Benefits and Drawbacks of Multi-Site Agreements Under PA’s Land Recycling Program: A Case Study. K. C. Fromme and J. J. Mahfood, Key Environmental, Inc., 1200 Arch Street, Carnegie, PA 15106
In 1995, the Commonwealth of PA passed Act 2, a risk-based approach to cleaning up contaminated sites. Our client negotiated a Consent Order to remediate over 20 former manufactured gas plant (MGP) sites throughout Pennsylvania. For this presentation, we will evaluate the benefits and drawbacks of the agreement. Benefits include streamlined investigations based on knowledge of similar sites, the ability to manage costs related to environmental remediation, and a uniform process for review and approval of submissions. Those considering multi-site agreements will be interested to learn of the potential hidden costs which may be associated with the points accrual system that is used to track environmental progress under the agreement. We will also review features that dominated a cost/benefit analysis of developing site-specific standards based on a risk assessment versus remediating the site to PA’s Statewide Health Standards. Under PA’s Land Recycling Program, a remediater may choose from three cleanup standards: 1) background, 2) Statewide Health Standards [based on a 1x10-5 risk], or 3) site-specific standards based on a site-specific risk assessment. This case study is interesting because the sites have similar contamination scenarios, but are located in different geographic locations.
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