In two recent decisions, ASARCO LLC v. Goodwin, 756 F.3d 191 (2d Cir. 2014) and ASARCO LLC v. Union Pacific Railroad Co., 755 F.3d 1183 (10th Cir. 2014), the Second Circuit and the Tenth Circuit each held that a reorganized bankruptcy debtor's direct contribution claims against other potentially responsible parties under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 U.S.C.