In preparation of the divestiture of its east coast refining, distribution and retail marketing facilities to consolidate its operations in the west, a major petroleum products corporation retained Roux Associates to provide support services at sites located in New Jersey, New York, Delaware, Maryland, Connecticut, Massachusetts, Pennsylvania and Rhode Island. At the time of divestiture, the majority of the affected assets were sold to a variety of companies under sales agreements that required it to retain its direct and third party liability for environmental releases which pre-dated the sale. In addition, liabilities were maintained for all unsold assets. Environmental support requirements for its eastern operations at that time included:
 

  • Review and management of claims made by purchasers regarding the client's potential responsibilities for prior releases at approximately 200 sites
  • Management of approximately 20 sites which the client had previously assumed direct environmental responsibility for cleanup
  • Management of New Jersey Environmental Responsibility and Cleanup Act (ECRA) filings, investigations and cleanups at four distribution terminals
  • Management of third-party litigation claims at approximately six retail stations and one refinery


Significant services provided in conjunction with this contract included:

  • Development and implementation of a document tracking and project management system to monitor, evaluate and develop recommendations for payment for all incoming environmental claims from buyers
  • Review of other consultant's work to evaluate closure strategies, confirm selection of appropriate remedies, and identify cost-saving opportunities
  • Management of multiple contractors in implementing projects at direct liability sites
  • Development and implementation of ECRA investigation work plans and cleanup plans for four terminal sites in New Jersey
  • Negotiation of potential liabilities and cleanup obligations with buyers and state regulatory agencies
  • Litigation claim support and expert witness testimony for litigation involving multiple retail service station, terminal and refining sites
  • Review of pending Federal or state legislation or regulations that might affect liabilities or cleanup requirementsDevelopment of a waste management program to assure compliance with industrial and hazardous waste reporting, record keeping and tax requirements


Roux Associates assisted our client with negotiations with one of the purchasing companies to have them assume all liabilities at the purchased sites. Roux Associates also was able to remediate many of the client owned sites so they could be sold.