Blogs > R. Scott Powell's - Watch The Language

Historical Recognized Environmental Condition (15 Comments)

Fri, 17 Jul 2009 20:34:28 +0000

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OK, so here is my disclaimer: I was trained to consider the HREC definition to be irrelevant. So, why do I now write about it… I now have the flexibility to interpret for myself. Only recently have I been digging into the HREC for a better understanding. These observations below are based on years of experience reviewing other consultants’ reports. Though I did not use HRECs in my reports previously, I did note how other consultants used it and questioned my training.

In my observations over the years the HREC has been the red-headed step child of the Phase I language. Some consultants like it, use it, and abuse it. Others completely ignore it, as if it did not exist. Few really understand it. I have read reports where the consultant summarized everything under the historical section as a HREC. In the conclusions they had a list of RECs and HRECs, and recommended assessment of each list. I have reviewed reports were the HREC was used to identify RECs listed by the previous consultant, even if the issue was current (i.e. a REC). I have only read a couple of reports from consultants that appear to understand the intent of the HREC.

As defined by ASTM-05, subsection 3.2.39: “an environmental condition which in the past would have been considered a REC, but which may or may not be considered a REC currently. The final decision rests with the EP and will be influenced by the current impact of the HREC on the property. If a past release of any hazardous substance or petroleum products has occurred in connection with the property and has been remediate, with such remediation accepted by the responsible regulatory agency (for example, as evidence by the issuance of a no further action letter or equivalent), this condition shall be considered a HREC and included in the findings section of the P1 ESA report… (EP opinion statement)… If this HREC is determined to be a REC at the time the P1 ESA is conducted, the condition shall be identified as such and listed in the conclusions section of the report.”

What qualifies as a HREC?

Based on my interpretation, you can use HREC when identifying conditions that could have been or were identified as a REC in the past but have been cleaned up to regulatory standards, such as a “properly” closed LUST site (and wow is that “properly” adjective so important these days). I’m assuming an ideal situation with good documentation, not a report you scratch your head at trying figure out how they made 2+2=5. I think I would skip the confusion of HREC at that point and go straight to REC or “suspect” REC (see “How do you say REC?” post). The HREC definition gives you the option to identify something historical that may be a REC as an HREC. To me this type of approach in your report would be redundant, and possibly confusing to your audience. I think qualifying an issue for HREC status is a choice since the definition is left open to interpretation. If it may be a REC (no matter what the time frame), then call it a “suspect” REC to reduce the number of terms in your report. I plan to use the HREC term in a limited capacity for historical issues that have been addresses appropriately, which I would not call a REC.

When in the report do you identify a HREC? (Historical section only?)

It could come up in multiple places such as the historical section, regulatory, or any other section you address an issue (something that could have been a REC) that was cleaned up. I do not believe you need to limit it to just the historical section.

When and why does a HREC become a REC?

Taking from my limiting perspective defined above, HRECs would not become RECs. A “may be” HREC would be a “suspect” REC, and HREC would only represent “cleaned up” RECs. If you wish to use “may be” situations as HRECs, then you will need to address the HREC in the identifying subsection and summarize it in Findings. ASTM subsection 12.5 indicates you have to list your HRECs in the Findings. The definition indicates you only have to list HRECs that you believe will become RECs in the Conclusions. Therefore, same as “suspect” RECs, you will be listing all HRECs and need to qualify them as a REC or non-REC. (Again, another reason I think using “suspect” REC would be easier, no matter what the time frame.)

Does a HREC have to be addressed with additional assessment?

By the time we are making recommendations we should have identified REC / Non-REC status. I do not believe recommending additional assessment for HRECs is appropriate or supported by AAI or ASTM-05.

I’ve outlined my interpretation and opinion on handling the HREC, but just as our opinions on what constitutes a REC varies from consultant to consultant and firm to firm, the interpretation of the HREC will also vary. I believe the HREC is a minor issue in comparison to the REC, and with discussion, we can come to an understanding between the Commonground members that will provide guidance to junior professional and create consistence across the community. I put it to you the members of Commonground, can we come to a consensus that is agreeable on the use of an HREC?

As I will always ask: How do you do it? What is your opinion?

Scott

Keywords

REC, HREC, AAI, ASTM-05, Phase I, Recognized Environmental Condition

Time to dispose of this issue! (17 Comments)

Fri, 08 Jan 2010 15:11:04 +0000

Entry by R Scott Powell

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English is our version of written and verbal communication in the USA (for the most part). We speak it every day and most of us write in the English language every day. Yet through all the practice we mess it up constantly. Most of us here on CG review reports of one type or another. Over time I have noticed a misunderstanding of a basic English language concept, verb phrases, particularly prepositional verb phrases. It is a scourge across all levels of writers. I am even an offender of multi-word verb use.

This blog is not just about general verb use, but in particular the verb “dispose.” This is a very important word in the environmental industry, and its proper use is, at least to me, important. The on-line dictionary Dictionary.com defines “dispose” for us. In particular, look for the two definitions of “disposed of,” the first is just a definition, the second gives examples. I have debated the proper grammatical use of this word with many people over the years, so I decided to write it down this time. I hope the following helps you in your professional writing.

There are three general types of multi-word verbs. If your interested in learning more about the different types follow this link to Englishclub.com. I’m interested in discussing prepositional verb phrases and its grammatical layout.

Prepositional verb phrases have a basic formula: verb + preposition + direct object. I will use my favorite example - J - “dispose of.” Read the following few examples and guess which are correct and which are incorrect.

The soil was disposed of in the landfill.
After excavation activities, the soil was disposed of.
The contractor disposed of the soil in the landfill.
Before the project was completed, the soil was disposed.
The soil was disposed of quickly.

Did you answer correctly? Here are the answers:

Remember the basic equation for a prepositional verb phrase? How many prepositions are after the verb “disposed?” Two. Therefore, this example is incorrect. The correct verb phrase would have been “disposed in …”
Again, return to the basic equation. Where is the direct object? There isn’t one. The sentence is incorrect. The correct phrase would be “… the soil was disposed.” This is not the best sentence to use. I would suggest making it a prepositional verb phrase and give it a direct object (incorporate the location where the soil was disposed), “… the soil was disposed in Timmy’s back yard.”
We have a winner. The prepositional verb phrase has a direct object, with a bonus prepositional phrase stating where the contractor took the soil.
Again, winner. Examples 2 and 4 also show one of my other pet peeves, starting a sentence with a preposition. It is not incorrect grammatically; however, it is not the best show of “technical writing.” I would suggest switching the main body of the sentence and the preposition, which would also create the verb phrase “… disposed before the project was completed.”
No, sorry. An adverb is not a direct object, but drop the “of” and you have “… disposed quickly,” an intransitive verb phrase, which would be correct.

I’m going to admit, I’m not an English professional, and I do not know all the rules and exceptions in English grammar. If you can refute my examples, please do so, just provide a reference so I can review it and learn more myself.

This was just one example of many we find in technical writing. What have you found? Do you have a word phrase (verb phrase, noun phrase, or prepositional phrase) that you feel incorrect but do not know the answer? Post it, lets find out.

Scott

Keywords

grammar, dispose, verbs

Your pen is only as mighty as your words (10 Comments)

Thu, 10 Dec 2009 01:36:16 +0000

Entry by R Scott Powell

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The saying “The pen is mightier than the sword” rings true from ancient times to now. However, more so now than then, the strength of your pen depends greatly on your mastery of words. I will admit, I goof my words while typing quickly or forecasting my sentences while reviewing. Recently I was caught red handed with one of the typo dreadnaughts of in the environmental world, contaminants (or how I spelled it contaminates). I felt a little sheepish when it was pointed out, but that is why I recognize the need for peer or senior technical review. So it prodded me ask everyone:

What is your favorite word you like to catch or dreaded word that haunts your reviews? Don’t just respond with the word, please share your reasoning with everyone.

Contaminates vs. Contaminants

This one generally arises under two separate conditions. Either the professional does not know most people just say “contaminants” wrong (i.e. most people say “contaminat’s” ending the work on the “t”) and they try to spell it reflecting the shortened pronunciation; or it is a typo. Basically, “contaminants” is the noun, and “contaminate” is the verb. Wait, was there no “s” at the end of that verb? Bingo! Though the electronic dictionaries will allow the “s” at the end, it is not correct... generally. Yes… if you were to say “My property contaminates his.” That would appear to be a proper use of the term, but how often do professionals use it in that type of context? It would be a safe bet, if you see the word “contaminates” it is incorrect.

Ground Water vs. Groundwater

This one still comes up once in a while, but Joe Derhake summarized it best in his blog Between a REC and Hard Place, Groundwater vs. Ground Water post.

Soils vs. Soil

Here is my irk. I’ll get right to the point. The word “soil” is a noun that can be singular or plural by definition. Soil can consist of one or many parts. The word “soils” should only be used for the specific task of distinguishing between different classifications of soil, or telling us how dirty your clothes have become (The oil at work soils my clothes). 99.9% of the time in professional writing we should be using the word “soil.” Maybe, if you were writing a dissertation on soil classification could you get away with the word “soils” … maybe.

What is your favorite word play?

Scott

Off-Topic: New Job! (4 Comments)

Tue, 01 Dec 2009 23:43:49 +0000

Entry by R Scott Powell

If you knew I worked for a firm in Metro Detroit... I no longer do. I now work for a firm in the Pittsburgh area. My new field will take me away from Phase I's and transplant me into remediation and design work. I will continue with my blog though. As I said in my general intro, our technical writing ties us all together, no matter what the topic. We should always strive to improve our writing techniques and grammar... and I love pointing out the obvious!

Scott

Continuity

Tue, 10 Nov 2009 20:06:35 +0000

Entry by R Scott Powell

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According to Dictionary.com continuity is defined as "the state or quality of being continuous."

When we are talking about reports, I would assume that could be interpreted loosely as "the same throughout". Therefore, when you make a reference or interpretation you should use the same format or keep the same opinion/interpretation throughout your report. I don't know about you, but I try not to confuse my reader. So, when I read a report that makes multiple references to another report, but uses different names each time (the XYZ Consultant's 2009 Phase I / the 2009 Phase I / the 2009 report / XYZ Consultant's Phase I report), I get flustered. Yes it is a small thing, but if your referencing multiple reports and call each report many different names, your opening the door to misunderstanding, client confusion, and in the end client dissatisfaction. Client dissatisfaction leads down a dark road, especially if you leave them feeling like they are missing something, they can not understand your reports, feel you do not have the ability to maintain a continuous thought, or feel your trying to cover an issue.

Small things may not turn the tide of decision; however, they do make a difference in the end. Especially concerning your clients perception of you professionalism. We'll take the example of two consultants that come to the same conclusion for a site report. Though they are both professionally competent, know the regulations and engineering controls thoroughly, one writes more clear and concise than the other (we will skip client maintenance skills for the purpose of this discussion). Who do you think will satisfy the client better? The one who can communicate clearly of course. Continuity is a major player when it comes to writing clearly.

If your project is comprised of multiple parcels and you refer to them as "the Property" then "the subject parcels" then "the property parcels" then "subject Property parcels" your not clear in your references. No, most of us, and likely your client, will understand what your referencing, but why leave it to chance? What's the difference between "subject property" and "subject parcel?" The report I read meant the "subject property" was the clients property, and the "subject parcel" was a reference to an adjacent site with known impact. That type of reference can cause confusion and miscommunication.

It may sound repetitive or blasé (we're not writing graphic novels here people), but consistency reduces the chance of miscommunication. As my buddy Jeff Lanier says "Remember to KISS it" (Keep It Simple Stupid).

Scott

Keywords

Reports

File Retention or File Hoarding (3 Comments)

Thu, 17 Sep 2009 19:45:14 +0000

Entry by R Scott Powell

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“Print your drafts on the other side of previously used paper. We try and recycle everything. Only use the new paper when you need to publish. Also, place drafts with correction notes in the file. We keep all drafts and field notes as reference and documentation for what we have done… also to learn from…”

OK, so whose heart has stopped? Did you stare blankly at those words? Laugh uncontrollably on the inside? Those were my reactions when I heard this story.

The difference between file retention and file hording is the same as staying afloat or scuttling your own boat in turbulent waters. I imagine our resident lawyers will have a few comments. Retaining all drafts and notes self-imposes a calamity the day those files make it to the plaintiff’s lawyer.

One of the senior staff members of a company I use to work with was called into court to defend statements in a report she published years before. The plaintiff’s lawyer laid into her because a piece of paper in the file, with notes pertaining to the project in question, had four grocery items in the corner. Her professional judgment and abilities were called into question the entire time she was on the stand. That was just for a silly non-related item that was kept in the file… more to the point, there is nothing “silly” in your project file. Everything retained in the final file should be taken seriously.

Random notes on possible project scenarios could actually reflect a reality you are not aware of at the time of the report. I remember having a senior staff member review my reports and write in the margins multiple different scenarios I should keep in mind. I have done the same thing while reviewing co-workers reports now. Those drafts should not make it to the final file, they should be placed in the trash, the recycle bin, or better yet the shredder then the recycle bin. As I understand, a consultant can be held accountable for hypothetical scenarios they note (and is retained in a file), but do not express in the final report.

Discussion Situation: On a draft Phase II report the senior reviewer made notes in the margin for the junior staff member such as “The VOC and PAH constituents are typical of a UST system. We may want to recommend a geophysical survey. In subsequent field work call me when you encounter staining and odors during field work. We should have stepped out, but we can make the data work for this initial assessment round.” Assume after the findings are reported (no opinions or recommendations, as the client is the owner doing due diligence at the demand of the bank to get a loan, and requests just the facts), the financing/deal falls apart and the client decides to sit on the property for a few more years. Some time later, an incident arises with a neighbor looking to sue to clean up the migrating VOCs on their site so they can build a day care (reality is so much more fun than this simple story). Your report gets identified by the plaintiff’s lawyer, and then your entire file is subpoenaed.

OK, multiple problems here. Primarily, the notes in the report (as highlighted above) should have been a verbal discussion, not written out. As I am not a lawyer I will not go into the myriad of possible legal scenarios. The basic gist is when this draft version is reviewed by the court/lawyers, your professional standing will be called into question, even if you were just following the clients request by not including discussion or recommendation sections. Would you be liable? Hey like I said, I’m not a lawyer… but you better have good exemption language and able to talk your way out of quicksand.

Scott

Keywords

File, draft, retention, liability

What did you say? What were you thinking?

Tue, 13 Oct 2009 18:30:41 +0000

Entry by R Scott Powell

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Who has ever made an assumption as a consultant? I’ve always gone by the rule “Assume and you make an A## out of U and Me.” I have had the auspicious benefit of being present while a senior consultant reviewed a 1928 diagram and made an assumption what the depicted USTs use was based on the piping layout and general notes on the diagram. The project scope was proposed under these assumptions, and the client was prepped for a quick and smooth closure based on the immobility of the assumed contents. Low and behold, when the UST was excavated and soil samples collected… wow did they stink and scream on the PID (bad assumption). If the UST only contained PNAs the soil would not have had PID readings in the hundreds or thousands… I was in the position to observe and report. After the samples were collected, notes compiled, and analytical selected, the consultant still stated the UST appeared to be used for the same assumed use from the 1928 diagram, and submitted samples for PNA analysis accordingly. Only after some questioning by me (in front of their client… I hate to see innocent people stare incomprehensively at actives conducted on their own property) to “clarify” their field procedures, did they submit a couple of the samples for VOC analysis since there were PID readings. The client was not happy since this was supposed to be quick and easy, with only a hand full of analysis (bad client maintenance). The classic “You said it was just a #### UST and shouldn’t be an issue,” was stated by their client (bad client relationship).

Situations like these make me feel bad for the consultant’s client, and makes me appreciate my training at a competent company. This outlines the point that making assumptions as a consultant is just bad practice. As consultants, we are here to provide the facts and assist the client in meeting regulatory requirements (and if we’re lucky to have a great client that is proactive, protect the environment). Creating assumptions to make the situation fit what you or your client wants does not protect the client or you as the consultant.

Though I doubt anyone will post an answer here for themselves, I ask you to ask yourself these questions for self-reflection:

How often do I go through the day making assumptions simply due to “That’s how I’ve always done it?” Assumed your thought process does not need to be re-assessed, you have not looked for updated regulations, or evaluated yourself to determine if you need additional training. Can I improve myself in that area I’ve practiced for #?# years and/or done a hundred/thousand times?

Those questions are hard for some, but I find the best consultants ask themselves these questions on a regular basis, if not everyday.

To assume you know it all, or every possible solution, is to become complacent. Complacency leads to no growth, assumptions, and errors.

Scott

Keywords

Assumptions, UST

How do you say REC? (8 Comments)

Wed, 15 Jul 2009 15:27:19 +0000

Entry by R Scott Powell

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With the different ways consultants present RECs, I thought it would be an interesting discussion on how each of us presents it in our reports. I am talking about the language you use to present a REC, not its definition (posted below for those wanting a quick recap). Lets also skip HREC for now, which will be a subsequent post.

As defined in ASTM-05, subsections 1.1.1 and 3.2.74, a REC means 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 material threat of a release of any hazardous substance or petroleum products into the structures on a property or into the ground, groundwater, or surface water of the property… The rest of the definition consists of comments on hazardous substances, petroleum products and de minimis conditions, which we will also hold for another discussion(s).

I have read various reports over the years and noted that consultants address RECs in different ways. My question is how different, in legal responsibility, are each of these statements?

I use the operative word “suspect” REC in each subsection to identify potential issues such as USTs, inappropriate chemical storage (material threat of release issues), regulatory listed sites within the prescribed search radius and so on. At the end of the report in Findings and Opinions (I prefer to lump them together) I’ll summarize all “suspect” RECs, possibly identified across multiple subsections. In each “suspect” REC discuss I will present my opinion and supporting evidence if the “suspect” REC actually represents a REC in connection with the property or not a REC. Then in the Conclusions section I will present my final list of RECs (and a recommendations section, if appropriate, based on client needs).

I have read other reports that use the operative word “potential” REC in the same way I use “suspect.” Others have used “suspect” or “potential” throughout their report and summarize their list of RECs at the end of the report as “Suspect RECs” or “Potential RECs,” not clearly stating if they consider them actual RECs. Again I don’t know if this is because they think “Suspect REC” or “Potential REC” = REC, or if they are knowingly trying to weasel around a clear statement/opinion. Other consultants state in each subsection if the concern they identified is a “REC” and sometimes reference each subsection it is addressed. I have read many variants of that process.

ASTM-05, subsections 12.5 and 12.6, addresses “suspect” RECs. In Findings you need to identify your “suspect” RECs and in Opinions you explain your rational for why your suspect RECs are or are not RECs (again, I do it all in one section for what I perceive as easier report flow). To me the regulations are clear, in the end you need a REC / Non-REC statement.

Stating “suspect” or “potential” before REC basically takes it out of the formal REC classification and allows you to manipulate the data in your Findings and/or Opinions section. This is assuming by the end of your report you have a former REC / Non-REC statement. If you do not have a formal REC / Non-REC statement, and constantly use some type of “modifier” before REC, that takes you out of compliance with AAI/ASTM-05.

What is your stance? What operative words do you use in your reports? What have lawyers told you about your language use associated with AAI/ASTM-05 and REC identification (if you’ve been “lucky” enough to have that discussion).

Scott

Keywords

ASTM, Hazardous substances, contamination, REC, UST

LUST is a LUST is a LUST (3 Comments)

Tue, 06 Oct 2009 20:37:37 +0000

Entry by R Scott Powell

Open or Closed, a LUST site is a LUST site. They represent a risk unless you have data to prove otherwise. If there is a closure on an adjacent site… great, good for them… your site is still at risk. Unless you review a report that documents the contamination is limited to soil in the area of the UST, or the contamination in the groundwater is not migrating to your site, the situation is a risk (REC). Explaining this to a client can be daunting at times because of the adjectives “Open” and “Closed.” As can be expected, a client will rely on the descriptions/categories created by the regulatory agency to be definitive. Unfortunately, those categorical descriptions are not reliable. This is where a consultant can shine or die. Our ability to explain the differences between arbitrary nomenclature and reality, and more importantly the risks associated with the assumptions imposed by the arbitrary nomenclature, can create a life long client or (if you fail to communicate effectively or the client refuses to see it) a distraught client that may never return. I have found the later is fine when the client does not want to understand, and just wants a piece of paper so he can move on to making money. We all like money, but if you don’t understand your risks, you’re going to get burned eventually.

Whether it is titled “Open” or “Closed,” an adjacent or proximate LUST site is a risk that should be highlighted for the client (i.e. a REC in a Phase I). You will have to use your own professional judgment and experience in the area of the site to determine what should be considered proximate. (Yes, I skipped gradient, preferential pathways, and many other little facets, but I'm not giving a lesson here, just making a comment.)

Many adjectives used in writing are misleading, it is best to stick to the facts. It is a LUST site, maybe it is “clean” = “Closed,” but the client needs to understand those two words are not mutual when it comes to contamination.

Scott

Standard of Care

Tue, 08 Sep 2009 20:53:29 +0000

Entry by R Scott Powell

In accordance with www.dictionary.com the “standard of care” means: the degree of care or competence that one is expected to exercise in a particular circumstance or role.

A question started brewing in my mind during the “EP? I don’t think so” discussion. How do we reflect the “standard of care” through our actions and reports. In the 1980’s it was whatever the environmental professional dreamed up, then it slowly headed toward local practice. “What were the other consultants in your market area doing?” When ASTM arrived on the scene in the 1990’s… it was local practice with some advice. Now we have AAI, and ASTM-05 referenced directly in AAI. Yes, previously we had ASTM-97 and ASTM-00, but not everyone followed them because there was no need (still isn’t a need to follow ASTM-05, most EP’s just do). Most did out of good practice, but that’s the hook, good practice verse blissful ignorance. Now that all consultants have been handed the AAI bible and told to worship and follow its teachings, does our perception of the “standard of care” need to change (at least for those who had blinders on and only looked a few feet away)? Basically… If you were not looking to meet a national standard before, you better meet it now.

The local standard still has a play though. If everyone in your local area is providing additional “out of scope” services, in addition to the basic Phase I, then your local standard for service may be more than other market regions; however, those addition services should not be considered the “standard of care.”

One person may take the “standard of care” to mean walking every inch of the site, taking 100 photos, sketching a scaled diagram, researching every street directory year, and other OCD actions. On the other hand I’ve seen someone else drive by the site, take one photograph, look at a record or two and call it good enough for a commercial lot… Disparity? Just a little. This is nothing new to any of us. We cringe at the costs associated with the over achiever consultants, and shake our heads at the 10 hour Phase I’s for industrial sites. Will everyone agree on a similar tactic to meet the “standard of care?” No, not exactly. Each EP has their own corporate and regional differences. As Ed has highlighted in his “CERCLA: It’s just Federal Law…” post, for our clients to show they are completing their due diligence appropriately, they need to contact an EP who is knowledgeable in the regulations of the region of interest. State requirements can augment the “standard of care” between regions.

Back to the definition above, I have yet to find a way for clientele to measure the “competence” of firms without using them first. They could always ask for a “sanitized” report… but how many of us have ever had that request. A larger matter would be, could the client recognize a “competent” report? A few, absolutely. The Users that are investing in real estate and developing sites tend to be aware of what they need; however, the majority of the Users do not have a full grasp of what makes a “competent” EP that can write a “competent” report that will meet the “standard of care.”

How do we fix this lack of a cohesive “standard of care” across regions? We really can’t, but we can help Users become educated indirectly. Start here at CG. It might sound trite, but the wealth of knowledge already contained here, and the constant input of opinions and examples is a wealth of knowledge to Users. Beyond CG, Users should ask some basic questions:

Do you follow AAI?

Do you use the latest ASTM format?

How many AAI compliant Phase I’s have you completed?

How do you identify RECs?

How will you help me meet my due diligence requirements? (If the answer is less than two sentences… run!)

EP’s should educate their clients and Users to their due diligence requirements and the “standard of care” they take to assist the client.

These are just a few of the questions and thoughts that came to me while reading the blogs and discussions here at CG. Yours are likely different, so express them.

1. How do you define your “standard of care?”

2. What do you do to educate your clients and Users of their due diligence responsibilities and the dichotomy of practice across regions?

Scott

Blogs > R. Scott Powell's - Watch The Language

Historical Recognized Environmental Condition (15 Comments)

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Time to dispose of this issue! (17 Comments)

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Your pen is only as mighty as your words (10 Comments)

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Off-Topic: New Job! (4 Comments)

Continuity

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File Retention or File Hoarding (3 Comments)

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What did you say? What were you thinking?

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How do you say REC? (8 Comments)

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LUST is a LUST is a LUST (3 Comments)

Standard of Care