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    Lauren617
    E2790 Event question #5: RCRA Sites
    Topic posted October 6, 2011 by Lauren617Elite Contributor, last edited January 19, 2012
    311 Views, 1 Comment
    Title:
    E2790 Event question #5: RCRA Sites
    Content:

    Has EPA weighed in on what this means for RCRA sites? 

    Comment

     

    • Tim Haley
      posted October 7, 2011 by Tim HaleyMember

      Not to my knowledge. 

      I don't think the CERCLA liability protections will apply directly to the RCRA context, so if you are purchasing a site subject that was a former TSD or former interim status facility and may be subject to RCRA Corrective Action you should take care to allocate financial responsibility in the purchase documents. 

      RCRA generators should also take care to avoid on-site releases, as those may trigger RCRA Corrective Action requirements, and may jeopardize any CERCLA liability protections.