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Tag Archive for file reviews

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.

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.