Attorneys Say EPA Model CERCLA Documents Need Additional Clarity

June 8, 2022
Private-practice attorneys say recently revised EPA model documents for Superfund enforcement agreements are improved from earlier versions but are suggesting the agency provide additional clarity on some aspects, such as authorities to modify remedial actions. During a recent American Bar Association (ABA) webinar, Peter Wright, former head of EPA’s waste office during the Trump administration who now is a partner with Barnes & Thornburg, compared EPA’s August 2021 revamp of its Superfund remedial design/remedial action (RD/RA) consent decree model and...

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