Comments
To build on the previous post: The half-life of any released hazardous substance is based on many variables. Is it in the soil or the groundwater, what type of soil, is it oxygen rich or not, etc. Not to mention you wouldn't know the contaminant mass that was released. It makes a big difference if it was a small release or if they were releasing large amounts of PCE continuously for 40 years.
Also, PCE is fairly resistent to degradation/biodegradation and thus has a relatively long half-life in groundwater. Especially compared to substances like gasoline. I've found gasoline related contaminants above cleanup criteria 30 to 40 years after last use. I'm sure others have found it after even longer in the right conditions.
To answer the original question, I don't think it will happen any time soon. Even if you get to the point where PCE was last used 100 yers ago, there are to many variables (such as contaminant mass) to be able to say it wouldn't be a problem. I don't think I would conclude that a gas station wouldn't be a problem either after 100 years. To many variables.
Does anyone out there feel comfortable making a decision regarding ANY historical use of the property based on age? I've seen in done in a report for a gas station before. But that report also said that they didn't know exactly where the gas station would have been (address change, but highly likely it was on site), so it wasn't a problem.
A gas UST may be present as well. Back when Michigan updated their UST code in 1999, I was involved with removal and sampling at several fire stations. Almost all of them had gasoline USTs as well. I think the police were using the fire stations to fill up and not all of the vehicles used by the fire department are diesels.
I agree with the rest of the posters. These circumstances where you have no direct evidence but a strong suspicion are very difficult to explain to your client. At the very least, do what Scott did for his report and discuss the situation with the client.
Many government officials won't respond unless its an official FOIA request in writing (fax, mail, email). I think the standard practice in my area is to use whatever means work. Many consultants use written requests. Good luck stopping by in person and getting a good response. Maybe if you bring flowers, candy, beer, whatever. Most of the government officials are swamped by FOIA requests and aren't likely to be happy to stop what they are doing to handle your request in person or over the phone. However, they respond very well to a nice email requesting the information.
As far as owner/occupants interviews, whatever method gets a response. Usually, I try to sit down with them during the site inspection and go through all the appropriate questions. It would be great to send them the questions and get a response before the site walk, but people are busy and put that sort of thing off. If they aren't at the site walk, then I usually have to pester them by phone or email.
So it might not technically be compling with the ASTM standard. I put some language in the report about varying from the standard because government officials typically require written requests blah blah blah.
I'm not sure that "Phase" is saying that it shouldn't be a REC. I think he is saying that an off-site condition is not a REC unless it is a material threat to migrate onto the site. He is saying that the migration of contaminants is the REC not the condition on the other site. Kind of nitpicky but technically correct.
For example, a LUST release at a adjoining site is not a REC. The REC is the likely migration of contaminated groundwater from the LUST release onto your site.
Other than that, I agree with Larry's posts that offsite plumes that may affect your site are RECs. Again, I may be wrong, but I don't think that is what "Phase" was saying.
Good point, Matt, but we are talking averages here so some newer buildings might not require any asbestos or lead surveys. So $0 for some sites, $1,000 to $1,400 or more for others.
Also, it depends on the level of the survey. I could see an asbestos and lead survey in this range if its simple. Limited testing etc. Asbestos/LBP costs are widely variable depending on the scope. Are we talking visual survey only, limited testing, or a demo level survey?
On another note, lets look big picture:
6,000 sites at $5,000 = $30 million
6,000 sites at $10,000 = $60 million
How accurate do you have to be? Is it better to be really conservative? Add a 50% buffer to the $10,000/site and round up to $100 million.
Where do I sign up for that project? :-)
Take a look at the 2009 Survey data:
http://commonground.edrnet.com/files/a3c8e4c518/Pricing_2009EDDBPSummary.pdf
Looking at the the first chart on page 3, the average Phase I cost is $2540. The Phase I Plus which includes non-scope issues (such as asbestos and lead) is $3,205. If you wanted to be more conservative, you could estimate the 90% percentile from the graphs. I'd say about $5,000 to $5,500 for the Phase I Plus.
Since its a large government agency (likely with holdings all over the country), you'd probably use a larger company. Look at the 2nd graph on Page 3. The larger companies average $4,096 for a Phase I Plus, which is about a 28% premium. Multiply the range from the 90th percentile from the previous paragraph by the premium and you get a range of $6,400 to $7,000.
You could even correct for region using other graphs in the study. However, I bet your sites are all over.
Hope this helps. It's somewhat scientific and defensible. I'm not aware of any more reliable data but perhaps another community member is.
I ran across an interesting article on Gizmodo about Tributyl tin. If anyone ever thinks that Tributyl tin isn't a big deal, show them the article.
Like Matt said, you might want to provide some more information.
Where are these sites located? Price ranges vary greatly by location.
What type of sites are these? Any industrial sites? Any large acreages?
When were the buildings built? If many of them are newer, your lead/asbestos costs could drop significantly.
For example, a Phase I ESA on a smaller, non-industrial site in Michigan would be under $2,000 from almost all consultants and many would do it for $1,500. If its a large industrial site in California, I imagine you could be pushing $5,000 or more for the Phase I.
What evidence does the current property owner present to back his case? Many property owners do not want to admit that their property could be contaminated. I would value the Sanborn map over the property owner's desire that his property wasn't a gas station.
Like jessedphillips, I've never encountered something wrong like that on a Sanborn map and have seen grocery stores selling gasoline in that time period. I'm also not surprised that the DEQ and assessor's office do not have any record of a gas station since it was there in 1948. Same thing with the database search. That just means its not a known site because no one has discovered a release there, or looked for it.
In my opinion, you have a preponderence of evidence that the site was a filling station. If it was my site, I'd need to see a lot of evidence to prove that the Sanborn map was wrong.
Also, I agree with jessedphillips about checking the city directories (if available) to see if they list a filling station or grocery store.
One of the most difficult tasks of a consulting is telling a client or property owner something that they don't want to hear and don't want to believe. Stick with what you know and can prove. You'll be sorry if you cave into the pressure and someone else finds USTs and contamination a few years later.
From my understanding of the previous posts on this topic, a large firm subcontracts out the Phase I work while providing the database report, aerials, sanborns, etc. So their client is probably paying at least $1200 for the Phase I. $700 for the subcontractor work, around $300 for the database report and historicals, and say 20% markup for profit.
While $1200 is still extremely low, I think its a bit sensationalistic to say that $700 Phase Is are being offered.
I think Mr. Schultz's position is valid. It doesn't matter if its purely supply and demand or the result of the driving forces that Mr. Welge describes. We have to deal with the cards we're dealt since they aren't likely to change anytime soon.
That leaves us with competing in the current market place, finding clients that value us, or finding another line of work.