Environmental Due Diligence in Real Estate Transactions Identifying and Mitigating Risks and Liabilities for Buyers, Sellers and Lenders

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THURSDAY, MARCH 22, 2012

Presenting a live 90-minute webinar with interactive Q&A

Cindy J. Karlson, Counsel, Day Pitney, Hartford, Conn.

Cynthia Retallick, Senior Vice President and Deputy General Counsel, TRC Companies, Inc., Windsor, Conn.

Derek Ezovski, President, Outsourced Risk Management Solutions, West Hartford, Conn.

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Transactional Environmental Due Diligence

March 22, 2012

Cindy Karlson, Esq. – Day Pitney LLP

Derek Ezovski – ORMs

Cynthia Retallick, Esq. – TRC Companies, Inc.

Page 6 |

Goal of Environmental Due Diligence

Assess potential for liability/costs to arise under Environmental Law

1. Compliance with Environmental Laws Common Law Issues

Statutory Compliance/Noncompliance

2. Evaluate Potential for Liability under Regulatory Regimes CERCLA, RCRA, Clean Air Act, Clean Water Act, state analogs

CERCLA Issues Site Nexus will be established with transaction

Assess Liabilities and Possible Defenses

Liabilities Determined by Current and Former Site Conditions

Defenses – Very Limited

Innocent Landowner Defense (Fmr Third-Party Defense) - ILO

Bona Fide Prospective Purchaser Defense - BFPP

Contiguous Landowner Defense -CLO

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Page 7 |

Transactional Considerations Stock Acquisition

Company transitioning unchanged

Corporate liabilities of company unchanged by transition

Asset Acquisition Liabilities arise only as related to the assets transitioning

Contamination present, contamination originating from, and current compliance status of the asset(s)

7

Risk Stock Acquisition Asset Acquisition

Current Site Condition X X

Off-Site Conditions - Migration Off-Site Conditions- Transportation

X X

X

Other Sites (e.g., Formerly Owned) X

Compliance History – Current Compliance History – Past

X X

X

Page 8 |

Due Diligence Strategy Considerations

All Appropriate Inquiry Primary Function – Support CERCLA Defenses Evolved into de facto Commercial Standard – ASTM – 1527-05 Specific elements to satisfy Still responsible for any New Conditions on the Site

Operational Compliance Permits

Violations? Transferrable?

Equipment Age/Maintenance Transfer of Warranties

Common Law Compliance Contractually Required Disclosures SEC Disclosure Review

8

Results you can rely on

Seller’s Due Diligence

Results you can rely on

Background: Risk Definition – Due Diligence

Due Diligence is the Cornerstone of Risk Mitigation

A Balance of Results and Costs

Comprehensive Data/Information Eliminates Risk Grossly Incomplete Data/Information Increases Risk

GOAL Balance the cost and schedule of

Due Diligence to achieve reasonably predictive levels of data/information

10

Results you can rely on

Seller’s Transactional Goals

• Sell Site “As Is” – Maximum Possible Price (minimize price impact associated with pollution) – Maximum Releases from Buyer – Maximum Indemnity/Protections

• Considerations – Assure that walk-away is complete – Liability Won’t Come Back!

Clean-up is completed to satisfaction of regulators – Before or after transaction? – Who will perform?

Prohibit uses contrary to final Site condition Assure maintenance of engineering/institutional controls

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Results you can rely on

Seller’s Due Diligence

• Prepare Data – Prepare the universe of data and information – Lack of Data is a Purchaser Risk $$

Technical Legal

– Control the information process Limited Access – Secure website or central location Full Access – Hard copies, CDs

– Compile Data Complete

– Withholding data/information limits/vitiates contractual protections – Disclosure Obligations – By state and by contract

Final Reports/Data Permits Information on Equipment/Facilities Term – How Far Back ??

– Data Gaps Identified Potentially Material? Benefit Analysis – Self-perform or accept risk-based price reduction?

12

Results you can rely on

The Fundamental “Raw” Data

Critical to establish level of materiality – Don’t get lost in the weeds

Permits, Notice of Violations, Agency Correspondence

Review of Existing Phase I and Phase II Reports

On-Going Site Remediation—What’s Left to Do?

Potential Responsibility Party Notices/Obligations

Pending or Threatened Litigation?

Prior Owned Sites---Any Legacy Liabilities?

EH&S Legal/Administrative Actions

Ongoing Indemnity Responsibilities

Expected Capital Expenditure Costs

Estimated Environmental Reserves

Air Compliance/New MACT Standard

Worker Health and Safety Record

13

Results you can rely on

Seller’s Due Diligence (cont.)

• Confidentiality Agreements – Basic protections – Expressly limit and define regulatory interactions – Include non-solicitation provisions

• Regulatory Access for Purchaser – Phases of the Deal – Initial Phase

Personal Visits - Not recommended – Alert regulators to change – increase regulatory interest – Potential for issues to identified/raised to regulators

File Reviews – Limit – Significant activity on a file – increase regulatory interest – Potential to allow if limited to single (final) Purchaser

– Final Phase/Negotiations Purchaser may want/need regulatory access to negotiate protections

– Never allow Purchaser access to regulator without Seller present – Maintain role in any regulatory protections negotiations – DEAL CAN CRATER

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Results you can rely on

Seller’s Due Diligence (cont.)

• Environmental Deal Team – Internal – Data review

EHS Director Plant Manager(s) In-House Counsel Knowledge Basis – Senior Managers/Officers, Current (not former) Employees

– External Environmental Counsel Environmental Consultant Insurance Broker – with Specific Environmental Expertise

• Define Assets – Stock or Asset Sale?

All assets? Former owned/operated assets?

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Results you can rely on

Seller’s Due Diligence (cont.)

• Site Visits/Sampling – Control/Oversee Visits

Prepare Site overview for Potential Purchasers Consider amassing questions and supplying answers to all

– Forbid/Limit Site sampling – INVASIVE TESTING BY PURCHASERS NOT RECOMMENDED

• AAI Considerations – Self perform – Confidentiality - Consider and Control

Current and past employees/owners, Neighbors, Regulators – Assess Identified Data Gaps – Benefit Analysis – Anticipate Limitations

Lead-based paint, Asbestos, PCBs, Health/Safety, Wetlands – Get reports in DRAFT – to Counsel – Property Condition Assessments?

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Results you can rely on

High Level Summary of Liabilities

General Summary of Environmental Liability

Environmental Liability Reasonable Low Cost Estimate

Likely Cost Estimate

Reasonable High Cost Estimate

Known Environmental Liability

On-Going Site Remediation $0 $0 $0

EH&S Compliance Issues $23,000 $87,000 $315,000

Total Known Environmental Liability $23,000 $87,000 $315,000

Potential Environmental Liability

Potential Remediation $40,000 $125,000 $400,000

Potential EH&S Compliance Issues $0 $0 $0

Total Potential Environmental Liability $40,000 $125,000 $400,000

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© 2012 Day Pitney LLP

Environmental Due Diligence: Considerations for Buyers

Page 19 |

What is an appropriate scope of due diligence?

1. Transactional Factors 2. Regulatory

Considerations 3. Corporate Governance

Page 20 |

Developing A Due Diligence Strategy Transactional factors

- Size of the deal does not necessarily dictate the nature and extent of a Buyer’s due diligence efforts

- Buyer’s risk tolerance - Financing conditions

- Commercial lender, private equity issues - Schedule constraints

- Buyer does not have to compromise on due diligence even under tight timeframes (i.e., e-due diligence rooms can be accessed 24/7)

- Budget limitations

Corporate Governance - Fiduciary duties

Page 21 |

What liability protections are available? 2002 SARA and the Small Business Liability Relief &

Revitalization Act (Brownfield Amendment) - Innocent landowner defense - Bona fide purchaser defense - Contiguous landowner defense What work is required to qualify for liability protections - All Appropriate Inquiry * 42 U.S.C. § 9601(35)(B) * 40 C.F.R. 312 (2005)

Page 22 |

All Appropriate Inquiries

Regulatory Considerations - All Appropriate Inquiries - Eligible persons for liability protection under CERCLA · Innocent landowners, contiguous property owners · Bona fide prospective purchasers · State or local government that acquire ownership/control involuntarily through bankruptcy, tax delinquency or abandonment - Conditions to satisfy AAI: · Must perform due diligence in accordance with 40 CFR Part 312 · AAI timelines prior to acquiring ownership of property:

Within 1 year prior to acquisition, perform or update AAI Within 180 days prior to acquisition, perform interviews of current and

past owners; review government records; on-site visual inspection and search for environmental cleanup liens

Page 23 |

All Appropriate Inquiries (Cont.) AAI alone does not guarantee CERCLA protection,

the following conditions must also be met: Comply with Continuing Obligations after acquiring the property

Provide all legally required notices with regard to discovery of releases of hazardous substances

Comply with land use restrictions, fully cooperate with persons conducting

response actions and information requests; use due care with respect to hazardous substances

Buyer must not be affiliated with any liable party through family, contractual, corporate or financial relationship (other than the property conveyance instrument)

Page 24 |

Practice Tips For Due Diligence Strategy 1. Know what work is necessary versus recommended - All Appropriate Inquiries - What information/tasks must be included in a ASTM

E1527-05 Phase I ESA - What is not included in ASTM E 1527-06 – mold, asbestos, wetlands, lead-based paint and

indoor air quality

2. Appreciate the factors that guide various lenders

Page 25 |

Selecting Consultants And Counsel Evaluate consultant and/or attorney’s experience and

credibility with government agencies Evaluate the business acumen and negotiation skills of

the key individuals (you want a strong person in your corner supporting you in post-due diligence negotiations)

Scrutinize the scope of work (the devil is in the details) Carefully review the consultant’s terms and conditions to

the contract You get what you pay for in most cases

Page 26 |

Read Between The Lines

Potential “buried” risks in due diligence findings: * Scrutinize waste disposal practices – no matter how small the

quantity of waste * Understand implications of water use/availability for your site and

development plans * Evaluate status of regulatory permits (any permit transfers

necessary?)

* Identify potential risks related to adjacent properties

Page 27 |

New On The Scene

Indoor air Vapor intrusion PCB in caulk Building Energy Performance Assessments (BEPA) ASTM Standard E2790-11

Page 28 |

Vapor Intrusion Migration of volatile chemicals from the

subsurface into buildings

Potential liability exposure Tenant and third party claims The CERCLA definition of “release” includes vapor intrusion Continuing obligations at site

Page 29 |

Building Energy Performance Assessments New ASTM standard: Standard Practice for Building Involved in a

Real Estate Transaction

It is a tool to calculate a building’s energy consumption and cost – different from an energy audit

Can be used for disclosure to an interested party

Intended to supplement ASTM E 2018 and E 1527 environmental site assessments

Consultant may offer bundle pricing for ESA, PCA and BEPA

Page 30 |

Throwing Good Money After Bad: Potential Risks Of Insufficient Due Diligence

Jeopardy for future protections Potential liability for malpractice

Post-closing liabilities and costs that could have been mitigated or otherwise allocated during the deal negotiations

Page 31 |

Recent Case Law The Highland Community Development District v. McGlinchey

Stafford PLCC, 2010 U.S. Dist. LEXIS 119992 (2010) - Town filed suit against bond counsel alleging that bond counsel

issued opinion letters and therefore had a duty to conduct a reasonable investigation into the facts supporting the opinions, including environmental due diligence.

- Town alleged that bond counsel promised to guide and ensure that all

necessary work was performed and later advised against performing any environmental assessment without informing the Town of such.

- Plaintiff claims that if a basic environmental assessment had been

performed, the fact that development site lay within the bounds of a historic bombing range would have been discovered before closing.

- On October 12, 2010, the federal district court dismissed defendant’s

motion to dismiss finding that the allegations are sufficient to create a question as to the scope of defendant’s work.

Page 32 |

Contact Information:

Cindy J. Karlson, Esq.

Day Pitney LLP (860) 275-0298

(860) 614-0184 (Cell) cjkarlson@daypitney.com

Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

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Environmental Due Diligence in Real Estate Transactions

Environmental Trends in the Lending

Community

Presented by:

Derek Ezovski

March 22, 2012

Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

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Current Trends in Lending

• Intense pressure from regulators

• Falling asset values/foreclosures • Distressed Assets/Private Equity

• SBA Lending

• Lenders updating environmental/appraisal policies

• More levels/forms of due diligence than ever before on more loans

Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

35

Current Status of Banking

• 13 banks and savings institutions have failed thus far in 2012, most of which have had unusually high commercial-mortgage exposure.

• 92 - 2011 • 157 – 2010 • 140 – 2009 • 25 - 2008 • From a survey conducted by the Environmental

Bankers Association, 63% of lenders that had an examination last year were asked about their environmental policy.

Property Values

CRE Defaults

Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

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How Did AAI Affect Lenders • Secured Creditor Exception – Protects Lenders

– Other Environmental Liabilities

– Protections for Future Buyers

• AAI Established Federal Statutory Authority Defining Scope of Phase I Environmental Site Assessment

– Effective November 2006

• Triggered Changes in Guidance - Regulatory Agencies

– Federal Deposit Insurance Corporation (FDIC) Guidelines

– Small Business Administration (SBA)

Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

39

“New” FDIC Guidance

• FDIC updated its Guidelines in November 2006.

• FDIC’s guidance set the standard; FDIC is regarded as a leader in terms of environmental requirements.

• FFIEC implemented environmental policy training/education for examiners across all agencies (October 2007, May and June 2008)

• A majority of banks have reconsidered and revised their environmental policies (and continue to do so).

Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

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FDIC Focus – FDIC emphasizes process and consistency.

– Ensures proper document management and records retention.

– Document due diligence.

– Track changes to policy and consistent application of policy.

– Banks must avoid “participating in management” of the business and thereby assuming liability under CERCLA.

– Many attorneys recommend a Phase I ESA in the event of foreclosure.

Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

41

SBA

– The changes to SOP 50 10 (5) took effect

August 1, 2008 and have been updated several times since.

– Went from 1000 pages to 400 pages.

– Especially important for institutions with preferred status who do SBA underwriting.

Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

42

Significant new SBA Environmental Due Diligence Items

• 2 levels of Environmental Due Diligence for SBA – AAI Phase I – for properties with environmentally

sensitive uses

– “Records Search with Risk Assessment” – low risk properties

• Includes a search of the government databases identified for AAI;

• A search of historical use records, and;

• A risk assessment by an environmental professional determining whether the site is “High”, “Elevated” or “Low” risk

• List of NAICS Codes of Environmentally Sensitive Conditions

• Unique Gas Station/Dry Cleaner Requirements

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Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

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Levels of Environmental Due Diligence used by Lenders

• Nothing • Environmental questionnaire • Desktop due diligence • Transaction Screen Assessment • Phase I Environmental Site Assessments • Phase II, III, Remediation, etc. • Environmental insurance • Property Condition Assessments • Sustainability/Green Issues • Others

Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

44

Impact of Bank Size/Resources Regional & National Lenders

– Resources in place to understand environmental issues on the property

• Screen for lower-risk loans

• Have staff/internal resources to manage environmental risk

Community Banks – No on-staff environmental expertise (typically)

– Not as sophisticated with regard to environmental issues or due diligence options available

– Often rely only on environmental questionnaires and/or proceed without accurate knowledge of environmental condition of property

– Rely on external guidance to dictate their practices

Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

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Tiered Due Diligence

• Over 50% of lenders stated they had

added more levels of due diligence to their environmental policies over the past 3 years.

• 51% of lenders said they would adopt the SBA policy for their traditional loans as well.

Sample Policy Matrix Minimum Due Diligence Requirements

Real Estate Loan Type <$250K $250K < $1M >$1M

Low Risk Loan - new

Desktop Review Desktop Review/Transaction

Screen

Phase I

High Risk* Loans - new

Phase I/Transaction Screen

Phase I/Transaction Screen

Phase I

Renewals -Low Risk

Desktop Review Desktop Review Desktop Review/Phase I

Renewals -High Risk

Desktop Review Desktop Review Desktop Review/ Transaction Screen/

Phase I

Multi-Family Desktop Review Desktop Review/ Transaction Screen

Desktop Review/ Transaction Screen

Outdated Phase I Desktop Review Desktop Review Desktop/Phase I update

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Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

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CMBS Maturities

Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

51

Summary

• Market pressures have reinforced long-term trend to increased risk management and due diligence.

• Regulators enforcing risk management due to a perceived over-concentration of risk regarding commercial real estate.

• Lenders are protected in originations by the secured creditor exemption.

• Environmental and appraisals are both pieces of the puzzle that are being revised in the current environment.

Due Diligence. Done Simply. Done Right. Outsourced Risk Management Solutions

52

Derek Ezovski 860.838.5388

dezovski@orms.com

Outsourced Risk Management Solutions 7 South Main Street, Suite 209

West Hartford, CT 06107

Results you can rely on

Two Special Topics

1. Valuation Methodology - Due Diligence

2. Private Equity Transactions

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Results you can rely on

Due Diligence Valuation Methodology

Results you can rely on

Valuation Due Diligence

Define Range of Remedial Costs/Responsibilities Accurate Quantification

Applications Support Insurance Underwriting

Liability Transfer Transactions

Setting Reserves

Trusts/Escrows

Bankruptcy

Foreclosure

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Results you can rely on

Valuation Due Diligence

Primary Sources of Uncertainty

Remedy Selection

- Deterministic Outcomes for Multiple Potential Alternatives

Remedy Implementation

- Multiple Potential Outcomes for Deterministic Alternative

Aggregating Sites Moderates Uncertainty Impacts

- Portfolio Effect

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Results you can rely on

Risk of Remedy Selection

• Purpose: To Develop an Understanding of the Potential Financial Risk Associated with Remedy Selection

• Approach: Develop a Probabilistic Distribution of Project Costs Associated with the Full Range of Remedial Action Alternatives with Assigned Probabilities.

• Output: Minimum Cost, Maximum Cost, Probability-

weighted Mean Cost, Most Likely Case Cost, And Cumulative Probability/Cost Curve

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Results you can rely on

Decision Trees Model Risks

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Results you can rely on

Risk of Remedy Implementation

• Purpose: To Develop an Understanding of the Potential Financial Risk Associated with Remedy Implementation.

• Approach: Develop and Cost the ‘Most Likely Future’ Scenario, Then Perform a Monte Carlo Simulation for Those Parameters (e.g., Quantities, Unit Costs, Durations) That Drive the Risk Uncertainty.

• Output: Minimum Cost, Maximum Cost, Probabilistic Mean Cost, Cumulative Probability/Cost Curve

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Results you can rely on

Basis of Attachment Point

Cum. Prob Chart

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

$500,000 $520,000 $540,000 $560,000 $580,000 $600,000 $620,000 $640,000 $660,000 $680,000

Remediation Cost

Cum

ulat

ive

Prob

abili

ty

Three Cost/Probability Curves • Decision Tree: Representation of

Risk Due to Uncertainty in Future Decisions (e.g. Remedy Selection)

• Monte-Carlo on Most Likely: Representation of Risk Due to Uncertainty in Field Conditions Under Most Likely Alternative

• Monte-Carlo on Expected Value: Representation of Weighted Risk Due to Uncertainty in Field Conditions Across All Potential Remedies/Decisions

Cum. Prob Chart

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

$500,000 $520,000 $540,000 $560,000 $580,000 $600,000 $620,000 $640,000 $660,000 $680,000

Remediation Cost

Cum

ulat

ive

Prob

abili

ty

Cum. Prob Chart

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

$500,000 $520,000 $540,000 $560,000 $580,000 $600,000 $620,000 $640,000 $660,000 $680,000

Remediation Cost

Cum

ulat

ive

Prob

abili

ty

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Results you can rely on

Private Equity

Results you can rely on

Private Equity Full Life Cycle Model

TWO-PHASES

Investment Strategy

Deal Screening

Due Diligence

Post-Acquisition Integration

Realization (Sale)

Traditional Transaction Activities Post-Acquisition Projects

Preparation for Sale

Sale-side Transaction Support

• Goal: • Optimize Operations Short-term • Prepare for Realization Long-term

• Due Diligence Must Support Short-Term and Long-Term Risk-Definition and Risk-Resolution Strategies

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Results you can rely on

Private Equity Due Diligence

• Typically, it depends on the source of funding

– Cash purchases Equity fund can dictate – Lender involved Lender typically dictates

due diligence – Contaminated properties Much more due

diligence required

• Due diligence options – Nothing Desktop Reviews Phase I

Remedial Action

63

Results you can rely on

Resources, Ag, Raw Materials, Energy

Casting, Forging, Stamping, & Melting

Chemical/Processing

Compounding

Assembly, Forming

Services, Technology

Construction

1.

2.

3.

4.

5.

6.

7.

Operations

Fleet/Logistics Sourcing/Procurement Facilities Management

8. 9. 10.

Water Waste Forest Products

Priority Chemicals GHGs

Cost Savings Revenue Expansion Risk Mitigation

• Changes to fuel mix

• Waste heat recovery

• Right sizing of motors

• Plant layout improvements

• Waste heat recovery

• Redesigned supply chains

• Waste heat recovery

• Refrigeration

• R&D Labs

• Data center analysis

• Logistics software

• Improved maintenance

• HVAC, lighting, sensors

• On-site generation

• Excess tradable credits

• Co-generation

• Biofuels production

• Composting, production of soil nutrients

• Backhaul contracting

• GHG consulting services

• GHG consulting services

• Emissions compliance

• Fuel & electricity supply

• Fuel & electricity supply

• Fuel & electricity supply

• Emissions compliance

• Fuel & electricity supply

• Emissions compliance

• Fuel & electricity supply

• Driver training

• Green procurement

• Lighting retrofits

• Supply chain

• Backhaul contracting • Car accident reduction

• Maintenance risk mitigation

Environmental Improvement and Value Creation Opportunity Areas

Heavy Industrials

Light Manufacturing

Services

All Sectors

EcoValuScreen – Environmental Improvement Identification During Due Diligence

How It Works: Use relevant business activities to identify an actionable list of operational projects that will enhance environmental performance.

Find Value, Not Just Liabilities

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Results you can rely on

Project Description Best Case ($M)

Reasonable Case ($M)

Worst Case ($M)

Prob. Of Success (%)

NPV Scenarios

Reuse scrap materials Sell unused scrap Shared material buying

$25M $5M $10M

$10M $2.5M $4M

$5M $1M $0

65 40 25

Driver training Speed governors Improved logistics software

$30M $10M $10M

$20M $5M $8M

$10M $4M $6M

70 30 25

Motion-sensitive water nozzles

$10M $8M $6M

90

TOTAL BENEFITS $100M $57.5M $32M

Waste

GHGs

Water

Best Case Worst Case

Env. Savings

10,000 10,000 5,000

2,000 2,000 0

25,000 20,000 10,000

8,000 9,000 6,000

15,000 8,000

Waste (tons)

GHGs (tons of CO2 eq.)

Water (gals)

• Waste (tons) • GHGs (tons CO2 eq) • Waste (gals)

25,000 55,000 15,000

Environmental Savings

4,000 23,000 8,000

Best Case Worst Case

15,000 40,000 12,000

Reasonable Case

TABLE 1: Summary Material Cost-savings Opportunities for Owned and Operating Facilities

EcoValuScreen – Environmental Improvement Upside Quantification Illustrative

Quantify projects benefits & identify highest priority environmental & financial performance initiatives.

65

Results you can rely on 66

Critical(>$5 M Cost)

Impact Major($2-$5 M Cost)

Manageable(<$2 M Cost)

Remote Possible Likely(<10% Chance of Occurrence) (10-50% Chance of Occurrence) (>50% Chance of Occurrence)

Likelihood

Low Risk Watch Mitigate Critical Risk

Confidential Project - Environmental Risk Map

EG1Mitigate

Watch

- Covered by Indemnity - Covered subject to $15 M deductible - Not Covered

EG2

SC1

CF2SC2

CF1

BP1

BP2

BP3 MS1

VI 1

HL 1

HL2

AL1

AL2

AL3

AL4

VI2

CI1

CI2

CI3

Single Site Probability Analysis Risk Mapping

Results you can rely on

Contact Information

Cynthia Retallick (860) 298-6390

(860) 573-5203 (C) cretallick@trcsolutions.com

21 Griffin Road North Windsor, CT 06095

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