EPA identified PCBs in the soil at commercial properties and residential yards in a community in Puerto Rico. Although no sources have been positively identified, our client owns one of the few former industrial properties in the area, a fert ilizer plant, and is therefore required to excavate contaminated soil and replace it with backfill. Implementing this remedy presents several challenges including landfill and backfill availability, coordination with demolition contractors in properties affected by natural disasters, potential presence of endangered species in work areas, and schedule constraints caused by hurricane threats. Further, because contamination sources are not understood, EPA has assumed, potentially incorrectly, that the fertilizer property presents an ongoing risk to the community.
Integral is working closely with our client, outside counsel, and local engineering and public relations firms to design an implementable remedy. Our tasks include developing work plans, designing remedies, procuring contractors, delineating impacts in soil, conducting a source control assessment of stormwater runoff, and assisting with community outreach and access agreements. We also support our client with regulatory coordination and strategic communications.
Our phased approach to source control investigation along with a responsive, yet reasonable, removal program will meet stakeholder goals. Integral has struck a balance between regulatory requirements, community protection, and client advocacy, such that a community heavily impacted by natural disasters will benefit from remedial action to reduce human health risks and improve properties.