unilateral administrative orders

By Andrew H. Perellis, Philip L. Comella, and Craig B. Simonsen

The U.S. Environmental Protection Agency has recently released its “Revised Policy on Managing the Duration of Remedial Design/Remedial Action Negotiations” (Revised Policy). The Revised Policy contains the Office of Site Remediation Enforcement’s (OSRE) procedures for reducing the duration of remedial design/remedial action (RD/RA) negotiations. The stated
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