A group of PRPs received an oversight cost bill pursuant to a
CERCLA consent decree. (The following details are
intentionally vague to protect both the innocent and the
guilty.) The bill was for several hundred thousand
dollars. During the year covered by the bill, the PRPs spent
no money cleaning up the area of the site covered by the
invoice. They spent little or no money monitoring the area of
the site covered by the invoice. They spent no money
preparing plans for the area of the site covered by the
invoice.
It would be bad enough if EPA's oversight costs were of the
same magnitude as the PRPs' direct response costs.
Unfortunately, EPA's oversight costs were more than the
PRPs' direct costs. Indeed, they were not just more than
the PRPs' costs. They were substantially, if not
infinitely, more than the PRPs' costs.
