Site Inventory, PRP Prioritization, and Strategic Case Building
Our client was the lone initial potentially responsible party (PRP) identified by the U.S. Environmental Protection Agency (EPA) for an estuarine urban river and harbor complex contaminated with dioxins, polychlorinated biphenyls (PCBs), mercury, and various other hazardous substances. Remedial action estimates for the site ranged up to several billion dollars.
TIG Environmental began by completing a historical inventory of the area to develop a more complete list of PRPs for the site. After prioritizing by contaminant and pre-screening PRPs for financial viability, TIG Environmental investigated and documented the historical operations of the other PRPs that resulted in discharges of hazardous substances to the waterway. In building liability cases against numerous PRPs for this site, TIG Environmental successfully documented cases of hazardous substance discharge from the PRPs to the waterway via direct discharge, sewerage systems including combined sewer overflows, and site runoff. In addition, TIG Environmental also investigated historical upland site operations for the PRPs and identified raw materials and waste streams to facilitate the work of expert witnesses.
On behalf of our client, TIG Environmental presented evidentiary cases to EPA that resulted in the issuance of General Notice Letters to more than 100 PRPs.