August Mack was retained by a law firm in Indiana on behalf of an oil company to perform a series of Phase I Environmental Site Assessments (ESAs) pending the sale of the company. The job included a total of 56 sites, consisting of active gas stations with attached convenience stores and a few vacant lots spread out over a wide area in Indiana. Most of the gas stations were relatively new structures, with many of them being fewer than 20 years old. A number of the locations had previously hosted gas stations/convenience stores belonging to other companies. In these cases, the client inherited the previously-existing structures.
The scope of
the Phase I ESA involved conducting a site inspection and reviewing the
regulatory history of the site. The assessments also consisted of evaluating
the potential for off-site and historical sources of contamination; and
conducting interviews and questionnaires with the site owners and occupants.
Given the past and current operations of the locations, a thorough review of
the condition of the underground storage tanks (USTs) was completed during each
assessment. Historical aerial photographs and other historical records were
reviewed to help document past usage of the sites. Additionally, the owner and
operators had prior Phase I ESA reports and other related documents for the
various sites on file, which August Mack was able to review.
The volume of
sites necessitated a high level of expertise and coordination in order to complete
the inspections within an approximately six-week timeframe. August Mack
communicated with owners and operators to verify sites’ availability and
developed an efficient route from location to location to successfully meet the
The result of
the Phase I ESAs indicated that a few of the sites had active leaking
underground storage tanks (LUSTs), however the majority of the sites were
issued No Further Action (NFA) letters. These results were communicated to the
client through an in-depth spreadsheet which kept track of each location, prior
information about location, August Mack’s findings, and August Mack’s
recommendations for follow-up action, if necessary.