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IDEM-EPA-Shell Oil Multi-Site Agreement
Memorandum: Promoting the Use of Multi-Site Approaches to Cleanup and Revitalize LUST Sites (PDF) (8pp, 110K About PDF) March 29, 2004
Contacts
- U.S. EPA - Laura Lodisio , 312-886-7090
- IDEM - Craig Schroer, 317-234-0974
Background
Multi-Site agreements provide an opportunity for federal leadership in innovation. Region 5 helped develop a multi-site agreement (MSA) between the Indiana Department of Environmental Management (IDEM) and Shell Oil. This agreement was the first MSA of its kind between the U.S. EPA, a State agency, and a major oil corporation for LUST remediation. The purpose of the MSA is to increase the pace of tank remediation of Shell Oil facilities in Indiana by standardizing the corrective action process, ensuring consistency, improving communication, prioritizing sites, and establishing response time frames. This MSA cleanup agreement provided Shell Oil an opportunity to voluntarily address environmental conditions within the context of a single cooperative, mutually beneficial, state-wide agreement. In the MSA, Region 5 will 1) provide any necessary oversight and assistance to further the remediation progress of the sites under the MSA, and 2) assist in the dispute resolution process to the appropriate degree if the dispute could not be resolved informally.
The MSA covers 77 Shell Oil LUST sites. It allows IDEM and Shell Oil an opportunity to agree on the prioritization of the sites, provides flexibility by allowing the state and company to negotiate which sites to move forward in a given year, commit resources in the form of an annual budget, and target 10-15 sites/year for cleanup completed.
The MSA provides an opportunity for federal leadership in innovation in promoting faster LUST cleanups for a multi-site owner. The agreement streamlined the corrective action process resulting in a more efficient use of resources and time.
For Shell Oil, the agreement accomplishes the following:
- Brings consistency to the company's approach to cleanup and State expectations
- Allows for effective communication with the IDEM by minimizing the number of State contacts
- Establishes a management system for prioritization and budgeting
- Provides flexibility by allowing Shell and IDEM the ability to negotiate which sites move forward in a given year
- Brings consistency to reporting and establishes time frames for State responses
- Improves the remediation process, allowing redevelopment/reuse to progress at a faster pace
- Overall, reduces oversight and remediation costs
For IDEM, the agreement accomplishes the following:
- Reduces oversight, each site does not have to be negotiated separately
- Sites with the greatest risk will be remediated first
- Standardizes the remediation process for Shell Oil
- Establishes response time frames for Shell Oil
- Provides a mechanism for Shell to expedite remediation, commit resources, and establishes an annual budget
- Limits the number of Shell Oil contacts, allowing for consistent communication
- Potentially limits the need for resource intensive enforcement actions
- Reduces the resources needed for State oversight
For Region 5, the MSA:
- Demonstrates the effectiveness of an innovative approach to increase the pace of LUST remediation
- Brought two parties together to work in a cooperative manner rather than the standard enforcement process
- Establishes common goals that are agreed upon by both IDEM and Shell Oil
- Provides a mechanism for Shell Oil or IDEM to communicate problems to U.S. EPA in a constructive manner
- Allows the Region an opportunity to expand MSAs in Indiana for other multi-site owners, as well as expand the use of MSA in other Region 5 States
- Establishes the basis to expand the MSA with Shell Oil into other States/Regions