Be Wary of “Low Risk/High Risk” Reports

I recently was asked by a banking client to review one of these reports to see if there was a necessity to perform a Phase I ESA. Many banks are using these “risk reports” to “evaluate” a property (and for loan) as to whether it or adjacent tracts have an environmental issue of concern.

The report I reviewed was the “typical” records research database and then a “review” of the database listings by an environmental professional (EP). This one in particular was a site in Texas that was adjacent to a retail strip center. After my review of the report, I was alarmed at the following aspects of these “EPs” and their findings.

  1. The report was reviewed by an out-of-state environmental company.
  2. The report is signed by two “analysts” and therefore presumed to be an “environmental professional” to have reviewed the records research database. However, on further inspection, they profess to have only an “environmental certificate” and do not identify as an EPA qualified Environmental Professional.
  3. Now, upon making comment regarding a dry-cleaning listing, it is important to note of a database listing with respect to a dry-cleaning facility is- how is the facility registered as to the cleaning solvents:
    1. ‘PERC” (this the bad stuff, now being phased out)
    2. PETROLEUM- naphtha and similar (not a concern)
    3. DROP STATION- no solvents, just a press and delivery (NO ISSUE!)

OUR TAKE:

This report surely did list the dry-cleaning facility, but the cleaning agent being used was not! So either the database was flawed, or the “EP” did not believe this was a very important “need to know” about such a listing. Nevertheless, their findings suggested a “HIGH” risk!

Conclusion:

So, this supposedly environmental low risk/high risk evaluation was prepared by two NON-EPA defined EPs, having probably never been to Texas, and as to the most important component listing of a dry cleaners, completely omitted the type of a registered solvent used.

I researched the site in question from the TCEQ registry, and easily found it was in fact registered as a “DROP STATION” – very “LOW risk”.

“A map is not the territory it represents, but, if correct, it has a similar structure to the territory, which accounts for its usefulness.”

– Alfred Korzybski, Polish-American scientist and philosopher