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    jeffl777
    Would a school chemistry lab be considered a REC?
    Topic posted July 14, 2010 by jeffl777Member, last edited January 19, 2012
    627 Views, 8 Comments
    Title:
    Would a school chemistry lab be considered a REC?
    Content:

    A co-worker of mine is currently performing an ESA on a private school site that operated a chemistry lab.  Discharges from the sinks went to a POTW but there was typical chemical usage and storage in the lab.  The hazardous chemicals have been removed in the past 10 years and they are currently using more benign household type chemicals in their experiments.  Would the storage/usage of these chemicals in a chemistry lab setting be considered a REC?

    Comment

    • Ken
      posted July 14, 2010 by KenMember

      I always default to the definition of a REC.  

      The presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater, or surface water of the property. The term includes hazardous substances or petroleum products even under conditions in compliance with laws. The term is not intended to include de minimis conditions that generally do not present a material risk of harm to public health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies.

      Since the lab chemicals are gone (and presumably there is no concern they were dumped on the baseball diamond), you need to discern if there is evidence of a past discharge into the structures (concrete staining) or ground, goundwater or surface water.  Since you stated the sinks went to the POTW I would eliminate the discharge to groundwater via a septic, and frankly I would not suspect a school would have good avenues of discharge to the soils as i would imagine it is either slab on grade or has a basement.

      Bottom line is that I would not call it a REC.  

       

    • jessedphillips
      posted July 16, 2010 by jessedphillipsElite Contributor

      My company has conducted work at schools where the lab tables were contaminated with mercury.  I'm not sure of the specifics because I wasn't involved, but apparently, mercury and potentially other chemicals can migrate into the lab tables, cabinets, etc.  As in other discussions on here, I remember playing with mercury and it was certainly present in school chemistry labs. 

      I also wonder about fume hoods having residues on them.  Not refuting the above, but it could be a REC.

    • Brian Olin, PG
      posted July 22, 2010 by Brian Olin, PGContributor

      While there is potential for things in the lab to have some residual traces of chemicals and you might want to test if it is going to be continued to be used as a school or before disposal, I would include this in other concerns rather than a REC.  Therefore I woul dbe inclined to agree with Ken.  Also the quantities they were using might be considered deminimus if you have that information available.

    • Mark_GA
      posted July 25, 2010 by Mark_GAMember

      While I, like Ken, tend to return the definition of a REC, I may have a more conservative view of "past release".  I see the situation, as presented, as a very clear scenario of likely release to the structure (teachers, students, lab assistants over the years accumulating spills of one or more haz materials to the walls, floors and cabinetry).

      The former chemical storage area can clearly be termed a REC - now what will your client want to do in response?  If you deem the lab a REC, best be ready with some alternatives.

    • akoperczak
      posted July 28, 2010 by akoperczakMember

      This article may provide some insight on potential RECs in laboratories in school or industry

      Reducing Environmental Risk Associated with Laboratory Decommissioning and Property Transfer.doc (111KB)
    • bkea
      posted July 28, 2010 by bkeaMember

      I am the one conducting this Phase I.   The site is a private high school.  The lab is small, four stations with four students at each station.   The lab was gutted and renovated in 1996.  There are no fume hoods.  The lab was also recently gutted again for renovations.  They started phasing out the more hazardous chemicals many years ago and dnet them to local collgees for disposal.  They also previously reportedly used a local private hospital (no longer private) for disposal of waste.   Mostly they now use video instruction.  Only a couple of small containers of chemcials present in the storage area, with was two glass enclosed racks of shelves.    No odors were noted and no evidence of a release was observed.   The school is using the Phase I to fund (refi) the renovations (which are already well underway).      

    • Patrick Sutton
      posted July 28, 2010 by Patrick SuttonSuper Contributor

      If there is no evidence of a release and no potential pathways for the chemicals to get into the subsurface, than it's not an REC.

    • rickreyn
      posted September 2, 2010 by rickreynMember

      The school may be a listed site because of its lab, but I don't see a conduit to soil or groundwater, and I see a paper trail for disposal of the one 55-gallon haz waste drum once in a blue moon.