Comments

Comments

  • Matt Fox
     
     

    I usually just include a very generic statement that it's my opinion that further investigation is warranted.  Scope of work would be in the Phase II proposal, if requested.

    There are pros and cons to leaving recommendations out or including them. The primary issue I see when reports don't include recommendations is that many people think "No recommendations" is the same as "No further action is recommended". The party that is the client will often try to trick other parties (lender, buyer, etc.) into thinking no further action is recommended by providing the Phase I, but not the side letter with the recommendation. I've seen many examples where lender or buyer didn't understand this nuance and ended up getting burned because of it.

     

     
  • Matt Fox
     
     

    Correct they do not look the same at all to me.

    Attached is the 1981 aerial photo showing a larger area. Note there are two other disturbed areas just west of the airport that look exactly like the disturbed areas we've been discussing north of the airport. Based on my experience, these look like engineered building pads for future construction.  There are also brand new paved roads right next to them which would back that conclusion up.

    Also note that the runway to the airport was significantly lengthened at the same time these building pads showed up and that runway appears to have been extended right through a hill, which would have created a lot of overburden.

    I stand by my original hypothesis. The disturbed areas are most likely overburden excavated from the runway expansion, not waste disposal ponds.

    Again, if it were me, I would have called the airport. I suspect someone there would be able to confirm.

     
    1981.jpg (681KB)
  • You're Fired!

    Thanks Max, I appreciate that, I wish all is best ever for you. :)

  • You're Fired!

    That's right, they don't look the same at all do they, lol. You're making the assumption with regard to the nearby sewage disposal plant, not yo. I'm just using those nearby waste disposal ponds to teach you what a waste disposal pond looks like from the air, in an aerial photograph. 

    Frankly, I have to admit, I am a little bit disappointed Matt ... you're seemingly combative nature coupled with your apparent failure to recognize these features ..... well, I'm sorry Matt .... you're fired!

  • Matt Fox

    Not sure I'd call it a REC based on RR ties leaching into GW. 

    But I might call it a REC or significant data gap if I thought likely that wastes were dumped into it based on current/historical use, etc. I also might identify it as a significant safety hazard.  That's beyond scope of Phase I, but your professional liability carrier would probably appreciate the CYA.

    Either way you look at it, the thing should be properly closed, which would probably involve taking some samples.

  • Matt Fox

    Your sewage disposal plant is 1/2 mile away and would have discharged to the river north of the area in question. It would have nothing to do with the white areas.  I'm still thinking the large white objects are piles of dirt, probably imported for future site development.

  • MaxEng

    Your abandonment of the "King of Snark" moniker was certainly premature.

  • You're Fired!

    I think there are some good options here:

    1) Report the distance of the LUST site in inches ... there is a case closed LUST site approximately 21,000 inches from the subject site, based on this distance, it appears unlikely ....

    2) Obtain a grab groundwater sample and submit to a laboratory for a fish bioassay test ... this data should be very useful. 

    3) Use updated acronyms in your report conclusions .... CER = Calculated Environmental Response, HCER = Historical Calculated Environmental Response.

    Anyway, good luck! 

  • Matt Fox

    I think you might be overthinking it a bit.  A closed diesel LUST site from 30 years ago that is 1750 feet from target property isn't going to be a REC or a VEC.

    Also, last I heard the "Can't be ruled out" option was getting pulled from E2600 standard, although I'm not really sure what the current status of the update is. It never should have been in there in the first place. 

  • JG

    D. None of the above.

    It can't be an HREC because it's offsite.  To be an HREC, the plume would have had to impact the TP and been remediated.  Reread the HREC definition.

    To be a REC, the impact has to be likely.  Your description ("high degree of variability in the groundwater flow direction and how that could assist a contaminant plume in growing in such a way as to contaminate the TP, provided the diesel actually reached it in the first place") sounds to me more like a possibility than a likely.

    As far as the VEC goes, the critical distance for petroleum is 30 to 100 feet (No NAPL/NAPL) so a pathway 200 feet from the TP isn't an issue.

    I would write it up describing what you mention in your post - NFA, >1,000 feet away, 20 years ago, etc.  If I was feeling wary I might describe in the opinion section that an impact is possible but not likely so it's not a REC.

  • Richard Bapst

    To all who have posted, in conclusion, i was able to get some good info from the elder statesman at the fire department who is retiring next month, talk about good timing....  Long story short, he noted them to be building pad/clearing sites.  He believed that the industrial park was permitted by the time of these aerial photographs in 81 and 84 and that a wildfire occured in the area in 1977-78 and at that time the area was virgin forest.  He also provided an older topo from 1954, photorevised in 1971, which did not depict any features of concern in the immediate vicinity, just the sewage treatment plant  way to the northwest.  Also, i obtained a preliminary assessment report for a nearby site which was issued a no further action letter/unrestricted use response action outcome whilst referring to the larger clearing to the north as building pad sites...for what thats worth, not that two potential wrongs make a right.  thanks to all who threw their hat into the ring on this one.   Rich

  • You're Fired!

    They are full, you can't see the bottom, so they are not going to be depicted with substantial depth, as deep pits or depressions, on the topo. Just like the ponds full of water, or the lake, they are not depicted as deep pits or a depressions on the topo either, you can't see the bottom. 

    What's important is that circa 1989 they are still substantial enough so that they are identified on the topo. So now you have them there for close to 10 years.

    Those are bermed waste disposal ponds, including the little one at the subject site, possibly from the nearby sewer treatment plant ... sewer easement road .... possibly sludge disposal ponds....

    Aloha! 

  • Z. Heine

    As JG stated, a discussion with your client is recommended on if they would like recommendations, and to what level.  The purpose / use of the Phase I can greatly impact the level of detail the client needs.

  • Z. Heine

    Good eye on the clamp.  I would concur with the water line suspicion, given the materials, the presence of the hose clamp and the corrosion / staining present around the pipe.  Construction doesn't appear common with a UST, although could be a distribution line, albeit a large one.  Personally, without additional information supporting a UST, would presume this is associated with water supply.

  • JG

    You're going to get differing opinions on this.  Really, the only correct answer is what your client wants.  I am in the camp that recommendations do not belong in the Phase I.  I generally state that the goal of the Phase I, to identify REC's, has been accomplished but the REC is based on the presumed likelihood of a release.  Further investigation could provide more certainty if warranted.

    Further investigation is never required based on a Phase I and it is not always warranted or wanted by the client.  Furthermore, Phase II recommendations are specific to the client and the proposed use of the property but the Phase I is not.  So the two should stand alone, IMHO.