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ASTM E1527-13

May 4th, 2016

EPA launches new Superfund database

EPA has launched the ‘Superfund Enterprise Management Systemepa_logo2 (SEMS) as a replacement database for the retired ‘Comprehensive Environmental Response, Compensation, and Liability Information System’ (CERCLIS) database.

SEMS contains sites that are either proposed to be, or are on, the National Priorities List (NPL) as well as sites that are in the screening and assessment phase for possible inclusion on the NPL. EPA’s Superfund program is responsible for cleaning up some of the nation’s most contaminated land and responding to environmental emergencies, oil spills and natural disasters.

Gabriel reviews nearby Superfund and NPL sites when conducting Phase I Environmental Site Assessments.  Our regulatory database search provider has updated their databases to include SEMS information.  Gabriel’s Phase I reports will now include SEMS data instead of CERCLIS data.

If you have questions about how Gabriel uses SEMS information in our Phase Is, contact Natalie Neuman at 773-486-2123 or nneuman[at]gabenv.com.

January 27th, 2016

Phase I Environmental Site Assessment Spotlight: File Review

One of the major changes to the Phase I Environmental Site Assessment ASTM standard during the recent revision (E1527-13) is the enhanced requirement to conduct file reviews of government records. This requirement can uncover environmental concerns documented by old building permits, wrecking permits, tank permits, and fire records.

Because this file review can add extra time – and expenses – to a Phase I, not all consultants include this research as part of their standard assessment.  Skipping this part of the due diligence process may result in missing important information, as illustrated by the case study below.

Sometimes municipalities have digitized these older records and can make them available via PDFs.  Other times, we are required to review records in person either on paper files or on microfiche.

Key records we’re looking for include:

  • Fuel or heating oil tank installation/removal
  • Previous uses of the building (eg: rug cleaner; tool & die shop)
  • Fire inspection records regarding storage and usage of hazardous materials
  • Violations caused by environmental concerns (eg: hazardous waste disposal or storage)
  • Permits to upgrade HVAC system which may indicate past use of heating oil

Case Study

Gabriel was conducting a Phase I in a Chicago suburb. This municipality made some of its old permit records available via PDF,

building permit - fuel tank2

“Fuel Tank” highlighted in red on this building permit application from 1957

including old building permits.  On the building permit to the right, we discovered “Fuel Tank” listed on this original application from 1957.  No indication of size or location was provided.

Gabriel then conducted an in-person review of the remaining records the village stored only on microfiche.  On many Fire Department inspection records from 1959-1970s, the heating system is identified as oil-forced air.  There is no documentation found for when the building switched to the current natural gas fueled unit heaters.

Due to the file review of these government records, Gabriel concluded that fuel oil had been used as the heating source at the site for many years, and that an underground fuel oil tank may still exist on site.

No USTs were registered at the site and no visual indications of a UST were found during the site inspection.  Therefore, without this file review, this Recognized Environmental Condition (REC) may have been missed.

If you have questions about how Gabriel uses file reviews in our Phase I research, contact Natalie Neuman, Group Leader Assessment Services, at 773-486-2123 or nneuman[at]gabenv.com.

May 15th, 2015

Phase I Environmental Site Assessment Spotlight: Aerial Photographs

During the course of a Phase I Environmental Site Assessment, Gabriel reviews aerial photographs showing the site and surrounding area.  Depending on its location, aerial photographs can be available as far back as ~1930, with updates every 5-15 years.

These aerial photos can help us determine when the property was first developed, as well as any changes in the property use, building size, and surrounding area development.  Key items that can be seen on aerial photographs include:

  • Historical gas station
  • Aboveground storage tanks
  • Past use as farmland
  • Building additions
  • Illegal dumping
  • Presence of wetlands
  • Drum storage
  • Location of roads or railroad tracks/spurs
  • Quarries
  • Vegetation

Case Study

Gabriel was conducting a Phase I at a suburban location in the Chicagoland area.  While reviewing the aerial photos, we found that the site was undeveloped in 1949; by 1970 had been developed into a gas station; and by 1990 had been redeveloped into its current use as a strip mall.  This 1970 aerial photo was the key historical documentation which showed there may be petroleum products still present at this site, especially since no other documentation existed of UST removal or soil sampling.

1949 Aerial Photo - shows vacant land

1949 Aerial Photo – shows vacant land

aerial photo 1970 - cropped

1970 Aerial Photo – shows site developed as a gas station

aerial photo 1990 - cropped

1990 Aerial Photo – shows site redeveloped as a strip mall

If you have questions about how Gabriel uses aerial photos in our Phase I research, contact Natalie Neuman, Group Leader Assessment Services, at 773-486-2123 or nneuman[at]gabenv.com.

April 9th, 2015

President Obama knows the value of a Phase I Environmental Site Assessment

In an interview with NPR’s Steve Inskeep  about the Iran nuclear deal, President Obama showed that he understands the importance of conducting a Phase I Environmental Site Assessment prior to purchasing a property, to make sure there are no “environmental disasters” on the land.

 

“The analogy I used is it’s sort of like you’ve signed a contract to purchase a home, but you’ve still got the, you know, the appraisal, the inspector, you’ve got to make sure that there isn’t some kind of environmental disaster on the land. And until you actually sign, you know, that mortgage and that document, the deal is not closed.”

 

Full interview: www.youtube.com/watch?v=p_T8rSmgMWQ

Transcript:  www.npr.org/2015/04/07/397933577/transcript-president-obamas-full-npr-interview-on-iran-nuclear-deal

March 4th, 2015

Going back in history with the Pullman District

In celebration of Chicago’s historic Pullman District being designated a national monument, the Chicago Tribune has published historical photos and maps of the area.  One of their interesting maps is an interactive “now” and “then” comparison using a fire insurance map from 1901 and a current aerial photograph.

 

sanborn map - pullman district

Click on the map to link to the interactive version on the Chicago Tribune website

 

This interactive map is a great example of how Gabriel uses historic fire insurance maps as part of our Phase I Environmental Site Assessment research.  We compare the fire insurance maps for the area where our subject property is located with today’s maps, looking for any past uses of a property that may indicate hazardous substances were used previously and therefore may still be present in the soil or groundwater, or may be associated with a vapor migration or intrusion issue today.

For more information on fire insurance maps, read our earlier blog post “History of Fire Insurance Maps.”

Thanks to Dianne Crocker at EDR for the link to this map.

November 19th, 2014

Why are dry cleaners often listed as a REC?

Dry cleaning machine from the 1960s

Dry cleaning machine from the 1960s

When conducting a Phase I Environmental Site Assessment, Gabriel’s Environmental Professionals (EP) know that when we find evidence of a current or past dry cleaner on site, we need to pay extra attention.

Dry cleaners raise a red flag for us due to the chemicals they use to clean the clothing (chlorinated and/or petroleum solvents) and historic poor housekeeping practices.  It was not uncommon for used solvents to be dumped out the back door before there were stricter environmental regulations.  Chemicals were often spilled around the machines, and rarely were the shops equipped with spill containment equipment as they are now required to have.

Contamination caused by dry cleaners can impact soil and groundwater, as well as cause vapor migration and intrusion issues.  Studies have shown that approximately 75% of all dry cleaners have some level of contamination.

As a result of these factors, EPs often list the former or current presence of a dry cleaner as a Recognized Environmental Condition (REC) in a Phase I.  While not every dry cleaner has serious contamination, it is generally prudent to investigate areas both inside and in the back of the building.

“‘Taken to the cleaners’ can have a particularly disturbing connotation for owners, sellers, and lessors of real estate,” says environmental attorney Lawrence Schnapf.

To learn more about the key risks posted by dry cleaners and strategies for managing these risks, download “Dry Cleaners: the Environmental Scourge of Commercial Real Property,” from Mr. Schnapf’s website.

If you have specific questions about dry cleaning contamination for a property you own or are considering purchasing, contact John Polich at jpolich[at]gabenv.com or 773-486-2123.

November 14th, 2014

Phase I Environmental Site Assessment Spotlight: City Directories

During the course of a Phase I Environmental Site Assessment (ASTM E1527-13), Gabriel reviews historical research from several sources to help determine  the previous use of the subject property and neighboring properties.  Some of the key historical documents we reference when conducting a Phase I are the city directory listings.

Polk City Directory 1923

These city directories list all known occupants of each street address for a certain address range, searching back to when city directories were first produced in that particular community. By reviewing an address range that includes the subject property and adjoining properties, we can get a more complete picture of what businesses were previously located at the subject site itself and nearby sites.  For corner properties, we review city directories along both roadways because historically the properties could be addressed as either street.

Some of the city directories that we review include R. L. Polk & Co., Illinois Bell Telephone, the Reuben H. Donnelley Corporation, Cole Information Services, and the Haines Company, Inc.

Case Study

Recently, Gabriel was hired to conduct a Phase I on a strip mall with a known former dry cleaner.  A previous Phase I, conducted by another firm, had discovered this former cleaning operation because it was listed as a Small Quantity Generator with the Illinois EPA.  When reviewing the city directories, Gabriel learned that this dry cleaner had moved within the shopping center in the 1980s, which meant that there were two storefronts that could have been affected by the dry cleaning chemicals.  A previous Phase II had shown contamination in the area of the known dry cleaner, so there is a good probability that the previous storefront with the dry cleaning operation also has contamination due to similar chemical usage and housekeeping practices.

If you have questions about how Gabriel uses city directories in our Phase I research, contact Natalie Neuman, Group Leader Assessment Services, at 773-486-2123 or nneuman[at]gabenv.com.

October 6th, 2014

EPA Amends All Appropriate Inquiries Rule

EPA has finalized its amendment to the All Appropriate Inquiries (AAI) epa_logo2regulations to remove reference to ASTM E1527-05.  With this final rule, EPA will only consider Phase I’s completed to the most current ASTM standard (E1527-13) to be compliant with its AAI regulations as of October 6, 2015.  EPA included this year delay in order to give all parties adequate opportunity to complete AAI investigations that may be in progress.

EPA states that the purpose of this amendment is to reduce any confusion associated with referencing a historical standard that is no longer recognized by ASTM as meeting its standards for good customary business practice.  They also specifically state that removing 1527-05 from the regulations does not impact any Phase I’s completed to this standard between November 1, 2005 and the effective date of the final rule (Oct 6, 2015).  Parties who purchased properties in this time span who obtained Phase I’s which complied with this 1527-05 standard would still be eligible for CERCLA liability protection (as long as all aspects of All Appropriate Inquiries were adequately completed).

The entire Final Rule can be found at www.regulations.gov.

All of Gabriel’s AAI-compliant Phase I’s are completed to the most current standard (E1527-13) and meet the All Appropriate Inquiries requirements.

September 2nd, 2014

EPA Set to Issue Final Rule for AAI Changes

EPA is finishing their review process prior to issuing the Final Rule EPA amending the All Appropriate Inquiry (AAI) regulations to remove reference to ASTM E1527-05 and replace with E1527-13.  This ASTM Phase I Environmental Site Assessment standard was updated in November 2013 and confirmed by EPA to be compliant with the AAI rule in December 2013.

EPA received five comments to their proposed rule in July 2014, four of which were positive and one of which was negative.  EPA will address the negative comment in the Final Rule’s preamble and explain its reasoning for why it disagrees with the comment.

EPA will also clarify in its preamble that any Phase I’s completed to the ASTM E1527-05 standard between November 1, 2005 and the effective date of the Final Rule will still be considered as compliant with the AAI regulations.

EPA has stated that it intends to make the effective date one year after the Final Rule is published, which is expected to occur in late September/early October.  They decided that an earlier effective date may be burdensome to some entities who are still transitioning to the new ASTM standard.  Any Phase I’s completed for federal Brownfields grants, however, must be completed to the E1527-13 standard effective immediately, upon the date the Final Rule is published.

For more information on the proposed Rule and to access the comments submitted, visit the EPA’s Proposed Rule for Standards and Regulations of All Appropriate Inquiries webpage.

If you have any questions about the ASTM standard or Phase I’s in general, contact Natalie Neuman, Group Leader of Assessment Services, at nneuman[at]gabenv.com.

August 22nd, 2014

History of Fire Insurance Maps

Photo courtesy of Historical Information Gatherers

Photo courtesy of Historical Information Gatherers

For environmental consultants, fire insurance maps (FIMs) can be a goldmine of historical information that is relevant to today’s environmental conditions on a particular property.  These FIMs were created for fire insurance companies to evaluate the degree of hazard for a particular building or area.  FIMs were first created in London in the late 1700s, and the practice quickly spread to the U.S.  The most well-known FIM company, the D. A. Sanborn National Insurance Diagram Bureau (later renamed to Sanborn Map Company) was founded in 1867 with an atlas of  fire insurance maps of the Boston area.  That book can be found today in the Library of Congress.

FIMs documented information that can still be important when conducting historical research during a Phase I Environmental Site Assessment.  They are recognized by ASTM as one of the standard historical sources that may be used to determine if a Recognized Environmental Condition (REC) exists at the subject site.

Key environmental information that can be found on a FIM includes: storage tanks (including gasoline, heating oil, etc.); historical use of the property or adjoining properties; location of petroleum products; industrial processes; heating sources; chemical storage; etc.  Other useful information that may be available: if a basement is present, when a building was constructed, and general layouts.

Historical Information Gatherers (HIG) has recently released an interesting white paper about the history of fire insurance maps.  The white paper includes information about land use, structures and possible environmental issues that one can discover using FIMs, as well as how FIMs were created and updated.  It is available for a free download on HIG’s website.  HIG is in the process of digitizing more than 500,000 color FIMs available through the Library of Congress.

More information about the history of the Sanborn Map Company is available on the Library of Congress website.