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Tag Archive for ASTM E1527-13

May 16th, 2018

Phase I Environmental Site Assessment Spotlight: Soil Conditions

Vent stack and fill port for a former fuel oil tank where the building has been converted to natural gas for its heat.

During the course of a Phase I Environmental Site Assessment (ASTM E1527-13), Gabriel attempts to document soil conditions through visual observations, regulatory database review, and historic document review.

Visual observations may include:

  • Above-ground storage tanks
  • Evidence of underground storage tanks (eg: vent stacks or fill ports)
  • Drums
  • Staining or corrosion
  • Stressed vegetation
  • Pools of liquid
  • Hazardous materials
  • Wells
  • Septic systems or cesspools
  • Geological/topographical observations

Regulatory database and historic document review may include:

  • Underground Storage Tank (UST) installation or removal records
  • Leaking USTs
  • Past uses of property
  • Records of hazardous materials usage and/or violations
  • Environmental remediation/clean up
  • Fire insurance maps

If a Recognized Environmental Condition (REC) impacting the site’s soil is discovered either through visual observation or a review of regulatory databases or historic documents during a Phase I, Gabriel may recommend soil borings to investigate if there is analytical data showing hazardous substances or petroleum products in, on, or at the property.

Contact Natalie Neuman, Group Leader Assessment Services, at nneuman[at]gabenv.com or 773-486-2123 with any questions about how Gabriel assesses soil conditions during a Phase I.

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.

April 1st, 2015

Phase I Environmental Site Assessment Spotlight: Government Records Review

During the course of a Phase I Environmental Site Assessment, Gabriel reviews government records from a variety of federal, state, local, and tribal agencies.  We will review all pertinent records available, including, but not limited to: underground storage tanks (USTs); hazardous materials stored, used or disposed; environmental violations; building permits; occupancy permits; fire inspection records; construction permits; demolition permits; and closure projects.

These records help us determine if hazardous substances or petroleum products are currently or were previously located on the site.

Case Study

Recently, Gabriel was conducting a Phase I ESA at an auto repair facility in Chicago.  The current owner/occupant did not have any knowledge of USTs on the property.  osfm

However, during a search of Illinois Office of the State Fire Marshal (OSFM) and Chicago Department of Public Health (CDPH) records, it was discovered that three tanks were installed at the property between 1972 and 1979, prior to the current owner purchasing the property.  The previous owner had operated the property as a gas station in addition to the repair shop, so a diesel tank, gasoline tank and used oil tank had been installed.

None of these tanks had any record of removal, which means there is a strong likelihood that the tanks are still on site and possibly leaking due to their age and material.

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

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.

May 28th, 2014

HUD Adopts E1527-13 for all Phase I Requirements

The U.S. Department of Housing and Urban Development (HUD) has updated its guidance documents for the Office of Housing and Federal Housing Administration (FHA) to require the latest ASTM standard (E1527-13) effective May 16, 2014.  This change affects several guidance documents throughout Office of Housing/FHA, including, but not limited to, the Multifamily Accelerated Processing (MAP) Guide, the Condominium Project Approval and Processing Guide, Handbook 4600.1 REV-1, Section 232 Mortgage Insurance for Residential Care Facilities, and Handbook  4615.1, Mortgage Insurance for Hospitals.

HUD specifically details the addition of the term CREC (Controlled Recognized Environmental Condition) and inclusion of vapor to the migration pathway as important reasons to require ASTM E1527-13.

“The new CREC definition will result in some environmental conditions being listed as CRECs if they have been remediated to restricted levels, as opposed to an unrestricted or de minimis level, and will be a great tool for Office of Housing/FHA staff to assess whether the site is appropriate for residential use,” stated Carol Galante, Assistant Secretary for Housing – Federal Housing Commissioner.

If you have any questions about the new Phase I standard, contact Natalie Neuman (nneuman[at]gabenv.com or 773-486-2123).

April 17th, 2014

Streeterville Developers Face Contamination Complications

Developers in the Streeterville area are learning how the past use of a property can affect today’s new developments due to lingering environmental issues. In this case, the environmental issue comes in the form of radioactive thorium.  Prolonged exposure to thorium can increase the risk of lung, pancreatic and bone cancer.

In the early 1900’s, Lindsay Light Co. manufactured lantern wicks for gas lanterns, coating them with a thorium-based solution.  Their original plant was located at 22 W. Hubbard St, and they later expanded to 316 E. Illinois St. and 161 E. Grand Ave.   The company gave away the sandy by-product of the thorium ore to be used around Streeterville as free landfill material.

Map source - Chicago Tribune April 17, 2014

Map source – Chicago Tribune, April 17, 2014

 

In the 1930’s, Lindsay Light Co. moved out to West Chicago, and the past use of the properties was forgotten for decades.  In the 1990’s, however, the EPA traced the company’s origins from West Chicago back to Streeterville after investigating radioactive contamination at the West Chicago facility and surrounding areas.  EPA now requires special permits and radiation consultants for developers working in Streeterville and the Near East Side.  All excavated dirt for new buildings, sewer repairs, or other street maintenance must be analyzed with a gamma ray detector.  If any of the dirt exceeds the EPA’s thorium limit, the soil is removed to a special radioactive waste landfill.  Developers of the Loews Hotel and various residential projects in the area have learned that this special protection means construction can take longer than expected – and cost more money too.  In the past decade, more than 50,000 cubic yards of thorium-contaminated soil have been excavated and shipped to a Utah landfill which is licensed to accept radioactive waste.

Developers in the area just got good news from the U.S. Department of Justice, who negotiated a legal settlement with Lindsay Light Co’s successor for a total of $5.1 billion for the continued cleanup of various thorium-contaminated properties across the United States.  Streeterville/Near East Side will receive $121 million for their continued cleanup efforts, and West Chicago will receive an additional $9 million.  To date, West Chicago has spent nearly $750 million cleaning up its radioactive contamination, with much of that funding also coming from earlier legal settlements with Kerr-McGee (Lindsay Light Co’s successor).

“We’re only halfway through the redevelopment of the neighborhood,” said Gail Spreen, the head of the Streeterville Organization of Active Residents. “They’ll likely find more thorium along the way.”

In addition to the thorium contamination, properties in the Streeterville area may also have contamination from other past industrial use.  The area was once heavily industrialized and a busy seaport.  Developers working in the area are learning the importance of doing their full environmental due diligence, including a Phase I Environmental Site Assessment completed by highly qualified Environmental Professionals and following the ASTM E1527-13 standard.  By knowing the site’s history and potential environmental risk prior to purchasing the property, developers can negotiate a better deal for the property and/or require clean up prior to taking title. They will also be able to factor in the additional time and expense to deal with the contaminated soil.

Caveat emptor: let the buyer beware…especially in Streeterville.

Source: Chicago Tribune, “Just off Mag Mile sits city’s toxic past.” 4/17/14.

EPA Superfund information: Lindsay Light Company sites

April 11th, 2014

3 Things To Know About the New Phase I Standard

ASTM finalized E1527-13, the latest Phase I Environmental Site Assessment  standard on November 6, 2013.  EPA subsequently approved E1527-13 as being compliant with All Appropriate Inquiry (AAI) regulations on December 30, 2013.
Here’s the top 3 things you need to know about these updated regulations:

VAPOR

ASTM updated the definition of a REC (Recognized Environmental Condition) to specifically include vapor as a potential concern. Previously, it was left to the Environmental Professional’s discretion or their client to determine if vapor should be considered when performing a Phase I.  Environmental Professionals (EPs) must now consider solid, liquid and vapor releases of hazardous substances or petroleum products.

Bottom Line:  You may see more RECs now that include vapor issues.

CREC

ASTM added the term CREC (Controlled Recognized Environmental Condition) to better define sites which have past releases that have been properly addressed but still have a required control (eg: commercial/industrial land use restriction, engineered barrier, etc).

Bottom Line:  If you see a CREC, don’t panic.  A CREC is a “good REC.”  Gabriel can advise you and your client about any site-specific requirements regarding the continuing obligations.

FILE REVIEWS

ASTM states that agency file reviews should be conducted if the subject property or adjoining property is identified in any of the standard environmental records sources.  Previously, some EPs would review these government records during their Phase I assessments but many would not.  Now, these reviews must be included unless records are not reasonably ascertainable.

Bottom Line:  Other firms might increase their prices to include this additional work.  Gabriel has always done file reviews for these types of sites, so you will not see an increase in our prices to add in the file review.