Reeducating the client 2.0 … thanks for the update Tom. It will get even funner when November 30 rolls around and we have to go through reeducation 3.0 with the VI pathway.
Everyone has already covered the basics of chlorinated VOCs above. In my mind, a dry cleaner is always a REC. Even the new ones that have epoxy floors and secondary containment, potentially have irresponsible people working for them. The natural attenuation parameters of Cl-VOCs changes from parent to daughter products, and PCE & TCE degrade better in anoxic conditions, which your less likely to encounter in the vadose zone and surficial aquifer. Therefore, these DNAPLs sink, even through clays, before degrading … if they degrade (got to have the right bugs). As outlined in the examples above, Cl-VOCs hang around for a long time.
This is will create an explosion in listable sites, but the bigger issue is the huge error of "real" sites in comparison to "perceived" sites. The new TCE risk numbers and proposed PCE risk numbers will make VI a monster to deal with for some sites, when it would have been simple before. Since this can effectively reopen formerly closed sites, many of our clients will be getting a rude slap on the money pocket.
We found a simple design was better than an intricate one. We moved from a full eagle to a silhouette of an eagle. It turned out to be more elegant. Your new logo is nice and simple.
To address your questions directly:
Is it de minimis as regulators are aware and have not taken any actions?
No, it is not a de minimis condition as it is extensive and potentially an enforcement issue. Though they have not taken action does not mean they won’t in the future. Follow this link for additional discussions on de minimis conditions.
Is it an historic REC as its been addressed to the satisfaction of the regulators?
Do you have documentation of it previously being called out as a REC? Was it cleaned up? Did natural attenuation take the concentrations below criteria levels? It does not fit as a HREC. HREC discussion.
Is there a discussion in diminution suggesting the commercial values have already worked this into the value?
That would be a question for your client. The User questionnaire asked about the purchase price as an indicator if there may be an environmental issue causing the reduction of the price. It is not to say, an environmental issue will reduce the price.
I would identify the issue in general in each section it arises and hold off on the big discussion until the Finding section where you can pull all the different sections you identified the issue into one conversation. As long as you have municipal water service, and, as far as you understand, your client will not be disturbing the GW, then I do not think it would be a REC. In some states you can just call it off as an off-site condition that does not present a human health concern.
No, the Clean Air Act is included by reference. See the definition of a hazardous substance, ASTM-05 3.2.36. It is also supported by ASTM-05 Appendix subsection X188.8.131.52. For a REC all you need is to suspect the release.
Touche. Conceded. I was thinking more in the lines of treating it like an ACM. I believe we'll find some professionals on the side that say a release must be to the ground/floor, other may take the more liberal approach and state a release is a release; soil, water, or air it does not matter. As Max said, it depends on the concentration of the vapor release.
Interesting. Can you post a link to this report? Since your talking about mercury vapor, it is not a REC. Depending on the concentration you may have health and safety issues, which are out of scope for a Phase I, unless you included Hg as part of your "other services." If you suspect Hg leaching ... then yes it is a REC. Given it's part of a polymer floor ... I wouldn't jump to any conclusions though. If it is a regional issue, find out as much as you can, it'll set you apart if everyone else has missed it. The other side of the blade is you'll be wasting your time if this is old news and all the gym floors were torn up years ago ... Good luck, keep us in the know.
Thanks for the comment Danzw. I will agree this discussion does not change any major outlook. I agree, however you use "dispose of," as long as your audience understands, you have met your objective.
This post in not about if you can convey your point, but looking into the mechanics of a specific phrase commonly used in our field. Though our clients may not care, as a reviewer I try to improve my own English skill, and those I review. As I said in the original post "I am not an English professional ... refute my examples ... just post a reference ..." Though grammar can be "obscure" at times, there are defined rules for many parts of English sentence mechanics.
As for regulation language ... I understand your point and I concede it is legally defensible. However, I would not base my professional style on wording presented in regulations ... just my view.
As for passive vs. active, I will agree and disagree (as much as the oxymoronic statement will allow). Historically most technical writing was passive in nature. However, recently you will find more professionals writing in the active tense (still in the minority in general, but the percentage is growing). Active tense brings confidence to your report. It is a subtle approach at confirming to your client that you know what your talking about, instead of sounding wishy-washy. It is only a subtle technique that can not counter gross error. A passive report presenting all data accurately will always be better than an active report with errors (obviously). It comes into play when two accurate reports stand side by side. Who would your client go with? The one that presents data confidently or the one that sounds a little wishy-washy (we're assuming you and the other guy have equal relations with the client of course).
Thank you for sharing your perspective Danzw.
Normally I dissuade anyone from using definitives [believe it or not : )], but I was emphasizing the definition of prepositional verb phrases.
SamWebb, a "data failure" is when something is wrong with your data. The aerial is blurry to the point it is useless, the municipal address file was pulled by the city for review and was not available at the time of your visit, and issues of that nature. They do not always mean a "data gap." If you have other historical data that covers the interval (sufficient for any questionable issues), then your historical review is still sufficient. You can have a "data failure" without a "data gap." That was the quick and the dirty. Do a search for "data gap" and "data failure" on the CG website. I know we have had a few discussions (at the least) on this issue.
By definition of a prepositional verb the direct object MUST come after the verb. See link to Richard Nordquist explanation of prepositional verbs below.
I'll clarify my statement, for a prepositional phrase the object MUST come directly after the preposition; however, as I indicated in answer 4 a preposition can begin a sentence, and yes, it can end a sentence also. I do not believe this is the best practice in technical writing though. I would have ended your example "... underneath it," with "it" as the object referring back to "the slab."
In accordance with "The Elements of Technical Writing" by Gary Blake and Robert W. Bly, technical reports include (but are not limited to) periodic reports, progress reports, research reports, field reports, recommendation reports, and feasibility reports. Based on the descriptions of each, most of us on CG write progress reports, field reports, recommendation reports, and feasibility reports.
Most reports are bland and boring. Hard-to-read comes across in your capabilities as a writer and your ability to organize and explain data, and sumarize it consicely. It is not determined by your report style.
I do agree with you in the end though, "our job is to communicate effectively to our clients and other project stakeholders, and that's the rule I try to follow above all else."
I contacted Richard Nordquist, Ph.D. for a response on "dispose of," see below.
Hi Scott. Do you mind if I fuel the discussion rather than attempt to resolve it?
I'd encourage folks to check out the difference between a phrasal verb (http://grammar.about.com/od/pq/g/phrasalverbterm.htm) and a prepositional verb (http://grammar.about.com/od/pq/g/prepverb.htm). They look alike but function a bit differently. At the end of the entry for phrasal verb, note the distinction drawn by R.L. Trask. Also, keep in mind that "on" may function either as a particle or a preposition: that is, you'll find "on" attached to both phrasal verbs and prepositional verbs.
Here's my selfish motive. If it turns out that a couple of savvy engineers can't reach an agreement after reading the two glossary items, I'll know that my pages need to be clarified if students are ever to make any sense out of them.
Richards home page at About.com com is below:
I want to get back to your responses soon, I'm just slammed at work right now. But really quickly, by definition any time you use a preposition the direct object MUST come after it, that is why it is a prepositional phrase. As to the location of the direct object for a prepositional verb phrase, I believe it follows the same rule.
As for your previous examples ... I would not use any of them in technical writing. They are applicable to creative writing. I would not argue their use in that style. I also do creative writing on the side and do not follow the same stringent guidelines as I do in my technical writing. Some of my blogs (e.g. this one) are posted to clear up the blurry line between creative writing and technical writing.
I want to look into your other commentary further, I just need to find time. If that was your final comment, then I have enjoyed our discourse and hope you comment more at a later date. You have prompted me to look into the matter further.
I've looked up compound verbs, and phrasal verbs (again), to find any reference to the grammar mechanics you mentioned. I can not seemto find any ... currently ... I will keep looking. Unfortunately, "my wife" is not a reference that has convincing weight behind it. Can you give an on-line citation or link to a website reflecting your claim. I will concede the point of my blog IF your claim can be documented.