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ARTICLE · 09 JANUARY 2013

Environmental Due Diligence Issues Clarified By EPA For 2013 And Beyond - Tenants And Other Operators Beware

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This Alert updates you on newly released U.S. Environmental Protection Agency (EPA) guidance relevant to help manage environmental liabilities and develop closure strategies for contaminated sites.

United StatesEnvironment
David Gillay
David Gillay
Charles Denton
Charles Denton
Susan Bodine
Susan Bodine
Joel Bowers
Joel Bowers
Timothy Haley
Timothy Haley
Bruce White
Bruce White
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This Alert updates you on newly released U.S. Environmental Protection Agency (EPA) guidance relevant to help manage environmental liabilities and develop closure strategies for contaminated sites. These new guides are: Revised Enforcement Guidance Regarding the Treatment of Tenants Under the CERCLA Bona Fide Prospective Purchaser Provision (Dec. 5, 2012) [referred to as "BFPP Tenant Guidance"]; Institutional Controls: A Guide to Planning, Implementing, Maintaining, and Enforcing Institutional Controls at Contaminated Sites, EPA-540-R-09-001 (Dec. 2012) [referred to as "IC Guidance"]; and Institutional Control: A Guide to Preparing Institutional Control Implementation and Assurance Plans at Contaminated Sites, EPA-540-R-09-002 (Dec. 2012) [referred to as "ICIAP Guidance"]. Please note that the BFPP Tenant Guidance is applicable for any site contaminated with hazardous substances (or petroleum for those sites in Indiana). The IC Guides are relevant to cleanup actions

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