Legal Support Services for Manufactured Gas Plant Sites: Liability Assessment, Cost Allocation, and Recovery

Northgate developed and implemented a programmatic regulatory strategy to assess liability in support of a case involving cost allocation and recovery for over 30 sites within a prominent gas company’s portfolio of properties. The projects ranged in both size and complexity.

Northgate assessed the appropriate regulatory framework and developed a systematic and defensible programmatic regulatory strategy which was used as the baseline for developing site-specific remedial approaches. These approaches were developed based on current and future land use, remediation timeline, nature and extent of contamination including impacted media, and operations and maintenance considerations.

For each site, three scenarios were developed including the minimum, expected, and maximum scenarios — representing the estimated minimum cost required to manage liability at the site, the estimated cost associated with a remedy most likely to be required by the regulatory agency, and the estimated cost for the most stringent feasible cleanup scenario based on regulatory guidance. Northgate also developed an innovative costing tool to develop rapid relative lifecycle costs for each scenario.