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Manufacturing
10 min read
Areas of Expertise :
Soil And Water Contamination, Toxicology, Hydrology
Published Date:
Last Modified Date:
Jurisdiction:
Federal. Seventh Circuit
Court:
Frey v. EPA arose from PCB contamination associated with capacitor manufacturing operations conducted by Westinghouse Electric Corporation, later CBS Corporation, in Bloomington, Indiana, from 1958 to 1972. Defective capacitors containing PCB insulating fluid were discarded at local dumps and landfills, while PCB-laden wastewater from the plant entered the sewer system and reached the Winston Thomas Sewage Treatment Plant. By the late 1970s, harmful PCB concentrations had been detected in streams, sediment, plants, and wildlife around Bloomington.
Federal, state, and local government parties pursued cleanup under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The remediation process addressed contaminated landfill material, groundwater, sediment, water collection, treatment systems, and long-term monitoring. Sarah Frey, Kevin Enright, and Protect Our Woods, Inc. filed a CERCLA citizen suit challenging the process, alleging that EPA selected remedies without completing the remedial investigation and feasibility study required by the statute.
The litigation produced Seventh Circuit decisions in 2001, 2005, and 2014. In the final appellate ruling, the court held that CERCLA § 113(h)(4) barred review of claims involving ongoing Stage 2 and Stage 3 work. It permitted review of Stage 1 claims not affected by continuing remediation but affirmed summary judgment for EPA after finding that the agency had completed the functional equivalent of an RI/FS for that stage. The U.S. Supreme Court denied certiorari on November 10, 2014.
From 1958 to 1972, Westinghouse operated a Bloomington plant that manufactured electrical capacitors using insulating fluid containing polychlorinated biphenyls, or PCBs. Defective capacitors were discarded at local landfills and dumps, where PCBs escaped into the surrounding environment. The company also discharged PCB-containing wastewater through the sewer system to the Winston Thomas Sewage Treatment Plant.
By the late 1970s, harmful PCB concentrations had been detected in area streams, sediment, plants, and wildlife. The contamination was traced to the manufacturing plant and six disposal or treatment sites. The later Frey litigation addressed Lemon Lane Landfill, Neal’s Landfill, and Bennett’s Dump.
A 1985 consent decree required Westinghouse to excavate PCB-contaminated material from six Bloomington-area sites, down to bedrock where necessary, and destroy the material in a high-temperature incinerator.
The proposed incinerator met public opposition. In 1991, Indiana enacted legislation that prevented its construction, requiring the parties to return to negotiations and develop alternative remedies for the affected sites.
EPA formalized Stage 1 remedies through separate Records of Decision for Bennett’s Dump in 1998, Neal’s Landfill in 1999, and Lemon Lane Landfill in 2000.
The Stage 1 work called for excavation and off-site disposal of PCB-contaminated material, including removal from contamination hot spots at Lemon Lane Landfill and Neal’s Landfill. Bennett’s Dump required more extensive excavation to an industrial cleanup standard. The remedies also included clay caps or soil cover intended to contain contaminated material left at the sites.
Groundwater, water treatment, and remaining sediment conditions were reserved for further investigation and later cleanup decisions. CBS completed the Stage 1 work at all three sites by the end of 2000.
Sarah Frey, Kevin Enright, and Protect Our Woods, Inc. filed a CERCLA citizen suit challenging the modified cleanup remedies for Lemon Lane Landfill, Neal’s Landfill, and Bennett’s Dump.
The plaintiffs sought declaratory and injunctive relief and argued that the cleanup plans did not comply with federal and state environmental requirements. The district court dismissed the complaint after concluding that it lacked jurisdiction to review the challenged remediation work.
The Seventh Circuit reversed the dismissal of the federal claims involving Bennett’s Dump and Neal’s Landfill and directed the district court to reconsider the claims concerning Lemon Lane Landfill. The court affirmed the dismissal of most of the plaintiffs’ state-law claims but remanded a public-nuisance claim against CBS.
The ruling rejected a categorical conclusion that incomplete or proposed future cleanup activity necessarily prevented review of every claim. It returned portions of the case to the district court for further proceedings.
After the district court again dismissed the CERCLA challenge as premature, the case returned to the Seventh Circuit. EPA maintained that it was studying additional cleanup options, but it had not yet identified an objective measure by which the court could determine whether further remedial action was underway or approaching completion.
The Seventh Circuit held that unspecified future plans were insufficient to trigger CERCLA § 113(h)(4)’s bar on judicial review. The ruling allowed the plaintiffs to proceed with claims tied to the completed Stage 1 work.
Testing conducted after Stage 1 showed that PCBs had migrated into the limestone bedrock beneath the sites and continued to enter water and sediment. Bloomington’s karst geology contains fissures, fractures, and conduits through which contaminated groundwater can travel to nearby springs and streams.
EPA formalized Stages 2 and 3 through Records of Decision issued in 2006 and 2007. The later remedies required operation of a water treatment plant at Lemon Lane Landfill, modification and operation of a groundwater collection and treatment system at Neal’s Landfill, and construction of drainage, collection, and water treatment measures at Bennett’s Dump.
CBS also agreed to conduct periodic domestic-well sampling and continue specified treatment activities until groundwater PCB concentrations remained at or below EPA effluent limits for one year. Storm-water management formed part of the broader water-control measures at the sites.
Following public comment and related proceedings, the Southern District of Indiana approved an agreed amendment to the 1985 consent decree. The amendment incorporated six Records of Decision and formalized the remedial requirements for Lemon Lane Landfill, Neal’s Landfill, and Bennett’s Dump.
It also resolved outstanding non-remediation matters among the government parties and CBS concerning the six contaminated sites. The Frey plaintiffs continued under their Third Amended Complaint, alleging that EPA had not completed an RI/FS, or its functional equivalent, before selecting the Stage 1, Stage 2, and Stage 3 remedies.
The Southern District of Indiana granted summary judgment to EPA and denied the plaintiffs’ cross-motion.
The court held that CERCLA § 113(h)(4) barred claims involving Stages 2 and 3 because work under those stages remained ongoing. It permitted review of the completed Stage 1 process but concluded that EPA had conducted the functional equivalent of an RI/FS before selecting the source-control remedies.
The court also determined that EPA had concluded that the Stage 1 remedies protected human health and the environment.
On May 1, 2014, the Seventh Circuit affirmed the district court’s judgment in all respects. It held that CERCLA § 113(h)(4) prevented review of claims concerning ongoing Stage 2 and Stage 3 work. Stage 1 claims that were not affected by the continuing cleanup could be reviewed, but the court affirmed summary judgment for EPA on those claims.
The Seventh Circuit also held that the plaintiffs were not prevailing parties on their consent-decree claim and affirmed the denial of their request to disqualify the district judge. The plaintiffs obtained no declaratory or injunctive relief and were not entitled to attorney fees as prevailing parties.
The plaintiffs petitioned the U.S. Supreme Court for review. The Supreme Court denied certiorari on November 10, 2014.
United States Court of Appeals for the Seventh Circuit
Case Name:
Frey v. Environmental Protection Agency
Environmental Contamination
Environmental Remediation
Environmental Sampling
Groundwater
Groundwater Contamination
Hydrogeology
Polychlorinated Biphenyl PCB
Superfund Sites
Water Treatment
Frey v. EPA arose from PCB contamination associated with capacitor manufacturing operations conducted by Westinghouse Electric Corporation, later CBS Corporation, in Bloomington, Indiana, from 1958 to 1972. Defective capacitors containing PCB insulating fluid were discarded at local dumps and landfills, while PCB-laden wastewater from the plant entered the sewer system and reached the Winston Thomas Sewage Treatment Plant. By the late 1970s, harmful PCB concentrations had been detected in streams, sediment, plants, and wildlife around Bloomington.
Federal, state, and local government parties pursued cleanup under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The remediation process addressed contaminated landfill material, groundwater, sediment, water collection, treatment systems, and long-term monitoring. Sarah Frey, Kevin Enright, and Protect Our Woods, Inc. filed a CERCLA citizen suit challenging the process, alleging that EPA selected remedies without completing the remedial investigation and feasibility study required by the statute.
The litigation produced Seventh Circuit decisions in 2001, 2005, and 2014. In the final appellate ruling, the court held that CERCLA § 113(h)(4) barred review of claims involving ongoing Stage 2 and Stage 3 work. It permitted review of Stage 1 claims not affected by continuing remediation but affirmed summary judgment for EPA after finding that the agency had completed the functional equivalent of an RI/FS for that stage. The U.S. Supreme Court denied certiorari on November 10, 2014.
From 1958 to 1972, Westinghouse operated a Bloomington plant that manufactured electrical capacitors using insulating fluid containing polychlorinated biphenyls, or PCBs. Defective capacitors were discarded at local landfills and dumps, where PCBs escaped into the surrounding environment. The company also discharged PCB-containing wastewater through the sewer system to the Winston Thomas Sewage Treatment Plant.
By the late 1970s, harmful PCB concentrations had been detected in area streams, sediment, plants, and wildlife. The contamination was traced to the manufacturing plant and six disposal or treatment sites. The later Frey litigation addressed Lemon Lane Landfill, Neal’s Landfill, and Bennett’s Dump.
A 1985 consent decree required Westinghouse to excavate PCB-contaminated material from six Bloomington-area sites, down to bedrock where necessary, and destroy the material in a high-temperature incinerator.
The proposed incinerator met public opposition. In 1991, Indiana enacted legislation that prevented its construction, requiring the parties to return to negotiations and develop alternative remedies for the affected sites.
EPA formalized Stage 1 remedies through separate Records of Decision for Bennett’s Dump in 1998, Neal’s Landfill in 1999, and Lemon Lane Landfill in 2000.
The Stage 1 work called for excavation and off-site disposal of PCB-contaminated material, including removal from contamination hot spots at Lemon Lane Landfill and Neal’s Landfill. Bennett’s Dump required more extensive excavation to an industrial cleanup standard. The remedies also included clay caps or soil cover intended to contain contaminated material left at the sites.
Groundwater, water treatment, and remaining sediment conditions were reserved for further investigation and later cleanup decisions. CBS completed the Stage 1 work at all three sites by the end of 2000.
Sarah Frey, Kevin Enright, and Protect Our Woods, Inc. filed a CERCLA citizen suit challenging the modified cleanup remedies for Lemon Lane Landfill, Neal’s Landfill, and Bennett’s Dump.
The plaintiffs sought declaratory and injunctive relief and argued that the cleanup plans did not comply with federal and state environmental requirements. The district court dismissed the complaint after concluding that it lacked jurisdiction to review the challenged remediation work.
The Seventh Circuit reversed the dismissal of the federal claims involving Bennett’s Dump and Neal’s Landfill and directed the district court to reconsider the claims concerning Lemon Lane Landfill. The court affirmed the dismissal of most of the plaintiffs’ state-law claims but remanded a public-nuisance claim against CBS.
The ruling rejected a categorical conclusion that incomplete or proposed future cleanup activity necessarily prevented review of every claim. It returned portions of the case to the district court for further proceedings.
After the district court again dismissed the CERCLA challenge as premature, the case returned to the Seventh Circuit. EPA maintained that it was studying additional cleanup options, but it had not yet identified an objective measure by which the court could determine whether further remedial action was underway or approaching completion.
The Seventh Circuit held that unspecified future plans were insufficient to trigger CERCLA § 113(h)(4)’s bar on judicial review. The ruling allowed the plaintiffs to proceed with claims tied to the completed Stage 1 work.
Testing conducted after Stage 1 showed that PCBs had migrated into the limestone bedrock beneath the sites and continued to enter water and sediment. Bloomington’s karst geology contains fissures, fractures, and conduits through which contaminated groundwater can travel to nearby springs and streams.
EPA formalized Stages 2 and 3 through Records of Decision issued in 2006 and 2007. The later remedies required operation of a water treatment plant at Lemon Lane Landfill, modification and operation of a groundwater collection and treatment system at Neal’s Landfill, and construction of drainage, collection, and water treatment measures at Bennett’s Dump.
CBS also agreed to conduct periodic domestic-well sampling and continue specified treatment activities until groundwater PCB concentrations remained at or below EPA effluent limits for one year. Storm-water management formed part of the broader water-control measures at the sites.
Following public comment and related proceedings, the Southern District of Indiana approved an agreed amendment to the 1985 consent decree. The amendment incorporated six Records of Decision and formalized the remedial requirements for Lemon Lane Landfill, Neal’s Landfill, and Bennett’s Dump.
It also resolved outstanding non-remediation matters among the government parties and CBS concerning the six contaminated sites. The Frey plaintiffs continued under their Third Amended Complaint, alleging that EPA had not completed an RI/FS, or its functional equivalent, before selecting the Stage 1, Stage 2, and Stage 3 remedies.
The Southern District of Indiana granted summary judgment to EPA and denied the plaintiffs’ cross-motion.
The court held that CERCLA § 113(h)(4) barred claims involving Stages 2 and 3 because work under those stages remained ongoing. It permitted review of the completed Stage 1 process but concluded that EPA had conducted the functional equivalent of an RI/FS before selecting the source-control remedies.
The court also determined that EPA had concluded that the Stage 1 remedies protected human health and the environment.
On May 1, 2014, the Seventh Circuit affirmed the district court’s judgment in all respects. It held that CERCLA § 113(h)(4) prevented review of claims concerning ongoing Stage 2 and Stage 3 work. Stage 1 claims that were not affected by the continuing cleanup could be reviewed, but the court affirmed summary judgment for EPA on those claims.
The Seventh Circuit also held that the plaintiffs were not prevailing parties on their consent-decree claim and affirmed the denial of their request to disqualify the district judge. The plaintiffs obtained no declaratory or injunctive relief and were not entitled to attorney fees as prevailing parties.
The plaintiffs petitioned the U.S. Supreme Court for review. The Supreme Court denied certiorari on November 10, 2014.
The published opinions discuss groundwater, sediment, toxic exposure, remediation, and karst geology but do not identify named testifying experts retained by the parties in Frey v. EPA. The following disciplines are commonly used in disputes involving comparable PCB cleanup conditions.
1. Hydrogeology Expert Witness
A hydrogeology expert may analyze groundwater flow, spring discharge, aquifer conditions, and contaminant movement through fractured bedrock or karst systems. The analysis may include monitoring data, groundwater elevations, discharge points, migration pathways, and the expected performance of collection or treatment systems.
In a site with karst limestone, the expert may also examine whether fractures and underground conduits permit contaminants to move beyond conventional monitoring locations.
2. Environmental Remediation Expert Witness
An environmental remediation expert may assess cleanup planning, available remedial alternatives, construction methods, and the performance of site controls. The review may cover excavation, off-site disposal, landfill caps, sediment removal, groundwater collection, water treatment systems, and long-term operation and maintenance.
The expert may also examine whether the technical record supports the selected remedy and whether remedial components address the conditions identified at each site.
3. Toxicology Expert Witness
A toxicology expert may evaluate potential exposure pathways and health risks associated with PCBs in soil, groundwater, surface water, or sediment. The assessment may address ingestion, inhalation, dermal contact, exposure duration, contaminant concentrations, and the populations potentially affected.
Toxicology analysis may also be used to assess whether cleanup goals correspond with the exposure assumptions used in a human-health risk assessment.
4. Soil and Water Contamination Expert Witness
A soil and water contamination expert may examine the presence, concentration, and movement of hazardous substances across soil, groundwater, surface water, and sediment.
The expert may review sampling plans, laboratory results, excavation limits, monitoring-well data, disposal records, sediment conditions, and treatment measures. The work may also include evaluating whether sampling locations and analytical methods adequately identify the affected areas.
1. Connect jurisdictional arguments to the status of each cleanup stage.
CERCLA § 113(h)(4) can restrict judicial review while remedial work remains underway. In Frey, Stage 1 had been completed, while work under Stages 2 and 3 continued. The courts therefore examined the jurisdictional status of each stage separately rather than treating the entire cleanup as a single action.
2. Document compliance with the RI/FS process in the administrative record.
The plaintiffs alleged that EPA selected remedies without completing the required remedial investigation and feasibility study. The courts reviewed the administrative record to determine whether EPA had performed the functional equivalent of an RI/FS for Stage 1.
Records documenting site investigations, remedy selection, public comment, technical analysis, and agency findings can determine whether the required process was completed.
3. Separate source-control measures from groundwater and sediment work.
The Bloomington cleanup involved different remedies for different environmental conditions. Stage 1 addressed contaminated material within the landfill areas through excavation, disposal, and caps. Stages 2 and 3 addressed continuing groundwater and sediment contamination through collection, treatment, drainage, sampling, and monitoring.
Separating those components allows the pleadings and technical record to identify which conditions each remedy was intended to address.
4. Describe contaminant migration according to the site geology.
The record associated PCB migration with Bloomington’s limestone karst, including fractures, fissures, underground conduits, groundwater, springs, streams, and sediment.
Technical descriptions should distinguish confirmed migration pathways from broader water-management measures. Groundwater movement through fractured bedrock, for example, should not be treated as interchangeable with surface runoff or storm-water control.
5. Distinguish documented testimony from technical disciplines discussed in the opinions.
The published decisions address hydrogeology, remediation, toxic exposure, sediment, and groundwater conditions but do not identify named testifying experts in the Frey litigation.
Descriptions of expert roles should therefore present these fields as disciplines commonly used in comparable PCB cleanup disputes rather than attribute testimony to an expert who is not identified in the public decisions.
Frey v. EPA concluded after the Seventh Circuit affirmed judgment for EPA and the Supreme Court declined further review. The courts permitted review of completed Stage 1 work but found that EPA had conducted the functional equivalent of an RI/FS before selecting those remedies. CERCLA § 113(h)(4) prevented review of the ongoing Stage 2 and Stage 3 work. The plaintiffs obtained no declaratory or injunctive relief and were not prevailing parties for attorney-fee purposes.
When was Frey v. EPA filed and finally resolved?
The plaintiffs filed their CERCLA citizen suit on April 20, 2000. The Seventh Circuit affirmed judgment for EPA on May 1, 2014, and the U.S. Supreme Court denied certiorari on November 10, 2014.
Which Bloomington sites were involved in Frey v. EPA?
The litigation addressed Lemon Lane Landfill, Neal’s Landfill, and Bennett’s Dump. The sites contained PCB contamination associated with capacitor manufacturing and disposal operations conducted by Westinghouse, later CBS Corporation.
What did the plaintiffs challenge in EPA’s cleanup process?
The plaintiffs alleged that EPA selected cleanup remedies without completing a remedial investigation and feasibility study, or the functional equivalent of that process. Their claims addressed the remedies selected for landfill source control, groundwater, sediment, water treatment, and long-term monitoring.
How did CERCLA § 113(h)(4) affect the lawsuit?
CERCLA § 113(h)(4) restricts judicial review of certain challenges while remedial work is ongoing. The Seventh Circuit held that the provision barred review of claims involving Stages 2 and 3 because work under those stages had not been completed.
How did Stage 1 differ from Stages 2 and 3?
Stage 1 addressed PCB-contaminated material within the landfill areas through excavation, off-site disposal, and caps or soil cover. Stages 2 and 3 addressed remaining groundwater and sediment contamination through collection systems, water treatment, drainage measures, domestic-well sampling, monitoring, and PCB concentration requirements.
The published opinions discuss groundwater, sediment, toxic exposure, remediation, and karst geology but do not identify named testifying experts retained by the parties in Frey v. EPA. The following disciplines are commonly used in disputes involving comparable PCB cleanup conditions.
1. Hydrogeology Expert Witness
A hydrogeology expert may analyze groundwater flow, spring discharge, aquifer conditions, and contaminant movement through fractured bedrock or karst systems. The analysis may include monitoring data, groundwater elevations, discharge points, migration pathways, and the expected performance of collection or treatment systems.
In a site with karst limestone, the expert may also examine whether fractures and underground conduits permit contaminants to move beyond conventional monitoring locations.
2. Environmental Remediation Expert Witness
An environmental remediation expert may assess cleanup planning, available remedial alternatives, construction methods, and the performance of site controls. The review may cover excavation, off-site disposal, landfill caps, sediment removal, groundwater collection, water treatment systems, and long-term operation and maintenance.
The expert may also examine whether the technical record supports the selected remedy and whether remedial components address the conditions identified at each site.
3. Toxicology Expert Witness
A toxicology expert may evaluate potential exposure pathways and health risks associated with PCBs in soil, groundwater, surface water, or sediment. The assessment may address ingestion, inhalation, dermal contact, exposure duration, contaminant concentrations, and the populations potentially affected.
Toxicology analysis may also be used to assess whether cleanup goals correspond with the exposure assumptions used in a human-health risk assessment.
4. Soil and Water Contamination Expert Witness
A soil and water contamination expert may examine the presence, concentration, and movement of hazardous substances across soil, groundwater, surface water, and sediment.
The expert may review sampling plans, laboratory results, excavation limits, monitoring-well data, disposal records, sediment conditions, and treatment measures. The work may also include evaluating whether sampling locations and analytical methods adequately identify the affected areas.
1. Connect jurisdictional arguments to the status of each cleanup stage.
CERCLA § 113(h)(4) can restrict judicial review while remedial work remains underway. In Frey, Stage 1 had been completed, while work under Stages 2 and 3 continued. The courts therefore examined the jurisdictional status of each stage separately rather than treating the entire cleanup as a single action.
2. Document compliance with the RI/FS process in the administrative record.
The plaintiffs alleged that EPA selected remedies without completing the required remedial investigation and feasibility study. The courts reviewed the administrative record to determine whether EPA had performed the functional equivalent of an RI/FS for Stage 1.
Records documenting site investigations, remedy selection, public comment, technical analysis, and agency findings can determine whether the required process was completed.
3. Separate source-control measures from groundwater and sediment work.
The Bloomington cleanup involved different remedies for different environmental conditions. Stage 1 addressed contaminated material within the landfill areas through excavation, disposal, and caps. Stages 2 and 3 addressed continuing groundwater and sediment contamination through collection, treatment, drainage, sampling, and monitoring.
Separating those components allows the pleadings and technical record to identify which conditions each remedy was intended to address.
4. Describe contaminant migration according to the site geology.
The record associated PCB migration with Bloomington’s limestone karst, including fractures, fissures, underground conduits, groundwater, springs, streams, and sediment.
Technical descriptions should distinguish confirmed migration pathways from broader water-management measures. Groundwater movement through fractured bedrock, for example, should not be treated as interchangeable with surface runoff or storm-water control.
5. Distinguish documented testimony from technical disciplines discussed in the opinions.
The published decisions address hydrogeology, remediation, toxic exposure, sediment, and groundwater conditions but do not identify named testifying experts in the Frey litigation.
Descriptions of expert roles should therefore present these fields as disciplines commonly used in comparable PCB cleanup disputes rather than attribute testimony to an expert who is not identified in the public decisions.
Frey v. EPA concluded after the Seventh Circuit affirmed judgment for EPA and the Supreme Court declined further review. The courts permitted review of completed Stage 1 work but found that EPA had conducted the functional equivalent of an RI/FS before selecting those remedies. CERCLA § 113(h)(4) prevented review of the ongoing Stage 2 and Stage 3 work. The plaintiffs obtained no declaratory or injunctive relief and were not prevailing parties for attorney-fee purposes.
When was Frey v. EPA filed and finally resolved?
The plaintiffs filed their CERCLA citizen suit on April 20, 2000. The Seventh Circuit affirmed judgment for EPA on May 1, 2014, and the U.S. Supreme Court denied certiorari on November 10, 2014.
Which Bloomington sites were involved in Frey v. EPA?
The litigation addressed Lemon Lane Landfill, Neal’s Landfill, and Bennett’s Dump. The sites contained PCB contamination associated with capacitor manufacturing and disposal operations conducted by Westinghouse, later CBS Corporation.
What did the plaintiffs challenge in EPA’s cleanup process?
The plaintiffs alleged that EPA selected cleanup remedies without completing a remedial investigation and feasibility study, or the functional equivalent of that process. Their claims addressed the remedies selected for landfill source control, groundwater, sediment, water treatment, and long-term monitoring.
How did CERCLA § 113(h)(4) affect the lawsuit?
CERCLA § 113(h)(4) restricts judicial review of certain challenges while remedial work is ongoing. The Seventh Circuit held that the provision barred review of claims involving Stages 2 and 3 because work under those stages had not been completed.
How did Stage 1 differ from Stages 2 and 3?
Stage 1 addressed PCB-contaminated material within the landfill areas through excavation, off-site disposal, and caps or soil cover. Stages 2 and 3 addressed remaining groundwater and sediment contamination through collection systems, water treatment, drainage measures, domestic-well sampling, monitoring, and PCB concentration requirements.
Environmental Contamination
Environmental Remediation
Environmental Sampling
Groundwater
Groundwater Contamination
Hydrogeology
Polychlorinated Biphenyl PCB
Superfund Sites
Water Treatment
Manufacturing
Metallurgy, +4
Manufacturing
Manufacturing, +4
Manufacturing