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EVEN 4100 Environ Sampling & AnalysisAnnouncements
indoor labs in ECCE 1B47
HAZWOP first lecture/lab – Wed, Sept 2, ECCE 1B47 second lecture – Thur, Sept 3, here
Labs first lab – Wed, Sept 9 field trip (on foot) for Phase I ESA assume you need all safety equipment and
clothing
Environmental Media of ConcernSolid
soil, sediment, bedrock building materials, containers
Liquid surface water ground water mixtures
Gas ambient air, indoor air soil vapor
Biota
Contaminants of ConcernOrganic compounds
volatile organic compounds solvents (e.g., acetone, alcohols)C O
C
C
C
O
H H
H
H H
H
OHC
CH3
H3C
CH3
Contaminants of ConcernOrganic compounds
volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons
(e.g., TCE, PCE)
Contaminants of ConcernOrganic compounds
volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons
(e.g., trichloroethene, tetrachloroethene)C C
Cl
H
Cl
Cl
C C
Cl
Cl
Cl
Cl
Contaminants of ConcernOrganic compounds
volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons (e.g., TCE, PCE) petroleum constituents – gasoline
BTEX
Contaminants of ConcernOrganic compounds
volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons (e.g., TCE, PCE) petroleum constituents – gasoline
BTEX (benzene, toluene, ethylbenzene, xylenes)
CH3
H2C
CH3
CH3
CH3
benzene
xylenes
ethylbenzene
toluene
Contaminants of ConcernOrganic compounds
volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons (e.g., TCE, PCE) petroleum constituents – gasoline
BTEX (benzene, toluene, ethylbenzene, xylenes) methyl tert-butyl ether H3C C
CH3
CH3
OCH3
Contaminants of ConcernOrganic compounds
volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons (e.g., TCE, PCE) petroleum constituents – gasoline
BTEX (benzene, toluene, ethylbenzene, xylenes) methyl tert-butyl ether
ketones (methyl ethyl ketone) refrigerants (chlorofluorocarbons)
Contaminants of ConcernOrganic compounds
volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons (e.g., TCE, PCE) petroleum constituents – gasoline
BTEX (benzene, toluene, ethylbenzene, xylenes) methyl tert-butyl ether
ketones (methyl ethyl ketone) refrigerants (chlorofluorocarbons)
analysis by GC/MS
Contaminants of ConcernOrganic compounds
volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons (e.g., TCE, PCE) petroleum constituents – gasoline
BTEX (benzene, toluene, ethylbenzene, xylenes) methyl tert-butyl ether
ketones (methyl ethyl ketone) refrigerants (chlorofluorocarbons)
analysis by gas chromatography/mass spectrometry
EPA Method 8260
Contaminants of ConcernOrganic compounds
semi-volatile organic compounds solvents (chlorinated benzenes)
Cl
ClCl
Contaminants of ConcernOrganic compounds
semi-volatile organic compounds solvents (chlorinated benzenes) petroleum constituents – diesel, fuel oil
PAHs
Contaminants of ConcernOrganic compounds
semi-volatile organic compounds solvents (chlorinated benzenes) petroleum constituents – diesel, fuel oil
polycyclic aromatic hydrocarbons (naphthalene, phenanthrene, styrene, etc.)
CH2
Contaminants of ConcernOrganic compounds
semi-volatile organic compounds solvents (chlorinated benzenes) petroleum constituents – diesel, fuel oil
polycyclic aromatic hydrocarbons (naphthalene, phenanthrene, styrene, etc.)
pesticides, herbicides organochlorine compounds (e.g., DDT) organophosphate compounds (e.g., malathion) triazine compounds (e.g., atrazine)
ClClCl
Cl Cl
H
S
P
O
O
OO
S
O
O
N
N
N
NH
NH
Cl
Contaminants of ConcernOrganic compounds
semi-volatile organic compounds polychlorinated biphenyls (PCBs;
Arochlor nnnn)
Contaminants of ConcernOrganic compounds
semi-volatile organic compounds polychlorinated biphenyls (PCBs;
Arochlor nnnn) dioxins and furans
2,3,7,8-tetrachlorodibenzo-p-dioxin tetrachlorodibenzofuran
O
Cl
ClCl
Cl
O
O
Cl
ClCl
Cl
Contaminants of ConcernOrganic compounds
semi-volatile organic compounds polychlorinated biphenyls (PCBs;
Arochlor nnnn) dioxins and furans
2,3,7,8-tetrachlorodibenzo-p-dioxin tetrachlorodibenzofuran
analysis by GC/MS EPA Method 8270
Contaminants of Concern Inorganic compounds
metals copper, zinc, lead cadmium, mercury, silver aluminum, manganese chromium
metalloids arsenic, selenium antimony
Environmental Site AssessmentComprehensive Environmental Responsibility, Compensation, and Liability Act (CERCLA), 1986(“Superfund”)
Environmental Site AssessmentComprehensive Environmental Responsibility, Compensation, and Liability Act (CERCLA), 1986(“Superfund”)
Liability strict – wrong-doers are liable for damages
without requiring proof of negligence joint and several – any and all of wrong-
doers can be forced to pay for all damages in cases of indivisible harm (proportion of total harm attributable to each wrong-doer cannot be determined)
Environmental Site AssessmentCERCLA liability
current property owners responsible for contamination cleanup regardless of responsibility for contamination
property owners, lenders, and lessees can potentially be held liable (civil and criminal)
prospective property owners must complete “due diligence” assessments to avoid liability
Environmental Site AssessmentWhat is due diligence for CERCLA?
Phase I ESA commercial and industrial real estate demonstrates lack of liability; allows “innocent
landowner” defense important for brownfield sites requires “all appropriate inquiry” by purchaser
Environmental Site AssessmentWhat is “All Appropriate Inquiry”? requirements for property
owner defenses under CERCLA
federal minimum standards for conducting ESAs
additional requirements beyond ESAs
environmental liens market value versus purchase
price analysis maintenance of institutional
and engineering controls in future
Environmental Site AssessmentWhat is a Phase I ESA?
assessment of potential or existing environmental liabilities of a site
real estate transactions brownfield sites
components site visit (including neighboring properties) review of operating records, zoning permits interviews historical aerial photography identification of “recognized environmental
conditions” (no sampling)
ASTM E1527-13 (on course web site here)
Environmental Site AssessmentWhat are “Recognized Environmental Conditions” (RECs)? “…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 release…into structures on the property or into the ground, groundwater, or surface water of the property.”
petroleum? excluded from CERCLA; not part of AAI included in ASTM E1527-13
Environmental Site AssessmentExamples of RECs
underground storage tanks (current or former)
even if no leaks have been reported oil and gas wells or tanks significant soil staining attributable to
spills observed leaks (drums, tanks, etc.) floor drains with staining adjacent property with identified
contamination dry cleaning (on site or adjacent) adjacent landfill
mining waste rock piles ordraining adits
Environmental Site AssessmentExamples of RECs
farm and ranch land dumps, cattle dipping vats improper pesticide use
Current/former auto dealerships/repair shops
Commercial properties with current/former septic systems
Previously demolished buildings asbestos in soil
Oily sheen on surface water Leaking electrical transformers
Environmental Site AssessmentHistorical RECs (HRECs)
conditions that would qualify as RECs that have been properly remediated
“no further action” status (may still be considered a REC) depends on site-specific cleanup levels example: petroleum storage tank formerly on
site, removed, contaminated soil removed, regulatory agency approves remediation result
Environmental Site AssessmentsWho hires environmental consultants to do Phase I ESAs? purchasers of commercial and
industrial properties owners of commercial and
industrial properties tenants of commercial and
industrial properties attorneys government agencies non-profit organizations
Environmental Site AssessmentsWho can conduct a Phase I ESA? ESAs be conducted under
supervision of an “Environmental Professional”
Professional Engineer Professional Geologist
3+ years experience B.S. degree in science/engineering
5+ years experience Anyone with 10 years of
experience Strongly recommend that the
Environmental Professional conduct site reconnaissance and interviews with owners
Environmental Site AssessmentPhase I ESA steps
client-provided information historical research regulatory agency research interviews
property owners site personnel
site reconnaissance subject property and adjacent properties assess topography, drainage, groundwater
flow direction report
Environmental Site AssessmentClient-provided information
title records known environmental liens activity and use limitations (AULs) “specialized knowledge” about
environmental problems “commonly known” information “reasonably ascertainable” information valuation reduction for environmental
issues owner, occupant, lessee, property
manager information reason for performing Phase I ESA
Environmental Site AssessmentHistorical research
search of records regarding contamination required distances based on site type,
contaminant type adjacent to property 1 mile
up-gradient sources back to “first developed use or 1940,
whichever is earlier” database research companies
historical aerial photos and topographic maps fire insurance maps land titles; zoning and building permit records mining claims
time resolution of about 5-year intervals
Environmental Site Assessment Interviews
conducted by Environmental Professional must include key personnel
current site owner current site manager current occupants and lessees
abandoned properties must interview adjacent property owners
questions current use, chemicals on site knowledge of previous use knowledge of environmental investigations
Environmental Site AssessmentSite reconnaissance
should be done by Environmental Professional
entire property (to extent practical) interior
maintenance areas chemical storage and use areas boiler rooms
exterior document any access limitations
locked rooms, gases, dangerous access snow cover
identify RECs document with photographs
Environmental Site AssessmentReport
describe purpose and scope of services document all findings
list RECs identified identify information gaps
were standards met? assess significance of gaps relative to RECs
provide opinions regarding RECs recommend additional investigation for
RECs list environmental concerns outside of
Phase I scope section 13.1.5 has partial list
declare certification as Environmental Professional
Environmental Site AssessmentPitfalls
Phase I ESAs often regarded as a commodity
lowest bidder regardless of quality example: Argo Mine, Boulder County
clients may not prioritize delivery of information
potentially different opinions about RECs caution regarding
“reliance letters” letter from one party to
another allowing reliance on previousPhase I ESA report
Environmental Site AssessmentsPhase I ESA
example:Valmont Butte,Boulder, Colorado
report
Environmental Site AssessmentBrownfield sites CERCLA property where re-
use or re-development is complicated by the presence or perceived presence of environmental contamination
potential liability limits remediation of under-used or abandoned properties
neighborhood blight reduced value of
surrounding property
Environmental Site AssessmentBrownfields Redevelopment – Small Business Liability Relief and Revitalization Act, 2002 liability protection for purchasers and
owners of contaminated property must conduct “all appropriate inquiry” to
qualify for liability protection other versions of innocent landowners
bona fide prospective purchaser purchaser unaware of another’s claim to property
title contiguous property owner
owner unaware of contamination from adjacent property
ability to apply for grants to pay for property remediation and re-development
Environmental Site AssessmentBrownfields grant
example:Elysian Park,Jamestown, Colorado
proposal
Environmental Site AssessmentsPhase II ESA
assessment of expected environmental liabilities of a site
sampling and analysis type, distribution, and extent of hazardous
substances components
Sampling and Analysis Plan Quality Assurance Project Plan Health and Safety Plan Report – purpose, summary of sampling and
analysis, health risk assessment, data validation, results and recommendations
ASTM E1903-11