There are too many questions to be answered to form an opinion based on your broad summary. You'll have to decide based on the file review if it's likely that a release from these off-site properties has reached your Site. Look at it as a whole - does the 1991 investigation shed light on impacts from the 1987 release?
You can use E2600 to evaluate the likelihood of a Vapor Encroachment Condition from the downgradient gas station.
De Minimus condition if identified and dealt within a soils excavation management plan which would be part of redevelopment or refurb of the site.
Sounds reasonable to me.
We wont issue reliance letters on any project that is more than 6 months old without updating it. The line referenced by JG is actually in every reliance letter we write. In fact, SBA adopted that from our language through extensive negotiations we had with them when they first started requiring the current version of their letter. Yes the open you up to greater exposure, but practically speaking, I've not heard of anyone suffering damages from the issuance of the letter. Our proposal actually contains language about issuing reliance letters 9a) in general (b) to the SBA, and (c) within the 6 month limit. The SBA letter is the most onerous I've seen, and I would definitely charge for it.
Five more very important items to study re: happiness in your workplace:
1) According to some studies our happiness level depend 50% on our genetics, 10% on circumstances and 40% on our intentional activities. That's right, each of us is born with a pre-disposition to a certain level of happiness ... pick people wisely.
2) Dopamine, Endorphin, Oxytocin, Serotonin, the chemistry of happiness - your happy chemicals. You can enjoy more happy chemicals if you know what turns them on. Try the book "Meet Your Happy Chemicals" for starters.
3) Some say earning more money will increase your emotional well being only up to a point. Huffington Post provides a state-by-state look at what household income level Americans reach a happiness plateau, check it out here
4) The Stanford Marshmallow Experiment, search it, study it - 40 years of Stanford research found that people with this one quality are more likely to succeed .... ability to delay gratification, or self-discipline ... trumps IQ.
5) Rounders, a 1998 American film about the underground world of high-stakes poker starring Matt Damon and Edward Norton ... "Listen, here's the thing. If you can't spot the sucker in your first half hour at the table, then you are the sucker. Guys around here'll tell ya... you play for a living. It's like any other job. You don't gamble. You grind it out. Your goal is to win one big bet an hour, that's it. Get your money in when you have the best of it, and protect it when you don't. Don't give anything away. That's how I've paid my way through half of law school. A true grinder. See, I learned how to win a little at a time. But finally, I've learned this... If you're too careful, your whole life can become a fckn' grind."
For this particular Client, we charged $100. But he's had a history of not paying so for the Phase I we required payment up front also.
I don't but I'm on the fence about it.
Did you charge for it?
Typically I agree with you on the AST in an basement on concrete. The key factors that concern me are the construction, obstruction and volume. There are two smaller AST (150 gal), which are elsewhere that are not RECs, I am just concerned about the construction of the big one. Thanks for the input.
I'm not a fan of that either. Although I have used that as an opportunity to explain why I decided a potential REC is not actually a REC.
I really don't like the requirement to explain de minimis conditions. De minimis is by definition the things you typically ignore. It's one thing to say the small oil stains on the garage floor are de minimis but it's not realistic to describe every de minimis condition and that door shouldn't be opened. I'm not going to describe every stain in the parking lot, every bottle of nail polish found in the grass, etc. Of course it would be ridiculous to even attempt reading into the requirement this closely but that's how it's written.
Without seeing the tank, it's obviously hard to say with certainty, but an AST in a basement with concrete flooring is not something from which I'd necessarily believe a release to have been "likely." I couldn't criticize a contrary finding, though.
Again, if the EP has not elected to subdivide RECs into CRECs and otherwise, then the Findings will only mention RECs without further discussion of whether they've been "controlled."
I don't like the weasel-wording in 12.5 relative to "known or suspect" RECs. Either you've found a REC or you haven't. It's inappropriate to talk about "suspect RECs" in my opinion.
If the building was in rough shape and falling apart then I might consider it "imminent". Otherwise, no. If the building is demo'd properly and the waste is handled correctly than there would be no REC.