Not a golf course - there are no greens.
Are you comfortable giving an approx current address or lat/long?
Seeing as it's in Los Angeles and those circles appear to be related to fluid storage of some site, my first thought is oil wells. But, the grass around it looks well maintained and there appears to be some sort of order to them so I also considered a golf course, perhaps during some kind of construction or maintenance project, although the number of them doesn't work out.
Sure, this Forum has been a very valuable tool for me generally being the only person in my office who does Phase I ESAs. Can't really ask some of these questions of office staff.
Thanks for the follow up.
It's an SBA loan also, and after finding the ACOE Report, they are still concerned about fill materials brought in, even though they were sampled as part of the soils investigation associated with removal of sewage disposal structures.
Property owner has decided to conduct Phase II before selling property.
We opined that the lack of information constituted a Data Gap, not REC. However, after further research, we found an old Army Core of Engineers Soils Report which closed the case after a soils investigation. Never any onsite application of solids and/or wastewater.
If there was on-site waste disposal, I would think it'd rate a REC even if it was general municipal sanitary waste rather than specifically industrial wastewater. Just think of all the stuff that went down the drain (and sometimes still does) from washing down factory floors and so on. EPA has land application standards for sewage sludge for a reason, due to metals and persistent organic (PCBs, etc) content.
Have you reviewed the regulatory file? I have seen huge problems at furniture manufacturing sites. Review of files could tell you whether hazardous materials were used at the site. Fire Dept and air management could might tell you more about the materials they used.
Also, I would discuss this with your client. They are probably less interested in whether it's a REC than how it affects them. Some clients really want to rule out the potential for a release, so they may want more investigation even if there is no REC.
I worked on a former furniture manufacturing facility that was an RP in a very large commingled solvent groundwater contamination plume with extensive complex litigation.
There may have been a large amount of metal degreasing conducted on-site at the facility you describe.
The question is do you think a release is likely? Doesn't sound like it to me. I wouldn't call it a REC.
You used the term "sewage disposal." Should the report instead have characterized the activity as "sewage treatment?" Are there industries who discharged wastewater to the facility? Is there sludge disposal onsite?
Too many questions outstanding to make a determination of REC or non-REC. But if the facility received industrial wastewater and disposed of sludge by landfilling or land-applying onsite, that would definitely be a REC in my view.
My understanding is that, in California, a consultant who is not a RG can state factual information regarding subsurface and geological conditions such as direction of groundwater flow, soil type, etc. that they obtain from authorative sources such as USGS. However, if an opinion is rendered, as would be the case in a VEC screening, in California anyway, I think you would be engaged in the "practice" of geology and would need a RG on board. I agree with MaxEng, it appears to be restraint of trade to me. I don't think you need to be a RG to do a basic VEC screen but I bet the state of California would disagree.
The Phase I would benefit the buyer a few ways: the bank will likely require it, it will demonstrate due diligence, just because there's a known elephant in the room (residual contamination) doesn't mean there isn't a tiger hiding behind the couch (off-site sources, forgotten abandoned tanks, etc.)
A few thoughts come to mind:
1- you may want to delete the site address from your post.
2 - If it's a good Phase I it should include an opinion section that explains the logic behind drawing this conclusion. Does it?
3 - "an absence of information" makes a data gap not a REC. If the consultant can say that based on their experience and the information available a release is likely then it's a REC. But this conclusion alone is not convincing.