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CERCLA

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA; aka Superfund) was enacted on December 11, 1980.  CERCLA gives USEPA the authority to clean up uncontrolled hazardous waste sites and assign liability to potentially responsible parties (PRPs).   

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In 1986, the Superfund Amendments and Reauthorization Act (SARA) reauthorized CERCLA.  SARA contained clarifications to the Superfund program, added technical requirements, and expanded USEPA enforcement authority.  SARA Title III also introduced the Emergency Planning and Community Right to Know  Act (EPCRA), which requires reporting and emergency planning for hazardous substances. 

 

In 2002, the Small Business Liability Relief and  Brownfields Revitalization Act (the Brownfields Law) provided liability relief for small business under certain conditions, provided funding to assess and remediate brownfields, and defined the requirements for liability relief under the "Innocent Landowner" provision of CERCLA.  The current "All Appropriate Inquiries" approach to conducting Phase I ESAs under ASTM E1527-13 resulted from the 2002 Amendments to CERCLA and the associated regulations at 40 CFR Part 312.  

CERCLA Experience

I have provided consulting support to numerous clients remediating sites under CERCLA.  My experience includes characterization of sites in accordance with CERCLA analytical requirements, preparation of CERCLA Remedial Investigation Work Plans/Reports, Quality Assurance Project Plans, Risk Assessment Reports, Feasibility Studies, and Remedial Work Plans/Reports.  I have led negotiations with CERCLA regulators and support agencies, and provided public communication on behalf of PRPs. 

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CERCLA sites that I have had significant involvement in include:

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  • Wayne Reclamation and Recycling, Fort Wayne, Indiana,

  • Old Springfield Landfill, Springfield, Vermont,

  • Rockwell Industries, Allegan, Michigan,

  • Morgantown Ordinance Works, Morgantown, West Virginia,

  • Hanlin-Allied-Olin Superfund Site, Moundsville, West Virginia

  • FikeArtel Superfund Site, Nitro, West Virginia,

  • Alcoa Properties, East St. Louis, Illinois, 

  • AVCO Lycoming, Williamsport, Pennsylvania, 

  • American Color and Chemical Corporation, Lock Haven, Pennsylvania.

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