State Concerns with the Process of Identifying Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Applicable, or Relevant and Appropriate Requirements

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Five years ago, the Association of State and Territorial Solid Waste Management Officials’ (ASTSWMO) CERCLA and Brownfields (CaBS) Subcommittee members began evaluating State and Territorial (State) roles at CERCLA cleanups. One constant issue was the process of identifying and accepting States cleanup standards and rules as Applicable or Relevant and Appropriate Requirements (ARARs) in CERCLA cleanups. CaBS and the ASTSWMO Board of directors have updated the 2018 position paper to show that the issue is still a concern.