Environmental database reports are an essential component of Phase I Environmental Site Assessments. However, a database listing should not be treated as an automatic indication of a Recognized Environmental Condition (REC).
The environmental database is a starting point for investigation. The significance of a listing must be determined using the available regulatory, historical, site, and environmental information.
What Does an Environmental Database Tell You?
Environmental databases may identify facilities associated with:
The presence of a facility in one or more databases establishes that an environmental record exists.
It does not necessarily establish that contamination is present at the subject property.
- Underground storage tanks
- Leaking underground storage tanks
- Hazardous waste
- RCRA facilities
- Superfund sites
- Spills
- Petroleum releases
- Brownfields
- State remediation programs
- Wastewater or air permits
- Other regulated environmental activities
Key Factors in Database Evaluation
When evaluating a database listing, several factors should be considered.
1. Location Accuracy
Database coordinates may not always accurately represent the physical location of the facility.
The listed address should therefore be compared with the actual facility location, parcel boundaries, historical maps, and other available information.
2. Distance
Distance from the subject property is relevant, but distance alone should not determine the environmental conclusion.
3. Direction
The location of the facility relative to the subject property should be considered.
4. Groundwater Flow
Where groundwater information is available, the likely groundwater flow direction can be an important factor in determining whether contamination could migrate toward the subject property.
5. Regulatory Status
The status of the environmental case should be reviewed.
An active remediation case may warrant greater consideration than a site that has received regulatory closure with no further action.
6. Nature of the Release
The type of release and contaminants involved should be evaluated.
Petroleum, chlorinated solvents, metals, and other contaminants have different environmental behavior and migration characteristics.
7. Available Regulatory Documentation
Database information should be supplemented with regulatory files where the listing may represent a potential environmental concern.
These records may provide information regarding:
- Release dates
- Contaminant concentrations
- Soil impacts
- Groundwater impacts
- Remedial activities
- Sampling results
- Regulatory closure
- Institutional controls
- Remaining contamination
Example: Nearby LUST Site
A LUST listing located 500 feet from the subject property may initially appear significant.
However, suppose regulatory records indicate that the release was limited to the source property, groundwater flows away from the subject property, remediation was completed, and regulatory closure was obtained.
The listing may therefore not represent a REC in connection with the subject property.
The opposite conclusion may be appropriate where documented petroleum impacts extend toward the subject property and the regulatory case remains active.
Database Review Is Only the Beginning
The environmental database provides a screening mechanism.
A technically defensible environmental conclusion requires interpretation of the available information in the context of the subject property's location, historical development, geology, hydrogeology, and surrounding land uses.
This is why database review should be considered an analytical process rather than a simple exercise in reporting database hits.
At Greenearth, environmental database research is integrated with historical research, regulatory file review, site information, and professional environmental judgment to support defensible environmental due diligence conclusions.