Corrective Action in RCRA Permits: An Emerging Rival to Superfund as the Hot Area for Environmental Lawyers and Consultants

November 1991
Citation:
21
ELR 10666
Issue
11
Author
Richard G. Stoll

Editors'Summary: The passage of CERCLA in 1980 has supported a growing number of environmental professionals. The Act's vague language, expensive cleanup requirements, and strict liability scheme require an army of environmental lawyers, engineers, and scientists. In the next few years, the RCRA corrective action program may begin to rival the CERCLA program. The corrective action program covers many facilities and often requires expensive studies and cleanup. EPA recently issued proposed regulations implementing the RCRA corrective action program, which EPA will apply until a final rule is issued. This Article describes the RCRA corrective action program, including EPA's proposed regulations, and compares it with the CERCLA remedial program.

Mr. Stoll is a partner in the Washington, D.C., firm of Freedman, Levy, Kroll & Simonds. He was formerly Deputy General Counsel for the Chemical Manufacturers Association and Assistant General Counsel of the U.S. Environmental Protection Agency. He is currently Chair of the American Bar Association's Section of Natural Resources, Energy, and Environmental Law.

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Corrective Action in RCRA Permits: An Emerging Rival to Superfund as the Hot Area for Environmental Lawyers and Consultants

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