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Liability for damages caused by a release below the RQ

If a facility releases a hazardous substance below its Reportable Quantity (RQ) level, could it be liable for damages caused by the release?

Yes. A release of a CERCLA hazardous substance below its RQ does not preclude liability from any damages that may result, including the costs of cleaning up that release or for any natural resource damages, should such costs be determined to be appropriate under CERCLA or any other applicable law.