KingCast 525 Revere Beach EPA 21E coverup: Geotech firm visit.... are Revere Neighborhood Developers and the City liable to EPA for failure to report?

Back Story.
MGL 21E reads, in pertinent part: “Owner”, or “Operator”, (a) (1) in the case of a vessel, any person owning, operating or chartering by demise such vessel, (2) in the case of a site, any person owning or operating such site, (3) in the case of an abandoned site, any person who owned, operated, or otherwise controlled activities at such site, vessel, onshore oil facility, offshore oil facility, deepwater port, or pipeline, any person who owned, operated, or otherwise controlled activities at such site immediately prior to such abandonment...

16 Dec. 2011 sale.

CLARK STREET REALTY TRUST 89-91	Grantor
DECESARE VINCENT A	Grantor
DICESARE VINCENT A	Grantor
SCOPPETTUOLO GERI	Grantor
SCOPPETTUOLO JERRY	Grantor
BEACH STREET LIMITED PARTNERSHIP	Grantee

25 Jan 2010 to 16 Dec. 2011 Mortgagor = 89-91 Clark Street Realty Trust, 

Vincent A. DiCesare, Geri Scoppettuolo as trustees.

..... Revere Neighborhood Developers ("RND") submitted a Site Plan Review request admitting that it had structured a Purchase & Sale Agreement (P&S) with 89-91 Clark Street Realty Trust, effective 11 April 2011, with the notation that "[T]he site will be acquired no later than Dec. 16, 2011." This was of course prior to the testing that Ira Novoselsky was aware of, as noted at the RND website relative to the minutes of the 24 May, 2011 meeting.  This testing was likely completed a long time ago, surely more than 120 days ago. During the testing they were ALL owners and operators pursuant to Statute. Therefore they meet the threshold ownership/management interest required by the case of In re Knott, Docket No. 2011-011, PAN-NE-11-3R001 ($10,787.00 fine for failure to report TCE, affirmed). Moreover, the City of Revere had held multiple liens on this property and arguably had a duty to report this matter to the EPA as well because it had actual and constructive knowledge of the issue since the tanks went into the ground back in 1924. A formal complaint will be lodged with Mass DEP on Monday, and here is the pertinent ownership/management history.