of disposal which would limit its meaning to “active human conduct.” United States v. Waste Ind., Inc., 734 F.2d 159, 164-65 (4th Cir.1984). In Waste Industries, the court held that Congress intended the 42 U.S.C. § 6903(3) definition of disposal “to have a range of meanings,” including not only active conduct, but also the reposing of hazardous waste and its subsequent movement through the environment. Id. at 164. Id. at 845. The Fourth Circuit concluded “that § 9607(a)(2) imposes liability not only for active involvement in the ‘dumping’ or ‘placing’ of hazardous waste at the facility, but for ownership of the facility at a time that hazardous waste was ‘spilling’ or ‘leaking.’ ” Id. at 846; accord Crofton Ventures Ltd. P’ship v. G & H P’ship, 258 F.3d 292, 300 (4th Cir.2001) (<HOLDING>). Four years later, in CDMG Realty, the Third
holding that disposal under  9607a2 includes a partys movement and spreading of contaminated soil to uncontaminated portions of property and that congress did not limit disposal to the initial introduction of hazardous material onto property holding that the district court did not err in finding the record sufficient to conclude prior conviction qualified as a violent felony for purposes of the acca as the evidence was sufficient to conclude the criminal action charged in one court was the basis for a judgment against the defendant in a different court holding that individual defendants were not liable under the elcra because they did not have the authority to rehire the plaintiff recognizing the increased breadth of the definition of property damage introduced in the more recent form of policy holding that given the breadth of the statutory definition of disposal the district court must be able to conclude that the buried drums did not leak when the defendants owned or operated the facility to make a finding that they were not liable under  9607a2