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EDR Due Diligence at Dawn REC, CREC, HREC

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Smart Data.

Smarter Workflow.

Contamination in, at or on the

target property.Is it de minimis? Has it been

addressed?

Would regulatory

officials view cleanup as inadequate

today?

Are there restrictions?

YES

NO

NO

YES

REC(“Bad REC”)

De minimis(“Not a REC”)

NO

CREC(“Good REC”)

HREC(“Not a REC”)

YES

YES

NO

▸ TARGET PROPERTY: 20 year old multifamily housing complex (six stories, no

basement below the building, gas heating)

▸ LOCATION: on a commercial main street

▸ GOVERNMENT RECORDS: No “hits” on the target property

▸ SITE VISIT: no evidence of contamination on the property

▸ PRIOR USE: vacant land

▸ Abutting the property (cross-gradient topographically) is a shopping center

that according to the city directory search had a dry cleaner that cleaned on-

site for more than 30 years but which closed approximately five years ago

▸ SOIL TYPE: loamy sandy soil

Does the former dry cleaner create a REC-HREC-CREC on the target

property?

▸ TARGET PROPERTY: 40 year old shopping center built slab-on-grade

▸ LOCATION: on a busy, commercial main street

▸ GOVERNMENT RECORDS: disclose a former gas station on the target property

that had a LUST, but which was cleaned up (USTs removed and replaced,

contaminated soil removed and contaminated groundwater cleaned to state

industrial/commercial standards, state issued an NFA letter)

▸ PRIOR USES: did not reveal any other uses that might have had an

environmental concern

▸ No environmental concerns were uncovered in the surrounding area

▸ SOIL TYPE: silty clay

Does the former gas station create a REC-HREC-CREC on the target

property?

▸ TARGET PROPERTY: an office building built on a brownfield site (former

industrial site that operated from 1930s to the 1960s)

▸ PRIOR USE: Former industrial site manufactured cosmetic applicators, tubes

and dispensers for the cosmetics industry and used chlorinated solvents

principally for cleaning

▸ The site was investigated in the late 1980 and early 1990s.

▸ Metals and VOCs were found in the soil and VOCs in the groundwater, above

state commercial/industrial cleanup standards.

▸ The state allowed the use of RBCA to establish soil and groundwater cleanup

levels.

▸ State issued an NFA letter.

Does the former industrial site create a REC-HREC-CREC on the

target property?

▸ TARGET PROPERTY: a shopping center with no tenants having environmental

issues

▸ PRIOR USE: A gas station that previously existed on the property was in the

LUST database

▹ Contaminated soil with BTEX was excavated and removed from the site.

▹ Contaminated groundwater with BTEX was treated with an SVE system until

levels were demonstrated below the existing residential cleanup level.

▹ The state issued an NFA letter.

Does the former gas station create a REC-HREC-CREC on the target

property?

▸ TARGET PROPERTY: has been a shopping center for more than 50

years with no current tenants having environmental issues.

▸ The property is being sold.

▸ PRIOR USE: vacant land

▸ The last Phase I (conducted in accordance with E1527-05 in 2006 by

a reputable Phase I firm) did not indicate evidence of any RECs

associated with the property or in the surrounding area.

▸ You are asked to “update” the last Phase I.

Would you agree to update the previous Phase I?

Would there still be any potential REC issues or would this likely be a

case of no RECs?

▸ TARGET PROPERTY: a newly constructed office building in the CBD

built on a property that included a former gas station.

▸ The former gas station had USTs that were removed.

▸ Sampling indicated BTEX contaminated soil that was excavated and

taken off-site.

▸ Groundwater was not sampled.

▸ The property received an NFA letter from the state.

▸ The new office building included a multi-level (four levels)

underground parking garage.

▸ No other environmental issues were uncovered in the site inspection,

or the government and historical records check.

Would the former gas station represent a REC on the property?