Superfund And Small Business Hearing Before the Subcommittee On Development of

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Superfund And Small Business Hearing Before the Subcommittee On Development of
Exports United States Congress House Committee On Small
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Guidance in these areas will be issued during September 1993. Finally, EPA will develop additional guidance regarding how to allocate responsibility among PRPs in the absence of volumetric information. Guidance will be issued during December 1993. " We are encouraged by the tone and substance of this proposed approach by EPA. An idea which can meld the use of ADR and NBARs is to allow the appointed mediator (e. G. A retired Federal judge) to determine that EPA should provide an NBAR to facilita...te a quicker and more reasonable global settlement at that site. But administrative policy modifications, while useful, will not suffice to right this program. There are many aspects associated with Super fund which contribute to its helter skelter nature. Consistency is lacking across a broad front, including site evaluation and remedy selection. Regional offices of EPA differ in their approach and policies. For example, "enforcement first" as EPA's way to show Congress a level of commitment and progress is fine as long as it is not misused by issuing Section 106 enforcement (injunctive) orders in a broad way when no actual emergency is involved.

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