Comments

Comments

  • Tom Speight

    I apologies for the ramifying tangents here, but..... I have worked on and fixed card punchers and card readers. 

  • King of Snark
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  • King of Snark

    Yes, above ground or below ground. 

  • maverick

    In California, the water application on the log decks would require a WDR permit from the RWQCB.  Call your local water quality folks and ask them.  Such a permit would be allowed for clean water uses only.  If the water is contaminated, the aerial application for the water would likely be a big no-no (in California for sure).  I don't know if I would call it a REC (need more info), but I would want to know if it was allowed without permit?

    For the tanks, for sure you are looking at a Phase II.  The other messy areas might also be included in the Phase II. If the site is on septic, watch out for industrial wastewater drains that discharge to the septic.  On a property like this my biggest concerns beside the fuel tanks would be history solvent usage and degreasing parts and septic systems that were used for industrial disposal.     

    Good luck on this mess! 

  • JG

    I would assume below ground.

  • spucketts

    What I've since found out, not a lot of restrictions on sawdust-can't use it as fill. As for the spray nozzles, sawmills keep the wood wet as it is easier to mill, keeps it from splitting, prevents certain fungal growth and keeps beetles out. Fire prevention is a bonus. What they've done on this property is to excavate linear drainage ditches across three parcels to collect and create the detention pond for the supply for spraying. Problem is it's collecting runoff from the northern parcel which contains his vehicle maintenance building, underground storage tanks (one series of tanks installed in '66 and removed in '91 and closure info can't be found), no safety bollards around unlabeled aboveground tanks (which are surrounded by black stains), no secondary containment under anything, empty (with residue) grease drums lying on their sides with the tops open, a truck wash bay that drains into an open detention pond then into the collection ditches, broken equipment and parts scattered and leaking all over, vehicle work bay floors you can skate on, just a general mess. Basically he's collecting his runoff from this property and is spraying it on his other property.

    But back to one of my original questions, would a municipal wastewater spray field present an environmental concern? Lets say its on an adjacent property up gradient, an REC?

  • maverick
    I would not consider wood to be a REC. It might cost somebody a pretty penny to move it, but that does not make it a REC. The spray nozzles were likely use to keep wood wet in advance of it being milled. The drainage creeks may have been part of a water recycling operation and maybe there is a pond or detention area on site at the end of the drainage area? I would doubt any sewer plant involvement in your site.
  • TESKCMO

    That make sense,it is the signature date vs the acquisition date.

     

    I have experienced the same the update cost issue, I have explained the cost of the database search, tracking down the interviews and/or finding other interviewees and the time (especially if it requires travel) for the site visit plus my time to write up the new report are costs. 

  • JG

    It could be read either way.  The standard does read that an ESA completed less than 180 days of acquisition is presumed valid.  However, further down it reads that an ESA completed within 1 year is valid if the interview, database search, file review, site visit, and EP declaration have been completed within 180 days.  Read strictly it does create a strange loophole in cases where the site visit, etc. were conducted >180 days ago but the report was completed <180 days ago.  To interpret it safely I advise my clients to follow the second, more detailed, part of the standard.

    I've also changed my approach to Phase I "Updates" over the years based on this standard.  I tell my clients that if a Phase I is over 1 year old it can't really be "updated", they need a new Phase I. However, the cost is reduced because the historic research is done and if I wrote the first report a lot of the writing is done too.  A report can be updated if it's less than 1 year old.  In this case I'll update the 5 components and document it in a letter.

  • FStephenMasek
    At one point in the task group discussions I suggested getting rid of all of the alphabet soup and simply requiring that the EPA provide a section on each issue identified. How many of you would prefer that approach?
  • MaxEng

    I seldom disagree with JG, but I will do so here.  The critical time for Property acquisition is 180 days; in other words, if acquisition occurs within 180 days of the "completed" report (which I agree is the date of the signature by the EP), the report is valid to satisfy AAI.  In the case of a report in which a records search was done 190 days ago and report was signed yesterday, according to the Standard the report technically remains valid for another 179 days.

    Personally I think this is a flaw in the current language of the Standard, but that's what it says.  I think language should be added relative to the "shelf life" of information collected during the Phase I process but prior to the report's being finalized.  But as it stands, there is no such language in the Standard.

    Off-topic, but I also think it's hilarious that many clients expect a Phase I "update" to be done for essentially nothing.  The "update" requires new interviews, a new database search, and new site reconnaissance.  Aside from getting historical records and actual writing of the report (which assuming conditions haven't materially changed should be minimal effort), the EP essentially has to re-do the entire assessment.

  • WG

    Globally, a draft, draft final and final report should each be titled so and reflect the date of production/issue.   Draft reports are just that, draft reports which indicate an in-progress work product with possible outstanding information gaps, yet-to-be assessed findings and is protective of both parties.  Report dates should reflect the date on which each version of a report irregardless of status is issued.   A report titled "final" is the report that the provider is rep/warranting/providing reliance on - if applicable. 

  • JG

    The date of the report should be the date you sign the final report.  However, refer to section 4.6 of E1527 for an explanation of continued viability.  It's the date the information was collected that is critical.  If the record search was done 190 days ago, the site visit was done 170 days ago, and the report was signed yesterday the record search would need to be updated.

  • Tom Speight

    If I had wanted to impress, I'd have mentioned that I actually learned FORTRAN.

    Phase IIs are usually a snapshot in time; although there isn't a strict use-by date like there is for Phase Is and sour cream, since Phase IIs are more site-specific and deal directly with environmental media that may or may not change over time.  Depending on the source and nature of the contaminants-- e.g. if groundwater was clean in 1995 but an abutting gas station had a sudden release in 2009, soil and groundwater conditions might have changed in the interim.  For other problems like lead, PCBs or coal tar, conditions aren't likely to change unless the site is reconfigured, soil is removed, etc. The key issue is that older data will likely be useful, absent these sort of changes, but if vapor intrusion or something is a worry now that wasn't a matter of concern when the prior report was done-- maybe soil and GW were OK at the time but soil gas/indoor air weren't part of the prevailing standard of practice at the time so those media weren't sampled.

    It also depends to some extent on what the Phase II is being used for-- if it included assessment of a UST ten years ago that's still in place and in use, and the issue is a property transaction, the buyer or lender might say that they want to know what current conditions are.

  • MaxEng

    Ignore these kings of snark, Mr. Hilbert.  The answer is that there's no single answer to your question.  Depends on a lot of factors, including the nature of contamination, whether there's been site work (excavation, fill, etc.) on the property, etc.

    Mr. Speight thinks he's impressing us by his reference to Lotus Notes, but I'll have everyone know I've written environmental reports on the Wang word processing system.  Eight-inch proprietary floppy disks and an operating system that no longer exists.  I understand that there are services such as www.retrofloppy.com who will recover those files for a substantial fee.