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  • Ryan Defilippi
    Dipping Vats2
    Topic last edited March 23, 2015 by Ryan DefilippiMember in Discussions > Environmental Due Diligence public
    Title:
    Dipping Vats
    Content:

    During a recent Phase I ESA I was performing on an 11,400 acre ranch in rural Nevada, I stumbled upon a livestock dipping vat. I had no idea what the buried concrete feature was until the ranch hand who was accompanying me, noted that it appeared to be a old dipping vat. I had never encountered a feature like this before and based on some research and poking around the internet I was able to confirm that this was indeed a dipping vat that appeared to be from the early to mid 20th century. My ignorance to not knowing what the structure was stems from the lack of dipping vats that were/are used in the western states, specifically Nevada.

    So what is a dipping vat and why should it draw an immediate red flag? I have summarized some of my research below.

    Dipping vats have been used on ranches and farms since the late 1800s. These vats or “plunge tanks” are utilized by ranchers to eradicate diseases and parasites on livestock. These vats became popular in the United States following the spread of the diseases known as Babesia (Texas tick fever) and scabies (common in Nevada). Dipping vats allow ranchers to completely immerse livestock in a liquid that contained a parasiticide and/or chemical solution formulated to treat infected animals. Historically, these chemical solutions contained arsenic, sulfur, toxaphene, organochlorines, organophosphates, and/or synthetic pyrethroids, all of which are known to potentially cause negative impacts to human health and the environment. These vats are known to have caused contamination to soil and groundwater on properties that have utilized some of the above listed chemicals. Contamination to the environment often occurs when the dipping solution is disposed of incorrectly or when the vats leak solution. Although dipping vats are seldom used today they are still the preferred method of tick eradication in certain parts of the United States. However, the  chemicals and parasiticides used today are safer to human health and the environment.

    Upon further review of the ASTM E2274-08 (Standard Practice for Phase I ESA for forestland and rural properties), Section 8.3.4.3 suggests reviewing Livestock Dipping Vat Records. I found out that these records do not exist in the state of Nevada, nor do they exist in a majority of the US States. Based on my research, records such as these are found primarily in Florida and some of the southern states. 

    We came to the conclusion that we would perform a Limited Phase II ESA to test the soil around the vat. Four soil samples were collected from different locations and depths located proximal to the structure. The vat ended up being about nine feet below the ground surface, which was about 2 feet deeper than we anticipated. The soil samples were tested for TCLP metals, organochlorine pesticides/insecticides, and organophosphate pesticides/insecticides. The results of the soil sampling revealed concentrations of dichlorodiphenyldichloroethane (DDD), dichlorodiphenyldichloroethylene (DDE), dichlorodiphenyltrichloroethane (DDT), β-hexachlorocyclohexane (b-BHC), toxaphene, and lindane. 

    We have not come to a conclusion on what the next step is, but I will be sure to post about it. Any recommendations? And has anyone encountered similar dipping vats on the west coast? 

     

    Image:
  • Z. Heine
    Large AST in Basement3
    Topic posted March 24, 2015 by Z. HeineMember in Discussions > Business Issues public
    Title:
    Large AST in Basement
    Content:

    We ran across a rather large (~5,300 gallons) AST in the basement of a commercial structure, which was former drycleaner.  Of course the owner claims that in the 70+year history no chemicals, only steam.  Besides the point though.  The AST is clearly a post construction addition to the building, based on location and construction materials and information provided by owner.  It is square, in the corner of the basement and surrounding with concrete block on all sides.  Only the top is visible.  I would include a pic, but the photo does it no justice.  There was a large commercial boiler onsite and the owner stated this was installed to supply fuel oil.  My concern is that the AST may be "homebuilt" and is definitely field constructed.  I am proceeding and calling this a REC, just another to the batch for the site, but wanted to get other opinions.  My opinion is that due to the size, date of construction (pre-1970), high % that it was "home-built" and building materials used to conceal the sides, there is a release is highly likely and would be significant.  Thoughts?

  • Mike M
    Opinions, please: Distinguising a CREC from an HREC.245.0
    Topic last edited January 28, 2015 by Mike MSuper Contributor in Discussions > Environmental Due Diligence public
    Title:
    Opinions, please: Distinguising a CREC from an HREC.
    Content:

    Hey fellow assessors, please chime in with your opinions on this issue.

    In my opinion, there is somewhat of an ambiguity in the wording of ASTM regarding CRECs and HRECs. Basically, I feel that the ASTM committee has ignored the fact that regulators do not base the wording of their case closure letters on ASTM language.

    Per the ASTM standard, an HREC means that a site has been cleaned up to a level that meets “unrestricted use.” Per the standard, the contamination "...has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted use criteria established by a regulatory authority, without subjecting the property to any required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls)."

    For the definition of CRECs, the standard  states the the contamination is "... allowed to remain in place subject to the implementation of required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls)."

    To further obfuscate the issue, the standard states: "Before calling the past release a historical recognized environmental condition, the environmental professional must determine whether the past release is a recognized environmental condition at the time the Phase I Environmental Site Assessment is conducted (for example, if there has been a change in the regulatory criteria)."

    Now, here are two scenarios for you all to consider:

    Scenario 1:

    Let's say you have a gas station site, and very high levels of soil and groundwater contamination are present. However, the agency has determined that since local groundwater is non-beneficial, no further action was required, and they issued a case closure letter. Let's say that the closure letter wording is somewhat vague, along the lines of "Based on the submitted information, no further action is required."

    So, this site does not have any stated land use restrictions or other required "controls." Therefore, one could argue that this is an HREC.

    However,  I would bet that the property would have a very hard time being redeveloped with, for example, a public school  without doing all sorts of additional investigation and likely remediation or other controls. 

    To me, that does not meet the definition of “unrestricted” land use. Just because an agency closure letter doesn’t explicitly state that there are land use restrictions doesn’t mean that they don’t exist based on other factors.

    For this scenario, lets assume that there have been no changes in regulatory standards since the closure was issued, so this would not be considered an REC.

    Scenario 2:

     

    Here's another scenario: 

     

    Let's say you have a site where NFA case closure was granted with significant contamination left in place, and it's your opinion that the agency that issued the case closure was simply incorrect in it's opinion (ex: significant PCE concentrations left in place, but no vapor intrusion assessment was conducted, or sampling protocol was inadequate.)

    Please provide your opinions of what you assess  these sites as: REC, HREC, or CREC, based on the scenario information. Please provide a rational for your opinions.

    Thanks!

    Mike

     

     

  • Camie
    Single Family Home from 1939 Fire6
    Topic posted December 9, 2014 by CamieMember in Discussions > Environmental Due Diligence public
    Title:
    Single Family Home from 1939 Fire
    Content:

    I am working on a Phase I ESA where there was a single family home, constructed in 1939. So likelihood of asbestos.  A fire occurred in 2010 - the house was unoccupied and vacant at the time.  It was ruled arson by the Fire Marshal.  To my knowledge, only water was used to control the spread, no foam.  Is the asbestos a concern in what's left of the structure on the site?

  • Nova Consulting HR
    Property Condition Assesor / Environmental Site Assessor
    Job Opportunity posted March 24, 2015 by Nova Consulting HRMember in Environmental Jobs Board public
    Job Title:
    Property Condition Assesor / Environmental Site Assessor
    Company Name:
    Nova Consulting Group, Inc.
    Company Address:
    Corporate Headquarters:
    1107 Hazeltine Blvd. Suite 400
    Chaska, MN 55318
    Google map
    Employment Status:
    Full-time
    Start Date:
    04/01/2015
    Employer Contact:
    Human Resources
    Contact Email:
    Job Description:

    Architecture/Engineering Applicants:

    Primary responsibilities will be to perform Property Condition Assessments (PCAs) as well as Project Capital Needs Assessments (PCNAs) in accordance with ASTM standards and local, state, and federal regulations. Project Managers complete all aspects of assessment including all field work, data compilation and report preparation for each project, depending on the scope of work and client needs. Secondary responsibilities to include Construction Loan Monitoring (CLM) services, incorporating up-front construction document reviews and monthly pay application request inspection/reporting. Project Manager may also review PCA inspection reports.

    Environmental Applicants:

    Primary responsibilities will be to perform Environmental Site Assessments (ESAs) in accordance with ASTM Phase I standards and local, state, and federal regulations; as well as, evaluate and recommend cleanup options and risk assessment analysis and costs.

    Required Experience:

    Architecture/Engineering Applicants:

    5+ years’ experience conducting  and/or managing PCAs, PCNAs, and/or engineering and architectural consulting services

     

    Environmental Applicants:

    5+ years of experience completing and/or managing ESAs

    Required Skills:

    Architecture/Engineering Applicants:

    • College degree in architecture, engineering, or construction-related field
    • Knowledge of building components, systems and cost estimating
    • Ability to manage multiple projects and meet deadlines
    • Strong technical writing skills and attention to detail
    • Proficiency in Microsoft Word, Excel, and Outlook
    • Current, valid state driver’s license (position requires a motor vehicle record background check)
    • Annual medical monitoring required
    • Field work will require travel up to 50% primarily throughout your region as well as occasional trips throughout the US to support national needs
    • Current professional licensure/registration preferred
    • Experience conducting Freddie Mac, Fannie Mae, HUD, and other specialty project scopes preferred
    • Physical Demands: Ability to physically navigate site properties in various weather conditions and the ability to climb a ladder and gain access to roofs

     

    Environmental Applicants:

    • Bachelor’s degree in engineering, geology, environmental science, or related discipline
    • Familiarity with ASTM E1527-13
    • Ability to manage multiple projects and meet deadlines
    • Strong technical writing skills and attention to detail
    • Proficiency in Microsoft Word, Excel, and Outlook
    • Current, valid state driver’s license (position requires a motor vehicle record background check)
    • Annual medical monitoring required
    • Field work will require travel up to 50% primarily throughout your region as well as occasional trips throughout the US to support national needs
    • Candidates with EP designation preferred
    • Experience conducting Freddie Mac, Fannie Mae, HUD, and other specialty project scopes preferred
    • Physical Demands: Ability to physically navigate site properties in various weather conditions and the ability to climb a ladder
    Local Candidates:
    no preference
  • Nova Consulting HR
    Property Condition Assesor / Environmental Site Assessor
    Job Opportunity last edited March 24, 2015 by Nova Consulting HRMember in Environmental Jobs Board public
    Job Title:
    Property Condition Assesor / Environmental Site Assessor
    Company Name:
    Nova Consulting Group, Inc.
    Company Address:
    Corporate Headquarters:
    1107 Hazeltine Blvd. Suite 400
    Chaska, MN 55318
    Google map
    Employment Status:
    Full-time
    Start Date:
    TBD
    Project Duration:
    Full Time Employment
    Employer Contact:
    Human Resources
    Contact Email:
    Job Description:

    Architecture/Engineering Applicants:

    Primary responsibilities will be to perform Property Condition Assessments (PCAs) as well as Project Capital Needs Assessments (PCNAs) in accordance with ASTM standards and local, state, and federal regulations. Project Managers complete all aspects of assessment including all field work, data compilation and report preparation for each project, depending on the scope of work and client needs. Secondary responsibilities to include Construction Loan Monitoring (CLM) services, incorporating up-front construction document reviews and monthly pay application request inspection/reporting. Project Manager may also review PCA inspection reports.

    Environmental Applicants:

    Primary responsibilities will be to perform Environmental Site Assessments (ESAs) in accordance with ASTM Phase I standards and local, state, and federal regulations; as well as, evaluate and recommend cleanup options and risk assessment analysis and costs.

     

    Required Experience:
    Required Experience:

    Architecture/Engineering Applicants:

    5+ years’ experience conducting  and/or managing PCAs, PCNAs, and/or engineering and architectural consulting services

     

    Environmental Applicants:

    5+ years of experience completing and/or managing ESAs

    Required Skills:

    Architecture/Engineering Applicants:

    • College degree in architecture, engineering, or construction-related field
    • Knowledge of building components, systems and cost estimating
    • Ability to manage multiple projects and meet deadlines
    • Strong technical writing skills and attention to detail
    • Proficiency in Microsoft Word, Excel, and Outlook
    • Current, valid state driver’s license (position requires a motor vehicle record background check)
    • Annual medical monitoring required
    • Field work will require travel up to 50% primarily throughout your region as well as occasional trips throughout the US to support national needs
    • Current professional licensure/registration preferred
    • Experience conducting Freddie Mac, Fannie Mae, HUD, and other specialty project scopes preferred
    • Physical Demands: Ability to physically navigate site properties in various weather conditions and the ability to climb a ladder and gain access to roofs

     

    Environmental Applicants:

    • Bachelor’s degree in engineering, geology, environmental science, or related discipline
    • Familiarity with ASTM E1527-13
    • Ability to manage multiple projects and meet deadlines
    • Strong technical writing skills and attention to detail
    • Proficiency in Microsoft Word, Excel, and Outlook
    • Current, valid state driver’s license (position requires a motor vehicle record background check)
    • Annual medical monitoring required
    • Field work will require travel up to 50% primarily throughout your region as well as occasional trips throughout the US to support national needs
    • Candidates with EP designation preferred
    • Experience conducting Freddie Mac, Fannie Mae, HUD, and other specialty project scopes preferred
    • Physical Demands: Ability to physically navigate site properties in various weather conditions and the ability to climb a ladder
    Local Candidates:
    no preference
  • Melanie
    REC, HREC, CREC4
    Topic posted March 20, 2015 by MelanieMember in Discussions > Environmental Due Diligence public
    Title:
    REC, HREC, CREC
    Content:

    There is a debate internally if a REC is limited to the property or if an adjacent property can be considered a REC.  Also, If a site has been remediated is it considered a CREC or HREC.

  • MargaretThibo
    Alaskan Pipeline Leak Still Unknown
    Entry posted March 21, 2015 by MargaretThiboContributor in Current Environmental Issues > Current Environmental Issues Blog public
    Title:
    Alaskan Pipeline Leak Still Unknown
    Entry:

    A recent oil spill in the Alaska has Hilcorp, the company that owns the pipeline, scratching its head as to what happened. The pipe that sprung the leak is a section of the North Slope pipeline has had no nearby field activity disturbing it. In fact the pipe had been inspected the night before. No individuals or equipment had any contact with the pipe, so the cause is truly still mystery.

    Cleanup crews have had to halt their efforts due to extreme blizzard conditions in the area of Alaskan tundra. Before ceasing cleanup efforts crews took the appropriate measures to preserve the spill site. One method included spraying the area down with water to create an icecap over the site. Before the cleanup was stalled 4,000 gallons of spilled fluids were vacuumed up. Upon initial site assessments, crews believe that 38,800 square feet have been contaminated, with the majority of the oil pooling below the damaged pipe. Some fluid was blown further by strong wind gusts.

    Hilcorp, a Houston based oil company is relatively new to the North Slope area where the pipeline is located. With that said they are being commended for their quick response to the spill. The company quickly sealed off the 15 foot section of the pipe affected using valves. They then plugged the hole with a wooden stopper and wrapped the pipe, preventing any continued leaking. By the following day they had installed an alternative pipeline so that production could continue as usual. If the pipe was lift untreated an ice plug can result and damage the pipeline even more.

    Once blizzard conditions have cleared federal regulators are expect to inspect the leak site and better determine the scope of the damage done. The broken pipe will then be removed from the site and carefully studied so that a cause for the leak can be determined.

     

    Keywords:
    site assessments
  • MargaretThibo
    The Tables are Turned on the EPA over Insecticide
    Entry posted March 21, 2015 by MargaretThiboContributor in Current Environmental Issues > Current Environmental Issues Blog public
    Title:
    The Tables are Turned on the EPA over Insecticide
    Entry:

    Several environmental groups have filed suit against the Environmental Protection Agency (EPA) after the federal agency officially legalized the use of an insecticide known as flupyradifurone. The environmental groups, including the Center of Biological Diversity, the Center for Food Safety, and the Defenders of Wildlife argue that the EPA is violating the Endangered Species Act by allowing the insecticides to be used.

    The EPA approved the use of flupyradifurone as a replacement to another insecticide known as neonicitoids, which had been ravaging North American bee populations in recent years. The reason that flupyradifurones are a good replacement for neonicitoids is that they function in the same manner. Unlike most pesticides which merely coat the plants surface, flupyradifurones enter all of the plant’s tissues. This makes it much more successful in killing crop pests. Flupyradifurone has proven to be completely nontoxic to bee colonies while successfully protecting crops from pests like aphids, thrips, and whiteflies. The insecticide is diverse in the variety of crops it protects, including citrus groves, cotton fields, and potato patches.

    The environmental groups suing the EPA do not feel that flupyradifurone is the ideal replacement, since it may unintentionally harm endangered species. All insect that feed on the treated crops as well as any species that rely on those insects for a food source could be affected. One example the groups provide is the Karner blue butterfly, an endangered species that could face extinction due to the insecticide’s use.

    The groups feel that they EPA did not perform its legal due diligence in consulting with the U.S, Fish and Wildlife Service or the National Marine Fisheries Service about the potential affect that flupyradifurone could have on the environmental safety of endangered species. They also feel that the while the insecticide may be non toxic to bee colonies, there are thousands of other solitary bee species that do not colonize that were left out of the research process.

    The EPA now has sixty days to respond to the complaint before going to court.

    Keywords:
    legal due diligence, environmental safety
  • Melanie
    ACM's4
    Topic posted March 19, 2015 by MelanieMember in Discussions > General public
    Title:
    ACM's
    Content:

    I have to identify ACM for a client in a Phase 1 ESA. Is asbestos considered a REC?