Due Diligence for National Expansion by a Major Service Industry
- Review of historical documents
- Site reconnaissance
- Identification of previously undisclosed contamination with high potential liability
- File reviews for off-site properties of potential environmental concern
- Negotiation with RWGCB for a “Comfort Letter”
- Perform phase II site investigations
EEC Environmental (EEC) conducted Phase I Environmental Site Assessments (ESA’s) at industrial properties in two California cities as part of an expansion of an east coast based service industry. One property consisted of one 3.7-acre parcel developed with a 70,080-square foot warehouse building that was developed in 1971. The property was historically occupied by a metal fabricating company, a vinyl record manufacturer, and two automotive service facilities. The vinyl record manufacturer utilized an electroplating room, machine shop, in-ground clarifier, and chemicals including heavy metals and chlorinated solvents. The automotive service facilities utilized degreasers and the in-ground clarifier. Previous environmental reports identified chlorinated solvents in the soil surrounding the clarifier.
The second location was a former dairy. The 3.5-acre property was historically used for agricultural purposes, a dairy, equipment storage, and vehicle and equipment maintenance. The property was located in a heavily industrialized area and hydraulically downgradient relative to a former oil refinery. Petroleum-contaminated groundwater was documented in the refinery’s groundwater wells located immediately adjacent to the sites. Onsite investigations indicated that groundwater beneath the site was also impacted by petroleum hydrocarbons.
The Phase I ESAs were performed in accordance with the United States Environmental Protection Agency (USEPA) Standards and Practices for All Appropriate Inquiries (40 CFR Part 312) and American Society for Testing and Materials (ASTM) Designation E 1527. The Phase I ESAs consisted of site inspections, agency record reviews, historical research, interviews with site representatives, and analysis of information to provide findings, identification of recognized environmental condition (RECs) and human research ethics committee (HRECs) and conclusions. The purpose of the Phase I ESAs was to assess the environmental condition of the subject properties and identify recognized environmental conditions as defined by the ASTM, in connection with the sites. The Phase I ESAs were prepared by an Environmental Professional, as defined in ASTM E1527 and pursuant to 40 CFR, 312.10.
Information found during the Phase I ESA at the first site result in the client declining to pursue the purchase of the property. Information found during the Phase I ESA at the second site resulted in a “Comfort Letter” being obtained from the California Regional Water Quality Control Board for the second site to indicate that the source of contamination in groundwater beneath the site was from an upgradient source, and relieve EEC’s client of responsibility for the petroleum remediation.