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Environmental Contamination

EN-04 · Matrix · Environmental Resources

Rating
3Resource is present, likely difficult to address
Why
Core of the site; partly avoidable
Worst case
Not above the rating
Evidence
Verified
Cited claims
19
Requirements
0
Requests
1

Rating

3Resource is present, likely difficult to address

The engine shows this rating as 3

The rule

Code computed the rating from the assessor's inputs:

extent=core, avoidable=partly -> 3

Set by the rule

Decision
Released with flags
The engine's reasons
  • Uncited absence claims to weigh: C-0af700a251 (no record in the annex), C-2ff0fce9c8 (no record in the annex), C-e9a687c1a0
  • Agencies not in the register or the evidence: Ohio EPA
Evidence state
Verified · field study or agency determination

Worst case

The same rule on the worst case gives no rating above the point.

Scenario

Phase II confirms brine and petroleum contamination across the proposed substation and BESS yard, needing agency-overseen remediation or relocation of the POI-adjacent facilities. Mine spoil on the East Block (not fully accessed) adds uncertainty.

Step still pending
Limited Phase II sampling at the Parcel 5 former tank battery
Inputs in the worst case
Extent core · Avoidable no · Pathway individual · Impact likely yes
The rule on the worst case
worst case (extent=core, avoidable=no -> 3) not above the point

Revision

Not revised.

The five inputs

Comments

Phase I ESA identifies REC 1: suspected brine and petroleum release at former tank battery on Parcel 5, with staining and stressed vegetation, where the substation and BESS yard are proposed. Limited Phase II recommended. Parcel 3 debris pile de minimis. Closed UST 0.8 mile south. East Block mine spoil noted.

Critique

Verdict
upheld
Suggested direction for the rating
same
Summary

The assessment is largely supported by the cited quotes. Only minor issues: the Phase I is over 180 days old at the cut-off, the clean lien search is ignored, and a few labels and details ('REC 1', 'POI-adjacent', SPCC) are unsupported. The extent call is a judgment. Category 3 is reasonable.

Critic model
Luminol

Issues

  1. Severity minor · Kind missing_next_step

    The Phase I is dated 2023-01-27. By the 2023-08-01 cut-off it is more than 180 days old, so its time-sensitive components would need updating before it could support a purchase or financing reliance. The assessment doesn't mention this.

    Cites C-fe98e6ae5a

  2. Severity minor · Kind missed_counter_evidence

    The lien next step ignores C-a898a65a41, which found no environmental liens in the public records searched. The AUL gap in C-061f16a94b is real, but the step should say that the lien search is already clean and that only the AUL and title review is outstanding.

    Cites C-a898a65a41, C-061f16a94b

  3. Severity minor · Kind unsupported_statement

    The quotes don't contain the label 'REC 1' or the words 'Phase I ESA'. The worst case calls the facilities 'POI-adjacent', and no cited quote places the substation next to the POI. The SPCC point rests on a truncated quote. SPCC is a federal EPA program, and no federal agency is listed.

    Cites C-fe98e6ae5a, C-e571f3a9eb

  4. Severity minor · Kind understatement

    The present rationale leaves out the East Block mine spoil (C-8dc8e662ac) and the inaccessible woodlots (C-421d66e93e). They appear only in the worst case and comments. C-0497ffe228 (no acid seeps seen) weakens the concern. A survey of the inaccessible areas would settle it.

    Cites C-8dc8e662ac, C-421d66e93e, C-0497ffe228

  5. Severity minor · Kind other

    The extent 'core' call is a judgment. The REC stain is about 60 by 90 feet on a 780-acre buildable area, yet it lies where the substation is proposed. Phase II delineation would settle whether it is core or only local.

    Cites C-b2025b56f8, C-faf2f8bc21

Checks

  • Passed

    rating_has_evidence · blocking

  • Passed

    presence_is_evidenced · not blocking

  • Failed

    counter_evidence_considered · not blocking

    Uncited absence claims to weigh: C-0af700a251 (no record in the annex), C-2ff0fce9c8 (no record in the annex), C-e9a687c1a0

  • Passed

    numbers_grounded · not blocking

  • Failed

    agencies_grounded · not blocking

    Agencies not in the register or the evidence: Ohio EPA

  • Passed

    cutoff_respected · blocking

  • Passed

    critic_not_refuted · blocking

Evidence (19)

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

Arrow keys move the selection. A middle-click opens the claim's own page.

  1. A farm debris pile with empty pesticide containers and scrap metal at the Strohl farmstead, Parcel 3, is a de minimis condition.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 1Exact
  2. No acid seeps were seen on the mine spoil.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 2Exact
  3. No title search for environmental liens or activity and use limitations was provided; a lien search is recommended once title commitments are issued.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 3Exact
  4. Removal of the debris pile and pesticide containers on Parcel 3 is recommended before construction.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 1Exact
  5. No landfill or dump is listed on or next to the Property.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 2Exact
  6. Parts of the East Block woodlots were not accessible because of reclamation spoil and dense autumn olive.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 3Exact
  7. A limited Phase II with soil and shallow groundwater sampling is recommended at the Parcel 5 former tank battery before the substation and BESS yard are sited there.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 1Exact
  8. No NPL, CERCLA, RCRA TSD facility or brownfield site is within the ASTM search distances.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 2Exact
  9. Surface mining occurred on the East Block in the 1950s and 1960s, reclaimed under the pre-1977 program; spoil can contain acid-forming material.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 2Exact
  10. Substation and BESS foundations are recommended after Phase II environmental sampling at the former tank battery.Preliminary Geotechnical Engineering Report - Tamsin Ridge Solar and Storage Project · Page 3Exact
  11. Two plugged and abandoned oil and gas wells are listed in ODNR records on Parcels 4 and 10.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 1Exact
  12. No environmental liens were found in the public records searched.Commitment for Title Insurance No. ATA-23-0418 (Parcels 2, 5 and 9) · Page 3Exact
  13. Dark staining and stressed vegetation cover about 60 by 90 feet down-slope of the former tank battery on Parcel 5.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 1Exact
  14. No HREC or CREC was identified; a 2016 brine spill was cleaned up under ODNR oversight and closed as de minimis.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 1Exact
  15. Parcel 5 hosts the substation and BESS yard and has a 138 kV line, gathering pipeline and oil and gas lease.Parcel Schedule 2023-07-14 · Page 1Exact
  16. Main power transformer holds about 14,000 gallons of mineral oil, so the substation needs an SPCC plan under 40 CFR Part 112.Stormwater, Floodplain and Drainage Memo - Tamsin Ridge Solar and Storage Project · Page 2Exact
  17. The suspected Parcel 5 release is a REC lying where the substation and battery yard are proposed; brine chlorides can also limit revegetation.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 3Exact
  18. One closed leaking UST case is 0.8 mile south at a former filling station on State Route 43, down-gradient, closed with no further action.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 2Exact
  19. REC 1: a release of brine and petroleum to soil is suspected at the former tank battery site on Parcel 5, with no release report found.Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · Page 1Exact

Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project

C-02dc91fd44 · Page 1 of 3 · DR-0012

Open the claim, C-02dc91fd44

A farm debris pile with empty pesticide containers and scrap metal at the Strohl farmstead, Parcel 3, is a de minimis condition.

Quote check Exact · Placed normalised · The quote matches the page once line breaks, hyphenation, case and punctuation are set aside, as the engine's matcher compares text. The marked words are the page's own. · Read as native

Ashgrove Site Assessment, LLC Environmental due diligence | Akron, Ohio Phase I Environmental Site Assessment Tamsin Ridge Solar and Storage Project, Harrison Township, Carroll County, Ohio Prepared for Northfold Energy Partners, LLC. Report A-2301-07. January 27, 2023. Executive summary Ashgrove Site Assessment performed this Phase I Environmental Site Assessment in conformance with ASTM E1527-21 and the All Appropriate Inquiries rule (40 CFR Part 312). The Project Area (the Property) comprises approximately 1,265 acres of cropland, hay, woodlots and reclaimed mine land, with four farmsteads. The site reconnaissance was on January 10 and 11, 2023. This assessment has revealed the following recognized environmental condition (REC) in connection with the Property: • REC 1 - Former tank battery site, Parcel 5. Dark staining and stressed vegetation cover an area of about 60 by 90 feet down-slope of the former brine and crude oil tank battery that served the Strand Utica unit wells until the tanks were moved in 2019. No release report for this area was found. A release of brine and petroleum to soil is suspected. No HREC or CREC was identified. A reported 2016 brine spill at the same pad was cleaned up under ODNR oversight and closed; it is noted as a de minimis condition because the closure letter was reviewed. Other findings that are not RECs: two plugged and abandoned oil and gas wells (Parcels 4 and 10) listed in ODNR records; a natural gas gathering pipeline across Parcels 5, 7 and 10; Quote starts. a farm debris pile with empty pesticide containers and scrap metal at the Strohl farmstead (Parcel 3), a de minimis condition Quote ends.; and a 500-gallon aboveground fuel tank for farm equipment at the Strohl farmstead, in good condition with no staining. Recommendations • A limited Phase II investigation (soil and shallow groundwater sampling for chlorides, petroleum hydrocarbons and BTEX) at the former tank battery on Parcel 5, before the substation and BESS yard are sited there. • Removal of the debris pile and pesticide containers on Parcel 3 before construction. • Survey and fence the plugged wells and keep the setbacks the operator and ODNR require. Ashgrove Site Assessment, LLC - Report A-2301-07 Page 1 of 3

The outline marks where the quote begins on the page.

Page 1 of Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project
  1. C-02dc91fd44

    A farm debris pile with empty pesticide containers and scrap metal at the Strohl farmstead, Parcel 3, is a de minimis condition.

    Quoted from page 1
    a farm debris pile with empty pesticide containers and scrap metal at the Strohl farmstead (Parcel 3), a de minimis condition

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 1 · 2023-01-27

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

  2. C-0497ffe228

    No acid seeps were seen on the mine spoil.

    Quoted from page 2
    no acid seeps were seen.

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 2 · 2023-01-27

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

  3. C-061f16a94b

    No title search for environmental liens or activity and use limitations was provided; a lien search is recommended once title commitments are issued.

    Quoted from page 3
    The user did not provide a title search for environmental liens or activity and use limitations

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 3 · 2023-01-27

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

    Filed under EN-04, PE-05

  4. C-1e239f0074

    Removal of the debris pile and pesticide containers on Parcel 3 is recommended before construction.

    Quoted from page 1
    Removal of the debris pile and pesticide containers on Parcel 3 before construction.

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 1 · 2023-01-27

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

  5. C-2ace1138d8

    No landfill or dump is listed on or next to the Property.

    Quoted from page 2
    No landfill or dump is listed on or next to the Property.

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 2 · 2023-01-27

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

  6. C-421d66e93e

    Parts of the East Block woodlots were not accessible because of reclamation spoil and dense autumn olive.

    Quoted from page 3
    Parts of the woodlots in the East Block were not accessible because of reclamation spoil and dense autumn olive.

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 3 · 2023-01-27

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

    Cited by EC-03 · Filed under EC-03, EN-04

  7. C-46481122cf

    A limited Phase II with soil and shallow groundwater sampling is recommended at the Parcel 5 former tank battery before the substation and BESS yard are sited there.

    Quoted from page 1
    A limited Phase II investigation (soil and shallow groundwater sampling for chlorides, petroleum hydrocarbons and BTEX) at the former tank battery on Parcel 5

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 1 · 2023-01-27

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

    Filed under AQ-03, EN-04

  8. C-5c2ccff84a

    No NPL, CERCLA, RCRA TSD facility or brownfield site is within the ASTM search distances.

    Quoted from page 2
    No National Priorities List (Superfund) site, CERCLA site, RCRA treatment, storage or disposal facility or brownfield is within the search distances.

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 2 · 2023-01-27

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

  9. C-8dc8e662ac

    Surface mining occurred on the East Block in the 1950s and 1960s, reclaimed under the pre-1977 program; spoil can contain acid-forming material.

    Quoted from page 2
    surface mining on the East Block in the 1950s and 1960s, reclaimed under the pre-1977 program. Mine spoil can contain acid-forming material

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 2 · 2023-01-27

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

    Filed under EN-02, EN-04

  10. C-94c3a5488e

    Substation and BESS foundations are recommended after Phase II environmental sampling at the former tank battery.

    Quoted from page 3
    after the Phase II environmental sampling at the former tank battery

    Preliminary Geotechnical Engineering Report - Tamsin Ridge Solar and Storage Project · DR-0018 · Page 3 · 2023-05-15

    Source consultant_memo · Claim type presence · Polarity presence · Confidence medium · Quote check exact, 100 of 100

  11. C-a7cffff0d2

    Two plugged and abandoned oil and gas wells are listed in ODNR records on Parcels 4 and 10.

    Quoted from page 1
    two plugged and abandoned oil and gas wells (Parcels 4 and 10) listed in ODNR records

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 1 · 2023-01-27

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

    Filed under EN-02, EN-04

  12. C-a898a65a41

    No environmental liens were found in the public records searched.

    Quoted from page 3
    Environmental liens: none found in the public records searched.

    Commitment for Title Insurance No. ATA-23-0418 (Parcels 2, 5 and 9) · DR-0006 · Page 3 · 2023-04-18

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

  13. C-b2025b56f8

    Dark staining and stressed vegetation cover about 60 by 90 feet down-slope of the former tank battery on Parcel 5.

    Quoted from page 1
    Dark staining and stressed vegetation cover an area of about 60 by 90 feet down-slope of the former brine and crude oil tank battery

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 1 · 2023-01-27

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

  14. C-b9b7baadd9

    No HREC or CREC was identified; a 2016 brine spill was cleaned up under ODNR oversight and closed as de minimis.

    Quoted from page 1
    No HREC or CREC was identified. A reported 2016 brine spill at the same pad was cleaned up under ODNR oversight and closed

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 1 · 2023-01-27

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

  15. C-df8aadf77e

    Parcel 5 hosts the substation and BESS yard and has a 138 kV line, gathering pipeline and oil and gas lease.

    Quoted from page 1
    Substation, BESS yard; 138 kV line; gathering pipeline; oil and gas lease

    Parcel Schedule 2023-07-14 · DR-0005 · Page 1 · 2023-07-14

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

    Cited by EN-01 · Filed under EN-01, PE-05

  16. C-e571f3a9eb

    Main power transformer holds about 14,000 gallons of mineral oil, so the substation needs an SPCC plan under 40 CFR Part 112.

    Quoted from page 2
    The main power transformer holds about 14,000 gallons of mineral oil, so the substation needs a Spill

    Stormwater, Floodplain and Drainage Memo - Tamsin Ridge Solar and Storage Project · DR-0019 · Page 2 · 2023-06-05

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

    Cited by PE-03 · Filed under EN-04, PE-03

  17. C-faf2f8bc21

    The suspected Parcel 5 release is a REC lying where the substation and battery yard are proposed; brine chlorides can also limit revegetation.

    Quoted from page 3
    it lies where the substation and battery yard are proposed. Brine chlorides can also limit revegetation.

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 3 · 2023-01-27

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

    Filed under EC-03, EN-01, EN-04

  18. C-fd18b09c16

    One closed leaking UST case is 0.8 mile south at a former filling station on State Route 43, down-gradient, closed with no further action.

    Quoted from page 2
    One closed leaking underground storage tank (UST) case is 0.8 mile south at a former filling station on State Route 43; it is down-gradient and closed with no further action.

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 2 · 2023-01-27

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

  19. C-fe98e6ae5a

    REC 1: a release of brine and petroleum to soil is suspected at the former tank battery site on Parcel 5, with no release report found.

    Quoted from page 1
    No release report for this area was found. A release of brine and petroleum to soil is suspected.

    Phase I Environmental Site Assessment - Tamsin Ridge Solar and Storage Project · DR-0012 · Page 1 · 2023-01-27

    Source consultant_memo · Claim type presence · Polarity presence · 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

  • IR-6b1aae03de · High priority

    Provide the regulatory database screen (federal epa and state contaminated-site, release and tank lists) for the project area, or confirm none exists.

    Missing evidence
    Regulatory database screen (federal EPA and state contaminated-site, release and tank lists)
    Consequence
    Environmental Contamination is rated on partial evidence without it.
    Blocks the decision
    No
    Raised by
    completeness

Next steps

  • Complete limited Phase II at Parcel 5 tank battery before fixing substation and BESS layout.
  • Remove Parcel 3 debris and pesticide containers before construction.
  • Obtain environmental lien and AUL search once title commitments are issued.

Agencies

  • Ohio EPA
  • ODNR

Cost and impact

Impact
C, S
Potential cost level
M
Why

Phase II sampling, debris removal and possible soil handling or resiting at the substation and BESS yard; the SPCC plan for the transformer is routine (C-e571f3a9eb). Cost would rise if remediation is required.

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