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What is Remediation after a Phase 2 Environmental Site Assessment?   Recently updated !

What is Remediation after a Phase 2 Environmental Site Assessment?

Remediation refers to the process of cleaning up a property with contamination issues that are usually discovered during the Phase 1 Environmental Site Assessment (ESA) and Phase 2 Subsurface Investigation process. Today, there are a variety of remediation methods and technologies to apply at a site. And environmental professionals can optimize the process for maximum effect and lowest cost. For instance, the type of chemical, or the extent of the contamination plays a major role in selecting the optimal remediation technique. Moreover, the type of media (for example- soil, soil gas and/or groundwater) is another important factor in the remedial action methodology. Lastly, the available timeframe and budget, as well as the extent of regulatory oversight for the contamination cleanup process, also plays a part in the formation of a remedial action plan. Updated February 18, 2020.

Altogether, one must understand that each site is unique, and it is necessary to consult a professional geologist or environmental engineer to determine the appropriate course of action. 

Prior Investigations

A Phase 1 Environmental Site Assessment looks for Recognized Environmental Conditions, which are “red flags” that warrant subsurface contamination testing. The secondary process of this assessment refers to a Phase 2 Environmental Test, or Phase II ESA, and typically includes soil, soil gas, and groundwater sampling. The samples undergo laboratory analysis for common contaminants, indicating the presence of contamination, or lack thereof. And if contaminants are observable above Phase II ESA Screening Levels, one can reasonably presume requirements for remediation and mitigation actions. However, a Phase II ESA will rarely comprise enough data to begin the cleanup process.

Additional Investigations

In essence, all Phase 2 Environmental Site Assessments are “limited” investigations because they are made affordable. Thus, Phase II ESA reports are typically shallow subsurface tests and don’t fully delineate the lateral and vertical extent of a contamination plume. Usually, if contamination above screening levels are observable, one or more Additional Subsurface Investigations will become the next phase requirement. This effort aims to produce data for the clean-up process and comprises deeper samples than the initial Phase II ESA. It is in order to create an accurate representation of the contamination plume. Judging by the final results of this site contamination model, engineers and geologists then prepare the best course of action with regards to cleanup, also known as a Remedial Action Plan.

Remediation Action Plan (RAP)

After enough information is gatherable by the Additional Subsurface Investigation process, professional geologists then decide how to go about cleaning up the site. The goal of remediation is to restore the subsurface as close to the natural state as possible, and also to reduce human and wildlife exposure to harmful contaminants. There are many ways to remediate a site with subsurface contamination. But the processes often group into a few general categories. For instance, if the remediation technology applies directly to the subsurface, without removing any soil or groundwater, it is “in-situ” or in-place treatment. On the other hand, if the soil is excavated, or groundwater pumped, in order to bring the media to treatment, it is called “ex-situ.” Alternatively, natural attenuation is the process by which a subsurface contamination plume dilutes and degrades on its own over time, and is verified by monitoring and periodic confirmation sampling.

Mitigation vs Remediation

Sometimes environmental engineers can reduce human exposure and health risks by implementing walls, barriers or caps to isolate the contamination plume before it migrates to an end-point. This process isn’t remedial, but rather mitigative. And typically, vapor intrusion mitigation measures occur alongside remedial action methods, to ensure the safety of onsite occupants.

Remediation action plan descision

In-Situ Remediation Options

In-situ remediation methods do not require excavations, nor any pumping of groundwater. For some sites, these methods can be part of an effective, yet energy- and waste- efficient cleanup plan. In-situ treatment always applies directly to the subsurface. And the process usually involves adding, or injecting an agent to accelerate the breaking-down of contaminants. Additionally, these methods can be minimally disruptive to ongoing business operations on-site (depending on logistics).

Chemical Oxidation

In-situ chemical oxidation (ISCO) typically relies on an oxidant to react with and break down contaminants. To illustrate, a common oxidant such as hydrogen peroxide can be strategically injected underground at specific depths and volumes, with the intent to react to contaminants. The result is a chemical and physical change into daughter products which are understandably less harmful, or completely harmless. In the process, technicians introduce the oxidants into the subsurface using existing wells, or new injection points via direct-push drilling. And the oxidant can even be combined with a catalyst, such as iron to speed up the chemical reaction and make the process more efficient.

Chemical Reduction

In-situ chemical reduction (ISCR) is similar to ISCO except for the fact that it utilizes reducing agents (usually a metal such as iron) that can react with other toxic metals (most commonly chromium) to make them less harmful. In fact, ISCR commonly applies to clean up the solvent known as trichloroethene, or TCE. Typically, the process includes injecting the reducing agent directly into holes drilled into the groundwater table. However, another method comprises a technician creating a semi-permeable underground wall made of the reducing agent, to allow the groundwater to be treated as it flows through the barrier.

Thermal Treatment

In contrast to harnessing a chemical reaction for remediation, in-situ thermal treatment uses heat to remove a wide range of chemical contaminants. By injecting steam, applying steel pipe heaters, or using electricity to create heat underground, the chemicals of concern undergo evaporation and degradation. After thermal treatment, the resulting soil gas can controllably migrate to the surface, and undergo further treatment if necessary. Thermal treatment is one of the optimal methodologies to clean up sites with non-aqueous phase liquids (NAPL) contamination

Air Sparging

This technique is technically in-situ but is also a supplement to the soil vapor extraction process, which is an ex-situ process as well. After the injection wells are drilled deep enough to reach groundwater, an air compressor then pumps air into the groundwater table, within the well-casing. This agitating exposure accelerates the volatilization process of chemicals, so they may become vapor-phase, and extract via the SVE system. And after the vapors draw up through the extraction wells, the air undergoes treatment with carbon or thermal applications, prior to atmospheric release.

soil vapor extraction SVE remediation after phase ii esa

Bioremediation

Bioremediation utilizes microbial activity to break down contaminants. Harmless bacteria, that occur naturally in the soil and groundwater, can consume and metabolize petroleum products, solvents, and even pesticides. However, the challenge of bioremediation is creating an environment where the select-bacteria can thrive. As a result, it may be necessary to add amendments to the soil, such as other bacteria, in order to make sure populations are large enough to consume the contaminants efficiently. Bioremediation is an attractive option because it uses natural microbial action, and it can take place in-situ. Alternatively, microbial action can occur ex-situ.

Ex-Situ Remediation Methods

When there is a large concentration of contamination that must commence quickly, responsible parties may consider ex-situ treatment. Ex-situ remediation methods typically involve a costlier and lengthier scope of work for cleanup. Whether impacts exist in soil, groundwater, or soil gas, the overall concepts comprise removing the contamination from its place underground and undergoing treatment above ground or off-site. For example, extraction and pumping from the subsurface. And depending on the extent of contamination and impact, a combination of these methodologies might be the most optimal approach to cleanup.

Soil Vapor Extraction

Soil vapor extraction (SVE) is an ex-situ treatment that does not involve the addition of any chemicals or reactive agents. Rather it utilizes extraction wells and vacuum pressure to draw out the vapors from chemicals as they volatilize (change into a gas) underground. The extraction wells are typically set within the vadose zone, which is a soil mass generally above groundwater, but below the ground surface. In fact, soil vapor extraction works best with dry soil. And when contamination exists in the saturated soils as well, deeper injection wells may apply to utilize air sparging methods, alongside SVE.

Soil Excavation

Contamination source excavation remediation is an original method of site clean-up. When there is a large concentration of chemicals in a relatively small amount of soil, it makes sense to excavate the site. Using traditional excavation equipment such as backhoes and dozers, contamination is removable from the site. And disposal methods include exportation to treatment facilities with appropriate certification. And in some cases, the soil contamination may undergo treatment on-site.

contamination remediation by excavating

Thermal Desorption

Another ex-situ way to treat soil is by applying heat. To illustrate, heat is applicable at strategic temperatures to volatilize or evaporate the chemicals out of the soil. Typical applications are by flame or by heating elements. Similarly, the in-situ thermal treatment uses subsurface heating elements to volatilize contaminants underground. In fact, large flame application chambers can heat and treat approximately 25 tons of contaminated soil per hour.

Pump and Treat

When groundwater is the target media of contamination, similar clean-up techniques can apply. Although, a strategic network of wells pumps the groundwater into a holding tank or an on-site treatment apparatus. Afterward, the clean groundwater returns through the system, which results in a pump-back into the same aquifer, or a nearby surface water system. In fact, under the proper permitting protocol, the resulting water may also end up within the local storm drain. A few ex-situ options to treat groundwater in this way include bioremediation, air stripping, and activated carbon treatment.

groundwater remediation pump and treat diagram

Activated Carbon

Carbon is a well known, highly efficient filter media that removes contaminants from air and water. For pump and treat applications, the water is run through an activated carbon filter. It’s here where common contaminants stick or “sorb.” The carbon removes all or most volatiles and hydrocarbons from air and water that passes through. And after treatment, the effluent air or water is environmentally friendly for discharge. Eventually, the carbon also needs retreatment by thermal desorption, in order to reuse. Alternatively, the carbon can just be sent to a proper landfill after serving its purpose.

Air Stripping

The air stripping method applies primarily to volatile organic compounds that are dissolved in water. These contaminants typically have a higher capacity for volatilizing by exposure to air and agitation. After the water is pumped into the aeration tank comprising the air stripper, it trickles down through a filter media that exposes the maximum surface area to the air. Simultaneously, a fan circulates air upwards from the bottom of the chamber, and the water passes through as it cascades. In essence, the contaminants volatilize and migrate to the top of the tank in vapor-phase. The resulting vapor can then undergo carbon treatment, per the descriptions above, before exhaustion into the environment.

Containment

In some cases, an acceptable course of action alongside remediation is to simply isolate the contaminants. In fact, by sealing off the source-area, one prevents contamination from further migration. This mostly applies to the protection of people and wildlife downgradient from a source-area. There are various containment methods involving vertical and horizontal barriers. For instance, a slurry wall. Although, the most common technique is capping.

Capping

This is a relatively straightforward procedure that involves putting a protective layer above or below a contamination plume. The most basic form of capping exists as a concrete or asphalt layer along the ground surface, with a vapor barrier. For example, these barriers can exist within a subterranean garage foundation overlying contaminated soil. Alternatively, a slurry or clay layer can apply atop and below a contamination plume in subsurface conditions. For example, landfills install these layers above and below the garbage they place underground. Vapor barriers are technically part of the mitigation effort, which can occur simultaneously to the remediation process. Furthermore, sites with higher contamination concerns might comprise multiple layers, comprising clays and other materials, along with a vegetative layering. Ultimately, the goal is to prevent toxic contaminants from migrating into other exposure pathways.

Ecological Revitalization

Ecological revitalization is an over-arching remediation plan that aims to return a contamination site to a more natural state, without the use of human engineering methods. By replanting native wildlife, enriching the soils, and providing wildlife habitat, land managers can provide aesthetic benefits and increase property value at the same time. And, ecological revitalization plays an even greater role, serving a very functional remedial purpose beneath the surface.

Evapotranspiration Covers

Plants can play an important role in remediation and are often the top layer to a capping strategy. In fact, with proper vegetation, the roots of plants draw water out of the ground and circulate it back into the air. The textbook term for this process is “evapotranspiration.” Additionally, it’s important for scientists to select the right soils for this strategy. And planners typically select a fine-grain combination of silt and clay that will be capable of holding high volumes of water. Moreover, it is important to prevent rainwater from percolating down to the level of the contaminants. This is because the chemicals can further-percolate downward, into the groundwater. As a result of proper soil and plant selection, absorbent sediments and thirsty roots can help to prevent the water from migrating.

Monitoring Natural Attenuation

Another common method of remediation is Monitoring Natural Attenuation (MNA). Natural attenuation refers to the environmental degradation of contaminants over time. And the keyword “monitoring” applies because of the importance to keep track of the degradation progress. And regulatory agencies typically prefer monitoring to proceed until safer levels of contamination are apparent. Usually, consultants and agencies prefer this method alone, for sites with low-level contamination or where time is not an issue. Otherwise, natural attenuation monitoring occurs alongside other remediation methods. Monitoring Natural Attenuation can also take decades to complete. Nonetheless, the same principles apply to qualify a site for clean-up closure.

Natural Attenuation Remediation

Resilience

Resilience is the ability of the land to recover and is an important concept in land management. Natural attenuation speaks to the extraordinary capacity of the environment to return to a point of stasis over time. Today, scientists understand that the natural systems on earth do return to a state of balance. However, there is a limit to what ecosystems can handle. As a result, humans must assist with remediation efforts for the preservation of the natural earth. And in doing so, the environmental industry will continue to improve on remediation methods, as well as sustainability technologies, in order to afford a more natural environment.

Remediation Professionals

With so many options available to landowners today, navigating the remediation process can be a daunting task.  Fortunately, there is ample assistance readily available through your local environmental professionals.

It is important to remember that each site is unique, and it is necessary to consult with a licensed professional geologist or engineer in order to determine the appropriate course of remedial action.


Authors:

Written By: Michael Joseph Sabo

Edited By: Adam Azad Kaligi, PG


Sources:

US Environmental Protection Agency

https://clu-in.org/products/citguide/

https://archive.epa.gov/ada/web/pdf/insituchemicaloxidation_engineering_issue.pdf

https://semspub.epa.gov/work/HQ/158711.pdf

American Petroleum Institute

https://www.api.org/~/media/Files/EHS/Clean_Water/Bulletins/09_Bull.pdf

United States Geological Service 

https://toxics.usgs.gov/pubs/eos-v82-n5-2001-natural/


Forward-Thinking Geologists, Engineers & Contractors!


How Long is a Phase 1 Environmental Assessment Good For?

How Long is a Phase 1 Environmental Assessment Good For?

How long is a Phase 1 Environmental Assessment good for? In general, a Phase 1 Environmental Assessment is good for one year. However, this answer can also vary depending on the purpose of the report, and relative current events. For instance, per the Small Business Administration, a Phase 1 ESAs expires precisely one year from the date of the respective report. On the other hand, AAI & CERCLA Liability Protection from a Phase 1 ESA expires within a 180-day timeframe after the date of the ASTM-compliant database report. Moreover, official ESA standards and regulatory agency screening levels do change periodically. And in such a case, an existing Phase 1 Environmental Site Assessment report cane become obsolete. And last but not least, certain job site operations (such as a continuous operating fuel stations) may warrant periodic Phase 1 updates. Typically, such updates can be within three-month timeframes. Updated November 20, 2019.

How Long is a Phase 1 Environmental Assessment Good For

How Long is a Phase 1 Environmental Assessment Good For

Updating a Phase I Environmental Site Assessment

In addition to inquiring how long is a Phase 1 Environmental Assessment good for, Clients also ask about the report updating process. Updating a recent Phase 1 ESA can be a faster and more affordable option. Especially when comparing the process to an entirely new report. At a minimum, updating a Phase 1 ESA comprises re-ordering any potential obsolete document(s), re-reviewing them in detail, and re-performing a physical inspection. Ultimately, a new report enters production, utilizing any of the non-obsolete information from beforehand, as well as any of the new information uncovered.

SBA’s One-Year Expiration Date

The Small Business Administration does have a series of environmental procedures and policies for lenders. According to the SBA, if a loan is securable with commercial real estate, there is an instant requirement for at least some level of environmental due diligence. Secondly, if the property use is identifiable with an “environmentally sensitive industry,” and the loan is over a specific dollar amount, a Phase I Environmental Site Assessment process commences. Otherwise, if loan amounts are lower or industries are not sensitive, applicants may commence with just an environmental questionnaire. Above all, at the moment the SBA only accepts Phase I Environmental Site Assessment reports within one year of the production date.

Liability Protection Expiration

Under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), a fully compliant Phase 1 ESA may serve to provide innocent landowner liability assistance for qualifying report users. Although CERCLA liability protection reportedly expires 180-days after the date of the Phase 1 ESA report. For site-specific or report-specific information pertaining to liability protection by CERCLA, consultation with an environmental attorney is advised.

Expiration by Continuing Land-Use Concerns

In some cases, the existing and on-going land-use of property poses a continuous recognized environmental condition. Even after the closure of an ESA report.

  • For instance, a gasoline service station can have continuously operating underground storage tanks (USTs) with the potential to leak anytime. Although the underlying soil may have already been proven clear during a recent Phase 2 Environmental Site Assessment, it is still possible for a release to occur after the assessment. As a result, the validity of a Phase 1 ESA honoring a recent Phase 2 ESA does have limitations. Consequently, when asking how long is a Phase 1 Environmental Assessment good for under these circumstances, the answer is “not long.”

In fact, most agencies, lending institutions, and purchasers may consider short-term and periodic updating. For example, update requirements can be as frequent as three months at a time. And upon overcoming any red flags during the updating, additional Phase 2 Subsurface Investigations can be required again.

Expiration by Standards & Screening Level Updates

The ASTM standards for a Phase 1 Environmental Site Assessment are typically subject to updates and modifications every decade. Consequently, updating the international standards for such reports renders all of the reports formatted to the prior standards as obsolete. Similarly, subsurface contaminant screening levels are also subject to change, at more frequent intervals of time. Upon any update of State or Federal environmental regulations, the conclusions and recommendations of prior Phase 1 ESA reports become obsolete.

Phase 1 Environmental Assessment Expiration by Regulation Changes

Phase 1 Environmental Assessment Expiration by Regulation Changes

How Long is a Phase 1 Environmental Assessment Good For Overall?

The final answer depends on the circumstance and user of the report.

As of the year 2019, it can be as low as 90 days, and as high as 180 days. Although in general, the reports are regarded as valid for a period of one year.


Forward-Thinking Geologists, Engineers & Contractors!


What is the Phase I Environmental Site Assessment Process?

What is the Phase I Environmental Site Assessment Process?

The Phase I Environmental Site Assessment process comprises a rigorous review of a property’s history, along with a physical inspection of the current conditions. And the end result is a lengthy report that follows regulation standards. For the convenience of Clients, environmental consultants usually provide executive summaries at the front of each report. Nonetheless, the entire Phase I ESA process has to follow the guidelines and standards of the American Society for Testing and Materials (or ASTM). If environmental concerns become apparent during the Phase I Environmental Site Assessment process, additional tasks (such as a Phase 2 Subsurface Investigation) become a requirement. Updated November 18, 2019.

What is the Phase I Environmental Site Assessment Process

What is the Phase I Environmental Site Assessment Process

1. The Initial Request for a Phase I ESA

A Phase I ESA can be per the request of one party, or all the entities and parties within a transaction, altogether. And because it is part of the real estate due diligence process, a Phase I Environmental Site Assessment is typically for a good reason. Nonetheless, it clears up any hidden legal and environmental liabilities in association with a property.

The Environmental Questionnaire

At the start of the Phase I Environmental Site Assessment process, an Environmental Questionnaire helps evaluate the general risk of a property, for lenders, buyers, agencies and other information seekers. The questionnaire is a form for the ESA “report user” to complete. In fact, the results of a questionnaire may prompt a Phase 1 ESA, or dismiss it altogether.

2. Finding an Environmental Professional

Upon identifying the fact that a Phase 1 ESA report is a requirement, report users must find an environmental professional with the appropriate professional licensing. For instance, a professional geologist or environmental engineer with state certification, and who has five or more years of ESA experience. Undoubtedly, it is important to verify that the consultant qualifies as an “environmental professional,” per the ASTM standard.

3. Property History Researching

The initial order of business in the Phase I Environmental Site Assessment process is research. This task includes compiling all the available historical files and data on a property. For example, off the bat, a consultant will schedule a file review with the State Water Board, as well as the other oversight agencies. Similarly, the environmental professional may also order government database compilation reports from third-party information vendors. Such orders are typically for back-up and the verification of facts. In actuality, there could be hundreds of data parameters to research. Consequently, the data gathering process can take up to 15 business days to complete, if not more. Simultaneously, a comprehensive review and study of the data are performed, for the formation of final conclusions and recommendations. And the data gathering process must meet the minimum requirements of the ASTM standard to qualify.

Rushing a Phase I ESA

Rushing a Phase I Environmental Site Assessment is always possible. Although, it is not the best recommendation by consultants. For instance, a rush Phase I ESA may have a five to six business day turnaround time. However, the regulatory agencies can’t provide their files within such a short timeframe. As a result, the file review at the government agency becomes an omission within the assessment. And this omission constitutes a limitation in the overall ESA, impacting the conclusions. On the other hand, a proper timeframe for the assessment allows for most agencies, if not all, to respond in time. Thus, resulting in the proper ASTM-compliant Phase I Environmental Site Assessment process.

4. ESA Physical Site Inspection

In addition to robust historical research, the Phase I ESA process also requires a physical inspection of current conditions and activities on site. This task intends to cover all grounds for the evaluation of environmental liability. For instance, a property may have always been vacant, and accordingly documented as such. Thus, no apparent environmental condition happens to exists by record. However, there could also be ongoing illicit dumping and pollution at the lot. Often times, this is unknown to the current owner and oversight agency. And if such impacts affect the quality of the subsurface, the owner can face penalties and cleanup obligations. Apart from this, all users of Phase I ESA reports must understand that phase one site inspections are not equivalent to regulatory environmental compliance audits.

5. The Phase I Environmental Site Assessment Process

Upon approaching the final stages of the Phase I Environmental Site Assessment Process, a final report compiles all the information and data, along with conclusions, recommendations, and professional certification. Often times, Phase I ESA reports are in excess of 350 pages. Thus, consultants do provide executive summaries, which comprise a brief synopsis of the findings and conclusions. Executive summaries tend to be anywhere from two to three pages long.

6. The Phase 1 Reliance Letter

Phase I Environmental Site Assessment reports are deliverable only to the official authorizing Client. It is important to understand that no other party can receive a Phase I ESA (except a regulatory agency if applicable). As a result, the report user must provide copies of reports to others, themselves. Similarly, no other parties can legally rely on the results of a Phase 1 ESA or Phase 2 ESA, without the written consent of the report user and consultant. In such a case, the consultant will prepare a reliance letter, on behalf of the user, for the additional parties.


Forward-Thinking Geologists, Engineers & Contractors!


What is the Methane Mitigation Process?

What is the Methane Mitigation Process?

The methane mitigation process entails eliminating the risk of an explosive event at a building, as a result of hazardous soil vapor intrusion. Vapor intrusion is the natural process by which underground gasses migrate upwards and into buildings. So in the case with structures built atop contaminated soils, the chemicals from the subsurface change phases from liquid-form to vapor-form, and move indoors. These gasses take the path of least resistance. Thus, the small cracks and seams which always exist within a concrete slab are the preferred migratory pathway. And because methane itself shows no coloration or smell, occupants are unaware of its build-up. Updated November 13, 2019.

Land Developers Dealing With Methane Zones

The requirement to mitigate soil vapors isn’t exactly a land developer’s favorite thing to hear. Neither is learning about a project being within a methane zone. To most developers, the methane mitigation process is understood to be timely and costly. Although, many of them do also understand that it is a non-negotiable requirement for occupant-safety. As technology improves and knowledge spreads, regulatory agencies also become more aware of the impacts on health and safety. As a result, environmental laws and health and safety regulations keep improving, to ensure a better future for America.

Methane Mitigation Zone Maps

Methane Mitigation Zone Maps

First Step – Test for Methane

Testing for methane soil gas underground might be the first step for any developer undergoing the methane mitigation process. This task generally entails drilling at a property and installing soil vapor probes for sampling. The sampling events take place over a period of 24 to 48 hours and require the oversight of a professional geologist. In fact, in some jurisdictions, the results of the methane soil test may serve to eliminate the methane mitigation requirement overall. In other cases, it helps optimize the parameters of a mitigation system, so that developers could reduce their costs and effort as much as possible, meanwhile satisfying the local agencies.

Methane Test Report Approval

Final methane test reports require submittal to the local building department or methane mitigation authority agency. These reports undergo a strict review process by the agency caseworker and may be subject to changes and revision. It is important to contract a proper methane testing company with experience in your area, to ensure that push-backs, revisions, and rejection don’t slow down the project.

Second Step – Design a Methane Mitigation Plan

A mitigation plan is the next step in building within a methane district. This is a special design process, and generally requires the input and certification of a licensed geologist or engineer. The final set of architectural and structural plans are a prerequisite for the methane mitigation process. Additionally, a copy of the geotechnical report and grading plan is helpful. The geologist will prepare a complete set of methane mitigation plans, which include all the necessary calculations and specs for contractors to build accordingly.

Methane Mitigation Plan Approval

As imaginable, methane mitigation plans need approval as well, before any building can commence. Typically, the same agency to review and approve the methane test reports will also review mitigation plans. In many cases, both of these items undergo review simultaneously. This is because mitigation plans comprise all the site-specific methane test data, to begin with.

 

Approved Methane Mitigation Plans

Approved Methane Mitigation Plans

Thirst Step – Build the Methane Mitigation System

Constructing a proper methane mitigation system, in accordance with building department codes and plans can be challenging. Especially when trying to schedule the work around the other job-site activities and timelines. Methane mitigation construction is a specialized area of work and requires manufacturer certification, as well as authorization by my regulatory agencies.

Fourth Step – Get a Qualified Inspector to Double-Check

In almost every jurisdiction, the oversight agency will require that a special methane system inspector oversee and approve the construction of a mitigation system. This task typically refers to as “Methane Deputy Inspection,” and requires a certification process. A deputy inspector is in charge of using his or her knowledge in the industry, to ensure, on behalf of the local building department, that a proper construction job is taking place. Deputy inspection is a crucial part of the methane mitigation process, as it remains the final step before the project can sign off. To avoid any conflict of interest penalties, the deputy inspector should have no relation, whatsoever, to the contractor on the job.


Forward-Thinking Geologists, Engineers & Contractors!


How Much Does an LADBS Methane Soil Test Cost?

LADBS Methane Soil Test Cost & Price

An LADBS Methane Soil Test cost can vary, depending on property conditions and plans for development. In fact, a proper methane test price for a standard job can range between $2,600 and $10,000. However, site-specifics can change the price on a case-by-case basis. Thus, a phone consultation is highly recommended to get a site-specific cost. Because a methane test comprises drilling, sampling, analysis, reporting and licensing, the cost does add up. Companies that offer a “suspiciously low price” typically result in rejection, change-orders, re-testing, and lawsuits. A price quote lower than $2,300 to $2,400 warrants concern. This article provides information and insight on pricing for a proper Methane Testing Report. Updated October 18, 2019.

LADBS Methane Soil Test Cost & Price

LADBS Methane Soil Test Cost & Price (creativecommonsstockphotos)

What Justifies the Price for an LADBS Methane Soil Test Cost?

Consumers must understand that Methane Testing comprises many pillars to meet the requirements of the Los Angeles Department of Building and Safety. These facets combine to complete a proper test and justify the minimum price of $2,600. Mitigation plans are not part of the testing process.

Laboratory Certifications & Professional Geologists

For instance, the company must qualify and maintain an active Laboratory Testing Agency License with the City of Los Angeles. Furthermore, the job requires multiple days of fieldwork by licensed professional geologists and drillers. The mobilization, materials and professional costs of drilling alone result in thousands of dollars.

Drilling Rigs & Sample Materials

Above drilling, there is also a requirement for these projects to include oversight and certification by a professional geologist. From the project planning stages to the soil gas sample collection and analysis, a state-certified professional must be in charge. By the standards of the City of Los Angeles, geologists, engineers, and drillers must install soil gas probes at various depths and locations, and collect samples for analysis.

Sampling & Analysis 

The analytical results of an LADBS Methane Soil Gas Test are the basis for report preparation. Following State EPA and DTSC standards, geologists perform soil gas sampling and testing from the field and in the laboratory. Analytical data is produced in tabular form, for the review of a senior geologist. This is the primary step for quality assurance and quality control.

Report Preparation

Methane reports are comprehensive and factor in many aspects of the property. For example, a methane test report can discuss historical land-use, site geology and hydrogeology, parcel characteristics, planned development, surrounding properties, and building code requirements. Moreover, the analytical results provide insight on the LADBS Site Design Level. And a professional geologist appropriately concludes and recommends per the standards of the LA City Building Codes.


Ramifications of “Suspiciously Low Cost” Reports

Many consumers complain about unethical methane soil testing consultants that “hook clients” over a suspiciously low price. According to these unhappy customers, these unethical companies typically boast about having “many years of experience,” and offer prices drastically below the competition. 

Prices Too Low = Improper Testing

Consequently, the construction project can undergo problems. In fact, disgruntled customers of these unethical consultants have mentioned insufficient “hand-drilling” methods, falsified sampling depths and fraudulent data. Ultimately, this can cause rejection by the building department, change orders, re-testing requirements and other additional work. 

Nobody Can Actually Predict or Promise Low Results

Additionally, there have been complaints about these companies “promising low results” at the time of the sale. This is highly misleading and unethical for any consultant or company to do. In fact, it is impossible for anyone to predict the results of a methane test. Typical Los Angeles Basin soils are non-homo-genius. Thus, soil and soil-gas baring characteristics are variable from site-to-site. As a result, each property can comprise different methane soil gas concentrations. And methane test results cannot possibly be predicted, even if the neighboring lot has been tested before.

In general, a methane test price quote lower than $2,400 warrants concern.

Avoid Cheap Methane Soil Test Cost

Avoid Cheap Methane Soil Test Cost (Hoomar)


Get a Site-Specific Price Estimate & Cost 

Despite the information above, Geo Forward recommends each consumer obtain a site-specific price quote for methane testing. Prices are variable as a result of property characteristics, design parameters regional geology and more. For more information, or to obtain a site-specific price quote, call (888) 930-6604 to speak with a professional geologist today.    


Forward-Thinking Geologists, Engineers & Contractors!


PCBs Contamination in Killer Whales and Orca Pollution

PCBs Contamination in Killer Whales and Orca Pollution

PCBs contamination in killer whales and orca pollution is an increasing concern in the environmental science community. Recent studies indicate hazardous levels of industrial chemicals exist in the bodies of orcas and other marine mammals, worldwide. In fact, toxicologists now hypothesize that rising concentrations of carcinogens like PCB pollution in killer whales are contributing to premature deaths, deformations, and growth stunts. Moreover, marine biologists understand that pregnant mother orca killer whales are unknowingly offloading an abundance of carcinogens onto their calves. With record-high mortality rates in whales across the world, scientists are beginning to believe the human impact is affecting marine wildlife now, more than ever. Updated November 25, 2019.

PCB Contamination in Killer Whale Orcas - Apparent in the Puget Sound

PCB Contamination in Killer Whale Orcas – Apparent in the Puget Sound

Preface by the Author:

By: S. Wilson Cablk, CA Professional Geologist

A few years ago, I found myself in Seattle, Washington for a family gathering. My seven-year-old son was into orca killer whales. In fact, he even named his band “The Killer Whales.”  I mentioned we might see a pod of killer whales from the Big Wheel at the end of the pier, so we went up for a look. However, we did not see any orcas.

I did not think he was going to hold me to see one, although I did believe it was a possibility. In over twenty years of surfing (mostly in southern California and venturing to areas as north as Tillamook, Oregon, and south to the tropics), I’ve seen more than my fair share of sea life. From dolphins, seals and sea lions, to gray and blue whales, sharks, and even a whale shark. Although, I’ve never seen killer whales. Nonetheless, after the ride on the Big Wheel in Seattle, I found myself researching orcas a bit more.

I did learn that next time we will need to go a bit more north in Puget Sound, to the San Juan Islands. However, I also learned we need to go sooner rather than later, due to the declining population of orcas. Furthermore into my research, I became aware of the fact that declining numbers of orca killer whales were not just apparent in the Puget Sound, but globally in part due to the health risks of PCBs contamination. And as a professional environmental geologist working to assess and remediate PCBs in soil and groundwater, I grew a concerning interest in the unfortunate topic of PCBs contamination in killer whales and orca pollution.

PCBs Contamination in Killer Whales and Orca Pollution

PCB pollution in killer whales is a topic of rising interest. In fact, the subject of oceanic pollution, as well as the overall harm to marine animals is gaining global attention. The truth is, it’s not just orcas that are suffering. Other species within the Delphinidae family, as well as other species of whales, fish, and pinnipeds, are also experiencing high levels of PCBs in their bodies. In just the year 2019, there has been an unusually high number of whale deaths reported across the world. Many of these deaths occurred with a variety of species. Although the general consensus for a root cause at this time is “environmental impact.”

PCB Pollution Killer Whales

PCB Pollution Killer Whales

PCB Pollution Killer Whales

As a result of being an apex predator, these industrial chemicals biomagnify within orcas. Thus, higher levels of pollution can be apparent in killer whale blubber, comparing to the other sea animals. As seen recently in Instagram posts, songs, music videos, and documentaries, environmental awareness for ocean pollution is rising by popular demand. Along with the concerns of unethical treatment in captivity, the subject “PCB pollution killer whales” is going viral. And by researching and sharing this information across the popular tech platforms, human beings can get a step closer to corrective action.

PCBs Contamination in Killer Whales and Orca Pollution

PCBs Contamination in Killer Whales and Orca Pollution

The Main Chemicals of Concern

There are a variety of harmful industrial chemicals in the ocean today. Most, if not all, of these occurrences, are unnatural and are the result of human pollution. Industrial activities, whether continental or coastal, have the tendency to release contaminants into storm drains, streams, and other runoff tributaries. Furthermore, releases of contaminants into the subsurface can result in groundwater contamination, which can transport chemicals off-site.

Polychlorinated Biphenyls aka “PCBs”

The acronym “PCBs” is short for polychlorinated biphenyls. And these chemicals are a group of man-made organics comprising carbon, hydrogen and chlorine atoms. This chemical of concern has been widely utilized for thousands of industrial and commercial purposes. In fact, PCBs were primarily a part of electrical transformers and capacitors, coolants and plasticizers in paints around the world. Moreover, PCBs were typically found in a variety of carbon-less copy-paper, plastics, and rubber products.

Aside from its functionality as an electrical insulator, PCBs were practical to industrialists. This is because PCB is non-flammable, chemically stable and has a high boiling point.

The Ban on PCBs

Within the previous decades, it became apparent to scientists that PCBs are unsafe to expose to the body, and do not degrade easily once introduced into the environment. As a result, the United States was the first to implement a ban on the manufacturing of PCBs by the year 1979.  

Through various studies in animal and human populations, various assessments indicate the potential carcinogenicity of polychlorinated biphenyls. Per modern research programs, PCBs theoretically cause cancer in animals, as well as humans.  Additionally, there are a number of serious non-cancer health effects in animals as well as humans. These include the impact on the reproductive organs, immune system, and the central and overall nervous system. Similarly, there are other health effects due to the long-term exposures of PCBs, which are currently undergoing research. 

Polychlorinated biphenyls (PCBs) are one of the most widely studied environmental contaminants. In fact, today geologists and engineers perform Environmental Site Assessments to study soil and groundwater samples for PCBs contamination at commercial and industrial sites. And marine biologists perform a variety of analytical procedures to study fauna and flora for PCBs contamination.

Polychlorinated Biphenyls PCBs contamination

Polychlorinated Biphenyls PCBs Contamination

How the Contamination Happens

The marine ecosystems are where polychlorinated biphenyls (also known as PCBs chemicals) go to travel, but not disappear. And consequently, they end up in the bodies of marine animals. In the environmental engineering industry, the term “source area” defines the precise location where a contaminant of concern is first introduced into the environment. In fact, engineers, geologists, and hydro-geologists can study the fate and transport of various chemicals of concern, in order to determine the level of threat during migration, and at the endpoint. This process involves an in-depth analysis of chemical properties and characteristics, in conjunction with environmental factors, settings, media of transport and health effects.

Migration & Exposure Points

Due to the high mobility properties of PCBs, the harmful chemical ends up in regions and environments far beyond their original source area. For example, migration can occur through the soil and into groundwater which flows into streams, rivers springs and into the ocean. Similarly, PCB migration can occur through sewers, storm drains and other human infrastructures which also deposit directly into the ocean. Even when humans are not running into PCBs on land, the chemicals are still migrating through these systems. And although migration patters can commence at source areas far away from the coastal line, PCBs still easily disburse into the nearest marine ecosystems.

Ocean Pollution & PCBs Contamination via Storm Drain (o-solara)

Ocean Pollution & PCBs Contamination via Storm Drain (o-solara)

Contamination in Killer Whales & Orca Pollution

PCBs contamination in killer whales and orca pollution: Killer whales (also known as orcas or Orcinus orca) are apex predators eating everything from small fish to large ones (including sharks), as well as aquatic mammals such as seals, sea lions other whales and more. And the current theory regarding the mode of PCBs contamination in orcas is by diet. As a result, killer whales at the top of the food chain, and accumulate more PCBs over time, than other ocean animals.

Exposure by Food

As a result of coastal pollution by humans, all of the animals which make up the orca’s diet from the coastal regions have direct exposure to the polychlorinated biphenyls (also known as the PCBs chemical) deposits. This includes, but does not limit to stingrays, fish, and seals. Subsequently, killer whales eat these animals with PCB contamination (however trace the concentrations might be). And the overall chemical concentration build-up within their own bodies, as a result of being the ultimate contamination endpoint.

Bio-Magnification

PCBs, being the organic chemicals that they are, chemically prefer to stay in the body fat of any animal, rather than the organs or lean sections. Thus, once introduced into the orca’s body, the bio-available chemical attracts itself into the blubber and resides there as the absolute final end-point. And the overall concentration of this end-point keeps increasing over time, as the whale consumes more food with PCB contamination. This process is called bio-magnification. Bio-magnification: pollutants become higher in concentration within the body of animals, as one moves up the food chain.

Orca Mothers Nursing their Calves with PCBs Contaminated Milk

Recent analytical observations indicate male killer whales contain more PCB-rich fat than the female killer whales. This discrepancy is likely a result of the male orca’s larger dietary intake, by volume. However, one of the highest complications with PCBs in female dolphins and orca is that their milk is high in fat. In fact, orca milk can contain up to 40% fat, which is a very high end-point for the PCBs in pregnant killer wales.

Dying Calves for Reasons Unknown to Mother Whales

Unfortunately, as female orcas use their body fat in milk production, they unknowingly offload dangerous levels of the toxic chemicals onto their calf. There is speculation in the scientific community that PCB enriched milk has already been the result of numerous premature deaths among orca and dolphin calves. And PCBs are also known to alter fertility and cause premature death before birthing.

Psychological Trauma Among Whales

Moreover, some marine biologists speculate that mother whales are experiencing extreme psychological trauma as a result of their calves dying prematurely. To summarize, researches believe the mothers blame themselves for the death of their young. And that the depression is shared by other members of their pod or community. Researchers also believe that such human-induced depression results in strange and unhealthy behavior among the whales, such as mass beaching, feeding deprivation and health defects. These strange behaviors after a calve’s premature death have also been researched among other whale species, such as pilot whales.

Food Contamination in Killer Whales Orca

Food Contamination in Killer Whales Orca

Laboratory Data Showing Contaminated Orca Killer Whales

At this time, some killer whales reportedly carry 25 times more PCBs than the threshold shown to alter fertility. Research indicates marine mammals with PCBs levels greater than 9 ppm are likely to suffer noticeable disruption to their body’s basic biological processes. In fact, the sources below indicate killer whales in Europe have recently been found to have up to 857 ppm of PCBs in their bodies.

In the environmental engineering industry, analytical results from a chemical analysis can be variable by sample location. For example, a laboratory analytical report may indicate one blubber sample from the front of an orca contains 2 ppm by volume of PCBs. Whereas another blubber sample from the rear areas of the same orca may result in concentrations of 8 ppm. In this simple example, the concentrations vary up to 4 times in concentration, depending on the location of the sample. However, another sample can be retroactively collected from the same location, and contain an entirely different concentration of PCBs.

Despite the standard deviation and variation of data set values, concentrations of PCBs as high as 857 ppm in marine mammals is alarming and concerning, beyond a reasonable doubt.

Other Chemicals of Concern

Similarly, hundreds of other harmful pollutants have been released into the marine environment and ecosystems. And consequently, many other toxic compounds are additionally accumulating within the bodies of whales and dolphins. Research programs commissioned by the US EPA generally report the maximum levels of organic chemical contaminants in food, water, air and more. These are screening levels, which establish a general foundation for human health risks and toxicity threshold limits.

Polybrominated Diphenyl Ethers (PBDEs) in Orca Killer Whales

Modern Flame retardant chemicals, typically polybrominated diphenyl ethers (PBDEs), are also an increasing concern for orcas in New Zealand. PBDEs are similar in chemical structure to PCBs and exhibit the same resistance to degradation. However, they are not currently under regulation or manufacturing restrictions. In fact, there are a whole slew of toxic chemicals in use today, which have not undergone a proper evaluation relating to the environmental and health impacts of marine mammals. Especially in conjunction with the already rising levels of PCBs.

Environmental scientists have observed government action and screening levels change over time, for various chemicals of concern. Such changes are typically in the conservative direction, for the betterment of environmental health. However, positive effects by such chemicals is hardly heard of.



Solutions:

  • Implement Stronger Coastal Management Plans
  • Build and Operate Multiple Coastal Depositional Dredging Facilities
  • Administer Proper Disposal Oversight Program for PCB Waste on Land, As Well As Other Chemicals of Concern
  • Enact Stricter Environmental Laws & Policies for Industrial Facilities Generating Waste
  • Implement Stricter Engineering and Remediation Methodologies for Existing Contamination Cases
  • Build More Environmental Waste-Water and Run-Off Treatment Facilities
  • Reduce Levels of Toxic Chemical Contamination to Groundwater and Soil

Authors:

Written by: S. Wilson Cablk, PG

Edited and Co-Written by: Adam Azad Kaligi, PG


Sources:

National Geographic Online: Orcas Killer Whales Poisoned PCBs Pollution

Northwest Fisheries Science Center: Toxic Killer Whales

Orca Aware: How Chemicals Are Killing the World’s Killer Whales and What Can Be Done

Whales.Org: Orca Killer Whale

The Seattle Times: New Orca Calf Reported in Southern Resident J Pod

US EPA: PCBs


Forward-Thinking Scientists & Engineers!


Phase 2 Environmental Screening Level Numbers

Phase 2 Environmental Screening Level Numbers

Phase 2 Environmental Screening Level Numbers are comparative concentrations of chemicals in soil or soil-gas, which represent a threshold for human health concern. In a Phase 2 Environmental Site Assessment, these numbers are tools to compare directly with the contaminant detection on site. And as a result, a practical risk assessment decision is made. Environmental screening level numbers can vary, depending on jurisdiction and degree of regulatory oversight. For example, in San Francisco, California,ESLs” are the applicable Phase 2 environmental screening level. Furthermore, screening levels have the tendency to evolve overtime, as ongoing research programs develop more data. Updated October 18, 2019.

Phase 2 Environmental Screening Level Numbers

ESLs: Phase 2 Environmental Screening Level Numbers

Commercial Real Estate vs. Residential Land-Use

In an effort to provide context for Phase 2 ESA results relative to a site’s land-use, environmental screening levels apply for residential and commercial purposes. For instance, there is a lower anticipation of exposure to subsurface vapors at commercial properties. This is because occupants are nominally present approximately 40 hours a week. Thus, commercial environmental screening levels tend to have a higher threshold limit. On the other hand, there is a higher anticipation of exposure to toxic vapors at residential properties. And this is because occupants are nominally present 168 hours a week. As a result, residential screening levels tend to be more conservative and have a lower threshold limit.

During a Phase 2 ESA, if the existing development includes residential land-use, it is most-appropriate to primarily compare results to residential screening levels, and secondarily to commercial screening levels.

Phase II Environmental Site Assessment or Phase II ESA

Phase II Environmental Site Assessment or Phase II ESA Screening Levels

DTSC-H.E.R.O Note 3 Screening Levels

The California Department of Toxic Substance Control, or the DTSC, provides screening levels to apply as a tool for evaluating human health risks. The acronym “H.E.R.O” stands for the Human and Ecological Risk Office, which is a division that administers human health risk assessment guidelines. Per the DTSC, these screening levels are based on the toxicity factors of various chemical contaminants, as per their potential exposure pathways from the subsurface (typically inhalation). As a result, an attenuation factor applies to subsurface soil gas concentrations, for a direct comparison with indoor air quality guidelines. The attenuation factor and indoor air screening levels are derived from the DTSC HERO Note 3 user’s guide.

H.E.R.O. Attenuation Factor Applications

In conformance with the DTSC requirement, the attenuation factor serves as a multiplier to soil gas detections. This represents the endpoint concentrations at exposure, after infiltrating into building structures. As of August 2019, the DTSC Vapor Intrusion Guidance states that an attenuation factor of 0.001 should be applied to subsurface detections approximately 5 feet below grade, in order to model potential indoor air concentrations within the structure.

DTSC Vapor Intrusion Guidance Phase 2 ESA Screening Levels

DTSC Vapor Intrusion Guidance Phase 2 ESA Screening Levels

Environmental Screening Levels (ESLs) for Soil-Gas

A primary purpose of Phase 2 Environmental Screening Level Numbers are to help expedite the assessment of potential environmental concerns at contamination sites. For instance, a widely applicable Phase 2 environmental screening level for soil-gas contamination in California is the San Francisco Bay Region State Water Quality Control Board “ESL.” These numbers are a conservative screening level for hundreds of the most frequent chemicals found at contamination sites.

ESLs provide commercial and residential thresholds with an emphasis on human inhalation and toxicity. Equally important, ESLs address attenuation factors for the impact of other media, such as soil, groundwater, and indoor air. Similarly, ESLs focus on a range of sensitive receptor concerns. For example, impacts to drinking water or aquatic habitats. ESLs don’t intend to establish policy, nor do they serve as a regulation standard. However, regulatory agencies have the option to apply them as action levels or clean-up standards to specific sites. This action varies on a case by case basis.

Vapor Intrusion Models

Additionally, environmental professionals implement a vapor intrusion model during assessments. In California, standard practice entails running vapor models in conjunction with the DTSC “Guidance for the Evaluation and Mitigation of Subsurface Vapor Intrusion into Indoor Air.”  This is also known as the Johnson and Ettinger Model, or J&E Model. In fact, the model is also an advisory-tool. Thus, it is most-applicable for predicting indoor air quality, with a basis of soil-gas. For example, the sub-slab soil-gas contamination migration into indoor air space.

Attenuation Factor

The J&E model produces an attenuation factor that represents the ratio of the indoor air concentration to the subsurface concentration. Indoor air concentrations a merely an estimation, from the Phase 2 Subsurface Investigation data. The United States Environmental Protection Agency (USEPA) programmed the J&E model with a human health risk assessment tool. As a result, the tool calculates the risk estimation, in association with the inhalation of contaminants indoors.

Environmental Variables

The J&E screening level model applies to an additional line of evidence for evaluating vapor intrusion at a site. The model has also been modified by the DTSC Human and Ecological Risk Office (HERO). As a result, the modifications include the California EPA’s toxicity criteria, for “risk calculation.” The J&E model also allows environmental professionals to determine the land-use of the site. For instance, commercial scenarios or residential scenarios. In the model, these factors are per the basis of the USEPA’s preset values. For example, exposure frequency of 250 days per year, for 25 years.

The model runs once, for each chemical of concern, at each respective depth. And the results indicate a cumulative “cancer risk factor” and “hazard quotient” for each parameter. It is important to understand that the J&E Model results are not a comprehensive Human Health Risk Assessment (HHRA). Instead, it is simply a scientific estimating tool to determine the necessity for further action.

Incremental Risk from Vapor Intrusion to Indoor Air

In a J&H Model, the “Incremental Risk” from vapor intrusion to indoor air (as carcinogens) are compared to the general point of departure of 0.000001. And this value applies to make conclusions and recommendations. For instance, Incremental Risk values which are less than 0.000001 generally require no further action. Where as Incremental Risk values which are greater than or equal to 0.000001, but less than or equal to 0.0001, fall within the “risk management” range. This means the site requires stakeholders to determine whether the risk estimates are acceptable or not. Typically, this translates into further investigation and safety evaluations. In the third place, Incremental Risk values which are greater than 0.0001 certainly require further action. Typically, parties proceed with indoor air quality mitigation and contamination remediation.

Hazard Quotient

The “Hazard Quotient” from vapor intrusion to indoor air (as non-carcinogens) represents a site-specific “Hazard Index” (or HI). The Hazard Index compares to the acceptable hazard levels defined by the DTSC and USEPA. This value is unit-less and applies to determine whether adverse health effects are likely to exist onsite. In general, HI values larger than 1.0 indicate adverse health effects are possible. Whereas HI values lesser than 1.0 indicate adverse health effects are not likely to occur.

Historical Phase 2 Environmental Screening Level Numbers for Soil-Gas

California Human Health Screening Levels (CHHSLs) are historical Phase 2 Environmental Screening Level Numbers. CHHSLs are now obsolete, per the Office of Environmental Health Hazard Assessment (OEHHA). In fact, the OEHHA now recommends using HHRA Note 3 (DTSC HERO) for Phase 2 Environmental screening level numbers.

CHHSLs are concentrations of chemicals in soil-gas that are below the theoretical thresholds of concern for human health risks. These numbers were mainly applicable during the years 2005 to about 2015. CHHSLs were developed by the California OEHHA, pursuant to California Health and Safety Code §57008. In the same way as other screening levels, CHHSLs are not enforceable standards for remedial action. Instead, they apply as tools for screening purposes. Besides, not all potential chemicals of concern have CHHSL values.

environmental_release_contamination_dry_cleaner_oil_gasoline_station_gas

©publicdomainstockpho

Regional Screening Levels (RSLs) & Soil

Regional Screening Levels (or RSLs) are general risk-base concentrations by the EPA for use to evaluate chemicals in shallow soil. RSLs combine human toxicity limitations and standard exposure values to approximate health-protective-thresholds for human exposure. RSL values have a base target cancer risk (or TR) of 0.000001. Similarly, RSL values also have a base target hazard quotient (or THQ) of 1.0 and 0.1. These values are the basis of the typical exposure modes. For example: inhalation; ingestion; skin contact; etc.

RSLs are not legally enforceable standards. Instead, they are considerable guidelines to determine if potential risks are in association with soil contamination and help decide upon the necessity of further evaluation.

Maximum Contaminant Levels (MCLs) & Groundwater

Maximum Contaminant Levels (MCLs) are national primary standards for drinking water. Unlike the screening levels above, these numbers actually do serve as regulatory standards. Various Water Boards and environmental agencies enforce MCLs as the baseline for groundwater testing and assessment. MCLs are available for various chemicals. Moreover, the base concentrations have human protective intent. The numbers are a basis of human exposures over a lifetime through direct-contact exposure pathways (for example: ingestion).


Forward-Thinking Geologists, Engineers & Contractors!


What is Methane Gas Testing?

What is Methane Gas Testing?

Methane gas testing is the process by which professional geologists and engineers determine the concentration of methane in vapor between soil grains, underground. Typically, this is a requirement by building departments and government agencies. In fact, the tests are mandatory in areas within proximity to oil wells, tar pits and landfills. However, the methane gas testing process can also apply to real estate due diligence investigations. For instance; testing during property transactions. Methane is also colorless and odorless. Thus, it isn’t easily detectable via the human node factor. Nonetheless, it posses a great danger for explosion when accumulating inside underground parking garages, basements and buildings above ground. Updated June 19, 2019.

Geo Forward is a Methane Gas Testing Company

Geo Forward is a leading provider of methane tests, for all agencies across the nation. For information about this process, or a price quote, call (888) 930-6604.

Methane Gas Testing Geo Forward

Methane Gas Testing Geo Forward

What is Soil-Gas?

Soil-gas is the vapor phase substance that exists within the pore spaces of soil grains underground. In scenarios where liquid phase toxins are dumped into the ground, chemicals migrate into the soil to great depths. Consequently, the liquid phase contamination can change phases, into vapors. And as a result, the vapor phase contamination can migrate even farther. The true danger about vapor phase migration is it’s ability to creep through building foundations and microscopic pathways in concrete walls. For example, a restaurant existing above a former oil well can be infiltrated with natural gas, along with other carcinogens, posing a health and combustion risk to the occupants inside.

Health & Safety

Carcinogen health risks tend to base on long-term exposure rates. However, are still material to the health, safety and well being of people. Similarly, combustion hazardous occur by the over-concentration of this flammable gas indoors. Any ignition source inside a room with methane gas above the “Lower Explosive Limit” or “LEL” can result in an explosion. These catastrophes have happened before. Thus, awareness and implementation of soil-gas testing and mitigation is a requirement in jurisdictions across the nation.

Methane Testing initially includes a shallow probe soil gas survey. Afterwards, a drilling rig is used to drill and install multiple sampling zones underground.

Methane Testing Shallow Soil Gas Probe – Photo Credit: University of Texas at Austin & Bureau of Economic Geology


Boyle Dayton Los Angeles

Boyle Dayton Los Angeles

The Boyle Dayton Los Angeles Company was a reputable manufacturer and seller of fueling pumps and standalone underground tanks, for automobiles in the early 1900s. Unlike modern gasoline service stations, the Boyle Dayton Company was a specialty manufacturer of curbside fuel station accessories. Curbside fueling stations were common in America before the demand for full service stations. In fact, curbside fueling stations were typically part of drug stores and hardware shops. And commonly fronting the major streets and roadways. The Boyle Dayton Los Angeles company had the reputation of making stylish, economic and easy-to-use standalone pumps and tanks for these curbside fueling stations. The company was in operation from approximately 1910 through 1929, on the corner of 52nd Street and Santa Fe Avenue, in the City of Los Angeles, California. The Boyle Dayton Company was a prominent part of the history of American gasoline, oil and automobile sectors.

Boyle Dayton Los Angeles UST Gas Pump

Boyle Dayton Los Angeles UST Gas Pump www.collectorcarproductions.com

Remains of Boyle Dayton

Take a walk in Los Angeles, and you will likely not think twice about the multitude of utility manways and vaults underlying the aging concrete beneath your feet. The City of Angels has undergone rebuilding and redevelopment several times since its inception, and continues to evolve to this day. Many of the metal lids and covers seen on the street are no longer in use and long forgotten. However, some may warrant a closer inspection, particularly if you are concerned about the environmental condition of a property.

Boyle Dayton Los Angeles UST Valve Manhole Lid

Boyle Dayton Los Angeles UST Valve Manhole Lid

Non-descript circular lids are seen in sidewalks across the city, with the words “Boyle Dayton Los Angeles” on them. These metal discs bear the name of a long-forgotten gasoline dispenser manufacturing company. The Boyle Dayton Company was a huge part of the gasoline service station industry, and American industrial history. Boyle Dayton Los Angeles essentially introduced factors of convenience, quality and style into their parts, much like Apple and Tesla do today. As a result, the Boyle Dayton Company history is a feature subject in automobile and petroleum museums across the country.

Curbside Fueling Stations

The world’s first fueling station was built in Wiesloch, Germany in 1888 to refill the tank of the first automobile. This station was reportedly setup at the city pharmacy during Bertha Benz’s inaugural trip from Mannheim to Pfrozheim. In the same way, pharmacies all over began selling gasoline on the side. The first fueling station made solely to sell gasoline was built in St. Louis, Missouri in 1905. With the growing rate of automobile manufacturing and ownership, curbside fuel stations became of higher demand. Consequently, new curbside gasoline stations began to appear across the United States.

The first generations of curbside fuel stations were quickly followed by full service auto fueling and repair stations. The idea for the full service station, was to create a one-stop-shop, where travelers can repair and fuel-up their cars while using the restroom, enjoying a meal and picking up road maps and tourist brochures. Consequently, the curbside fueling stations became obsolete, and the standalone gas pumps and USTs were put out of commission. According to a review of historical fire insurance maps, these replacements began as early as the 1930s. However, fueling was not a regulated service at the time. Additionally, there had been a lack of environmental impact understanding during the early dates of decommissioning. Thus many curbside station owners chose to remove the above ground accessories, leaving the underground components in place.

Boyle Dayton Los Angeles Aug 1925 Newspaper AD

Boyle Dayton Los Angeles Arizona Republic – Aug 1925

The First Drive-Up Fuel Stations

The first drive-up station opened in Pittsburgh, Pennsylvania in 1913. In fact, prior to drive-up stations, gasoline was typically purchasable at general or hardware stores. Early gas stations were powered by kerosene adapter pumps. These pumps would require hand-cranking, and could accurately measure and dispense fuel. Earliest pump models include a metal tank with wooden cabinet, and have a hand-operation suction pump. These early systems were capable of holding approximately 40-gallons of fuel at a time. Moreover, the early systems did not entail direct fueling into and automobile. Instead, the system would require a technician to dispense the fuel into a secondary container, and manually transfer it into the vehicle’s gas tank. As a result, most gasoline stations chose to store the fuel in the dispensers themselves, in effort to save time.

Boyle Dayton Los Angeles Jun 1928 Newspaper AD (2)

Boyle Dayton Los Angeles San Francisco Examiner – Jun 1928

Early 1900 Technology & Style

The Boyle Dayton Company was born in Los Angeles in approximately 1910 and manufactured a gasoline pump called the “Boyco” by 1920. The company continued operations through 1929, until agreeing to a corporate acquisition by the Wayne Pump Company. Boyle Dayton Los Angeles had a reputation for making stylish pumps that accurately measure oil and gasoline, as well underground storage tanks, lubrication pumps, and air compressors. Pumps by the Boyle Dayton Company included bolting assemblies to the ground and connections to product pipes leading to underground storage tanks directly underground. Additionally, Boyle Dayton secured a patent for an air-powered technology which increases the speed an automobile could be fueled. As a result of the innovative design, there had been a significant increase in popularity of their pumps and sales. Consequently, installations of their pumps began spreading radially outward from their home base in Los Angeles.

Although the Boyle Dayton Company was in business for a brief period of time, signs of the former gas pump and tank manufacturer exist all throughout Los Angeles. For instance, their legacy still displays in the form of small utility covers within the city walkways, and in petroleum museums.

History of Underground Storage Tanks

In the urban areas across America, underground storage tanks (USTs) became popular for both aesthetic and functional purposes. Early tanks were typically single-wall steel sheets, and under 1,000 gallons by volume. Boyle Dayton did advertise a study manufacturing process, with galvanized steel, riveting and soldering. Moreover, the tanks and pumps had glossy paint jobs, much like cars the at the time. And according to an Automobile Trader listing for Boyle Dayton Los Angeles Company, the pumps and dispensers were capable of an easy quick connection to a variety of tanks (any capacity).

Boyle Dayton Los Angeles UST

Boyle Dayton Los Angeles UST www.worthpoint.com

These tanks typically comprise of three openings. One serves a purpose for ventilation piping. Another is for a filling port. And in the third place, a suction line, leading directly to the pump. Additionally, the fill pipe appears to include a strainer to prevent debris from flowing inside the tank.

An average set up of the original Boyle-Dayton pumps may include two curbside pumps on a sidewalk. Each pump would be directly connecting to a stand-alone underground storage tank. Typically, the underground storage tanks underlay the sidewalk as well. Furthermore, additional lines were likely to extend from the UST, toward an air compressor for pump operational purposes. Fill ports are typically flush with the ground surface, and directly lead to the top of the UST for easy deliveries.

Boyle Dayton Los Angeles Jun 1928 Newspaper AD

Boyle Dayton Los Angeles San Francisco Examiner – Jun 1928

City Sidewalks

Since the original Boyle Dayton Los Angeles Company pumps were located within city sidewalks, the remnant features remain in place for over a century. Especially in areas which have not undergone road-widening and redevelopment. For example, a former curbside fueling station operational in 1915, may not have sold gasoline for decades. However, there may still be an existing fuel storage tanks (UST), as well as ventilation and product lines within the sidewalk. And although these items are technically off site, the owner may still be held responsible for any environmental issues arising from the original curbside gasoline station.

In the City of Los Angeles, municipal substructure maps often denote the locations of known underground tanks in city sidewalks. Additionally to gasoline tanks in association with former curbside stations, many city buildings historically maintain heating fuel tanks in the street. Underground storage tanks in association with former gasoline fueling activities will often still have piping and access ports to the former fill pipe and former pump locations. The “Boyle Dayton Los Angeles” utility covers in age-old sidewalks indicate the prior locations of these features. Often, these underground storage tanks are unnoticeable due to having no record of the substructure or former use of the property and the lack of familiarity with the former gasoline pump manufacturer brand.

Boyle Dayton Los Angeles Jun 1921 Newspaper AD

Boyle Dayton Los Angeles Jun 1921 Newspaper Ad

Environmental Site Assessment Concerns

Remaining underground storage tank features represent an environmental concern. This is due mostly to the lack of corrosion protection and secondary containment. Despite advertisements to the contrary, the single-wall steel piping and tanks with riveted sheet metal are prone to damage and rust. Consequently, hazardous contamination compounds include gasoline, diesel, fuel, oil and metals such as lead. As a result, these substances may impact the surrounding soil, soil vapor, and groundwater.

If a property undergoes redevelopment or selling, a Phase I Environmental Site Assessment is the prudent coarse of due diligence. Environmental due diligence reports entail professionals which may identify the potential underground fuel tanks and piping. If evidence of former fueling activities are noticeable, there would be a recommendation to perform a geophysical survey. Furthermore, the existing underground storage tanks can undergo a removal and official abandonment process, under the proper permits and environmental protocol. Typically, this includes sampling oversight by a licensed Professional Geologist.

Informational Sources

Explore Pennsylvania History

Antique Trader

Los Angeles Navigate LA

Handbook of Storage Tank Systems Available Now

American Oil & Gas Historical Society

Cali Spphere – University of California


Los Angeles County Well Permit and Drilling Permit

Los Angeles County Well Permit and Drilling Permit

Per the Department of Public Health Drinking Water Program, a Los Angeles County Well Permit and Drilling Permit is mandatory for most environmental, geotechnical and hydro-geological projects in LA County. As of August 2018, the County of LA enforces a new set of stricter well permit guidelines. The new standards require oversight for soil sampling boreholes deeper than 10 feet. Additionally, permits are necessary for any borehole that encounters groundwater. Lastly, a C-57 Licensed Driller is mandatory for this process. There are various drilling service categories under the purview of a Los Angeles County Well Permit and Drilling Permit. And various forms of supporting documents are essential to the application process. Updated December 10, 2018.

Los Angeles County Well Permit and Drilling Permit

Los Angeles County Well Permit and Drilling Permit

Los Angeles County Exclusions

Most Phase 2 Environmental Site Assessment and remediation projects will require a Los Angeles County Well Permit and Drilling Permit. However, a Well Permit and Drilling Permit are not necessary for soil gas probe boreholes without soil sampling. Moreover, the Environmental Protection Agency exempts the requirement of a drilling permit for Superfund CERCLA sites. Although, to qualify for this exemption, there may be additional forms to provide Los Angeles County.

Some cities within Los Angeles County, such as the City of Pasadena, Long Beach, Vernon and more, have their own Health Departments which require Well Permits and Drilling Permits. In such a case, other permits may be required in addition to the Los Angeles County Well Permit and Drilling Permit.

Environmental Projects with Well Permit and Drilling Permits

Environmental Site Assessments and geological investigations within Los Angeles County boundaries are subject to a variety of permits, depending upon the nature of the sampling. Notably, for locations within the unincorporated County limits, and within certain city jurisdictions, the Department of Public Health (LADPH) requires an approved Los Angeles County Well Permit and Drilling Permit to advance soil borings and groundwater monitoring wells. Additionally, permit fees apply for each sampling event from existing groundwater monitoring wells may apply.

Typically, environmental soil borings and groundwater monitoring wells assist in researching contamination conditions and concentrations at specific locations. For example, subsurface investigations help to identify the source of an environmental release. Furthermore, deep soil borings aim to define the width and depth of a plume. Moreover, exploratory boreholes identify a site’s geology and soil characteristics. Groundwater monitoring wells are devices which aid in identifying hydro-geologic and environmental conditions, as well as the the lateral and vertical extent of aquifer contamination. Using this information, geologists can also define contamination migration pathways. Groundwater monitoring wells are also usable for remediation purposes.

Approval for Los Angeles County Well Permit & Drilling Permit

Approval for Los Angeles County Well Permit and Drilling Permit ©remg

Exploration Projects with Well Permits and Drilling Permits

Los Angeles County Well Permit and Drilling Permit is also necessary for “Exploration Hole” purposes. Typically, these boreholes explore subsurface and hydro-geological conditions at a property. For instance, any soil sampling boring, hydropunch boring and Cone Penetrometer Test (CPT) will require oversight. Furthermore, any soil sampling boreholes with depths exceeding 10 feet into the vadose zone, and any borehole or CPT encountering groundwater will require oversight by the Los Angeles County Department of Public Health (LADPH).

Prior to commencing work, consultants must submit a work plan and well permit application to the Drinking Water Program within the LADPH. The investigative work may only commence after the County’s approval of the well permit and drilling permit.

Soil Vapor Probe Investigations and LA County Permitting

The vadose zone is a area represented by dry soil, above the groundwater table. Generally, soil gas probe boreholes only (within the vadose zone) do not require an LADPH Well Permit and Drilling Permit. In fact, if a CPT or soil boring does not extend beyond 10 feet below grade, it will also be exempt from a Los Angeles County Well Permit and Drilling Permit.

However, if any probe or borings extends into a groundwater zone during installation, a permit will become necessary. Similarly, if an investigation involves the installation of a groundwater monitoring well, groundwater production well, piezometer, injection well, extraction well, sparge well, CPT boreole into groundwater, or a HydroPunch temporary well, a Los Angeles County Well Permit and Drilling Permit is mandatory. As with the soil boring permits, applicants must provide a comprehensive work plan and application to the Drinking Water Program. And the package must disclose the professional C57 contractors and geologists overseeing the job.

Methane Soil Gas Survey Probe Set

Permanent Methane Testing Probe Set

Although groundwater depths are variable in Los Angeles County, some areas have water tables shallower than 10 feet. In fact, some beach areas have reported first-encountered groundwater as shallow as 2 feet below grade. For instance, Santa Monica, Venice Beach and Long Beach area are generally known to have shallow groundwater. As as result, a well permit and drilling permit will be required, even for boreholes less than 10 feet.

Groundwater Monitoring Well to Test Groundwater for Possible Contamination during Environmental Site Assessments

Groundwater Monitoring Well to Test Groundwater for Possible Contamination during Environmental Site Assessments

Well Permit & Drilling Permit Service Categories 

Additional well service categories that require a permit from the LADPH include irrigation, production and geothermal heat exchange wells. And the Los Angeles County Well Permit and Drilling Permit application also includes services such as well decommissioning, rehabilitation and renovation of existing wells. Moreover, some procedures to service existing water supply wells are likely to require oversight. For example, yield evaluations, yield enhancement procedures, performance tests, in situ water treatment and more.

In the same way, permit approval may be required for periodic sampling of commercial food service facility water, for United States Department of Agriculture (USDA) certification.

The LADPH turnaround time for processing these permits is approximately 10 business days. The processing time commences upon receipt of the application and payment of fees. And work plan modifications or design amendments might be mandatory to achieve approval by the LADPH.

Properties undergoing soil or groundwater assessment within Los Angeles County are more than likely in need of a Well Permit and Drilling Permit, as well as a work plan prepared by a Professional Geologist. Contact Geo Forward for more information, or to determine if your project requires a Los Angeles County Well Permit and Drilling Permit.


Phase 1 Reliance Letter Cost & Price

Phase 1 Reliance Letter Cost & Price

A Phase 1 Reliance Letter cost can vary. However, typical prices for a Phase 1 ESA Reliance Letter range from $250 to $600. Moreover, prices for a Phase 1 ESA and Phase 2 ESA Reliance Letter together can range between $850 and $2,000. In addition to the time spent preparing this legal document, the supplemental fees are also based on the original cost of the work performed, as well as the extension of liability. In most cases, environmental professionals will charge 10% to 20% of the original cost of work, to prepare an additional Phase 1 Reliance Letter. Other companies might also implement a flat rate or minimum cost for this service. Updated January 15, 2019.

A Phase 1 ESA Reliance Letter cost is not the same as a Phase 1 Environmental Site Assessment Report Cost. A Phase 1 reliance letter simply grants legal ability for other parties to use and rely on an existing Phase 1 ESA report. Thus it is usually a fraction of the cost of a complete Phase 1 Environmental Site Assessment Report.

What is a Reliance Letter?

A Phase 1 Reliance Letter is a legal document which authorizes additional parties to rely on an existing environmental report. A reliance letter essentially serves as an extension of liability, on behalf of the Environmental Professional. As a result, the additional fees typically apply. In the case of writing reliance letters for lenders and the SBA, Environmental Professionals must document their understanding that the property serves as collateral for the loan. Additionally, the professional must legally authorize the lenders to use and rely on the Environmental Site Assessment Reports. Moreover, a Phase 1 Reliance Letter should certify that the assessments are in compliance with the recent ASTM Standard, and meet the qualifications of the Brownfields AIA for Innocent Landowner Liability Protection.

What is a Phase 1 Reliance Letter?

What is a Phase 1 Reliance Letter ©Kineticimagery

The Pillars of a Phase 1 Reliance Letter Cost

Despite what Clients may think, there is more to a reliance letter than it seems. Preparation time for these letters plays almost no role in the cost. The most significant pillar of a Phase 1 reliance letter cost is the extension of liability on behalf of the environmental company. And according to our counsel, the legal liability that comes with a Phase 1 reliance letter poses a higher risk than assumed in the price of the original contract. Consequently, the environmental professionals are expected to charge for this.

Shelf Life of the Phase 1 ESA Report

It is widely known in the industry that Phase I Environmental Site Assessment reports age and expire. Certain aspects of a Phase 1 ESA report have a 180 day limitation to meet AAI and CERCLA protection laws. At this time, the Small Business Administration (SBA) will accept a Phase I ESA within 1 year of the date completed.  However, many other lenders may stick to the 180 days. The SBA’s 1 year acceptance policy is a deviation from EPA’s AAI requirements.

Phase 1 Reliance Letter ©Adrian_Lucki

Phase 1 Reliance Letter ©Adrian_Lucki

Average Costs for Additional Reliance Letters

The overall cost for reliance letters is variable. Thus, we don’t recommend solely relying on these approximate price ranges. This information should  be regarded as a learning tool. For a proper estimate, call Geo Forward at (888) 930-6604.

  • Typical Phase 1 ESA reliance letters approximately range from $250 to $600 per letter. 
  • However, the cost for a reliance letter of a Phase 1 ESA and Phase 2 ESA approximately ranges between $850 and $2,000.

Ultimately, the cost will depend on the price of the original assessment. A larger scope assessment, and thus more expensive, will likely have a higher reliance letter cost. Generally, consultants charge anywhere from 10% to 20% of the original cost of work.


Contaminated Soil Excavation & AQMD Rule 1166

Contaminated Soil Excavation & AQMD Rule 1166

AQMD Rule 1166 applies to Southern California construction sites undergoing contaminated soil excavation. To start, AQMD Rule 1166 requires a mitigation plan.  Moreover, this report is also goes by the title “Contaminated Soil Excavation Plan.” Additionally, the rule requires air quality testing during excavation. The primary oversight agency is the Air Quality Management District (also referred to as the AQMD or SCAQMD in the South Coast). Updated February 19, 2019.

Contaminated Soil Excavation and AQMD Rule 1166 ©Dmitry_Kalinovsky

Contaminated Soil Excavation and AQMD Rule 1166 ©Dmitry_Kalinovsky

Discovering Contaminated Soil Excavation Issues

Unless a Phase 1 Environmental Site Assessment or Phase 2 Subsurface Investigation calls it out, you may be surprised to find contaminated soil at a job site. It happens from time to time. As a result, there are legal requirements for disposal and monitoring. Consequently, an environmental engineering firm should be retained to achieve proper contaminated soil excavation and AQMD Rule 1166 compliance.

In the first place, the process starts with soil sampling by an environmental consultant. Next, the consultant will prepare a waste profile and manifest. At this point, the engineering firm should also complete a mitigation plan. Some mitigation plans are site-specific. Others are for various locations. Lastly, the SCAQMD will need to approve the mitigation plan, and issue a permit to dig.

Tasks that require AQMD Rule 1166 Compliance

Per the rule, compliance is necessary for each of the following activities:

  • Removal of any underground storage tank (UST) or associated product piping.
  • Contaminated soil excavation.
  • Stockpiling and movement of contaminated soil.
  • The treatment of contaminated soil at a disposal facility.

Accordingly, there is a need to monitor disturbed soil via an organic vapor analyzer (OVA). Often times a photo-ionization detector (PID) is exemplary. Other times a flame-ionization detector (FID) may be more ideal.

Costs for Contaminated Soil Excavation

Unfortunately, we are unable to provide any general cost estimates via the internet. There are just too many variables in each project. A custom price quote is a requirement for each specific project.  However, you can expect to pay for the following items for an AQMD Rule 1166 compliant contaminated soil excavation:

  • Soil sample laboratory analysis.
  • AQMD Rule 1166 permit application.
  • Mitigation Plan preparation.
  • Contaminated soil excavation air monitoring labor.
  • Permit closure process.
Finish the Job Right and Save Money

AQMD Rule 1166 compliance is a requirement for contaminated soil excavation. Although this process is costly, the fines and penalties for violating them are more. Thus, its best to consult an proper environmental engineering firm. Moreover, a Phase 1 Environmental Site Assessment at the purchase stage is the best recommendation for staying one step ahead. If contaminated soil becomes apparent during the assessment, a proper budget can be set.

 


Phase 1 Environmental Cost? The Phase I Environmental Site Assessment Cost

Phase 1 Environmental Cost &
Phase I Environmental Site Assessment Cost

Phase 1 Environmental cost can vary, depending on the region and characteristics of a property. A Phase I Environmental Site Assessment cost (for a typical commercial lot) ranges between $2,000 and $3,500. In fact, some prices can be as high as $6,000. This article clarifies that prices can, and do, vary. And just like all other services, suspiciously low prices can result in errors at the expense of the Client. In fact, due to the lengthiness of these reports, errors can be unnoticeable by Clients. Consequently, errors come to light later down the line and can cost a fortune to deal with. Nonetheless, this article provides insight into what to expect when purchasing a Phase 1 Environmental Site Assessment. Additionally, this article highlights some do’s and don’ts for purchasing a Phase I ESA Report. Updated November 18, 2019.

Phase I Environmental Report Cost ©creativecommonsstockphotos

Phase I Environmental Report Cost ©creativecommonsstockphotos

Variable Costs of a Phase 1 Environmental Site Assessment Report

Property characteristics base the cost for a Phase I Environmental Site Assessment. The location and size of the property are the main pillars. Some lots require more research. Others require more time and resources to physically inspect. For example, car dealerships can require multiple days to inspect compared to a small office. Other complexities and special requirements also weigh in on Phase I ESA pricing. For instance, some organizations require specific reporting elements above the ASTM Standard.

Price Ranges to Expect in the Year 2019

Phase I Environmental cost is variable depending on the area and characteristics of a property. Thus, it is not recommended to solely rely on these approximate price ranges. The information below is merely to reference as a tool for learning. To learn how much a Phase I ESA will actually cost on your property, call Geo Forward at (888) 930-6604 for a site-specific proposal.

  • A small sized typical commercial lot in the Year 2019 may range between about:
    • $2,000 and $3,000
  • A medium to large-sized industrial lot (<1 acre) in the Year 2019 may range between about:
    • $2,500 and $4,500
  • A large scale industrial facility (1 to 5 acres) in the Year 2019 may range between about:
    • $4,500 and $6,500
  • A large-sized rural property (>5 acres) in the Year 2019 may range between about:
    • $3,500 and $4,500

As years go on, so does the cost to perform a Phase I Environmental Site Assessment. Factors of price changes over time are the result of changing ASTM standards, technology, labor and employment costs, industry demand, and more. Moreover, as environmental laws strengthen over time, the necessity for a proper Phase 1 ESA becomes similarly vital.

Suspiciously Low Phase 1 Environmental Cost – Watch Out!

Whether buying, selling or applying for a loan, Clients tend to be curious about variable pricing, and the comparisons to quality of work. A low-cost or cheap Phase 1 Environmental Site Assessment generally entails small budget restrictions and is subject to short cuts. Thus, suspiciously low-cost assessments usually perform below the professional standard of care. Under review, the lowest Phase I Environmental Report cost will typically have significant errors and data gaps. And as history has shown, this can result in heavy lawsuits, unforeseeable remediation, costly agency fees, and possible forfeiture.

Earlier this year, geologists were hired to investigate an industrial property, where a major error was discovered in a prior Phase 1 ESA by a different company. There was no surprise to learn the report was sold at a low-cost. The report completely missed a gas station on the lot for over 10 years and didn’t mention the existing underground tank. Other errors and omissions were also found. This disqualified the report from the CERCLA Innocent Landowner Liability Protection policy. The buyer was misled by the conclusions of the lower Phase I Environmental Report cost. Consequently, the buyer already purchased the property with a massive amount of liability.

Numerous cases like this arise each week. And they consequently link back to going cheap on the Phase 1 ESA process. For every three price quotes, Clients might find one for about 30% less than the others. This should raise a red flag. Consumers must know that it can actually cost hundreds to thousands above the lowest bidder’s price, just to make a proper Phase 1 Environmental Site Assessment.

Phase I Environmental Report Cost Savings ©YanikChauvin

Phase I Environmental Report Cost Savings ©YanikChauvin

Agency File Review Fees

Another factor that affects the average Phase 1 Environmental Report cost is the ever-changing municipality fee structure for government file reviews. Some local agencies (examples below) charge fees for file recovery and review. Additional fees typically apply for copying, printing and binding.

Most State agencies (examples below) typically don’t charge for file recovery. However, copy and printing fees usually apply.

Phase I Environmental Site Assessment Cost

Phase I Environmental Site Assessment Cost

Takeaway

The environmental liabilities, damages, and attorney fees that come with a faulty Phase 1 ESA aren’t cheap! And since everyone’s got a lawyer on speed dial these days, it’s best to do the job right the first time, with a proper Phase I Environmental Report. In fact, the industry’s best practice standards advise researching companies before opting for the lowest cost. Although one may be faced with a strict budget, it is generally best to avoid the suspiciously low Phase I Environmental Report cost. Additionally, Geo Forward recommends confirming that a professional geologist or engineer, with a clear license to practice, is in charge of the work to be done.


Forward-Thinking Geologists, Engineers & Contractors!


Can You Retest Methane Test of Soil?

Can You Retest Methane Test of Soil?

Is it worthwhile to get a retest methane test of soil: Generally Not. Sometimes a methane test will show high results of the hazardous soil-gas on a property. And developers will try a retest methane test to get “favorable results.” Regardless, there is a general legal requirement to still submit the original test data (whether it has higher or lower methane levels). This is a public health code concern governed by law, and delves into the matter of developer ethics. The rule is to submit the original report with the retest methane test report for the agency to review. And even when multiple reports indicate conflicting data; more than likely the agency will use the highest overall results. Thus, retesting in hopes of “favorable results” can be pointless and a waste of money. Updated July 31, 2019.

The City of Los Angeles Department of Building and Safety (also known as the LADBS agency) has distinguished methane zones and methane buffer zones. Additionally, the Los Angeles Fire Department (also known as the LAFD agency) has oversight. As a result, methane mitigation standards apply. And therefore, a methane test becomes necessary.  Other cities and counties also administer the same methane test policies. Cities like Huntington Beach have their own standards, while others may reference the LADBS policies and guidelines directly.

Retest Methane Test of Soil - Oil Fields

Retest Methane Test of Soil – Oil Fields

 

Interest to Retest a Methane Test

Building Safety Codes base the standard on the highest overall test results. Consequently, the LADBS and LAFD typically select a Level per the highest overall result. For Example, consider a scenario with two methane test reports by different companies. The first methane test reports Level 5, and the retest methane test reports Level 4. In this case, the agency is likely to use the highest methane test, which is the Level 5.

The Legal Requirement to Report all Methane Test Data

High levels of methane soil gas become a matter of public health concern. Anyone that has discovered high levels of methane test results, is required to obey the California Health and Safety Code and report results to LADBS and LAFD. In other jurisdictions, all potential public health hazards should also be reported to the appropriate agency for proper evaluation.

Thus, the policy entails the appropriate agency receive a copy of each methane test report, including the original and retest methane test.

What will the Agencies Decide?

Only the appropriate oversight-agency has the authority to decide what methane level a property is. One cannot guarantee whether the agency decides to accept the original report or retest methane test. For instance, in the scenario above, the decision in the matter is entirely up to the City of Los Angeles.

Methane Test Results for Properties with Oil Wells

Developers must acknowledge that properties including (or within proximity to) oil wells typically result in high-level methane mitigation systems. Thus, it is common that a Level 5 mitigation system has an appropriate level of building safety components. Accordingly, the higher results between a methane test and a retest methane test are likely to prevail. Building an appropriate level mitigation system is not just about construction costs. Its about the health safety of those who will use the building.

For more information about the inquiry and your specific property, call (888) 930-6604 and request a free consultation today.


Additional Information & Sources: 

DTSC Reporting Nonemergency Hazardous Substance Releases

EPA Groundwater & Drinking Water

EPA Risk Assessment

U.S. EPA

U.S. EPA Guidance for CH4 Landfill Gas Sampling & Testing

City of Los Angeles, Department of Building & Safety

The CH4 Zone – The Land Developer’s Guide


Dry Cleaner Soil Contamination

Dry Cleaner Soil Contamination

Dry cleaner soil contamination issues are no mystery to commercial property owners and investors. Even when landlords trust their dry cleaning tenants run a clean shop, the process remains stressful. For instance, soil contamination cleanup can cost hundreds of thousands of dollars. Additionally, time and development opportunities may be impacted. The requirement for cleanup may depend on the results of a Phase 2 Subsurface Investigation. Updated October 18, 2019.

Dry Cleaner Soil Contamination – How it Happens

Most modern dry cleaners have upgraded equipment with leak-prevention systems and environmentally friendly solvents. Various types of dry cleaning solvents have been used since the early 1900s. However, the most commonly used is tetrachloroethylene or “PCE.” Additionally, older machines are known to lack secondary containment. Consequently, the older dry cleaning facilities tend to have a higher potential for contamination. Moreover, additional potential sources of dry cleaner soil contamination exist within sewer and drainage systems. In the same way, hazardous waste storage areas tend to be a hot spot.

Dry Cleaner Soil Contamination

Dry Cleaner Soil Contamination ©Vladimir

Dry Cleaner Soil Contamination Testing

Typically, today’s standard for due diligence starts with a Phase I Environmental Site Assessment. However, due to the known issues with dry cleaner soil contamination, Clients often request a Phase II Subsurface Investigation when there is a known cleaner onsite.

Sometimes, a commercial property owner may find it in their best interest to independently conduct a series of limited subsurface investigations. For example, a sub-slab soil gas test, shallow soil sampling, etc. This could occur prior to a Phase II Subsurface Investigation. By taking smaller steps in the form of limited subsurface investigations, landowners can use limited results as a decision-making tool.

Environmental Due Diligence

The goal of limited environmental due diligence tests is to obtain a particular set of data that is: (1) Not certain enough to verify actual contamination on-site; (2) Not significant enough evidence to warrant a reporting obligation to environmental agencies; and (3) Provide -at the same time- reliable enough information for use by the landowner towards better judgment.

Although limited dry cleaner soil contamination tests can provide some insight, they do not qualify as an official Dry Cleaner Phase II ESA. To meet the ASTM standards for the Phase II Environmental Site Assessment and satisfy major lending entities, a full-scope dry cleaner Phase II ESA will be required.

The Remediation Process

If soil and groundwater contamination becomes apparent after a Dry Cleaner Phase II ESA, landowners may find that their best option would be to begin remediation and restore their property value over time.  The geologists and engineers at Geo Forward, Inc. are knowledgeable of all modern methods of dry cleaner remediation.  The remediation process can vary from site to site, and become complicated over time.  In most cases, remedial efforts at contaminated dry cleaning facilities include soil vapor extraction, groundwater pumping and treating, and controlled chemical injection to accelerate the degradation of contaminants.

©John S. Quarterman – Contamination Plume Clean-Up


Forward-Thinking Geologists, Engineers & Contractors!


Reporting the Results of an Environmental Due Diligence Investigation

Reporting Results of an Environmental Due Diligence Investigation

“Are there requirements for reporting results of an Environmental Due Diligence Investigation to the government?” Each case is different. The answer is generally “no,” because ESA reports are typically proprietary. However, if there is any trace of danger or impact on the public’s health or well being (in any way or form), the answer may be “yes.” This is a frequent inquiry by property owners and report users. Especially during real estate environmental due diligence periods with observable impacts. For example, when a Recognized Environmental Condition becomes apparent in a Phase 1 Environmental Site Assessment process, there is a potential for subsurface contamination to occur. Thus, a Phase 2 Environmental Site Assessment is necessary. And depending on the results, along with a few other facts, there might be an obligation to report the findings of an environmental due diligence investigation to an agency. Updated November 21, 2019.

An article about Environmental Due Diligence by a California Professional Geologist.

Laws on Reporting the Results of a Phase 1 Environmental Site Assessment Report

Laws on Reporting the Results of a Phase 1 Environmental Site Assessment Report

Notice

This article was not written by an attorney. And this article does not intend to provide legal advice. This article simply serves to guide inquirers towards publically available supportive information using the engineering and geological professional standards in California. In all cases, Geo Forward advises readers to consult such matters with an attorney.

Do the Results of an Environmental Site Assessment need to be reported to local regulatory agencies?

In most cases, the requirement to report subsurface investigation results to government agencies generally depends on three factors of the job:

  • Whether the results reveal any potential danger or risks to public health.
  • If the job-site is within a jurisdiction that requires agency-permitting and data submission.
  • Whether the purpose of the work intends to intercept known contamination or just test for it.

Reporting the Results of a Phase 1 ESA if a Public Danger Exists 

In general, the information within a Phase 1 Environmental Site Assessment is proprietary. Depending on the terms and conditions of the agreement, all data and conclusions (whether written or verbal) are the proprietary information of the report user. Although users may choose to share the information with other parties themselves, consultants are generally obliged to report directly to their Client. However, it should be known by all parties that there is an absolute requirement to report the results of a Phase 1 ESA (as well as any other environmental report), if or when any danger to the public is discovered. For example, if a Phase 2 Environmental Site Assessment report reveals that a migrating vapor contamination plume is impacting the indoor air quality at a nearby school, the responsible parties may be legally required to report the findings to the local environmental agency or health department.

California Proposition 65 Warning 

In California, Proposition 65 is the requirement for businesses and landowners to post warnings about significant chemical exposures that may cause cancer and reproductive system concerns. The source of the chemical does not matter. Whether from inside building materials, from within the subsurface, or in the air, there must be a warning. In fact, the Office of Environmental Health Hazard Assessment provides publications about the chemicals and products in association with Prop-65 warnings.

Reporting ESA results to Government - California Proposition 65 Warning

Reporting ESA results – CA Proposition 65 Warning

California Health & Safety Code

California Health & Safety Code 25359.4 indicates a person or entity must not release or allow for the release of reportable quantities of hazardous substances into the environment without agency authorization and/or permission. The code continues to define exceptions. And but for those exceptions, it indicates that any release must be reported to the authorities within a 30-day timeframe from discovery.

California Health & Safety Code Reporting Environmental Report Results

California Health & Safety Code Reporting Environmental Report Results

Duty for Reporting the Results of an Environmental Due Diligence Investigation

Much like California Health & Safety Code 25359.4 and California Proposition 65, Federal guidelines and other State and local health code regulations similarly specify the obligation to report contamination that may be a risk to the public or environment. Most commercial real estate due diligence reports have the purpose of identifying whether a site is in (or out of) compliance with current environmental laws and regulations. Consequently, these matters do tend to arise during the property transaction due diligence periods.

Environmental Due Diligence & Public Health

Responsible Parties (or RPs) are typically the individuals or organizations responsible for a release. For instance, this can include property occupants, compliance violators and/or landowners. In the Phase 1 Environmental Site Assessment process, the environmental professional identifies each party, as well as their role to the property. And when necessary, the environmental professional will typically advise the appropriate parties to report the concerning findings of the environmental due diligence report.

Sensitive Receptors

Sensitive receptors are items that are considerably essential to society, subject to impact. For example, water wells, schools, hospitals and more. The distance and direction to the nearest sensitive receptor from a contamination case determines the risk of public danger. In fact, major sensitive receptors can be discussion points within a Phase I ESA or Phase II ESA report itself. Nonetheless, during environmental due diligence, property owners should refer to their environmental engineering consultant to determine whether a risk to public health exists or not.

Reporting Results of an Environmental Due Diligence Investigation

Reporting Results of an Environmental Due Diligence Investigation

Agency Involvement

If the results of a subsurface investigation show contamination impacting a sensitive receptor, there is a legal responsibility to recommend further action and report findings to the government. And various agencies have overlapping oversight on various sensitive receptors. For example, a threat to potable water resources is best applicable to the State Water Board. Similarly, a threat to indoor air quality due to soil contamination is best applicable to the State Department of Toxic Substance Control. Moreover, some contamination cases might also require involvement by local agencies, such as City Fire Departments, County Health Departments, and State Environmental Departments. Furthermore, federal involvement may be a requirement, depending on severity. As a result, the United States EPA may additionally require oversight.

Environmental Site Assessment Results

Reporting the results of an environmental due diligence investigation may not always be a requirement. Phase 2 Environmental Site Assessment reports compare onsite results with industry screening levels. And screening level numbers vary by location. In fact, some local, State and Federal advisories overlap in jurisdiction. Moreover, various agencies administer media-specific and land-use-specific screening levels. For instance, the Federal EPA has leading jurisdiction across the nation and publishes standards per region. Whereas State regulatory agencies may apply action levels inside their State boundaries only. In fact, some States (for example: California) have multiple divisions of their EPA, which also overlap each other. Furthermore, County and City agencies such as fire departments, health departments, and water agencies, also have overlapping jurisdiction above the State and Federal EPAs.

Screening Levels

Typically, screening levels are simply a reference point for reporting the results of an environmental due diligence assessment. In most cases, screening levels aren’t actionable levels. However, an environmental government agency can choose to use screening levels as an action level within its own oversight program. For example, a government environmental agency overseeing an ongoing remediation case may require the RP to clean up soil contamination until the contamination is below RSL screening levels.

Reporting the Results of an Environmental Due Diligence Investigation

Example Table: Reporting the Results of an Environmental Due Diligence Investigation – Soil-Gas & CA Screening Levels (CHHSLs are now obsolete, and the DTSC HHRA Note 3 Figures are the Prevailing Screening Levels for Phase 2 Reports)

Various Screening Levels

The US EPA provides Regional Screening Levels (RSLs) which primarily apply for soil sample comparisons. Similarly, the California EPA provides Human Health Screening Levels (CHHSLs) for soil and soil-gas. Although in the recent term (as of April of 2019), the leading soil-gas screening levels are now the DTSC HERO Note 3 Screening Levels. In fact, these publications provide a list of minimum chemical concentrations allowable for risk assessment purposes. And screening levels like these assist geologists and engineers when conducting toxicology and risk evaluation projects. In environmental due diligence investigations, screening levels are not typically associated with reporting limits. However, if health-threatening circumstances arise beyond a reasonable doubt, then reporting the results of an environmental due diligence investigation to a government agency may be apparent. This professional duty is a matter of public policy.

Actionable Groundwater Levels to Report Over

Unlike the abovementioned numbers, the Federal EPA also provides actionable Maximum Contaminant Levels (MCLs) as a drinking water standard. Consequently, Environmental Site Assessment work with groundwater testing utilizes MCLs as a basic guideline for risk assessment and reporting authority. Similarly, some local agencies establish their own screening and action levels for groundwater, basing on the research of the Federal EPA MCLs.

Reporting the Results of a Phase II Environmental Site Assessment

A Phase II Environmental Site Assessment generally includes drilling for the analysis of soil, soil gas, and groundwater. But these three media are not alike in terms of risk assessment and reporting obligations.

Additional Testing to Make Sure

A typical Phase 2 ESA report in California relates all onsite detections of soil and soil gas to screening levels. In most assessments, geologists and engineers also apply soil sample analytical data to geologic models to estimate risk. Some models focus on the extent of contamination. Whereas other models focus on human exposure risks. Nonetheless, there is a professional and legal responsibility to recommend further action if the results of a Phase 2 Environmental Site Assessment suggests any of the following

  • (1) the likelihood of contamination to groundwater near a potable source;
  • (2) there is a potential health risk to the occupants of the lot by mode of vapor intrusion; or
  • (3) any other possible human health dangers.

Jurisdictional Obligations

In some jurisdictions, exceeding screening levels alone can create an immediate obligation to report results. Some agencies also adopt the screening levels other larger agencies, to use as their own clean-up standards. This is typical during the course of remediation. Environmental engineering consultants and their clients should always contact the lead environmental agency for a site’s jurisdiction to confirm reporting obligations.

Sampling Groundwater in Phase 2 ESAs

Groundwater reporting requirements hold to a higher standard. Under the California EPA, the State Water Quality Control Board (SWRCB) protects groundwater on a statewide basis. In fact, the board is divisible into nine regions. And each regional board makes up the official “Regional Water Quality Control Boards (RWQCB).” Each regional board provides oversight and interest in groundwater quality, with a focus on sensitive receptors. For instance, standards are higher for sites nearby a drinking water well, river, wash, school, hospital, etc. And in most cases, the RWQCB will act as the leading agency for oversight programs, alongside with County and City agencies.

When Groundwater Detentions Exceed MCLs

If a Phase II ESA detects groundwater contamination which exceeds MCLs, the RP will likely need to report the data to their regional water board. Similarly, the same groundwater data may be a requirement for the County and City agencies, if a drilling permit is necessary. In most cases, agencies refer to MCLs as the minimum allowable contamination to groundwater before requiring notification.

Groundwater Monitoring Well to Test Groundwater for Possible Contamination during Environmental Site Assessments

© SonoranDesert NPS

Other Environmental Investigations

Some subsurface contamination investigations have a limiting scope of work, which differs from a Phase 2 Environmental Site Assessment. Nonetheless, the process of drilling to collect soil and groundwater samples from below the ground surface entails similar reporting obligations. Ultimately, it is important for all property owners and consultants to acknowledge each project is different. Variations exist in scope, purpose, jurisdiction, and result. And because reporting obligations can vary on a case by case basis, property owners should refrain from blindly relying on general information. Especially when undergoing real estate environmental due diligence periods. Instead, parties should consult with their environmental engineer, attorney, and local regulatory agency.

Drilling Permits

Some County and City environmental agencies will also require a borehole permit for any drilling project within their jurisdiction. On the other hand, some agencies only require a permit when groundwater is present. Often times these permits have a closure process that requires reporting all the laboratory data, regardless of the result. Consumers can rely on their environmental engineering consultants to provide such information. If so, consumers must prepare to release analytical data to the respective government agency, no matter what the result.

Ongoing Remediation Cases

A responsible party may also need to report analytical data from a subsurface investigation if the site is already undergoing regulatory oversight for remediation. Under these circumstances, the lead agency caseworker will directly require a copy of the assessment report to review and publish as municipal information. Prior to any subsurface testing, a Phase I ESA report discloses whether the property is undergoing regulatory oversight or not. In the State of California, assessment reports for properties with known groundwater and soil contamination cases are visible via the SWRCB Geotrackter Database. Similarly, reports for properties with known soil and soil-gas contamination cases are available via the DTSC Envirostore Database.

For more information or a free consultation about site-specific environmental due diligence reporting requirements, call (888) 930-6604.

California Requirements Study – Health and Safety Code, Section 25359.4:

Section A

(a) A person shall not release, or allow or cause a release of, a reportable quantity of a hazardous substance into the environment that is not authorized or permitted pursuant to state law.

Section B

(b) Any release of a reportable quantity of hazardous substance shall be reported to the department in writing within 30 days of discovery unless any of the following apply:

  1. (1) The release is permitted or in the permit process.
  2. (2) The release is authorized by state law.
  3. (3) The release requires immediate reporting to the Office of Emergency Services pursuant to Section 11002 or 11004 of Title 42 of the United States Code, or pursuant to Section 25507.
  4. (4) The release has previously been reported to the department or the Office of Emergency Services.
  5. (5) The release occurred prior to January 1, 1994.

Section C

(c) For the purposes of this section, “reportable quantity” means either of the following:

  1. (1) The quantity of a hazardous substance established in Part 302 (commencing with Section 302.1) of Title 40 of the Code of Federal Regulations, the release of which requires notification pursuant to that part.
  2. (2) Any quantity of a hazardous substance that is not reportable pursuant to paragraph (1), but that may pose a significant threat to public health and safety or to the environment. The department may establish guidelines for determining which releases are reportable under this paragraph.

Section D

(d) The owner of property on which a reportable release has occurred and any person who releases, or causes a reportable release and who fails to make the written report required by subdivision (b), shall be liable for a penalty not to exceed twenty-five thousand dollars ($25,000) for each separate violation and for each day that a violation continues. Each day on which the released hazardous substance remains is a separate violation unless the person has either filed the report or is in compliance with an order issued by a local, state, or federal agency with regard to the release.

Section E

(e) Liability under this section may be imposed in a civil action or may be administratively imposed by the department pursuant to Section 25359.3.

Section F

(f) If the violation of subdivision (b) results in, or significantly contributes to, an emergency, including, but not limited to, a fire, to which a county, city, or district is required to respond, the responsible party may be assessed the full cost of the emergency response by the city, county, or district.”

Additional Information & Sources: 

DTSC Reporting Nonemergency Hazardous Substance Releases

EPA Groundwater & Drinking Water

EPA Risk Assessment


Forward-Thinking Geologists, Engineers & Contractors!


Dry Cleaner Soil Testing

Dry Cleaner Soil Testing

Dry cleaner soil testing is an environmental engineering and geology service which aims to determine the presence of chemical contamination to the subsurface, resulting from dry cleaning operations. The primary contaminant of concern during dry cleaner soil testing is tetrachloroethylene (PCE), as well as it’s break-down products. PCE is a manufactured volatile organic compound which doubles in use as an industrial solvent, as well as a cleaning agent of fabrics. In the scientific community, PCE is a chemical of concern, mainly due to its carcinogenic properties, along with his high mobility tendencies and groundwater solubility characteristics. Moreover, PCE can breakdown over time, into various other chemical products which also hold presumable carcinogenic properties. Updated October 18, 2019.

Dry Cleaner Soil Testing during Phase 2 Environmental Site Assessment

Dry cleaner soil testing is a common requirement during commercial real estate due diligence periods. This includes Phase 1 Environmental Site Assessments and Phase 2 Environmental Site Assessments. Today, commercial real estate professionals and investors are well aware of the legal ramifications of innocently acquiring properties with contamination issues. As a result, it is reasonable to presume that most lots comprising this activity will, at some point, entail dry cleaner soil testing. This process can become a requirement upon buying or selling a lot. In fact, merely applying for an equity loan on a property with dry cleaning history will result in some kind of environmental due diligence investigation.

Limited Dry Cleaner Soil Testing can be Conducted Prior to a Phase 2 ESA

(c) rhinman Dry Cleaner Soil Testing for Phase 2 ESA

Commercial Real Estate Environmental Due Diligence

Today’s standard for commercial real estate due diligence typically starts with a Phase I Environmental Site Assessment (Phase I ESA). And only when the conclusions of a Phase I ESA recommend further action, a Phase II Subsurface Investigation becomes necessary. However, due to the environmental risk, savvy lenders and investors occasionally insist on a Phase II Subsurface Investigation that is simultaneous to the Phase I ESA.

Performing a Phase I ESA & Phase II ESA at the Same Time

In fact, an environmental professional may not recommend performing a Phase II Subsurface Investigation at the same time as a Phase I ESA. For instance; another recognized environmental conditions (RECs) might not become apparent until the final stages of the Phase I Environmental Site Assessment. And upon prematurely commencing the Phase 2 ESA which aims solely to test for dry cleaner contaminants, half (or more) of the Phase I ESA recommendations may be missed. Consequently, the Phase 2 ESA will have considerable data gaps, disqualifying it from CERCLA Innocent Landowner Liability Protection laws.

Dry Cleaner & Gas Station Examples

For example; during escrow for a lot with a dry cleaning business, the buyer requests to perform both Phase 1 & Phase 2 ESAs at once. As a result, the Phase 2 ESA fieldwork commences on Day 1, with a scope of work specifically for dry cleaner soil testing. However, by day 10 of the Phase 1 ESA, the environmental professional discovers a gasoline service station on-site from the year 1930. In such a case, the likelihood of old fuel tanks being in-place is high, along with the potential for gasoline and diesel contamination. However, the already-performed Phase 2 ESA fieldwork didn’t comprise a geophysical survey, nor the analysis of gasoline contaminants.

environmental_release_contamination_dry_cleaner_oil_gasoline_station_gas

©publicdomainstockpho: Environmental Release & Contamination at Dry Cleaner & Gasoline Station

How Dry Cleaner Contamination Happens

Various types of dry cleaning agents have been in use since the early 1900s. But the most common substance is tetrachloroethylene (PCE). In the liquid phase, PCE and other break-down chemicals easily migrate through concrete slabs and soil layers. As a result, the bulk of the dry cleaning solvent passes right through the shallower soils and accumulates in deeper zones. And in some cases, the PCE can leach into groundwater zones, and spread in accordance with the aquifer characteristics.

During the vertical migration process, trace amounts of solvent will remain within the pore spaces of the dry soil layers it passes through. And over time, evaporation occurs causing an abundance of toxic soil vapor intrusion issues. Consequently, shallow soil samples usually don’t yield representative data at historical dry cleaners. Instead, vapor phase PCE, TCE and other volatile organic compounds are detected at higher concentrations at shallow depths. Ironically, fractions of the very same toxic material released into the ground evaporates and migrate right back into the breathing zone of the building. At which point, the vapor phase chemical remains toxic but colorless and odorless.

Some level of a subsurface release, however slight, is a reasonable expectation at any historical dry cleaner site. In general, older dry cleaning facilities have a higher potential for contamination. This is because of the prevailing use of PCE prior to the 1990s. Moreover, older machinery typically lack the secondary containment and leak-prevention features that newer devices comprise. Other potential pathways of PCE subsurface contamination exist in the onsite sewage and drainage system, as well as waste storage areas. Modern facilities can upgrade equipment with leak prevention systems, and also operate using environmentally friendly solvents. However, its the historical releases of PCE that could still pose environmental concerns for landowners well into the future.

Smaller Steps in Dry Cleaner Soil Testing

Commercial real estate professionals occasionally request a series of limiting subsurface investigations for decision-making purposes. For example, a sub-slab soil gas intrusion screening, or shallow soil gas survey provides a brief snapshot of under-slab conditions. Limiting scopes such as these do not qualify to be a Phase 1 ESA or Phase 2 ESA, and do not satisfy the All Appropriate Inquiries rule. In fact, sub-slab soil gas surveys are now less regarded and are not supported by the scientific community standards. However, the information might be applicable to determine whether dry cleaning solvent contamination is an issue, however slight. Reports such as these, are not likely to satisfy lenders, as they do not meet the ASTM standard for a Phase II Environmental Site Assessment or Phase 2 Subsurface Investigation.

Interior Footprint Dry Cleaning Soil Testing Using Sub-Slab Vapor Probes

Interior Footprint Dry Cleaning Soil Testing Using Sub-Slab Vapor Probes

Dry Cleaner Remediation

In some cases, a dry cleaner Phase II ESA may reveal soil and groundwater contamination above the actionable level. As a result, remedial action becomes a requirement, with regulatory agency oversight. Alternatively, commercial real estate investors can also voluntarily take on dry cleaner contamination remediation and mitigation. Using modern technology, geologists and engineers apply a combination of methods to clean-up the solvent-contamination to soil and groundwater. Additionally, environmental scientists can implement vapor intrusion safety components into buildings, in an effort to eliminate PCE health risk affects. Best practice remediation and mitigation methods vary from site to site, in terms of applicability. Typical remedial action methods are soil vapor extraction, air-sparge, groundwater pump/treat, and chemical injection. One or all of these methods are applicable to accelerate the degradation of contaminants.

Geo Forward is an industry leader in dry cleaner soil contamination testing and remediation. For more information call (888) 930-6604 to speak with a professional geologist or engineer.   

Additional Information & Sources: 

U.S. Environmental Protection Agency (USEPA), Office of Air Quality Planning and Standards,  Health and Environmental Impacts Division, Research Triangle Park, NC. “Economic Impact Analysis of the Perchloroethylene Dry Cleaning Residual Risk Standard” – July 2006, https://www3.epa.gov/ttnecas1/regdata/EIAs/eiafinalpercdrycleanersresidrisk.pdf

USEPA, Technology Transfer Network – Air Toxics Web Site, “Rule and Implementation Information for Perchloroethylene Dry Cleaning Facilities” – Docket ID. No. OAR-2005-0155, Legacy Docket #A-88-11 – February 2016, https://www3.epa.gov/airtoxics/dryperc/dryclpg.html


Forward-Thinking Geologists, Engineers & Contractors!


What is a Brownfield Site and Brownfields?

What is a Brownfield Site?

An article about the Brownfields Act by Azad A. Kaligi, PG.


The Brownfields Revitalization and Environmental Restoration Act of 2001 (also known as the Brownfields Act) defines a Brownfield Site as “real property, the expansion, redevelopment or reuse of which may be complicated by the presence or potential presence of hazardous substance, pollutant, or contamination.”

In other words, a Brownfield Site is land that might be contaminated, and the purpose of the Brownfields legislation is to encourage remediation, if needed, so that the site can be redeveloped.


CERCLA & Brownfields Sites

A Brownfield Site is Land that Might be Contaminated, and the Brownfields Legislation Encourages Remediation.

© Paige Foster

The Brownfields Act amends the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980. The redevelopment process starts with a Phase I Environmental Site Assessment and the due diligence process.   The purpose of environmental due diligence s to determine the extent of contamination and possible legal and financial risks.


Brownfields Redevelopment & Environmental Due Diligence 

If a Phase I Environmental Site Assessment concludes that there are no Recognized Environmental Concerns related to contamination or human health risks, the property can undergo redevelopment.  Although, if recognized environmental concerns (REC) are reported, a Phase II Environmental Site Assessment will be required, which entails field sampling, laboratory analysis, and geological/engineering based conclusions.


 Cleanup of Brownfields Sites

Cleaning up a Brownfield Site is considered Phase III Environmental Remediation, or simply “remediation.”  Often times with remediation, additional site assessments and groundwater monitoring will be conducted.  Modernly, environmental remediation efforts are comprised of soil vapor extraction, groundwater pump & treat, or in-situ chemical/microbial injection. However, in some cases remediation by soil excavation (also known as contamination source removal) is most practical.


For information about the environmental due diligence process for Brownfields Sites, check out Geo Forward’s Phase I ESA and Phase II ESA pages, or call Geo Forward, Inc. at (888) 930-6887 to speak with a licensed professional geologist or engineer.


References:

U.S. Environmental Protection Agency, 2005, Brownfields Cleanup and Redevelopment: http://www.epa.gov/enforcement/brownfields-and-land-revitalization-cleanup-enforcement.



Leaking Septic Tank & Environmental Concerns

Environmental Concerns for a Leaking Septic Tank

The area directly underlying a leaking septic tank is a biologically active zone known as the “Infiltration Zone,” and is approximately 1 to 3 inches thick.  Usually, some oxygen is present at this depth, causing a process called “Nitrification.” Nitrification basically means ammonium nitrogen is being converted to nitrate.

An article about Nitrate and Nitrite, by Azad Kaligi, PG.


Nitrate from a Leaking Septic Tank – Into the Soil

Nitrate is a form of nitrogen that is found in the soil underlying septic systems. Other sources of nitrate are agricultural areas where fertilizers and animal manure are stockpiled.

High levels of nitrate and chloride in the soil surrounding a septic system indicate contamination of soil from leaking septic tanks.  A known fact about the California water resources industry is that more groundwater production wells have been shut-down due to high nitrate concentrations than any other chemical constituent.


Nitrate From a Leaking Septic Tank – Into the Groundwater

A Property with a Leaking Septic Tank can Include Nitrate and Nitrite Concentrations in Soil and Groundwater

Nitrate & Nitrite

Nitrates can fall through soil, and form a contamination plume in groundwater. Natural concentrations of nitrate in groundwater range from 0.1 milligrams per liter (mg/L) to 10 mg/L. Nitrate is soluble in groundwater, and has a high rate of mobility through aquifers. Nitrate has also been known to accumulate at specific portions of aquifers, depending on the geology and soil characteristics.

Since high-nitrate water  can cause fatal diseases affecting infants, drinking water standards are set at 10 mg/L.


After “Nitrification” – Nitrate Can Become Nitrite

After a some percolation time, nitrate changes to become nitrite with the help of bacteria in the subsurface. The bacterial count pre-existing within the septic system is usually an aid to this process.

Nitrite From a Leaking Septic Tank – Into to Soil and Groundwater

Through the underlying soil horizons, nitrite goes through a sorbtion process.  During seepage phosphorus and pathogens are removed along with all other septic tank matter. However nitrite (along with nitrate) typically fall through these zones and contaminate groundwater.


Environmental Evaluation of a Leaking Septic Tank

The Federal EPA developed Maximum Contaminant Levels (MCLs) as a health-based protective drinking water standard.  Nitrate and nitrite are included in the list of MCLs.  When conducting an Phase I Environmental Site Assessment or a Phase II Subsurface Investigation related to a potential septic tank release, it is important to consider the depth to groundwater, the regional geology & hydrogeology, and the findings of the percolation test prior to installation.


Leaking Septic Tank in Industrial or Commercial Properties 

At industrial sites, nitrate and nitrite may not be the only chemicals of concern potentially released to the subsurface.  Historical land use of industrial properties usually include dumping hazardous chemical waste into the onsite sewage system.  In such cases, a leaking septic tank serves as a pathway for various contaminants to reach soil and groundwater once dumped onsite.

For more information about leaking septic tanks and the environmental concerns for soil and groundwater contamination, call Geo Forward, Inc. at (888) 930-6887 and speak with a licensed professional geologist or engineer.

For information about environmental risk assessments and soil and/or groundwater sampling, check out Geo Forward’s Phase I ESA and Phase II ESA pages.


References:

U.S. Environmental Protection Agency, office of Ground Water & Drinking Water, July 2002, List of Drinking Water Contaminants & MCLs: http://www.epa.gov.safewater/mcl.html#organic



Lower vs Higher Prices for Phase II Environmental Site Assessment (Phase II ESA)

 Lower vs Higher Prices for Phase II Environmental Site Assessment (Phase II ESA)

An article about Phase 2 ESA Reports, by Azad A. Kaligi, PG.


Clients seeking a Phase II Environmental Site Assessment (also known as a Phase II ESA) are usually attracted to the lowest priced proposals.  As a person who truly believes that “money saved” is just as good as “money earned,” I understand the incentive to seek lower prices.  However, when it comes to environmental due diligence, not all scopes are created equal.  Usually unknown to Client’s, reduced prices for Phase II Environmental Site Assessment may result in a reduced scope of investigation.


Prices For Phase II Environmental Site Assessment aka Phase II ESA

Prices For Phase II Environmental Site Assessment

Not All Phase II ESA Scopes Are Equal

Far too many times, I have witnessed individuals rejecting a proposal for a properly scoped Phase II ESA, and turning to a lesser-expensive proposal that is inadequately scoped and lacking of reasonable investigation methods.

In most cases, when a Client turns to the lower-costing Phase II Environmental Site Assessment, they are unaware that the difference in cost is due to a reduced scope.  Without a reliable scope of work, the decision to save money on a Phase II ESA can backfire later down-the-line.


Simple Example/Scenario:

  • Purchaser is interested to buy a property with a gasoline station, where groundwater is approximately 30 feet below the ground surface. Purchaser needs a Phase II ESA to address environmental risks and concerns.
  • Consultant A submits a proposal for the higher cost, which includes drilling to 35 feet to collect soil and groundwater samples.
  • Consultant B submits a proposal for the lower cost, and only includes drilling to 15 feet to collect shallow-soil and shallow-soil-gas samples.
  • Both consultants claim their proposals are for a comprehensive Phase II Environmental Site Assessment. Purchaser mistakenly believes that both scopes are equal, and chooses the lesser expensive option by Consultant B to save money.
  • Years later, a nearby subsurface investigation reveals that gasoline contaminants have been found in the groundwater flowing from Purchaser’s property.  Now Purchaser and his/her attorney are facing pollution fines and remediation costs, and are having a difficult time proving that the groundwater contamination was not Purchaser’s fault, mainly because the lesser expensive Phase II ESA didn’t include groundwater analysis.

 A Proper Scope for Proper Prices – Phase II Environmental Site Assessment

A reasonable scope of work is objectively created by experienced geologists or engineers to address all potential contamination concerns onsite.  Various site conditions, such as depth to groundwater, type of soil, regional land use, and more play a great role in the designing of a Phase II ESA scope.


Phase I ESA & Phase II ESA: Environmental Due Diligence

Environmental Due Diligence is a critical process that typically warrants a comprehensive investigation for reliable results and legal liability protection. In some cases, Clients (who are not seeking legal liability protection) specifically request a Limited Environmental Site Assessment as a tool for better decision making.

Before blindly awarding a Phase II ESA to the lowest bidder, it is important to review and compare the listed scopes of work for each proposal.  Be sure to compare apples to apples, and communicate with a licensed professional geologist or engineer to accurately understand what is a reasonable scope of work is for your property.


Benefit from a Free Consultation with a Licensed Professional Geologist or Engineer

For a free consultation with a licensed professional geologist or engineer about your Phase I and/or Phase II Environmental Site Assessment, call Geo Forward, Inc. at (888) 930-6604, or Click Here to Visit the Contact Page.