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Manufacturing
11 min read
Areas of Expertise :
Environmental Engineering, Environmental Science, Hazardous Waste, Demolition, Soil And Water Contamination
Published Date:
Last Modified Date:
Jurisdiction:
Federal. Eighth Circuit
United States v. Dico, Inc. arose from the demolition of industrial buildings at a Des Moines, Iowa, property where the U.S. Environmental Protection Agency had identified polychlorinated biphenyls in adhesive used with building insulation. On March 4, 1994, EPA issued an administrative order under Section 106 of the Comprehensive Environmental Response, Compensation, and Liability Act. The order required Dico, Inc. to remove certain PCB-contaminated materials, encapsulate insulation that remained, maintain the protective measures, submit reports, and notify EPA of property changes that could cause or threaten another release.
In 2007, Dico acted through Titan Tire Corporation in several transactions with Southern Iowa Mechanical involving buildings at the property. Southern Iowa Mechanical dismantled the structures and retained structural steel beams, which it stored outdoors at its facility in Ottumwa, Iowa. EPA later detected PCBs on some beams, attached insulation, and nearby soil. The United States sued Dico and Titan Tire under CERCLA, alleging arranger liability and violations of the 1994 administrative order. The litigation proceeded through district court rulings in 2012, 2013, 2014, and 2017, Eighth Circuit decisions in 2015 and 2019, and a consent decree entered in 2021.
An environmental investigation at the Des Moines property documented PCBs in adhesive associated with insulation in several industrial buildings. The investigation formed part of broader EPA work involving contamination at the property, including concerns related to soil and groundwater. The findings later supported federal requirements governing the removal, encapsulation, inspection, and maintenance of the affected building materials.
EPA issued an administrative order under CERCLA Section 106 directing Dico to remove part of the PCB contamination and encapsulate insulation that remained in the buildings. The order also required Dico to implement operation and maintenance measures, conduct inspections and testing, submit reports, and notify EPA of changed conditions that could cause or threaten another release.
Dico submitted a completion report in 1997. EPA later advised that the report did not end the continuing inspection, maintenance, reporting, and notice obligations imposed by the order.
By 2002, Dico was no longer using the affected buildings and requested relief from recurring testing requirements. EPA agreed that certain testing could stop while the buildings remained unused, provided Dico submitted annual status reports. In 2003, Dico confirmed that it would continue annual reporting and resume the applicable operation and maintenance requirements if the buildings returned to use.
The modification changed certain procedures but did not terminate the 1994 CERCLA order. Its continuing obligations remained in effect.
In 2007, Dico, acting through Titan Tire, entered into three transactions with Southern Iowa Mechanical involving the Maintenance Building, the western portion of Building 3, Buildings 4 and 5, and the northern portion of the Production Building. Some of the structures were subject to the 1994 EPA order, while others were not.
Southern Iowa Mechanical dismantled the buildings, discarded most of the materials, and retained the structural steel beams for salvage. Dico and Titan Tire did not notify EPA before the transactions. Southern Iowa Mechanical also was not informed that certain buildings contained PCBs or remained subject to an EPA administrative order.
During a five-year inspection of the Des Moines property, an EPA project manager discovered that most of the buildings involved in the transactions had been dismantled. EPA traced the retained steel beams to Southern Iowa Mechanical’s property in Ottumwa, where they had been stored outdoors. Many of the beams rested directly on the ground and were exposed to weather.
Sampling detected PCBs on some beams, in insulation still attached to the steel, and in nearby soil. EPA later directed response work that recovered and disposed of more than four tons of insulation removed from the Dico buildings.
The United States filed a civil action against Dico and Titan Tire in the U.S. District Court for the Southern District of Iowa. The government sought recovery of past and future response costs associated with the Southern Iowa Mechanical property.
The complaint also sought civil penalties against Dico for violating the 1994 administrative order and punitive damages based on the failure to perform required response action. Southern Iowa Mechanical was not named as a defendant.
The district court found Dico and Titan Tire liable as CERCLA arrangers at the summary judgment stage. It concluded that the transactions resulted in disposal of PCB-contaminated materials and that the defendants knew the buildings would be dismantled.
The ruling resolved arranger liability without a trial on intent. Whether the evidence permitted that determination at the summary judgment stage later became the central issue in the first Eighth Circuit appeal.
The district court granted summary judgment finding that Dico violated continuing obligations imposed by the 1994 CERCLA order. The court concluded that Dico failed to comply with operation and maintenance requirements and failed to notify EPA of changed conditions involving the buildings.
That ruling established the liability basis for the civil penalty later determined after trial.
On February 24, 2014, the district court issued its monetary ruling following a bench trial. Judgment was entered on February 25, 2014.
The court awarded the United States $1,477,787.73 in reported response costs. It also imposed a civil penalty of $1.62 million for Dico’s violations of the EPA order and awarded $1,477,787.73 in punitive damages. The civil penalty was calculated at $10,000 per day for 162 days. Dico and Titan Tire appealed.
In United States v. Dico, Inc., 808 F.3d 342, the Eighth Circuit held that arranger liability could not be resolved on summary judgment because the evidence presented a disputed issue concerning Dico’s intent. The court explained that knowledge of eventual disposal may support an inference of intent but does not independently establish arranger liability.
Because the arranger-liability finding had been entered without resolving the disputed question of intent at trial, the Eighth Circuit reversed that portion of the judgment and vacated the related response-cost award. It also reversed the initial punitive-damages award because, without an established arranger-liability finding, the government had not yet shown that the Southern Iowa Mechanical cleanup costs were incurred as a result of Dico’s failure to perform the required response action.
The appellate court reached a different result on Dico’s violation of the 1994 EPA order. It affirmed that ruling and left the $1.62 million civil penalty in place.
On remand, the district court conducted a bench trial focused on whether Dico and Titan Tire intended to dispose of PCB contamination through the transactions with Southern Iowa Mechanical. On September 5, 2017, the court issued findings concluding that the defendants entered the transactions with the required intent. Judgment followed on September 7, 2017.
The post-remand ruling rested on findings made after the court evaluated the full evidentiary record rather than resolving intent at the summary judgment stage. The court held Dico and Titan Tire jointly and severally liable for $5,454,370 in past response costs. It also awarded unreported costs, future response costs, enforcement costs, and attorney fees. The court imposed an additional $5,454,370 in punitive damages against Dico.
In United States v. Dico, Inc., 920 F.3d 1174, the Eighth Circuit affirmed the district court’s post-remand findings. The record supported the determination that Dico and Titan Tire intended to dispose of PCB contamination through the building transactions and subsequent demolition.
The 2019 decision did not conflict with the earlier ruling that intent could not be decided on summary judgment. The first appeal required a trial because the evidence presented a disputed factual question. After the remand trial, the district court made findings based on the complete record, and the Eighth Circuit concluded that those findings were adequately supported.
The appellate court also affirmed the past response-cost award, punitive damages, enforcement costs, attorney fees, and joint and several liability. Dico and Titan Tire had not established a reasonable factual basis for dividing the environmental harm.
The parties lodged a proposed consent decree on September 15, 2020. The district court approved and entered the decree on February 1, 2021.
Dico, Titan Tire Corporation, and Titan International, Inc., Dico’s ultimate parent, agreed to pay $11.5 million plus interest to resolve judgments associated with the Southern Iowa Mechanical property and earlier litigation involving the Des Moines TCE site. The decree allocated $7 million to response costs connected with the Southern Iowa Mechanical site.
The decree also required Dico to transfer the property to the City of Des Moines, generally by donation and free from liens and encumbrances.
Court:
United States District Court for the Southern District of Iowa
Case Name:
United States v. Dico, Inc.
Polychlorinated Biphenyl PCB
Environmental Remediation
Environmental Compliance
Environmental Contamination
Environmental Sampling
Environmental Protection Agency EPA
Waste Management
Hazardous Chemicals
Toxic substances control act
Soil Chemistry
United States v. Dico, Inc. arose from the demolition of industrial buildings at a Des Moines, Iowa, property where the U.S. Environmental Protection Agency had identified polychlorinated biphenyls in adhesive used with building insulation. On March 4, 1994, EPA issued an administrative order under Section 106 of the Comprehensive Environmental Response, Compensation, and Liability Act. The order required Dico, Inc. to remove certain PCB-contaminated materials, encapsulate insulation that remained, maintain the protective measures, submit reports, and notify EPA of property changes that could cause or threaten another release.
In 2007, Dico acted through Titan Tire Corporation in several transactions with Southern Iowa Mechanical involving buildings at the property. Southern Iowa Mechanical dismantled the structures and retained structural steel beams, which it stored outdoors at its facility in Ottumwa, Iowa. EPA later detected PCBs on some beams, attached insulation, and nearby soil. The United States sued Dico and Titan Tire under CERCLA, alleging arranger liability and violations of the 1994 administrative order. The litigation proceeded through district court rulings in 2012, 2013, 2014, and 2017, Eighth Circuit decisions in 2015 and 2019, and a consent decree entered in 2021.
An environmental investigation at the Des Moines property documented PCBs in adhesive associated with insulation in several industrial buildings. The investigation formed part of broader EPA work involving contamination at the property, including concerns related to soil and groundwater. The findings later supported federal requirements governing the removal, encapsulation, inspection, and maintenance of the affected building materials.
EPA issued an administrative order under CERCLA Section 106 directing Dico to remove part of the PCB contamination and encapsulate insulation that remained in the buildings. The order also required Dico to implement operation and maintenance measures, conduct inspections and testing, submit reports, and notify EPA of changed conditions that could cause or threaten another release.
Dico submitted a completion report in 1997. EPA later advised that the report did not end the continuing inspection, maintenance, reporting, and notice obligations imposed by the order.
By 2002, Dico was no longer using the affected buildings and requested relief from recurring testing requirements. EPA agreed that certain testing could stop while the buildings remained unused, provided Dico submitted annual status reports. In 2003, Dico confirmed that it would continue annual reporting and resume the applicable operation and maintenance requirements if the buildings returned to use.
The modification changed certain procedures but did not terminate the 1994 CERCLA order. Its continuing obligations remained in effect.
In 2007, Dico, acting through Titan Tire, entered into three transactions with Southern Iowa Mechanical involving the Maintenance Building, the western portion of Building 3, Buildings 4 and 5, and the northern portion of the Production Building. Some of the structures were subject to the 1994 EPA order, while others were not.
Southern Iowa Mechanical dismantled the buildings, discarded most of the materials, and retained the structural steel beams for salvage. Dico and Titan Tire did not notify EPA before the transactions. Southern Iowa Mechanical also was not informed that certain buildings contained PCBs or remained subject to an EPA administrative order.
During a five-year inspection of the Des Moines property, an EPA project manager discovered that most of the buildings involved in the transactions had been dismantled. EPA traced the retained steel beams to Southern Iowa Mechanical’s property in Ottumwa, where they had been stored outdoors. Many of the beams rested directly on the ground and were exposed to weather.
Sampling detected PCBs on some beams, in insulation still attached to the steel, and in nearby soil. EPA later directed response work that recovered and disposed of more than four tons of insulation removed from the Dico buildings.
The United States filed a civil action against Dico and Titan Tire in the U.S. District Court for the Southern District of Iowa. The government sought recovery of past and future response costs associated with the Southern Iowa Mechanical property.
The complaint also sought civil penalties against Dico for violating the 1994 administrative order and punitive damages based on the failure to perform required response action. Southern Iowa Mechanical was not named as a defendant.
The district court found Dico and Titan Tire liable as CERCLA arrangers at the summary judgment stage. It concluded that the transactions resulted in disposal of PCB-contaminated materials and that the defendants knew the buildings would be dismantled.
The ruling resolved arranger liability without a trial on intent. Whether the evidence permitted that determination at the summary judgment stage later became the central issue in the first Eighth Circuit appeal.
The district court granted summary judgment finding that Dico violated continuing obligations imposed by the 1994 CERCLA order. The court concluded that Dico failed to comply with operation and maintenance requirements and failed to notify EPA of changed conditions involving the buildings.
That ruling established the liability basis for the civil penalty later determined after trial.
On February 24, 2014, the district court issued its monetary ruling following a bench trial. Judgment was entered on February 25, 2014.
The court awarded the United States $1,477,787.73 in reported response costs. It also imposed a civil penalty of $1.62 million for Dico’s violations of the EPA order and awarded $1,477,787.73 in punitive damages. The civil penalty was calculated at $10,000 per day for 162 days. Dico and Titan Tire appealed.
In United States v. Dico, Inc., 808 F.3d 342, the Eighth Circuit held that arranger liability could not be resolved on summary judgment because the evidence presented a disputed issue concerning Dico’s intent. The court explained that knowledge of eventual disposal may support an inference of intent but does not independently establish arranger liability.
Because the arranger-liability finding had been entered without resolving the disputed question of intent at trial, the Eighth Circuit reversed that portion of the judgment and vacated the related response-cost award. It also reversed the initial punitive-damages award because, without an established arranger-liability finding, the government had not yet shown that the Southern Iowa Mechanical cleanup costs were incurred as a result of Dico’s failure to perform the required response action.
The appellate court reached a different result on Dico’s violation of the 1994 EPA order. It affirmed that ruling and left the $1.62 million civil penalty in place.
On remand, the district court conducted a bench trial focused on whether Dico and Titan Tire intended to dispose of PCB contamination through the transactions with Southern Iowa Mechanical. On September 5, 2017, the court issued findings concluding that the defendants entered the transactions with the required intent. Judgment followed on September 7, 2017.
The post-remand ruling rested on findings made after the court evaluated the full evidentiary record rather than resolving intent at the summary judgment stage. The court held Dico and Titan Tire jointly and severally liable for $5,454,370 in past response costs. It also awarded unreported costs, future response costs, enforcement costs, and attorney fees. The court imposed an additional $5,454,370 in punitive damages against Dico.
In United States v. Dico, Inc., 920 F.3d 1174, the Eighth Circuit affirmed the district court’s post-remand findings. The record supported the determination that Dico and Titan Tire intended to dispose of PCB contamination through the building transactions and subsequent demolition.
The 2019 decision did not conflict with the earlier ruling that intent could not be decided on summary judgment. The first appeal required a trial because the evidence presented a disputed factual question. After the remand trial, the district court made findings based on the complete record, and the Eighth Circuit concluded that those findings were adequately supported.
The appellate court also affirmed the past response-cost award, punitive damages, enforcement costs, attorney fees, and joint and several liability. Dico and Titan Tire had not established a reasonable factual basis for dividing the environmental harm.
The parties lodged a proposed consent decree on September 15, 2020. The district court approved and entered the decree on February 1, 2021.
Dico, Titan Tire Corporation, and Titan International, Inc., Dico’s ultimate parent, agreed to pay $11.5 million plus interest to resolve judgments associated with the Southern Iowa Mechanical property and earlier litigation involving the Des Moines TCE site. The decree allocated $7 million to response costs connected with the Southern Iowa Mechanical site.
The decree also required Dico to transfer the property to the City of Des Moines, generally by donation and free from liens and encumbrances.
The following expert categories may be involved in similar environmental litigation. They are not presented as a complete list of experts retained or called to testify in United States v. Dico.
Environmental Remediation Expert Witness
Environmental remediation experts evaluate site investigations, sampling plans, removal actions, decontamination methods, disposal procedures, and cleanup documentation. They may assess whether response activities were technically appropriate and whether claimed expenses were connected to an actual or threatened release of hazardous substances.
Industrial Hygiene Expert Witness
Industrial hygienists examine potential exposure pathways involving contaminated insulation, dust, air, surfaces, and demolition work areas. Their work may address respiratory protection, air monitoring, personal protective equipment, work controls, and hazardous-material handling procedures.
Hazardous Waste Management Expert Witness
Hazardous waste management experts assess the identification, packaging, transportation, storage, treatment, and disposal of PCB-containing materials. They may compare site activities with CERCLA requirements, EPA administrative orders, PCB regulations, and approved waste-management practices.
Environmental Cost Recovery Expert Witness
Environmental cost recovery experts review invoices, contractor records, laboratory charges, sampling expenses, enforcement costs, and other amounts claimed as response costs. They may determine whether the expenses were necessary, adequately documented, properly allocated, and connected to the cleanup work performed.
Arranger Liability Requires Evidence of Intent
CERCLA arranger liability requires evidence that the seller intended hazardous substances to be discarded, although knowledge that disposal would occur may support that inference. After remand, the court found intent based on the transaction’s purpose, demolition plans, nondisclosure, avoided cleanup costs, transaction value, and the parties’ conduct.
EPA Administrative Orders May Create Continuing Obligations
An EPA order may continue to require inspection, maintenance, testing, reporting, and notice even after the primary cleanup work is complete. Dico’s 1997 completion report did not terminate the ongoing obligations imposed by the 1994 order.
Known Contamination Should Be Addressed Before Demolition or Transfer
Transactions involving contaminated structures should address hazardous materials, regulatory restrictions, notice requirements, sampling, and disposal responsibilities. In Dico, the failure to notify EPA or disclose the PCB contamination and continuing order to Southern Iowa Mechanical became part of the courts’ analysis.
CERCLA Response Costs May Include Enforcement Expenses
CERCLA allows the United States to recover qualifying cleanup and remedial expenses, including certain enforcement costs. The Eighth Circuit upheld the recovery of response costs, attorney fees, and other enforcement-related expenses in the Dico litigation.
Civil Penalties and Punitive Damages Are Separate Remedies
Civil penalties may apply to willful violations of an EPA order, while CERCLA punitive damages require additional findings tied to a failure to perform ordered response actions. The Eighth Circuit preserved Dico’s $1.62 million civil penalty but initially vacated punitive damages, which the district court later reimposed after trial.
The Dico litigation turned on two related but distinct questions: whether Dico violated continuing obligations imposed by the 1994 EPA order and whether Dico and Titan Tire intended to arrange for the disposal of PCB contamination through the 2007 building transactions. The administrative-order violations and $1.62 million civil penalty remained intact after the first appeal, while the arranger-liability, response-cost, and punitive-damages rulings required further proceedings because intent could not be resolved on summary judgment.
Following the remand trial, the district court found the required intent and entered awards of $5,454,370 in past response costs and $5,454,370 in punitive damages, together with additional recoverable expenses. The Eighth Circuit affirmed the post-remand judgment in 2019. The litigation concluded through a consent decree entered on February 1, 2021, requiring payment of $11.5 million plus interest and transfer of the Des Moines property to the City of Des Moines.
Why Did the Eighth Circuit Reach Different Outcomes in 2015 and 2019?
In 2015, the Eighth Circuit held that Dico’s intent could not be decided on summary judgment because the evidence presented a disputed factual issue. After a bench trial on remand, the district court made findings based on the full record, and the Eighth Circuit affirmed those findings in 2019.
Can Materials With Salvage Value Still Support CERCLA Arranger Liability?
Yes. The presence of salvage value does not prevent arranger liability when the evidence shows that the transaction was entered with an intent to dispose of hazardous substances. In Dico, the district court considered the demolition plans, nondisclosure, avoided cleanup expenses, transaction value, and the conduct of the parties before finding the required intent.
Why Was the Original Punitive-Damages Award Vacated in 2015?
The Eighth Circuit vacated the initial punitive-damages award because arranger liability had not yet been properly established. Without that finding, the government had not shown that the Southern Iowa Mechanical cleanup costs were incurred as a result of Dico’s failure to perform the required response action.
Did Dico’s 1997 Completion Report Terminate the 1994 EPA Order?
No. EPA advised that continuing inspection, maintenance, reporting, and notice obligations remained in effect. Later modifications changed certain testing procedures while the buildings remained unused but did not terminate the order.
What Did the 2021 Consent Decree Resolve?
The consent decree resolved outstanding judgments associated with the Southern Iowa Mechanical property and earlier litigation involving the Des Moines TCE site. Dico, Titan Tire Corporation, and Titan International, Inc. agreed to pay $11.5 million plus interest, with $7 million allocated to response costs connected with the Southern Iowa Mechanical site, and Dico agreed to transfer the property to the City of Des Moines.
The following expert categories may be involved in similar environmental litigation. They are not presented as a complete list of experts retained or called to testify in United States v. Dico.
Environmental Remediation Expert Witness
Environmental remediation experts evaluate site investigations, sampling plans, removal actions, decontamination methods, disposal procedures, and cleanup documentation. They may assess whether response activities were technically appropriate and whether claimed expenses were connected to an actual or threatened release of hazardous substances.
Industrial Hygiene Expert Witness
Industrial hygienists examine potential exposure pathways involving contaminated insulation, dust, air, surfaces, and demolition work areas. Their work may address respiratory protection, air monitoring, personal protective equipment, work controls, and hazardous-material handling procedures.
Hazardous Waste Management Expert Witness
Hazardous waste management experts assess the identification, packaging, transportation, storage, treatment, and disposal of PCB-containing materials. They may compare site activities with CERCLA requirements, EPA administrative orders, PCB regulations, and approved waste-management practices.
Environmental Cost Recovery Expert Witness
Environmental cost recovery experts review invoices, contractor records, laboratory charges, sampling expenses, enforcement costs, and other amounts claimed as response costs. They may determine whether the expenses were necessary, adequately documented, properly allocated, and connected to the cleanup work performed.
Arranger Liability Requires Evidence of Intent
CERCLA arranger liability requires evidence that the seller intended hazardous substances to be discarded, although knowledge that disposal would occur may support that inference. After remand, the court found intent based on the transaction’s purpose, demolition plans, nondisclosure, avoided cleanup costs, transaction value, and the parties’ conduct.
EPA Administrative Orders May Create Continuing Obligations
An EPA order may continue to require inspection, maintenance, testing, reporting, and notice even after the primary cleanup work is complete. Dico’s 1997 completion report did not terminate the ongoing obligations imposed by the 1994 order.
Known Contamination Should Be Addressed Before Demolition or Transfer
Transactions involving contaminated structures should address hazardous materials, regulatory restrictions, notice requirements, sampling, and disposal responsibilities. In Dico, the failure to notify EPA or disclose the PCB contamination and continuing order to Southern Iowa Mechanical became part of the courts’ analysis.
CERCLA Response Costs May Include Enforcement Expenses
CERCLA allows the United States to recover qualifying cleanup and remedial expenses, including certain enforcement costs. The Eighth Circuit upheld the recovery of response costs, attorney fees, and other enforcement-related expenses in the Dico litigation.
Civil Penalties and Punitive Damages Are Separate Remedies
Civil penalties may apply to willful violations of an EPA order, while CERCLA punitive damages require additional findings tied to a failure to perform ordered response actions. The Eighth Circuit preserved Dico’s $1.62 million civil penalty but initially vacated punitive damages, which the district court later reimposed after trial.
The Dico litigation turned on two related but distinct questions: whether Dico violated continuing obligations imposed by the 1994 EPA order and whether Dico and Titan Tire intended to arrange for the disposal of PCB contamination through the 2007 building transactions. The administrative-order violations and $1.62 million civil penalty remained intact after the first appeal, while the arranger-liability, response-cost, and punitive-damages rulings required further proceedings because intent could not be resolved on summary judgment.
Following the remand trial, the district court found the required intent and entered awards of $5,454,370 in past response costs and $5,454,370 in punitive damages, together with additional recoverable expenses. The Eighth Circuit affirmed the post-remand judgment in 2019. The litigation concluded through a consent decree entered on February 1, 2021, requiring payment of $11.5 million plus interest and transfer of the Des Moines property to the City of Des Moines.
Why Did the Eighth Circuit Reach Different Outcomes in 2015 and 2019?
In 2015, the Eighth Circuit held that Dico’s intent could not be decided on summary judgment because the evidence presented a disputed factual issue. After a bench trial on remand, the district court made findings based on the full record, and the Eighth Circuit affirmed those findings in 2019.
Can Materials With Salvage Value Still Support CERCLA Arranger Liability?
Yes. The presence of salvage value does not prevent arranger liability when the evidence shows that the transaction was entered with an intent to dispose of hazardous substances. In Dico, the district court considered the demolition plans, nondisclosure, avoided cleanup expenses, transaction value, and the conduct of the parties before finding the required intent.
Why Was the Original Punitive-Damages Award Vacated in 2015?
The Eighth Circuit vacated the initial punitive-damages award because arranger liability had not yet been properly established. Without that finding, the government had not shown that the Southern Iowa Mechanical cleanup costs were incurred as a result of Dico’s failure to perform the required response action.
Did Dico’s 1997 Completion Report Terminate the 1994 EPA Order?
No. EPA advised that continuing inspection, maintenance, reporting, and notice obligations remained in effect. Later modifications changed certain testing procedures while the buildings remained unused but did not terminate the order.
What Did the 2021 Consent Decree Resolve?
The consent decree resolved outstanding judgments associated with the Southern Iowa Mechanical property and earlier litigation involving the Des Moines TCE site. Dico, Titan Tire Corporation, and Titan International, Inc. agreed to pay $11.5 million plus interest, with $7 million allocated to response costs connected with the Southern Iowa Mechanical site, and Dico agreed to transfer the property to the City of Des Moines.
Polychlorinated Biphenyl PCB
Environmental Remediation
Environmental Compliance
Environmental Contamination
Environmental Sampling
Environmental Protection Agency EPA
Waste Management
Hazardous Chemicals
Toxic substances control act
Soil Chemistry
Manufacturing
Metallurgy, +4
Manufacturing
Manufacturing, +4
Manufacturing