Historical Research and Litigation Support for the Arizona Department of Environmental Quality


HGL has performed potentially responsible party (PRP) investigations for 23 Water Quality Assurance Revolving Fund (WQARF) Registry sites under five (5) successive Arizona Department of Environmental Quality (ADEQ) contracts. Tasks performed under site-specific task orders include records collection, industrial surveys, mailings of information request letters, interviews, title searches, business and individual financial viability research, cost allocations, and aerial photograph reviews. Records obtained through these research efforts are processed into document databases to allow for full-text searches of relevant information, and results are summarized in deliverables such as PRP reports and case summaries. The liability analysis sections of the PRP reports and case summaries identify the PRPs for a site and are used to allocate response costs among PRPs and to assist ADEQ and the Arizona Attorney General’s Office (AGO) in cost recovery efforts.

Sites investigated include complex industrial sites, mine sites, landfills, and dry-cleaning facilities. In some cases, contamination at these sites has not been characterized and intrusive investigations are ongoing. The findings of HGL’s research are used to identify potential sources of contamination and to focus future field investigations. HGL has also conducted Comprehensive Environmental Response, Compensation, and Liability Act preliminary assessment-type investigations and provided community relations support under the ADEQ contracts.

Project Highlights
Worked closely with ADEQ and AGO to develop an approach for meeting the WQARF statute’s unique “best efforts” requirement in which the liability allocation process is based on each PRP’s proportionate share of liability, a standard more rigorous than CERCLA’s “joint and several” liability scheme.
Developed a matrix to identify the statutorily required PRP and community relations tasks to be completed at each stage of the WQARF process.
Managed over 20 Concordance® databases with an average of 2,400 documents (24,000 pages) each for WQARF sites for which PRP investigations have been conducted.
Completed four industrial surveys and 90 facility letter reports, and compiled a Microsoft Access database documenting relevant information from a review of regulatory records for over 1,600 facilities to support the Remedial Investigation of a WQARF site in a heavily industrial part of Phoenix, Arizona.
Conducted over 1,000 interviews with private and government parties to identify over 250 PRPs associated with a landfill site in Tucson, Arizona.