United States v. Atlantic Research Corp.: who should pay to clean up inactive hazardous waste sites?

The issues related to the payment for cleaning up of inactive hazardous waste sites were discussed. The Supreme Court held a potentially responsible party at a Superfund site who voluntarily cleaned up the site and did not had a contribution claim against the person who caused the contamination. In United States v. Atlantic Research Corp., the Supreme Court resolved the split in the circuits and approved the volunteer's right to bring a cost recovery action against a person who caused the contamination. It was observed that the Atlantic Research Court suggested that only one who performed the remediation incurred the response costs. It was concluded that a non-volunteer who remediates and a volunteer who remediates need to be treated the same with respect to having section 107(a)(4)(B) claim.