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<br />Brent said Good Sam continues to be a priority issue for the Administrator. He has . <br />testified a number of times in the past few weeks, and always mentions Good Sam. <br /> <br />Lynn Buhl, EPA, clarified that the AOC is CERCLA-oriented, and that the Clean Water <br />Act liability needs to be addressed through legislation. <br /> <br />Q.-With a comfort letter, does the project have to be in compliance with National <br />Contingency Plan (NPC). Answer is "Yes" <br /> <br />Q. - would AOC just be geared to smaller sites since it is for "removal" rather than <br />remediation. A.-- Probably just smaller sites, but it would be up to EP A. It will not <br />include NPL sites. <br /> <br />Q. -Will AOC be streamlined? TV case was very cumbersome! A.-Yes, that is the <br />idea. EP A learning from the TV case. <br /> <br />Q. - Under the AOC, will there be a reopener for unknown conditions. A.-Not in the <br />model being drafted. This is guidance. If it is a complex site, EP A could include a <br />provision to reopen it. <br /> <br />Q.-What is the process for state involvement in the AOC? A.-They are still refining <br />the AOC, and it is not perfect. There will be an opportunity for public comment. <br /> <br />Q.-What are the holes with the AOC, i.e., would legislation have any advantages? . <br />A.-Legislation would provide greater certainty. This Administration is committed to <br />this kind of an effort. Administrations come and go, so no guarantees in the future. <br /> <br />Key Issues in the WGA Strawman <br /> <br />Scope <br /> <br />Rich Nolan-CERCLA remains an important issue for inclusion. The Salazar bill had <br />strong bi-partisan support. NMA would like it to be the starting point for this Congress. <br />They believe Superfund should be included. <br /> <br />Lori Faeth-Given the new Congress, and the strong comments from Committee Chairs <br />that Superfund is not going to happen, would NMA at least look at a CW A-only bill? <br /> <br />Rich Nolan.-would need to look at the bill, and particularly see how the EP A work on <br />AOCs plays out. <br /> <br />Michael Gianotto-Once see EPA's work on AOC, willing to revisit the issue of CW A- <br />focused bill. Mining industry doesn't want to get left holding the bag with these <br />cleanups. Either they won't do it, or the only sites that will get done are smaller sites. <br /> <br />. <br /> <br />2 <br />