Ahhh. That helps a lot. Thanks JG
1) A REC by definition is for the subject property.
2) The upgradient brownfield is not a REC. Contamination migrating from the brownfield onto the subject property is the REC. No migration (or likely migration) = no REC.
Since you are "here2learn" I will give you some unsolicited advice. Review and re-review the ASTM definitions of a REC, HREC, CREC, and De-minimis conditions. Refer to these definitions as you are drawing your conclusions. In your opinion section lay out the logic used to come to your conclusion and match your opinion to the definition.
Interesting. So say I have a Brownfield site under Institutional Control up-gradient of my site. My site has no Env. Liens or AULs. Would I just consider the Brownfield site a REC? It was my understanding it would be a CREC since it has had a release but is being subject to a form of control.
If I declare it a REC, would you say it "is considered a REC for the subject property."
It does not matter if the adjoining property has site use limitations or not. There's no such thing as an "off-site REC" or, in this case, an "off-site CREC". The question is does contamination from the adjoining property likely impact your site? If it does then a REC exists. If it does but it's been addressed (on your site) and your site has a use limitation then it's a CREC.
Thank you for the response! I've done only a handful of these myself, and was never too sure of my numbers, so just posing the question in general to see if there are any additional resources out there. Every time we get an RFP for low-income housing, noise assessment requirements is one of the first things I look for.
Yes, I find that noise contours for major airports and traffic counts for major highways are usually readily available online. I think it gets tricky when you have to factor in railroad data, military airfields, and the like. Phone calls never seemed to get me anywhere. Seems so far out of the typical environmental realm...but a lot of HUD stuff is.
Since no one else has piped up yet on this one, I'll bite. I've done only one of these, and there the major noise source was a nearby airport for which SPLs were well established. Traffic counts on the US route near the site were readily available. I did the necessary data gathering and noise modeling in about half a day. Sounds like you're not so lucky on your project.
Without knowing what the levels are at the site, it's hard to make a convincing argument about what is background and what is not-- you may be going out on a limb more by doing that than by doing anything else. In particular, if you're dealing with a site like a tannery that you recognize yourself as typically highly polluted, there's a certain burden of proof you need to overcome in making a case that whatever might be there is background.
Imagine someone else had made an argument for background at a site with a historic use that indicates a high likelihood of contamination without doing an investigation. In effect, they're certifying site unseen [pun intended] that whatever's there or that could potentially be there, from arsenic to PCBs to CVOCs to the #2 fuel oil tank someone finds when laying a new drain, is background even though there are potential sources. If you you were reviewing his or her work, would that pass even a straight face test? If the next guy comes along in five years during a bank re-fi, does some sampling and finds a major problem, your client may come back at you even if nobody's going after him.
In my experience, tanneries are usually more of a soil/direct contact hazard for metals and cyanide, but other uses since 1920 could add other problems to the pot.
Some of it also depends on what your jurisdiction's understanding of 'background' is, and whether historic fill or other deposition of metals, PAHs, etc. can be counted as background.... or indeed, whether counting it as background actually gets you much. E.g. the equivalent category in Connecticut is "widespread polluted fill" and writing a site up as that doesn't really help you (it's still actionable) except when you're making a feasibility argument against having to clean up a half-acre lot to a depth of ten feet.
I agree with Tom....we need to know exactly what type of oil we are talking about...nevertheless....there were some discussions on this issue several years ago that don't seem to come up when I searched. Maybe they have been cleared out. Here is a picture like some I posted several years ago of various excavations associated with leaking hydraulic lifts. This particular facility had been operating more than 30 years and had leaking lifts. Some of the leaks pushed down to the 30 foot bgs range....and this soil was not a coarse sand/gravel or the like. So, yes, some of these fluids can be mobile.
Clint: When formulating a Phase II strategy, it is typically more appropriate to sample in areas of specific concern rather than going around the perimeter of a building or lot as you propose. Sometimes grid samples are collected but it would be unusual for a small building as you have described. And like JG noted, you need to assess what releases were likely to have occurred (if any). Look for heavy staining, evidence of a former solvent parts cleaning tank, dead vegetation behind the building, things of that nature. Given the relatively recent age of the building, TPHg and BTEX might be enough for this site with regard to the analytical suite. Your depth might be a little shallow. Other than that, it is difficult to guesstimate much more without looking at your Phase I.
Hello Clint: PCBs are commonly related to waste oils and are sometimes specified in State regulatory programs. Waste oils are sometimes an accumulation of oils from various processes such as motor oil plus solvents or a manufacturing facility different types of waste oils all being placed into one container. The burden is on you and your client to decide if the need exists based on the Phase I ESA identified chemical use.
I am mainly concerned with TPH/btex and heavy metals but was wondering if it is standard to sample for PCB's when a hydaulic lift was not present-I was not sure if there presence is possible rather than likely for this kind of operation and if it would be appropriate to include them in the sampling from a cost verse risk perspective.
If you are conducting a Phase II then I assume it was concluded in the Phase I that a release had likely occured and the client requested additional information to support/rule out that REC. What you test for in the Phase II is based on what release you determined was likely in the Phase I.
Open containers are a major no-no under hazardous waste regs. If you improve the upkeep practices, that will help prevent a future release (and save you a fine and a hassle in the event someone in authority does an inspection).
Hydraulic oil is usually fairly immobile in soil if 1) it wasn't hot when it was discharged, 2) it didn't hit a preferential pathway such as a crack in the floor, a seam along a foundation or a void between soil and concrete. That said, I worked on a plastics injection molding factory a few years ago that had enough hydraulic oil go through a gap between a wall and a floor that we had NAPL in an indoor monitoring well. Competent concrete with no cracks, seams, etc. in it will usually keep it out of the soil.
Since it's a machine shop, consider that cutting oils or lubricants, as distinct from hydraulic oils, can behave differently. Lube is usually immobile stuff (some lubricants are virtually a solid) but some specialty cutting oils are low viscosity or more soluble, and can be pretty mobile. Waste oil of any kind can also accumulate other contaminants, including chlorinated hydrocarbons from solvents and metals from the workpieces.
from a practical standpoint, clients (and lay persons) are usually not well-equipped to evaluate the skills of vendors. licensing ensures certai minimum skills-but more importantly prevents the rogues from engaging in unlawful work.
written exams test minimum knowledge but usually the license rules require some apprentice time.
i agree that sometimes the need for using a licensed person can result in delays and some increased costs but that seems a reasonable tradeoff to protect the public. Tying to squeeze out the very last penny is what leads to the problem of reliance on under-trained, under-experienced and dishonest individuals.
Does everyone charge extra to print the report in hardcopy or do you provide a certain number of copies in the base price?