Environmental

 


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 with rejection, change-orders, re-testing and law suits. A price quote lower than $2,400 warrants concern. This article provides information and insight on pricing for a proper Methane Testing Report. Updated June 14, 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 to 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 many aspects about the property. For example, a methane test report can discuss historical land-use, site geology and hydro-geology, 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 a 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 2

PCBs Contamination in Killer Whales and Orca Pollution

PCBs contamination in killer whales and orca pollution are an increasing concern in the environmental science community. Recent studies indicate that hazardous levels of industrial chemicals exist in the bodies of orcas and other marine mammals around the world. In fact, toxicologists now hypothesize that rising concentrations of carcinogens 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. Updated July 5, 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 seeing 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 the 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

 

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.

Poly-chlorinated 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 it’s 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 impacts include impact to 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 biphenylsare (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 the 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, medias 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 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 overtime, 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 may be). And the overall chemical concentration build-up within their own bodies, as a result of being the ultimate contamination end point.

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 overtime, 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 wales.

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 an 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 restriction. In fact, there are a whole slough 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 overtime, 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 by: Azad A. 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 August 20, 2019.

Phase 2 Environmental Screening Level Numbers

ESLs: Phase 2 Environmental Screening Level Numbers

Commercial Real Estate vs. Residential Land-Use

In 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 users guidance.

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.

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 are the San Francisco Bay Region State Water Quality Control Board “ESLs.” 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 medias, 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 options 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 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) represent 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 a 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 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 1

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 3

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 on 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 August 1, 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 overtime are the result of changing ASTM standards, technology, labor and employment costs, industry demand, and more. Moreover, as environmental laws strengthen overtime, 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, the 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 law suits, 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 mislead 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 which 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.

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, the 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 request a Phase II Subsurface Investigation when there is a known cleaners 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 the 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 onsite; (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 overtime.  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 overtime.  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


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?” This is a frequent inquiry we get from property owners and report users. Especially during real estate environmental due diligence periods. For example, when a Recognized Environmental Condition becomes apparent in a Phase 1 Environmental Site Assessment, there is a potential for subsurface contamination. Thus, a Phase 2 Environmental Site Assessment is necessary. And depending on the results, along with a few facts of the site, there might be an obligation to report the findings to an agency. Updated April 20, 2019.

An article about Environmental Due Diligence.

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 depend on three factors of the job:

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

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 supportive information using the engineering and geological professional standards in California. In all cases, we advise readers to consult such matters with their attorney.

Duty for Reporting the Results of an Environmental Due Diligence Investigation

Health and safety codes across the United States specify that everyone has a duty to report contamination that can be a risk to the public, or environment.

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 owners.

Sensitive Receptors

Sensitive receptors are items that are considerably essential to society.  For example, water wells, schools, hospitals and more. The distance and direction to the nearest sensitive receptors, from a contamination case, determines the risk of public danger.  In fact, major sensitive receptors can be discussion point in a Phase I ESA or Phase II ESA. Nonetheless, during environmental due diligence, property owners should refer to their environmental engineering consultant to determine if a risk to public health exists.

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 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. As a result, the United States EPA may 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 screening levels. Screening levels vary by location. Moreover, various agency administer specific screening levels. And some local, State and Federal advisories overlap. For instance, the Federal EPA has jurisdiction across the nation, and publishes standards per region. Whereas State regulatory agencies may apply action levels inside their state 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 their own oversight program. For example, a government environmental agency overseeing an ongoing remediation case, may require the RP to cleanup soil contamination until the contamination is below 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). Similarly, the California EPA provides Human Health Screening Levels (CHHSLs). In fact, these publications provide a list of minimum chemical concentrations to for risk assessment purposes. And screening levels like these assist geologists and engineers when conducting toxicology and risk assessment 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 may be apparent. This duty is a matter of public policy.

The Federal EPA also provides 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 on the other hand, some local agencies establish their own screening and action levels.

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.

A typical Phase 2 ESA report in California relates all onsite detentions of soil and soil gas to screening levels. In most assessments, geologists and engineers also apply soil sample analytical data to geologic models and programs to estimate the overall 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: (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 quality on a statewide basis, and comprises 9 groups. The groups make up Regional Water Quality Control Boards (RWQCB). Each regional board provide 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 in scope, purpose, jurisdiction and result. Because reporting obligations can vary on a case by case basis, property owners undergoing real estate environmental due diligence projects should never blindly rely on general information. 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. Consumer 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 RP may also be 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


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 cleaning agent of fabrics. In the scientific community, PCE is a chemical of concern, mainly due to it’s carcinogenic properties, along with his high mobility tendencies and groundwater solubility characteristics. Moreover, PCE can breakdown overtime, into various other chemical products which also hold presumable carcinogenic properties. Updated April 22, 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, its 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 of the Phase 1 ESA, the environmental professional discovers a gasoline service station onsite from the year 1930. In such a case, the likelihood of old fuel tanks being in-place is high, along with 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 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 overtime, 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 migrates right back into the breathing zone of the building. At which point, the vapor phase chemical remain 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 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 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



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.