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IMA-NA Comments on CERCLA §108(b)

Posted By Mark Ellis, Wednesday, July 12, 2017

IMA-NA filed comments yesterday on EPA's CERCLA §108(b) notice of proposed rulemaking.  This rulemaking would establish financial assurance requirements for Superfund liability at individual hardrock mining facilities.   These financial assurances have the potential to be extremely costly . . . as in millions of dollars per industrial minerals facility.  The IMA-NA comments are specific to the industrial minerals sector.  IMA-NA also have been participating in a coalition of other hardrock mining trade associations, as well as trade associations representing industry sectors that EPA has indicated it likely next would subject to CERCLA §108(b) financial responsibility requirements (e.g., chemicals manufacturing, petroleum and coal products manufacturing, electrical power generation, transmission and distribution).  The coalition comments also are attached for your information.

 

Both the IMA-NA and coalition comments are attached.


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Tags:  CERCLA  Comments  EPA  Regulations 

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