Comments

Comments

  • MaxEng

    "I have seen leaks cause big problems" is NOT the same as "likely contamination," which is the criterion for calling out a REC.  But I agree, a leak can indeed cause big problems.

    One of the challenges associated with Phase I ESAs is how to deal with conditions that are not "likely" to have caused contamination, but if contamination is present the problem could be very expensive.  IMO that's a good situation in which to call out a Business Environmental Risk (BER).

     

  • JG

    I'd treat this as any abandoned tank on an abutting property.  The REC/no REC call lies with the potential for migrating contamination.  The town owns the tank. 

  • PWoloszyn

    You need to come up with an effective strategy to protect yourself or you are going to be looking at doing a lot of phase II subsurface investigations at your facilities. MaxEng is pointing you in the right direction = strong written documentation provided to the environmental consultant during the site visit, be prepared, maybe cc the property owner, make sure the written documentation that you provide is included in the report, make the consultant work to explain in the report why with all this documentation that you have provided, there is any concern.

    If the report still concludes REC with phase II recommendation, dispute it in writing, point out the weaknesses in the consultants report, ask the consultant to provide examples where sites with similar strong documentation have been discovered to have significant subsurface contamination.

    Of course, any such strategy is likely to work only if it applies......

     

  • manno

    Yes, I should have used a different word in that sentence.........likely.  

    However, I totally disagree with you on not calling this a REC. Wells are often abandoned with no regulator anywhere nearby.  If you say nothing about this then you have to trust the crews that did this work followed all the correct procedures. On top of this, you have to hope there was never an earthquake or some other failure issue.  Not only that, but these wells tend to get "lost" over the years.  I do work for a company with a LOT of shopping centers, many of them over old oil fields. I have "found" them under parking lots and buildings where they were unmarked and obviously damaged.  I have had to do geophysical surveys to find them because they were 'lost'.  And soil gas surveys have shown elevated emissions, not just on the old wells. If someone is putting a building, especially something residential over a well......I would definitely call it a REC.   I personally would never disregarded such an installation. We probably live in different parts of the country. Wells have been a huge issue here and verrry low levels of emission are a concern.  I would agree with you on one thing.....if we lived in a perfect world....the wells as designed and or abandoned might not leak.

  • MaxEng

    Once again confusion about the definition of REC.  "Can emit?"  "Can leak?" Sure, but a REC is defined as "likely contamination," which in my experience is a criterion that most recently installed (1990s and later) gas wells do not meet. There's no way I could justify calling a gas well constructed in this timeframe a REC.

    Remember the definition of REC.  It's not "possible contamination," it's "likely contamination."  Very different things.

  • manno

    This topic seems to come back around every other year.  My experience on older dealerships has been somewhat different than those posted above.   I have seen these units leak and cause big problems.  Attached is a photo from a site I managed several years ago that had approx 16 lifts. Many of these lifts leaked and resulted in 30 foot excavations (and these soils were not sands).

  • manno

    If it were me, I would say REC.....yes.  You do not state whether the well is active or abandoned.  Either way, these installations can emit various types of hazardous gases.  If the well was abandoned, it must have been done correctly and approved, usually by the state.  Check with state agency.  In some cases, the well could require special expertise for current status evaluation. More could be said if anyone still interested. 

  • Here2Learn

    I do not believe Georgia has vapor regs yet, we usually default to federal.

    OK thanks AGAIN!!!

  • JG

    A VEC is not always a REC because a VEC is any vapors at all on the property, no matter how low the concentration.  But a VEC that could trigger regulatory enforcement is a REC.  It really depends on your state regs.

    Modeling it is too much for a Phase I.  You only need to estimate the likelihood based on the data you've got.

  • Here2Learn

    This is for a Phase I so we have no vapor data. In a file review, we found the highest reported benzene concentration in the cross-gradient plume to be 110 ug/L benzene. Are you saying in a Phase I we should plug this groundwater data into a model to see the vapor concentrations? 

    My understanding is that VECs are not RECs because they would not pose health threats to people, making them de minimis. 

  • JG

    It's just like groundwater or soil.  If you have groundwater contaminants above reportable drinking water limits (assuming they apply to the subject property) then it's a REC regardless of whether or not the groundwater is actually used for potable water.  Similarly, if vapor concentrations are too high to be considered de minimis then the VEC could be a REC even without a current VIC.

  • Here2Learn

    Please go on..... in what cases would a VEC be a REC without a VIC? I could see calling it a REC if a planned structure was going to be in the area of your VEC but how could a VEC alone constitute a REC in another case?

  • JG

    Beautiful!

    It's good that you explain that a VEC is not a VIC with the existing building.  Also verify that the VEC at the property line is a de minimis condition too, not just at the existing building.  You could have a situation where a VEC is a REC without a VIC.

  • Here2Learn

    OK I get it. For the project I'm working on now with the cross-gradient gas station... based off quarterly monitoring well reports and distances provided by Buonicore (no free product, petroleum, cross-gradient) I determined that a VEC was likely present on the subject property, however, since the facility is a a few more hundred feet from the property line, a VIC was unlikely. Then I conclude by stating a the VEC is not a REC, it is de minimis, because there would likely be no enforcement action taken if brought to the attention of appropriate governmental agencies. Makes sense I hope.

     

    Thanks again JG!

  • JG

    The Tiers make more sense if E2600 is used as a stand alone process.  In conjunction with a Phase I ESA the line becomes blurred.  If I have the data from a file review then I proceed to Tier 2.

    A Phase I in accordance with E1527-13 does include a vapor encroachment screen in the scope of work.  It doesn't have to be E2600 but you need some way to decide if the cross gradient gas station is a REC due to vapors.