Bay Sediment Cleanup Cost Allocation Project
- Reviewed hundreds of wastewater discharge and combined sewer overflows (CSOs) reports
- Calculated the mass of lead in the sediment and our client’s wastewater discharge
- Proposed a methodology to the USEPA to determine each potentially responsible party’s (PRP) fair cost to be allocated
- Negotiated with the other PRPs and the USEPA mediator to reach a technically-based resolution
EEC Environmental (EEC) was retained by an international food manufacturer to work with their environmental attorneys on a CERCLA remediation cost allocation. EEC conducted extensive historical research and sample data analysis to determine the appropriate cost to be allocated to our client. EEC’s client was identified by the USEPA as a PRP for the sediment contamination due to industrial activities ending over 30 years ago. EEC proposed a technically-based approach for an equitable allocation which was approved by the USEPA mediator.
The project involved evaluating a variety of potential contaminant sources including wastewater discharge, CSOs, stormwater discharge, contaminated fill, and illegal dumping. The final allocation percentage attributed to our client was limited to their contribution of lead in wastewater that overflowed from the City’s sewer system during CSO events. The final amount was substantially less than what was originally proposed by the USEPA, saving our client over $1 Million.