeting was fantastic and productive. I am weeding out and not going to the North Gowanus Visioning meetings – I won’t support this motion – I do support Peter’s reporting back to us.

Doug Sarno noted that the CAG explicitly asked to have a liaison to the North Gowanus Visioning group. You were upset when the CAG didn’t have a liaison. Ben offered to create one. The CAG is designed to work together with other groups in the community. It is not supposed to do everything. It has its own things that are clearly tied to the Superfund cleanup.

EPA noted that it is responsive to the CAG and did not want to convolute the functions of the CAG with other groups. The CAG consensus and your voice are the resolution that is your consensus – EPA goes to the Regional Administrator with the CAG consensus.

The motion to remove the CAG North Gowanus Visioning liaison was not passed.

3 in favor, 9 opposed, 5 abstentions.


Nothing to report.

Land Use

Nothing to report.

Water Quality/Technical

Letters of Invitation

Two friendly invitation letters: one to DEP, one to DCP, to invite them to present to us on some city issues, and develop a way for them to present to us regularly on things that affect Superfund, one of which was the tunnel, and another one is that we’d like DEP and DCP to engage with their timelines for their items that affect Superfund. This has nothing to do with other visioning efforts. We request that they come together, but present their own parts and explain how those timelines affect policy.

Invitations were approved by vote of the Quorum.

Resolution for Reclassification of the Water of the Canal

Resolution to DCP asking that they include reclassification of the water as part of their rezoning. DEP has moved the target date for reclassification to be after they complete all the Superfund work. The changes of use are no longer industrial, it should complement the land use along the water.

Region 5 EPA in Chicago, about how they had reclassified the water – we discovered that DEP is not responsible, but the state is.


Institutional controls in place – right now there are none – I will vote in favor of this, but I don’t think that you can reclassify the Gowanus as any better than the East River.

DEC would have to change this classification, so we did have a version of the letter talking about what DCP and DEP could do to agree to this. It is not our place to tell them what to do. We’re aiming this at DCP, so that DCP can change DEC’s mind. The city needs to take action – there is another resolution that is stronger – we were making a resolution and this highlights the need to revamp how we are voting on resolutions.

Doug Sarno noted there appeared to be general support, but there is no particular rush for this. The CAG process is complicated, it can be slow. All resolutions are consensus of the whole CAG, and need to have full and robust discussions. Committees need to take the time to raise issues and discuss them so that resolutions are reflective of the full CAG, and well constructed.

A member noted that proposed resolutions should be cleaner, we should not be addressing grammar and typos at CAG meetings, but focused on the substance.  The Water Quality and Archaeology committees need to take minutes of meetings as a record, and so that others can see what is being discussed.

The Resolution was approved with grammatical corrections.


Met this month – some Columbia students joined, December 13 meeting planned.

December Meetings

No Land Use this month

Archaeology and Water Quality meeting this month

Admin – needs attendance, no applications – will discuss in January.

The meeting adjourned at 9:12 p.m.

CAG Members Present

Janet Atchison
Diane Buxbaum
Michelle de La Uz
Marlene Donnelly
Nathan Elbogen
George Fiala
Ben Jones
Louis Kleinman
Stephen Kondaks (alternate for John McGettrick)
Linda Mariano
Eric McClure
Rita Miller
Andrea Parker
Peter Reich
Chrissy Remein
Buddy Scotto
Brad Vogel
Susan Yung

Others Present

Doug Sarno, Facilitator
Natalie Loney, EPA
Christos Tsiamis, EPA
Brian Carr, EPA
Pete Lopez, EPA

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