Manufacturing plant environmental due diligence: what to check
Buying an old plant means buying its process history. Know it before you spend on a full study.
Why manufacturing and heavy industrial buildings carry this risk
Manufacturing used degreasers, metals, PCBs in old transformers and fuel for boilers, often for decades before modern waste rules. Releases from the 1950s through the 1970s are still being found.
Federal law can hold a current owner responsible for past contamination, so buyers need to show they looked before buying to qualify for the law's protections.
What usually turns up
Solvents and metals from past processes
Often seriousDegreasing, plating and finishing are the classic sources. Federal hazardous waste records often name them.
Superfund and state cleanup listings
Often seriousA listing on the site or next door changes the deal. Check federal and state lists and their status.
Transformers, pits and sumps
Worth checkingOld electrical gear may have held PCBs, and floor pits collect whatever spilled.
Recorded use limits
Worth checkingPast cleanups often end with restrictions on use, digging or groundwater.
What the pre-screen checks for a manufacturing building
- EPA hazardous waste, Superfund and enforcement records for every past operator.
- State cleanup and tank lists for the site and neighbors.
- Historical aerials and maps to date buildings, tanks and outdoor storage.
- Flood zone for the plant and storage yards.
Pre-screen a property before you spend on a Phase I
A desk review of one address: past uses from historical photos and maps, federal and state environmental records, and flood risk, ready usually within the hour. $100 for one report, or $100/month for 3.
Questions to ask the seller
- What was manufactured here, by whom, and for how long?
- Any state or federal cleanup orders, past or present?
- Any recorded environmental covenants or use limits?
- Do you have prior Phase I or Phase II reports?
When to order a full Phase I
Always order a full Phase I for a manufacturing building, and usually a Phase II. The pre-screen tells you in about an hour whether the history is worth the cost of finding out more.