Phase 1 Environmental Site Assessments

Guernsey visited and evaluated 33 sites. An Independent Engineers Report (IER) was developed by Guernsey.

An Environmental and Regulatory Summary based on existing permits and approvals, the limitations and requirements they place on operations and a general assessment of each facilities’ compliance and a Health and Safety Overview of each facilities’ health and safety track record relative to industry benchmarks including a matrix of reported injuries and fatalities reported by individual facilities was developed and included in the IER.

The Phase-1 ESAs were performed in accordance with US EPA 40 CFR Part 312 “Innocent Landowners, Standards for Conducting All Appropriate Inquires” and ASTM 1527-13 “Standard Practice for Environmental Site Assessment: Phase I Environmental Site Assessment Process.” Scope of services included:

• Step 1 – Pre-Planning and Discovery
• Step 2 – Perform 33 Site Visits
• Step 3 – Collect and Review Data
• Step 4 – Prepare 33 Phase I ESA Reports: The reports (33 separate reports) followed the representative outline presented below:
  • Certification Page
  • Executive Summary
  • Introduction
  • Site Description
  • Site Reconnaissance, User Information and Interviews
  • Records Review
  • Data Gaps
  • Findings and Opinions
  • Conclusions and Recommendations
  • Qualifications