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The first steps in any formal program to compel others to address contamination include the <br />following: <br />1: An environmental consultant should be engaged to examine available reports with <br />the specific charge. of identifying <br />a. Reasonable and necessary response actions associated with imminent and <br />substantial threats or releases, and <br />b. Responsible persons, past and present (viable or not). <br />C. without checking with any consultants, but based upon the general nature of <br />the existing available reports, we anticipate that the costs for this analysis <br />would be in the $20-$401,000 range* <br />I An attorney should be engaged to evaluate the viability of any specific claims against <br />identified responsible persons. <br />a. In general, the costs associated with this analysis would be in the $1 - 30,000 <br />ranger. <br />3. The attorney and. consultant should work with the City to develop a plan relating to <br />. A specific plan to identify any work that the City considers necessary and <br />reasonable under applicable enviironmental standards, including a timetable <br />and rationale. for when the steps need to be takers; <br />b. A plan. for communications with the MPCA or, less likely, the 'A. to see if <br />the MPCA will prompt actions by the responsible persons or will authorize <br />the City to tale any response actions with anticipated cost recovery; <br />C, Ensuring that any steps taken in which the City would advance costs would <br />comply with the NCI' to ensure eligibility for cost recovery; <br />d. ,Attending to any notices to EPA, the State and responsible parties if any <br />injunctive relief is contemplated under R..CRA. <br />e. It is premature to estimate costs associated with the costs of work or <br />implementation of this plan. These costs could be better identified in <br />connection with the work that is outlined in sups I and 2. <br />As noted above, it is possible that the costs incurred in eoneetion with this work would b. <br />recoverable from responsible parties. However, -this would depend upon a valid showing that <br />potentially responsible parties have caused or contributed to past or ongoing releases of hazardous <br />wastes or hazardous materials and that the relief proposed is consistent with one or more of the <br />applicable statutes that allow such recoveries. <br />8 <br />