Moving Beyong Compliance: Developing Remediation Strategies to Minimize Total Liability

摘要

Remediation is often performed in response to regulatory drivers, with the intention of achieving closure based on the attainment of cleanup goals established by those drivers. RCRA Corrective Action is typically performed under a prescriptive process that focuses on identification, investigation, and remediation of contaminated media based on risk to human health. However, performing remediation to achieve compliance with RCRA or state regulations (i.e., meeting the cleanup goals) does not ensure that all liabilities are minimized. As an example, an off-site migration of contaminated ground water could result in litigation from third parties, despite the remediation effort being in compliance with regulations.