controlled correspondence for r7 regional administrator

Controlled Correspondence ForR7 REGIONAL ADMINISTRATOR

CONTROL NO

STATUS:

AL-0000362

PENDING

ORIG. DUE DATE: 03/14/2000

CORRES. DATE:RECEIVED DATE:ASSIGNED DATE:CLOSED DATE:

02/04/200002/15/200003/01/2000

FROM:ORG:SALUTATION:CONSTITUENT:

TO:TO ORG:SUBJECT:

ASSIGNED:

GRASSLEY CHARLES E.-R/IAUNITED STATES SENATEDEAR SENATOR GRASSLEYEBEL.JEFF

CLAIM OF THE EPA AGAINST MIDWEST FARMERS COOPERATIVE

Superfund Division

COPIES OF INCOMING PROVIDED TO: OCIR/MARIE MULLER, REGION 07

SIGNATURE:R7 COMMENTS:

REGIONAL ADMINISTRATOR

AL INSTRUCTIONS: SEND RESPONSE TO STATE OFFICE AS REQUESTED

SEND "HARD" COPY OF SIGNED, DATED REPLY ALONG WITH ORIGINALCONTROL SLIP TO MYRTLE LASHLEY (1304) HEADQUARTERS FAXEDCOPY ACCEPTABLE (FAX # 202/260-8866)

R7 INSTRUCTIONS: . To coordinate response, contact LaTonya Flint, Ext. 7555For General Information, contact OEP, Ext 7003

Lead

Assigned

SUPR

Date Assigned

03/01/2000

Code/Status

ACTION

Date Completed byAssignee

-

Date Returned toR7:

-

uit.'.jfa'^ -'* • V ' ' ^ ""'S 12 >-'/'/ •

(Unfitted)

OFFICE OF CONGRESSIONAL AND INTERGOVERNMENTAL RELATIONSCORRESPONDENCE CONTROL SLIP

CONTROL NO:

STATUS:

AL-0000362 ORIG. DUE DATE: 0229/2000EXT. DUE DATE: 03/14/2000

PENDING CORRES. DATE:RECEIVED DATE:ASSIGNED DATE:CLOSED DATE:

GRASSLEY CHARLES E.-R/IAUNITED STATES SENATEDEAR SENATOR GRASSLEYEBEL.JEFF

02/04/200002/15 '200002/29/2000

FROM:ORG:SALUTATION:CONSTITUENT:COMMITTEE:

TO:TO ORG:SUBJECT: CLAIM OF THE EPA AGAINST MIDWEST FARMERS COOPERATIVE

ASSIGNED: REGION 07

COPIES OF INCOMING PROVIDED TO: OCIR/MARIE MULLER. REGION 07

SIGNATURE:INSTs:

COMMENTS:

IMS:IMT:

REGIONAL ADMINISTRATORSEND RESPONSE TO STATE OFFICE AS REQUESTED.

SEND "HARD" COPY OF SIGNED, DATED REPLY ALONG WITH ORIGINALCONTROL SLIP TO MYRTLE LASHLEY (1304) HEADQUARTERS. FAXEDCOPY ACCEPTABLE (FAX # 202/260-8866)

CASSAUNDRA EADESCASSAUNDRA EADES/DC/USEPA/US

L**d

Assigned

OECA

R7

Date Assigned

02/15/2000

02/29/2000

Code/Status

ACTION

ACTION


-

•

Date Returned toOCIR:

02/29/2000

AL Correspondence - Control No AL-0000362

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION VII901 N. 5TH STREET

KANSAS CITY, KANSAS 66101

OFFICE OFTHE REGIONAL ADMINISTRATOR

MAR 1 6 2000

The Honorable Charles GrassleyUnited States Senator103 Federal Courthouse Building320 6* StreetDes Moines, Iowa 51101

Dear Senator Grassley

Thank you for your recent inquiry to the EPA on behalf of your constituent Mr Jeff Ebel,of Midwest Farmers COOP, in Hospers, IA Mr Ebel is concerned with past costs incurred at theFarmers Mutual Cooperative National Priority List site We have reviewed the letter andadditional information presented to you from the COOP This letter provides a summary of theactivities at the site and EPA's efforts to settle these matters involving the COOP

BACKROUND

The site involves a facility which was started as the Farmers Mutual COOP of Hospers in1908, and has undergone several expansions since that time On July 1, 1989, the FarmersMutual COOP of Hospers was merged into the Farmers Cooperative Elevator Association ofSheldon, Iowa The company changed its name in January 1997 to Midwest Farmers Cooperative(the COOP) Activities related to grain storage and grain fumigation with pesticides wereconducted at the Facility In 1991, the COOP removed all bulk chemicals from the Facility

The site on which the Facility is located (the Site) was initially investigated due to thepresence of herbicides and volatile organic compounds (VOCs) in the city of Hospers watersupply Three of the city's wells located adjacent to the Facility were first found to becontaminated in 1984 Results of this early sampling and subsequent sampling of the groundwaterdemonstrated that the Facility was a source of the contamination The city of Hospers has sincebeen prohibited from using these three wells

Both EPA and the Iowa Department of Natural Resources (IDNR) have been involved atthis site since the contamination was discovered. Primarily because the contamination impacted asource of drinking water, the site was proposed for the National Priorities List (NPL) in June of1988 and became a final NPL site in August of 1990

RECYCLE v*

IDNR assumed the lead agency role on the site to oversee the COOP's investigations.EPA was very closely involved at the site in support of the IDNR In addition, EPA and IDNRconducted an investigation to identify potential contaminant sources not located on COOPproperty and to determine the extent and magnitude of carbon tetrachloride contamination ingroundwater. No source of contamination other than the COOP Facility has ever been identified.

After a series of investigative activities, a proposed plan for remediating the site waspresented to the public in May 1991 This plan called for a ground water extraction and treatmentremedy. Significant comments were received from the city and public regarding this plan and insupport of other alternatives Subsequent to acquiring additional data, EPA and IDNR released asecond proposed plan in August 1992 for natural attenuation as a means to remediate the groundwater contamination, a ground water pump test and additional ground water monitoring TheRecord of Decision for the site was signed by both the EPA Regional Administrator and theDirector of IDNR in September 1992

The COOP subsequently conducted a ground water pump test and significant additionalmonitoring This included preparation of work planning and design documents. This work wasoverseen by IDNR and EPA Based upon these tests and the additional data, a decision was madenot to pursue blending of the water from the various city water supply wells for public watersupply purposes, rather the city was connected to a rural water system in 1996.

COST ASSESSMENT

EPA's costs at this site represent its expenses in conducting the initial investigations andlisting the site on the NPL, separate investigations into other potentially responsible parties andtechnical activities related to supporting IDNR These technical activities include EPA laboratorycosts, review of work planning documents and other documents including a remedialinvestigation, feasibility study, and risk assessment, and review of the pump test and ground watermodeling data. Some of the costs EPA seeks to recover represent funds given directly to IDNRby EPA, to support IDNRs work on the Site. In addition, EPA has expended funds in preparingcost documentation in response to the COOP's challenges and questions

EPA costs are currently estimated to be approximately $300,000 EPA has made severalattempts to settle the matter since 1995 and has met with attorneys representing the COOP onseveral occasions Our original demand for costs was presented to the COOP on August 31,1995, when they were at a level of approximately $215,000 Our discussions at that time failedto settle this matter Two years later, EPA again requested that its past costs be paid but nosettlement was reached The COOP has stated it is financially able to pay the costs and is notdisputing its liability at the site. EPA's understanding of the COOP's position is that EPA costsshould be much lower in a case where the state of Iowa conducted most of the activity.

Because EPA was unable to reach a settlement in this matter, EPA requested the U.S.Department of Justice (DOJ) initiate an action and file a civil complaint for recovery of our pastcosts In an effort to continue discussion with the hope of settling this matter outside of DistrictCourt, we entered into a tolling agreement to provide the parties some additional time. However,that agreement ends on March 31, 2000

In an attempt to settle this case prior to filing a civil complaint, representatives from theDOJ and EPA met with the COOP and their attorneys on February 22, 2000. This has been thefirst time actual representatives from the COOP have participated in discussions with EPA. Atthat time we again stressed our desire to settle this matter We have agreed to conduct furtherdiscussions and exchange information over the next few weeks, again with the hope of settlingthis matter

If we may be of any further assistance, please feel free to contact me at (913) 551-7006 orLaTonya Flint in our Office of External Programs at (913) 551-7003

Sincerely,

Dennis Grams, P ERegional Administrator


CONTROL NO

STATUS:

AL-0000367

PENDING

OR1G. DUE DATE: 03/14/2000


02/04/200002/15/200003/01/2000


TO:TO ORG:SUBJECT:

ASSIGNED:

GRASSLEY CHARLES E.-R/IAUNITED STATES SENATEDEAR SENATOR GRASSLEYPOHLEN.DANIEL


Superfund Division

COPIES OF INCOMING PROVIDED TO: OCIR/MAR1E MULLER. REGION 07

SIGNATURE: REGIONAL ADMINISTRATORR7 COMMENTS:



R7 INSTRUCTIONS: , To coordinate response, contact LaTonya Flint, Ext 7555For General Information, contact OEP, Ext. 7003

Lead

Assigned

SUPR

Date Assigned

03/01/2000

Code/Status

ACTION


-

Date Returned toR7:

-

(Unfitted)


CONTROL NO:

STATUS:


AL-0000367 ORIG. DUE DATE: 02/29/2000EXT. DUE DATE: 03' 14/2000


GRASSLEY CHARLES E.-R/IAUNITED STATES SENATEDEAR SENATOR GRASSLEYPOHLEN,DANIEL

02/04/200002/15/200002/29/2000

TO:TO ORG:SUBJECT:

ASSIGNED:


REGION 07

COPIES OF INCOMING PROVIDED TO: OCIR/MARIK MULLER. REGION 07

SIGNATURE:INSTs:

COMMENTS:



IMS:IMT:


Lud

Assigned

OECA

R7

Date Assigned

02/15/2000

02/29/2000

Code/Status

ACTION

ACTION


-

-


02/29/2000


«""•>UNITED STATES ENVIRONMENTAL PROTECTION AGENCY



MAH 1 L onflfl OFFICE OFF1AK I 0 LUUV THE REGIONAL ADMINISTRATOR



Thank you for your recent inquiry to the EPA on behalf of your constituent Mr. DanielPohlen, of Midwest Farmers COOP, in Hospers, IA Mr Pohlen is concerned with past costsincurred at the Farmers Mutual Cooperative National Priority List site. We have reviewed theletter and additional information presented to you from the COOP This letter provides asummary of the activities at the site and EPA's efforts to settle these matters involving the COOP

BACKROUND

The site involves a facility which was started as the Farmers Mutual COOP of Hospers in1908, and has undergone several expansions since that time On July 1, 1989, the FarmersMutual COOP of Hospers was merged into the Farmers Cooperative Elevator Association ofSheldon, Iowa The company changed its name in January 1997 to Midwest Farmers Cooperative(the COOP). Activities related to grain storage and grain fumigation with pesticides wereconducted at the Facility In 1991, the COOP removed all bulk chemicals from the Facility.

The site on which the Facility is located (the Site) was initially investigated due to thepresence of herbicides and volatile organic compounds (VOCs) in the city of Hospers watersupply Three of the city's wells located adjacent to the Facility were first found to becontaminated in 1984 Results of this early sampling and subsequent sampling of the groundwaterdemonstrated that the Facility was a source of the contamination The city of Hospers has sincebeen prohibited from using these three wells.


RECYCLE

IDNR assumed the lead agency role on the site to oversee the COOP's investigations.EPA was very closely involved at the site in support of the IDNR. In addition, EPA and IDNRconducted an investigation to identify potential contaminant sources not located on COOPproperty and to determine the extent and magnitude of carbon tetrachloride contamination ingroundwater No source of contamination other than the COOP Facility has ever been identified.

After a series of investigative activities, a proposed plan for remediating the site waspresented to the public in May 1991 This plan called for a ground water extraction and treatmentremedy. Significant comments were received from the city and public regarding this plan and insupport of other alternatives Subsequent to acquiring additional data, EPA and IDNR released asecond proposed plan in August 1992 for natural attenuation as a means to remediate the groundwater contamination, a ground water pump test and additional ground water monitoring. TheRecord of Decision for the site was signed by both the EPA Regional Administrator and theDirector of IDNR in September 1992.


COST ASSESSMENT

EPA's costs at this site represent its expenses in conducting the initial investigations andlisting the site on the NPL, separate investigations into other potentially responsible parties andtechnical activities related to supporting IDNR. These technical activities include EPA laboratorycosts, review of work planning documents and other documents including a remedialinvestigation, feasibility study, and risk assessment, and review of the pump test and ground watermodeling data Some of the costs EPA seeks to recover represent funds given directly to IDNRby EPA, to support IDNRs work on the Site In addition, EPA has expended funds in preparingcost documentation in response to the COOP's challenges and questions

EPA costs are currently estimated to be approximately $300,000. EPA has made severalattempts to settle the matter since 1995 and has met with attorneys representing the COOP onseveral occasions. Our original demand for costs was presented to the COOP on August 31,1995, when they were at a level of approximately $215,000 Our discussions at that time failedto settle this matter. Two years later, EPA again requested that its past costs be paid but nosettlement was reached The COOP has stated it is financially able to pay the costs and is notdisputing its liability at the site EPA's understanding of the COOP's position is that EPA costsshould be much lower in a case where the state of Iowa conducted most of the activity.

Because EPA was unable to reach a settlement in this matter, EPA requested the U.SDepanment of Justice (DOJ) initiate an action and file a civil complaint for recovery of our pastcosts In an effort to continue discussion with the hope of settling this matter outside of DistrictCourt, we entered into a tolling agreement to provide the parties some additional time. However,that agreement ends on March 31, 2000.


If we may be of any further assistance, please feel free to contact me at (913) 551-7006 orLaTonya Flint in our Office of External Programs at (913) 551-7003.

Sincerely,


^21 di (I.A B .;..•..

DC- M •.( • IA -,G30y . '40

20f I I M I - A , B .[ •.10- is- S - K I I • SiCi: '" «»>•; • IA 52401 W.II1. 36? 6H'..'

United States SenateCHARLES E G R A S S L F V

WASHINGTON. DC 20blO IbOl

February 4, 2000

.'1C V V A - I » H . : '.'531 ( >.".«(•• .-• ! > • " ( ; •V\ A • [ •-. • IA bC (.'' ' 4^-3 IS 23." 66; '

116 FH I « A . B . [ " • ,131 i f- S- IMI •

>319 32; 4 3 3 1

J07 Fn in*. B .i.f"...8 S . H - M ( , I M S - » M 'COUNLH B..'»s IA51M11 4204|712I 322 7103

Mr. John ReederDeputy Assoc. Admininstrator of Cong. AffairsEnvironmental Protection Agency401 M Street, S.W.9th Floor, West TowerWashington, DC 20460

Dear Mr. Reeder:

I have enclosed a letter from Mr. Daniel Pohlen regarding hisconcern with an EPA decision.

1 would appreciate your assistance in this matter by providingany information that would be helpful to Mr. Pohlen. Please sendyour reply to my Sioux City office, 103 Federal CourthouseBuilding, 320 6:;- Street, Sioux City, Iowa 51101.

Your assistance is appreciated.

Sincerely,

larlesT:.'United States Senator

CEG/waEncl .

FINANCEJUDICIARY

Committee Assignments

AGRICULTUREBUDGET

CHAIRMAN.SPECIAL COMMITTEE ON AGING

POINTED ON RECvCiK

Narrative Regarding the Claim of the Environmental Protection AgencyAgainst Midwest Fanners Cooperative

; Our cooperative purchased the assets of the Fanners Mutual Cooperative at Hospers,Iowa, approximately 10 years ago. At that time, the Hospers Cooperative's site wasidentified as a National Priority List (NPL) site by the United States EnvironmentalProtection Agency (EPA). This site was contaminated with pesticides, fertilizers andcertain other contaminants. Our cooperative and our attorneys have had very littledirect contact with the EPA. Tns™^, the Iowa Department of Natural ResourcesCEDNR) was designated as the lead governmental agency by the EPA with respect to thesite. We dealt almost exclusively with the IDNR with respect to this entire proceeding.

After years of testing, work at the site and negotiating with the IDNR, we ultimatelyresolved the proceeding and met all the responsibilities imposed upon us. A Record ofDecision was issued, and the EPA concurred with all aspects of it and the otheragreements reached with the IDNR. Based on anticipated results from the most recentround of testing, we now expect that this site may be eligible for removal from theNPL. The City of Hospers now has rural water and all nearby wells have been sealed.

In August of 1995, the EPA presented a claim against our cooperative for$214,007.17! By adding interest and additional, "subsequently discovered" costs, theEPA now asserts that it is owed $298,798. EPA claims these amounts asreimbursements for its "costs" in the NPL proceeding. Needless to say, we wereshocked. Sines IDNR did almost everything, we cannot understand, nor do webelieve, that the EPA claim is proper, ethical or accurate. The IDNR's claim for costreimbursements was approximately 550,000, over $200,000 less than the amount theEPA now claims from our cooperative. Whatever real costs the EPA has in thisproceeding should be well below the IDNR's costs. Please recall that the IDNRhandled virtually the entire case. It is inconceivable that the costs of the agencyoverseeing the IDNR would be several times the cost that the IDNR expended.

Our cooperative has expended several hundred thousand dollars to address this matter.Please understand that we (this cooperative) did not have anything to do with causingthe contamination. We continued the monitoring plan when we purchased the site fromthe Hospers Cooperative many yean ago. In addition, the Hospers Cooperative wasnever proven to be the actual sources, as there are several government grain binsadjacent to the site, plus other businesses, any one of which may have handled certaincontaminants.

Given the condition of the farm economy and grain prices, we cannot justify to our1,971 members payment of this claim to the EPA. It is patently excessive. The EPAsimply did not involve itself with respect to this matter. These dollars will comedirectly out of the farmers' pockets and will also restrict the ability to retire equity,which is farmer-owned. The past expenses arc one of the factors that led the HospersCooperative to sell its assets in the first place. Please help us to significantly reduce or

eliminate this improper EPA claim against us. For purposes of identification, thefollowing identifies the proceeding and the improper EPA claim:

Site: Farmers Mutual Coop Company, Hospers, IAEPA Site ID: 07 Q8

^7>€>v-*i

-^x^*^0*^* / '/~v »

I | UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

'"' Pwo'i° REGION VII901 N. 5TH STREET


MAP 1 6 2000OFFICE OF

THE REGIONAL ADMINISTRATOR


Dear Senator Grassley:

Thank you for your recent inquiry to the EPA on behalf of your constituent Mr Ellis FHein, of Midwest Farmers COOP, in Sheldon, IA Mr Hein is concerned with past costs incurredat the Farmers Mutual Cooperative National Priority List site We have reviewed the letter andadditional information presented to you from the COOP This letter provides a summary of theactivities at the site and EPA's efforts to settle these matters involving the COOP

BACKROUND




RECYCLE/*

Because EPA was unable to reach a settlement in this matter, EPA requested the USDepartment of Justice (DOJ) initiate an action and file a civil complaint for recovery of our pastcosts In an effort to continue discussion with the hope of settling this matter outside of DistrictCourt, we entered into a tolling agreement to provide the parties some additional time. However,that agreement ends on March 31, 2000.

In an attempt to settle this case prior to filing a civil complaint, representatives from theDOJ and EPA met with the COOP and their attorneys on February 22, 2000. This has been thefirst time actual representatives from the COOP have participated in discussions with EPA Atthat time we again stressed our desire to settle this matter We have agreed to conduct furtherdiscussions and exchange information over the next few weeks, again with the hope of settlingthis matter


Sincerely,


IDNR assumed the lead agency role on the site to oversee the COOP's investigations.EPA was very closely involved at the site in support of the IDNR. In addition, EPA and IDNRconducted an investigation to identify potential contaminant sources not located on COOPproperty and to determine the extent and magnitude of carbon tetrachloride contamination ingroundwater. No source of contamination other than the COOP Facility has ever been identified.

After a series of investigative activities, a proposed plan for remediating the site waspresented to the public in May 1991 This plan called for a ground water extraction and treatmentremedy Significant comments were received from the city and public regarding this plan and insupport of other alternatives Subsequent to acquiring additional data, EPA and IDNR released asecond proposed plan in August 1992 for natural attenuation as a means to remediate the groundwater contamination, a ground water pump test and additional ground water monitoring TheRecord of Decision for the site was signed by both the EPA Regional Administrator and theDirector of IDNR in September 1992

The COOP subsequently conducted a ground water pump test and significant additionalmonitoring. This included preparation of work planning and design documents. This work wasoverseen by IDNR and EPA Based upon these tests and the additional data, a decision was madenot to pursue blending of the water from the various city water supply wells for public watersupply purposes, rather the city was connected to a rural water system in 1996

COST ASSESSMENT

EPA's costs at this site represent its expenses in conducting the initial investigations andlisting the site on the NPL, separate investigations into other potentially responsible parties andtechnical activities related to supporting IDNR. These technical activities include EPA laboratorycosts, review of work planning documents and other documents including a remedialinvestigation, feasibility study, and risk assessment, and review of the pump test and ground watermodeling data Some of the costs EPA seeks to recover represent funds given directly to IDNRby EPA, to support IDNRs work on the Site. In addition, EPA has expended funds in preparingcost documentation in response to the COOP's challenges and questions

EPA costs are currently estimated to be approximately $300,000. EPA has made severalattempts to settle the matter since 1995 and has met with attorneys representing the COOP onseveral occasions Our original demand for costs was presented to the COOP on August 31,1995, when they were at a level of approximately $215,000 Our discussions at that time failedto settle this matter Two years later, EPA again requested that its past costs be paid but nosettlement was reached The COOP has stated it is financially able to pay the costs and is notdisputing its liability at the site EPA's understanding of the COOP's position is that EPA costsshould be much lower in a case where the state of Iowa conducted most of the activity.


CONTROL NO

STATUS:

AL-0000428

PENDING



01/25/200002/22/200003/01/2000


TO:TO ORG:SUBJECT:

ASSIGNED:

GRASSLEY CHARLES E.-R/IAUNITED STATES SENATEDEAR SENATOR GRASSLEYHEIN.ELLIS

CLAIM OF THE ERA AGAINST MIDWEST FARMERS COOPERATIVE

Superfund Division


SIGNATURE: REGIONAL ADMINISTRATORR7 COMMENTS:


SEND "HARD" COPY OF SIGNED, DATED REPLY ALONG WITH ORIGINALCONTROL SLIP TO MYRTLE LASHLEY (1304) HEADQUARTERS FAXEDCOPY ACCEPTABLE (FAX # 202/260-8866).

R7 INSTRUCTIONS: ; To coordinate response, contact LaTonya Flint, Ext 7555For General Information, contact OEP, Ext. 7003

Lead

Assigned

SUPR

Dale Assigned

03/01/2000

Code/Status

ACTION


-

Date Returned toR7:

-

(Unfitted)

1OFFICE OF CONGRESSIONAL AND INTERGOVERNMENTAL RELATIONS

CORRESPONDENCE CONTROL SLIP

CONTROL NO:

STATUS:

AL-0000428 OR1G. DUE DATE: 03/07/2000EXT. DUE DATE: 03/14/2000


GRASSLEY CHARLES E.-R/IAUNITED STATES SENATEDEAR SENATOR GRASSLEYHEIN.ELLIS

01/25/200002/22/200002/29/2000


TO:TO ORG:SUBJECT: CLAIM OF THE EPA AGAINST MIDWEST FARMERS COOPERATIVE

ASSIGNED: REGION 07


SIGNATURE:INSTs:

COMMENTS:

IMS:IMT:


SEND "HARD" COPY OF SIGNED, DATED REPLY ALONG WITH ORIGINALCONTROL SLIP TO MYRTLE LASHLEY (1304) HEADQUARTERS. FAXEDCOPY ACCEPTABLE (FAX # 202/260-8866).


LMd

Assigned

OECA

R7

Date Assigned

02/22/2000

02/29/2000

Code/Status

ACTION

ACTION


-

-


02/29/2000






The Honorable Charles GrassleyUnited States Senator103 Federal Courthouse Building320 6* StreetDes Moines, Iowa SI 101


Thank you for your recent inquiry to the EPA on behalf of your constituent Mr DaleHansen, of Midwest Farmers COOP, in Sheldon, I A. Mr Hansen is concerned with past costsincurred at the Farmers Mutual Cooperative National Priority List site We have reviewed theletter and additional information presented to you from the COOP This letter provides asummary of the activities at the site and EPA's efforts to settle these matters involving the COOP

BACKROUND

The site involves a facility which was started as the Farmers Mutual COOP of Hospers in1908, and has undergone several expansions since that time On July 1, 1989, the FarmersMutual COOP of Hospers was merged into the Farmers Cooperative Elevator Association ofSheldon, Iowa The company changed its name in January 1997 to Midwest Farmers Cooperative(the COOP). Activities related to grain storage and grain fumigation with pesticides wereconducted at the Facility In 1991, the COOP removed all bulk chemicals from the Facility

The site on which the Facility is located (the Site) was initially investigated due to thepresence of herbicides and volatile organic compounds (VOCs) in the city of Hospers watersupply Three of the city's wells located adjacent to the Facility were first found to becontaminated in 1984 Results of this early sampling and subsequent sampling of the groundwaterdemonstrated that the Facility was a source of the contamination The city of Hospers has sincebeen prohibited from using these three wells


RECYCLE^

IDNR assumed the lead agency role on the site to oversee the COOP's investigations.EPA was very closely involved at the site in support of the IDNR. In addition, EPA and IDNRconducted an investigation to identify potential contaminant sources not located on COOPproperty and to determine the extent and magnitude of carbon tetrachloride contamination ingroundwater. No source of contamination other than the COOP Facility has ever been identified.

After a series of investigative activities, a proposed plan for remediating the site waspresented to the public in May 1991 This plan called for a ground water extraction and treatmentremedy Significant comments were received from the city and public regarding this plan and insupport of other alternatives Subsequent to acquiring additional data, EPA and IDNR released asecond proposed plan in August 1992 for natural attenuation as a means to remediate the groundwater contamination, a ground water pump test and additional ground water monitoring. TheRecord of Decision for the site was signed by both the EPA Regional Administrator and theDirector of IDNR in September 1992

The COOP subsequently conducted a ground water pump test and significant additionalmonitoring. This included preparation of work planning and design documents. This work wasoverseen by IDNR and EPA Based upon these tests and the additional data, a decision was madenot to pursue blending of the water from the various city water supply wells for public watersupply purposes, rather the city was connected to a rural water system in 1996.

COST ASSESSMENT

EPA's costs at this site represent its expenses in conducting the initial investigations andlisting the site on the NPL, separate investigations into other potentially responsible parties andtechnical activities related to supporting IDNR. These technical activities include EPA laboratorycosts, review of work planning documents and other documents including a remedialinvestigation, feasibility study, and risk assessment, and review of the pump test and ground watermodeling data. Some of the costs EPA seeks to recover represent funds given directly to IDNRby EPA, to support IDNRs work on the Site. In addition, EPA has expended funds in preparingcost documentation in response to the COOP's challenges and questions

EPA costs are currently estimated to be approximately $300,000. EPA has made severalattempts to settle the matter since 1995 and has met with attorneys representing the COOP onseveral occasions. Our original demand for costs was presented to the COOP on August 31,1995, when they were at a level of approximately $215,000 Our discussions at that time failedto settle this matter Two years later, EPA again requested that its past costs be paid but nosettlement was reached The COOP has stated it is financially able to pay the costs and is notdisputing its liability at the site. EPA's understanding of the COOP's position is that EPA costsshould be much lower in a case where the state of Iowa conducted most of the activity.

Because EPA was unable to reach a settlement in this matter, EPA requested the U.S.Department of Justice (DOJ) initiate an action and file a civil complaint for recovery of our pastcosts. In an effort to continue discussion with the hope of settling this matter outside of DistrictCourt, we entered into a tolling agreement to provide the parties some additional time. However,that agreement ends on March 31, 2000.





CONTROL NO

STATUS:

AL-0000515

PENDING



02/23/200002/29/200003/02/2000


TO:TO ORG:SUBJECT:

ASSIGNED:

GRASSLEY CHARLES E.-R/IAUNITED STATES SENATEDEAR SENATOR GRASSLEYHANSEN.DALE

EPA AGAINST THE MIDWEST FARMERS COOPERATIVE

Supcrfund Division

COPIES OF INCOMING PROVIDED TO: OCIR/MARIE MULLER. OFFICE OF ENFORCEMENT &COMPLIANCE ASSURANCE





R7 INSTRUCTIONS: ; To coordinate response, contact LaTonya Flint. Ext 7555For General Information, contact OEP. Ext 7003

(Lead

Assigned

SUPR

Date Assigned

03/02/2000

Code/Status

ACTION


-

Date Returned toR7:

-

(Unfitted)

OEPAOFFICE OF CONGRESSIONAL AND INTERGOVERNMENTAL RELATIONS


CONTROL NO:

STATUS:


TO:TO ORG:SUBJECT:

ASSIGNED:

AL-0000515 ORIG. DUE DATE: 03/14/2000


GRASSLEY CHARLES E.-R/IAUNITED STATES SENATEDEAR SENATOR GRASSLEYHANSEN.DALE

02/23/200002/29/200002/29/2000

KPA AGAINST THE MIDWEST F A R M E R S COOPERATIVE

REG ION 07

COPIES OF INCOMING PROVIDED TO: OCIR M A R I E MULLER, OFFICE OF ENFORCEMENT &COMPLIANCE ASSURANCE

SIGNATURE:INSTs:


SEND "HARD" COPY OF SIGNED. DATED REPLY ALONG WITH ORIGINALCONTROL SLIP TO MYRTLE LASHLEY (1304) HEADQUARTERS FAXEDCOPY ACCEPTABLE (FAX « 202 260-8866).

COMMENTS:

IMSIM1

L«M

>: CASSAUNDRA EADESf: CASSAUNDRA EADES/DC/USEPA/US

Assigned

R7

Date Assigned

02/29/2000

Code/Status

ACTION


-


-

AL Correspondence - Control No: AL-0000515

I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY



MAR 1 f] 2000 OFFICE OF\\i-\\\ u (- THE REGIONAL ADMINISTRATOR



Thank you for your recent inquiry to the EPA on behalf of your constituent Mr. StanDibbet, of Midwest Farmers COOP, in Hospers, IA. Mr Dibbet is concerned with past costsincurred at the Farmers Mutual Cooperative National Priority List site We have reviewed theletter and additional information presented to you from the COOP This letter provides asummary of the activities at the site and EPA's efforts to settle these matters involving the COOP

BACKROUND

The site involves a facility which was started as the Farmers Mutual COOP of Hospers in1908, and has undergone several expansions since that time On July 1, 1989, the FarmersMutual COOP of Hospers was merged into the Farmers Cooperative Elevator Association ofSheldon, Iowa The company changed its name in January 1997 to Midwest Farmers Cooperative(the COOP) Activities related to grain storage and grain fumigation with pesticides wereconducted at the Facility In 1991, the COOP removed all bulk chemicals from the Facility.

The site on which the Facility is located (the Site) was initially investigated due to thepresence of herbicides and volatile organic compounds (VOCs) in the city of Hospers watersupply Three of the city's wells located adjacent to the Facility were first found to becontaminated in 1984. Results of this early sampling and subsequent sampling of the groundwaterdemonstrated that the Facility was a source of the contamination The city of Hospers has sincebeen prohibited from using these three wells.


RECYCLE v*


After a series of investigative activities, a proposed plan for remediating the site waspresented to the public in May 1991. This plan called for a ground water extraction and treatmentremedy. Significant comments were received from the city and public regarding this plan and insupport of other alternatives. Subsequent to acquiring additional data, EPA and IDNR released asecond proposed plan in August 1992 for natural attenuation as a means to remediate the groundwater contamination, a ground water pump test and additional ground water monitoring. TheRecord of Decision for the site was signed by both the EPA Regional Administrator and theDirector of IDNR in September 1992

The COOP subsequently conducted a ground water pump test and significant additionalmonitoring. This included preparation of work planning and design documents. This work wasoverseen by IDNR and EPA Based upon these tests and the additional data, a decision was madenot to pursue blending of the water from the various city water supply wells for public watersupply purposes, rather the city was connected to a rural water system in 1996.

COST ASSESSMENT

EPA's costs at this site represent its expenses in conducting the initial investigations andlisting the site on the NPL, separate investigations into other potentially responsible parties andtechnical activities related to supporting IDNR. These technical activities include EPA laboratorycosts, review of work planning documents and other documents including a remedialinvestigation, feasibility study, and risk assessment, and review of the pump test and ground watermodeling data Some of the costs EPA seeks to recover represent funds given directly to IDNRby EPA, to support IDNRs work on the Site. In addition, EPA has expended funds in preparingcost documentation in response to the COOP's challenges and questions.

EPA costs are currently estimated to be approximately $300,000 EPA has made severalattempts to settle the matter since 1995 and has met with attorneys representing the COOP onseveral occasions Our original demand for costs was presented to the COOP on August 31,1995, when they were at a level of approximately $215,000 Our discussions at that time failedto settle this matter. Two years later, EPA again requested that its past costs be paid but nosettlement was reached. The COOP has stated it is financially able to pay the costs and is notdisputing its liability at the site EPA's understanding of the COOP's position is that EPA costsshould be much lower in a case where the state of Iowa conducted most of the activity.

Because EPA was unable to reach a settlement in this matter, EPA requested the U.S.Department of Justice (DOJ) initiate an action and file a civil complaint for recovery of our pastcosts In an effort to continue discussion with the hope of settling this matter outside of DistrictCourt, we entered into a tolling agreement to provide the parties some additional time However,that agreement ends on March 31, 2000

In an attempt to settle this case prior to filing a civil complaint, representatives from theDOJ and EPA met with the COOP and their attorneys on February 22, 2000 This has been thefirst time actual representatives from the COOP have participated in discussions with EPA. Atthat time we again stressed our desire to settle this matter We have agreed to conduct furtherdiscussions and exchange information over the next few weeks, again with the hope of settlingthis matter


Sincerely,



CONTROL NO

STATUS:

AL-0000366

PENDING

OR1G. DUE DATE: 03/14/2000


02/04/200002/15/200003/01/2000


TO:TO ORG:SUBJECT:

ASSIGNED:

GRASSLEY CHARLES E -R/IAUNITED STATES SENATEDEAR SENATOR GRASSLEYD1BBET.STAN

CLAIMS OF THE EPA AGAINST MIDWEST FARMERS COOPERATIVE

Superfund Division




AL INSTRUCTIONS: SEND RESPONSE TO STATE OFFICE AS REQUESTED.


R7 INSTRUCTIONS: , To coordinate response, contact LaTonya Flint, Ext 7555For General Information, contact OEP, Ext 7003

[Lead

Assigned

SUPR

Date Assigned

03/01/2000

Code/Status

ACTION


-

Date Returned toR7 :

-

(Unfitted)


CONTROL NO:

STATUS:

A1.-0000366 ORIG. DUE DATE: 02/29/2000EXT. DUE DATE: 03/14/2000


GRASSLEY CHARLES E.-R/1AUNITED STATES SENATEDEAR SENATOR GRASSLEYDIBBET.STAN

02/04/200002/15/200002/29/2000


TO:TO ORG:SUBJECT: CLAIMS OF THE EPA AGAINST MIDWEST FARMERS COOPERATIVE

ASSIGNED: REGION 07


SIGNATURE:INSTs:

COMMENTS:

IMS:1MT:


SEND "HARD" COPY OF SIGNED. DATED REPLY ALONG WITH ORIGINALCONTROL SLIP TO MYRTLE LASHLEY (1304) HEADQUARTERS. FAXEDCOPY ACCEPTABLE (FAX # 202/260-8866).


LMd

Assigned

OECA

R7

Date Assigned

02/15/2000

02/29/2000

Code/Status

ACTION

ACTION


-

-


02/29/2000





.. . r, . , , OFFICE OF'"'"'' :: '•, THE REGIONAL ADMINISTRATOR

The Honorable Tom HarkinUnited States Senator210 Walnut Street733 Federal BuildingDes Moines, Iowa 50309

Attn John Mooreland

Dear Senator Harkin:

Thank you for your recent inquiry to the EPA on behalf of your constituent Mr Ellis FHein, of Midwest Farmers COOP, in Sheldon, IA. Mr. Hein is concerned with past costs incurredat the Farmers Mutual Cooperative National Priority List site We have reviewed the letter andadditional information presented to you from the COOP This letter provides a summary of theactivities at the site and EPA's efforts to settle these matters involving the COOP

BACKROUND

The site involves a facility which was started as the Farmers Mutual COOP of Hospers in1908, and has undergone several expansions since that time On July 1, 1989, the FarmersMutual COOP of Hospers was merged into the Farmers Cooperative Elevator Association ofSheldon, Iowa. The company changed its name in January 1997 to Midwest Farmers Cooperative(the COOP) Activities related to grain storage and grain fumigation with pesticides wereconducted at the Facility In 1991, the COOP removed all bulk chemicals from the Facility

The site on which the Facility is located (the Site) was initially investigated due to thepresence of herbicides and volatile organic compounds (VOCs) in the city of Hospers watersupply Three of the city's wells located adjacent to the Facility were first found to becontaminated in 1984. Results of this early sampling and subsequent sampling of the groundwaterdemonstrated that the Facility was a source of the contamination The city of Hospers has sincebeen prohibited from using these three wells.


RECYCLE**


After a series of investigative activities, a proposed plan for remediating the site waspresented to the public in May 1991. This plan called for a ground water extraction and treatmentremedy. Significant comments were received from the city and public regarding this plan and insupport of other alternatives. Subsequent to acquiring additional data, EPA and IDNR released asecond proposed plan in August 1992 for natural attenuation as a means to remediate the groundwater contamination, a ground water pump test and additional ground water monitoring. TheRecord of Decision for the site was signed by both the EPA Regional Administrator and theDirector of IDNR in September 1992


COST ASSESSMENT


EPA costs are currently estimated to be approximately $300,000 EPA has made severalattempts to settle the matter since 1995 and has met with attorneys representing the COOP onseveral occasions Our original demand for costs was presented to the COOP on August 31,1995, when they were at a level of approximately $215,000 Our discussions at that time failedto settle this matter. Two years later, EPA again requested that its past costs be paid but nosettlement was reached The COOP has stated it is financially able to pay the costs and is notdisputing its liability at the site. EPA's understanding of the COOP's position is that EPA costsshould be much lower in a case where the state of Iowa conducted most of the activity.

Because EPA was unable to reach a settlement in this matter, EPA requested the U.SDepartment of Justice (DOJ) initiate an action and file a civil complaint for recovery of our pastcosts. In an effort to continue discussion with the hope of settling this matter outside of DistrictCourt, we entered into a tolling agreement to provide the parties some additional time. However,that agreement ends on March 31, 2000



sincerely,

Dennis Grams, P.ERegional Administrator

CONTROL NO

STATUS:


Congressional

R7-O000020-C

PENDING



02/04/200002/08/200002/09/2000

FROM: TOM HARKINORG:SALUTATION:CONSTITUENT: ELLIS F HEIN

TO:TO ORG:SUBJECT: NATIONAL PRIORITY LIST SITE

ASSIGNED: Supcrfund Division

COPIES OF INCOMING PROVIDED TO:


R7 INSTRUCTIONS:

To coordinate response, contact LaTonva Flint. Ext 7555For General Information, contact OEP. Ext 7003

Lead

Assigned

SUPR

Date Assigned

02/09/2000

Code/Status

ACTION


-

Date Relumed toR7:

-

(Unfitted)

TOM HARKIN .;c: ;;« 32^4IC-AA ••"• •;:: ..« 4633

United States SenateWASHINGTON. DC 20510 160? S,.,A.. P ^-uss

i/.HGh AM: HUMAN

February 4, 2000

ftfl 08Dennis GramsRegional AdministratorEnvironmental Protection Agency726 Minnesota AvenueKansas City, KS 66101

Dear Mr. Grams:

I have been contacted by Ellis F. Hein, of Midwest FarmersCooperative of Sheldon, Iowa, requesting my assistance regardinga claim the EPA has made against this farmer-owned coop foradministrative expenses relating to a National Priority Listsite.

Please find enclosed a copy of the correspondence which Ihave received related to this matter. I appreciate your reviewof the issues raised by this constituent and ask that you forwardyour response to the attention of John Moreland in my Des Moinesoffice listed below.

Sircerelv,

Tom Hark inUnited States Senator

TH/jnm

l f .C F I H S T A . F N U S M 210 W A L N U T S ' 1 3 1 E 4 T M S ' 3SD WE S 1 6 !H ST 3 2 0 6 T H S TSUlT f TO >33KDtHAl BLDC, 314B FEOf HAl Hi D>, 3lf FF DF RAi BLDG 1 10 f EOf RAL BlDG

C f U A M hAIX;s IA -,2*0 ' 48M Df S MOINES IA 5,030?- DAVE NPORT ,.-. ' w [iUBUOUt I.'. S.'OOi SIC),; x rr 1 IA Jl 101, 3 1 9 ' 36S 4b04 i 5 1 5 i ? B 4 4 6 7 4 1319' 322 133h . 3 ' 9 b H 7 2 1 3 C ' ' 1 2 . 7 5 2 1 5 S O

F A R M E R S C O O P

PO Box 128, She ldon . lA 51201PHONE 71 2-324-2548 1-800-945-8368 FAX 712-324-5297

January 17, 2000

TO: Senator Tom HarkinSenator Charles CrasslyCongressman Tom Latham

Gentlemen:

I am requesting your assistance and influence in what I considera serious case of uncontrolled power by EPA. I am attaching anarrative of a scenario covering two decades and now an additional$300,000 charge of interest and supposed staff involved overheadexpenses. These charges, in my opinion, border on fraud and certainlyare unfounded!

As the narrative outlines, hundreds of thousands of dollars havebeen paid by our company and portions of our company that mergedtogether in 1989. The EPA made one visit to the site and turned thesupervisory, monitoring, and on-going work over to the Iowa Departmentof Natural Resources as the lead agency. This cost Hospers and thecompanies making up Midwest a total of $50,000. Now, the EPA isforcing Judicial Action for nearly $300,000.

How can a tax supported, public funded division charge staffoverhead when they were not the lead enforcement body and then five tosix times more than the designated group who did the work on the entireproject?

Our cooperative has met and exceeded all DNR, Hospers community,and on-going testing requests. We now have a three year record ofbelow threshold levels requiring action and are eligible to be removedfrom the National EPA Listing.

Over two and one-half years ago, our cooperative offered to settlefor the same $50,000 figure payable to the Iowa DNR for the totalproject supervision and testing. We feel this is fair but consider$300,000 for one trip to the site an example of "government out ofcontrol". One cooperative was bankrupt and forced out of businessalready. Is it governments' goal to push our cost to $1,000,000 andjeopardize another one?

Your assistance would be appreciated by our over 1900 farmer-owners who could use the $300,000 in the form of retained equity payoutin these difficult times in agriculture.

Sincerely,

Ellis F. HeinGeneral ManagerphEnclosure

Narrative Regarding the Claim of the Environmental Protection AgencyAgainst Midwest Fanners Cooperative

Our cooperative purchased the assets of the Farmers Mutual Cooperative at Hospers,Iowa, approximately 10 years ago. At that time, the Eospers Cooperative's site wasidentified as a National Priority List (NPL) site by the United States EnvironmentalProtection Agency (EPA). This site was contaminated with pesticides, fertilizers andggmin other contaminants. Our cooperative and cur attorneys have had very littledirect contact with the EPA. Instead, the Iowa Department of Natural Resources(IDNR) was designated as the lead governmental agency by the EPA with respect to theshe. We dealt almost exclusively with the IDNR with respect to this entire proceeding.

After years of testing, work at the site and negotiating with the IDNR, we ultimatelyresolved the proceeding and met all the responsibilities imposed upon us. A Record ofDecision was issued, and the EPA concurred with all aspects of it and the otheragreements reached with the IDNR. Based on anticipated results from the most recentround of testing, we now expect that this site may be eligible for removal from theNPL. The Cry of Eospers now has rural water and all nearby wells have been sealed.

In August of 1995, the EPA presented a claim against our cooperative for5214,007. 17! By adding interest and additional, •subsequently discovered" costs, theEPA now asserts that it is owed 5298,793. EPA claims these amounts asreimbursements for hs "costs" in the NPL proceeding. Needless to say, we wereshocked. Since IDNR did almost everything, we cannot understand, nor do webelieve, that the EPA claim is proper, ethical or accurate. The IDNR's claim for costreimbursements was approximately 550,000, over 5200,000 less than the amount theEPA now claims from our cooperative. Whatever real costs the EPA has in thisproceeding should be well below the IDNR's costs. Please recall that the IDNRhandled virtually the entire case. It is inconceivable that the costs of the agencyoverseeing the IDNR would be several times the cost that the IDNR expended.

Our cooperative has expended several hundred thousand dollars to address this matter.Please understand that we (this cooperative) did not have anything to do with causingthe contamination. We continued the monitoring plan when we purchased the site fromthe Eospers Cooperative many years ago. In addition, the Eospers Cooperative wasnever proven to be the actual sources, as there are several government grain binsadjacsnt to the site, plus other businesses, any one of which may have handled certain

Given the condition of the farm economy and grain prices, we cannot justify to our1,971 members payment of this claim to the EPA. It is patently excessive. The EPAsimply did net involve itself with respect to this imftgr These dollars wfll comedirectly out of the farmers' pockets and win also restrict the ability to retire equity,which is farmer-owned. The past expenses arc one of the factors that led the HospersCooperative to sell its assets in the first place. Please help us to significantly reduce or

eliminate this improper EPA claim against us. For purposes of identification, thefollowing identifies the proceeding and the improper EPA claim:

Site: Farmen Mutual Coop Company, Hospers, IAEPA Site ID: 07 Q8

? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

""' ""^ REGION VII901 N. 5TH STREET



The Honorable Tom LathamMember, U.S Congress324 Cannon BuildingWashington, DC 20515

Dear Representative Latham

Thank you for your recent inquiry to the EPA on behalf of your constituent, MidwestFarmers COOP, in Hospers, I A. This letter provides a summary of the activities at the site andEPA's efforts to settle these matters involving the COOP

BACKROUND




RECYCLE**

IDNR assumed the lead agency role on the site to oversee the COOP's investigations.EPA was very closely involved at the site in support of the IDNR In addition, EPA and IDNRconducted an investigation to identify potential contaminant sources not located on COOPproperty and to determine the extent and magnitude of carbon tetrachloride contamination ingroundwater No source of contamination other than the COOP Facility has ever been identified.

After a series of investigative activities, a proposed plan for remediating the site waspresented to the public in May 1991 This plan called for a ground water extraction and treatmentremedy Significant comments were received from the city and public regarding this plan and insupport of other alternatives Subsequent to acquiring additional data, EPA and IDNR released asecond proposed plan in August 1992 for natural attenuation as a means to remediate the groundwater contamination, a ground water pump test and additional ground water monitoring. TheRecord of Decision for the site was signed by both the EPA Regional Administrator and theDirector of IDNR in September 1992


COST ASSESSMENT


EPA costs are currently estimated to be approximately $300,000 EPA has made severalattempts to settle the matter since 1995 and has met with attorneys representing the COOP onseveral occasions Our original demand for costs was presented to the COOP on August 31,1995, when they were at a level of approximately $215,000 Our discussions at that time failedto settle this matter Two years later, EPA again requested that its past costs be paid but nosettlement was reached The COOP has stated it is financially able to pay the costs and is notdisputing its liability at the site EPA's understanding of the COOP's position is that EPA costsshould be much lower in a case where the state of Iowa conducted most of the activity

Because EPA was unable to reach a settlement in this matter, EPA requested the US.Department of Justice (DOJ) initiate an action and file a civil complaint for recovery of our pastcosts In an effort to continue discussion with the hope of settling this matter outside of DistrictCourt, we entered into a tolling agreement to provide the parties some additional time. However,that agreement ends on March 31, 2000



Sincerely,



CONTROL NO

STATUS:

AL-0000338

PENDING



02/10/200002/14/200003/01/2000


TO:TO ORG:SUBJECT:

ASSIGNED:

LATHAM TOM-R/IAU.S. HOUSE OF REPRESENTATIVESDEAR CONGRESSMAN LATHAM

SIGNIFICANT CLAIM FILED BY EPA AGAINST MIDWEST FARMERSCOOPERATIVE

Supcrfund Division

COPIES OF INCOMING PROVIDED TO: ADMINISTRATOR, DEPUTY ADMINISTRATOR,OCIR/MARIE MULLER, PREVENTION, PESTICIDE & TOXIC S, REGION 07



AL INSTRUCTIONS: SEND "HARD" COPY OF SIGNED, DATED REPLY ALONG WITH ORIGINALSLIP TO MYRTLE LASHLEY (1304) HEADQUARTERS FAXED COPYACCEPTABLE (FAX # 202/260-8866)

R7 INSTRUCTIONS: , To coordinate response, contact LaTonya Flint, Ext 7555For General Information, contact OEP, Ext. 7003

Lead

Assigned

SUPR

Date Assigned

03/01/2000

Code/Status

ACTION


-

Date Returned toR7:

-

(UnMIed)

OEPAOFFICE OF CONGRESSIONAL AND INTERGOVERNMENTAL RELATIONS


CONTROL NO:

STATUS:


AL-0000338 OR1G. DUE DATE: 02/28/2000EXT. DUE DATE: 03/14/2000


LATHAM TOM-R/IAU.S. HOUSE OF REPRESENTATIVESDEAR CONGRESSMAN LATHAM

02/10/200002/14'200002/29/2000

TO:TO ORG:SUBJECT: SIGNIFICANT CLAIM FILED BY EPA AGAINST MIDWEST FARMERS

COOPERATIVE

ASSIGNED: REGION 07

COPIES OF INCOMING PROVIDED TO: ADMINISTRATOR, DEPUTY ADMINISTRATOR.OCIR'MARIE MULLER, PREVENTION.PESTICIDE & TOXIC S. REGION 07

SIGNATURE:INSTs:

COMMENTS:

REGIONAL ADMINISTRATORSEND "HARD" COPY OF SIGNED. DATED REPLY ALONG WITH ORIGINALSLIP TO MYRTLE LASHLEY (1304) HEADQUARTERS. FAXED COPYACCEPTABLE (FAX # 202/260-8866)

IMS:IMT:


l«»d

Assigned

OECA

R7

Date Assigned

02/14/2000

02/29/2000

Code/Status

ACTION

ACTION


-

-


02/29/2000


controlled correspondence for r7 regional administrator

Documents