Synergy Environmental, Inc. was retained by a large Gas Station owner to complete Phase I Environmental Site Assessments (Phase I ESAs) to facilitate the purchase of 22 facilities located in the Chicago, Illinois suburbs. The facilities were all fuel stations. Eighteen of the fuel stations were located in Illinois. The remaining four fuel stations were located in Indiana. Some of the fuel station sites included car wash buildings and/or attached restaurants.
The Phase I ESAs were conducted in accordance with the American Society for Testing and Materials (“ASTM”) document entitled “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process,” (E152713), which pursuant to 40 CFR § 312.11 meets the requirements of all appropriate inquiry. The objectives of this project were to evaluate the environmental conditions at the Sites, to document that due diligence was exercised; and, to perform “all appropriate inquiry” for the purpose of CERCLA sections 101(35)(B)(i)(I) and 101(35)(2)(B)(ii) and (iii) and in accordance with 40 CFR Part 312.
The Phase I ESA activities included:
- Performance of Site visits by Synergy personnel;
- Review of regulatory databases and historic aerial photos, topographic maps and city directories;
- Attempted retrieval/retrieval and review of regulatory files available through the Illinois Environmental Protection Agency and the Indiana Department of Environmental Management;
- Review of environmental lien and activity and use limitations information for each site;
- Review of vapor migration screenings for each site; and
- Preparation of a summary report.
The Phase I ESAs were completed within approximately nine weeks, wrapping up during early June 2014. However, a listing of recognized environmental conditions, by location, was provided within seven weeks to meet the settlement deadline.