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Hazardous Materials and Contamination

EN-04 · Matrix · Environmental Resources

Rating
1Resource is present within area, impact unlikely
Why
Present; impact unlikely
Worst case
Not above the rating
Evidence
Verified
Cited claims
2
Requirements
0
Requests
0

Rating

1Resource is present within area, impact unlikely

The rule

Code computed the rating from the assessor's inputs:

present, impact unlikely -> 1

Set by the rule

Decision
Released with flags
The engine's reasons
  • Numbers not found in cited evidence: 2023
  • Agencies not in the register or the evidence: IDEM
Evidence state
Verified · field study or agency determination

Revision

Not revised.

The five inputs

  • Present: yes

    The Phase I found no RECs (C-42ffa60059), but also observed a small de minimis farm debris pile near the Parcel 12 barn (C-18f20d1141). The two do not truly conflict: a de minimis debris pile is not a REC. Debris is a hazardous-materials/contamination-type site feature, so the resource is rated present at a minimal level.

    Cites C-18f20d1141, C-42ffa60059

  • Extent: peripheral

    The only documented item is a small de minimis debris pile near the Parcel 12 barn (C-18f20d1141). The Phase I found no RECs (C-42ffa60059), so no contamination affects central buildable areas.

    Cites C-18f20d1141, C-42ffa60059

  • Avoidable: yes

    The debris pile is small and localized, and the Phase I recommends simple removal (C-18f20d1141). It can be removed or avoided.

    Cites C-18f20d1141

  • Pathway: standard

    Removal of debris is the recommended action (C-18f20d1141). No RECs means no regulated remediation or agency oversight is expected (C-42ffa60059).

    Cites C-18f20d1141, C-42ffa60059

  • Impact likely: no

    With no RECs (C-42ffa60059) and only a de minimis debris pile needing routine removal (C-18f20d1141), no further assessment or remediation is likely to affect cost or schedule materially.

    Cites C-18f20d1141, C-42ffa60059

Comments

The January 2023 Phase I ESA identified no recognized environmental conditions. A small de minimis farm debris pile was observed near the Parcel 12 barn; removal is recommended.

Critique

Verdict
upheld
Suggested direction for the rating
same
Summary

Category 1 is broadly supported by the Phase I. The issues are minor: 'simple' removal is not in the quote, IDEM is listed without support, the ASTM viability point is not attributed, and the Phase I's 180-day shelf life is near or past expiry at cut-off.

Critic model
Luminol

Issues

  1. Severity minor · Kind unsupported_statement

    The avoidable rationale and the pathway rationale say the Phase I recommends 'simple removal'. The quote says only 'removal is recommended'. 'Simple' is not in the quote. The statement that no regulated remediation or agency oversight is expected also goes beyond an absence-of-RECs quote.

    Cites C-18f20d1141, C-42ffa60059

  2. Severity minor · Kind unsupported_statement

    The extent rationale says no contamination affects central buildable areas. The quotes do not give the debris pile's location relative to buildable areas, only that it is near the Parcel 12 barn. The Phase I absence of RECs is for the Property, so the claim is partly supported. 'Peripheral' is a judgment call. A site map showing the barn location would settle it.

    Cites C-18f20d1141

  3. Severity minor · Kind unsupported_statement

    The Comments and Next steps cite 'ASTM E1527-21 viability window' and the Phase I date, with no quote or as-of note supplying the standard. The 180-day viability point is reasonable regulatory context but is not attributed. The listed agency IDEM is also not supported, because the assessment itself says no agency oversight is expected.

    Cites C-42ffa60059

  4. Severity minor · Kind missing_next_step

    The Phase I is dated 2023-01-20 and the cut-off is 2023-08-15, which is about 6.8 months. The assessment could state that the 180-day component shelf life is near expiry or expired, and that an update will be needed. It only says to confirm currency.

    Cites C-42ffa60059

Checks

  • Passed

    rating_has_evidence · blocking

  • Passed

    presence_is_evidenced · not blocking

  • Passed

    counter_evidence_considered · not blocking

  • Failed

    numbers_grounded · not blocking

    Numbers not found in cited evidence: 2023

  • Failed

    agencies_grounded · not blocking

    Agencies not in the register or the evidence: IDEM

  • Passed

    cutoff_respected · blocking

  • Passed

    critic_not_refuted · blocking

Evidence (2)

Each claim the row cites: the statement in the assessor's words, then the quote the engine found on the page.

Phase I ESA 2023-01-20

C-18f20d1141 · Page 1 of 1 · DR-0004

Open the claim, C-18f20d1141

A small de minimis farm debris pile was observed near the Parcel 12 barn; removal is recommended.

Quote check Exact · Placed verbatim · The quote occurs on the page exactly as written. · Read as native

SYNTHETIC TEST FIXTURE - FICTIONAL PROJECT Phase I Environmental Site Assessment (ASTM E1527-21) Brook Hollow Solar Project January 20, 2023 This assessment has revealed no recognized environmental conditions (RECs) in connection with the Property. Quote starts. A small farm debris pile (de minimis) was observed near the Parcel 12 barn; removal is recommended. Quote ends.

The outline marks where the quote begins on the page.

Page 1 of Phase I ESA 2023-01-20
  1. C-18f20d1141

    A small de minimis farm debris pile was observed near the Parcel 12 barn; removal is recommended.

    Quoted from page 1
    A small farm debris pile (de minimis) was observed near the Parcel 12 barn; removal is recommended.

    Phase I ESA 2023-01-20 · DR-0004 · Page 1 · 2023-01-20

    Source field_study · Claim type presence · Polarity presence · Confidence high · Quote check exact, 100 of 100

    Cited by EN-01, CU-01, CU-02 · Filed under EN-01, EN-04

  2. C-42ffa60059

    The Phase I ESA revealed no recognized environmental conditions (RECs) in connection with the Property.

    Quoted from page 1
    This assessment has revealed no recognized environmental conditions (RECs) in connection with the Property.

    Phase I ESA 2023-01-20 · DR-0004 · Page 1 · 2023-01-20

    Source consultant_memo · Claim type absence · Polarity absence · Confidence high · Quote check exact, 100 of 100

Requirements and permits

The requirements the assessor tied to this row, by level. Each quote from dated law is shown with its source.

No requirement is tied to this row.

Information requests

No information request for this row.

Next steps

  • Remove the debris pile near the Parcel 12 barn before construction.
  • Confirm Phase I ESA remains current (ASTM E1527-21 viability window) before financing or closing.

Agencies

  • IDEM

Cost and impact

Impact
None given.
Potential cost level
N/A
Why

Debris removal is a minor cost, not a material exposure for a utility-scale budget.

Impact: C = cost, S = schedule. Potential cost level: L, L-M, M, M-H, H (relative to a utility-scale solar budget).

Lumerian Labs 2026