Environmental Site Assessment Phase 1: Fundamentals, Guidelines, and Regulations - Chapter 3 ppt

Chapter A Proper Beginning Introduction A complete understanding of the client’s needs and a systematic plan of attack are vital to expedite an assessment and avoid confusion The paper shuffle can easily end in a maze whereby the beginning is not obvious and the end may seem to be somewhere in Never‑Never Land First, the client’s needs must be assessed Whereas one client may express unclear requirements in terms of a “normal” site assessment, another will have a well‑defined scope of work Others will know they want an All Appropriate Inquiries assessment but may not have considered other con‑ cerns that could result in a poor property investment decision Client needs and defined requirements are highly variable Second, with an understanding of the client’s needs, you can create a struc‑ tured framework to help you organize and maintain control over the process This step is easy to ignore, particularly by those who have performed numer‑ ous surveys and think they have the routine committed to memory On the other hand, a survey can become particularly confus­ing when an individual or team of people is working on different site assessments at the same time, and each participant is assigned a single task, part of the whole Consistency may be sacrificed, and information may be reported piecemeal Third, support agencies and other sources of information must be con‑ tacted immediately Although some may respond over the tele­phone, many will require a letter of request and two to six weeks’ lead time Your job gets placed on the production line, and you must wait your turn Some sources offer assistance, then forget the request or lose it within their own paper shuffle They may take a little longer than anticipated, and sometimes they may require a gentle reminder The paper shuffle will have the greatest impact on the time required to complete the investigation Finally, develop a sketch of the property This last step, although not required, can be helpful and aid the investigator to visually review the situation All four steps are discussed in depth within this chapter The methodol‑ ogy is not set in stone It is only a start, and one of many approaches that can be developed These basic steps are a guide to give you direction and help you to begin to organize the information neces­sary to determine whether hazardous substances will affect the property under investigation 45 © 2008 by Taylor & Francis Group, LLC 7966.indb 45 10/19/07 6:49:00 AM 46 Environmental Site Assessment Phase I Interview the Client Clients generally make their initial contact by telephone They always ask for price and completion time requirements Some will ask what is involved, whereas others will know exactly what they require Prior to answering their most important concerns, how­ever, you may want to determine purpose, scope of work, and known property information You may then advise them about the efficacy of going beyond the basic requirements of the All Appro‑ priate Inquiries Rule Purpose of the Site Assessment The purpose of a Phase I site assessment depends on the client’s association with the property As discussed in the previous chapter, the client may be a: (1) seller; (2) buyer; (3) lender; (4) lessor/lessee; (5) broker representing a buyer or seller; or (6) corporate shareholder They all seek to determine the probability that the property is or can become a liability due to hazardous substances on and/or associated with the prop‑ erty, and some may seek to be informed as to environ­mental factors that could restrict land use and development Yet, each has a different vested interest Most site assessments are initiated by a buyer or lender Both the buyer and lender stand to lose their investment and to incur unex­pected liabili‑ ties if there is a preexisting condition They want to avoid or minimize the chances of making a bad investment Many repossessed properties also are assessed Prior to its disso­lution on December 31, 1996, the Resolution Trust Corporation (RTC) served that function Now, the Federal Deposit Insurance Corporation (FDIC) man‑ ages the assets previously managed by the RTC The purpose of their site assessments is the same as that of the seller They want to know of any preexisting conditions that might impact the sale of owned or repossessed properties When they prepare to sell, a last-minute disclosure as to factors that devalue the property may bring about a change in plans More impor‑ tant, however, the seller may avoid liability for a preexisting condition if disclosure is made prior to a sale and the responsible parties are identi‑ fied The seller’s purpose is to avoid last‑minute surprises and forfeiture of defense in a liability suit Small corporations and individuals rarely seek an environmental site assessment A lessor may be held responsible for a lessee’s misuse of property The broker has a duty to advise a client as to the risk potential A shareholder involved in the decision making of a corporation that is operating, buying, or selling property may be held liable, beyond the corporate veil An understanding of purpose will give the consultant a point of depar‑ ture, a means for communicating effectively with the client con­cerning the required scope of work Some clients need to be educated Knowing the cli‑ ent’s intent is important © 2008 by Taylor & Francis Group, LLC 7966.indb 46 10/19/07 6:49:01 AM A Proper Beginning 47 Scope of Work An environmental site assessment may also be referred to as an environ‑ mental audit, environmental evaluation, pre-acquisition site assessment, real estate environmental study, environmental impairment risk assessment, or any variation thereof The client may request an assessment under another term, or the client may be requesting something altogether different, such as a dedicated endangered species environmental impact study On the other hand, the client may need only an All Appropriate Inquiries assessment Seek clarification! For the client who seems to be lost in a fog of uncertainty, explain the dif‑ ferent phases of a site assessment and limitations to the scope of work that is being requested The scope of work may be re­defined once this information is clear to the client This will, once again, affect the anticipated amount of time and the cost Clarification The understood scope of work must be clear and concise Similar to institu‑ tions, individual clients have differing requirements and perceived needs Some may even require guidance The only information the client may have is that a lender mandated that an environmental site assessment be completed prior to real estate closing Find out which lending institution is involved and what, if any, special requirements they have in addition to the All Appropriate Inquiries assessment Client requirements vary from “go look and see” to “a five‑pound manual of procedures and checklists to be completed.” The requirements will sig‑ nificantly affect the time required to perform a survey Some clients will be very specific and provide a detailed checklist of items to be included in the survey; others may only know the purpose of avoiding liability or keeping a loan officer happy An assessment that is performed to placate a loan officer can be difficult to negotiate if the loan officer has failed to clarify the requirement In these cases, clients want the least expensive product they can get They see their money drawn into a vacuum for no understandable reason, while the con‑ sultant tallies up the liability issues Cheap and thorough are not compat‑ ible An All Appropriate Inquiries investigation requires more than a token drive‑by The Rule, however, does not cover petroleum or petroleum products, and failure to identify preexisting petroleum contamination on property may result in costly cleanup for the unwary buyer Thus, the acceptable level of risk versus cost must be clarified For example, past experience dictates that what appears to be raw land may harbor a sleeping liability Industrial properties in urban environments are not the only ones that present risk; pristine rural properties may have had dumping on or around the premises at some time in the past © 2008 by Taylor & Francis Group, LLC 7966.indb 47 10/19/07 6:49:01 AM 48 Environmental Site Assessment Phase I Once the risk has been explained, if the client still insists on a minimum scope of work, the consultant may opt to either back out of the deal or clar‑ ify in writing the client’s desires and that the client has been duly warned Even in the latter scenario, the consultant’s insurance carrier could still end up paying legal fees for defense Thus, a consultant may opt not to perform assessments that are less than that required by law as protection from liabil‑ ity—under the Superfund Law Some consultants say they can guarantee “no hazardous substances on the property.” This is the fool’s folly! There are no 100% guarantees that a site is clean—unless every inch of the property has been sampled, which is an absurd situation Never offer a guarantee! Those people who probably don’t have anything to lose—money or reputation According to the All Appropriate Inquiries Rule (the Rule), an assessment should include at least: (1) a records review; (2) a site and area reconnais‑ sance; and (3) interviews The Rule does not detail how to go about it It only mandates what must be included and by whom The ASTM E 1527-05 does, however, provide details where the Rule leaves off The ASTM Standard also recommends a petroleum and petroleum prod‑ uct search, which is not included in the Rule The detailed components for an ASTM assessment, with comments regarding the Rule, include: • Physical setting (Not mandated by the Rule) Topography Geology Hydrogeology Hydrology • Historic usage of the property (Mandated by the Rule back to first property usage; recommended by ASTM back to first developed or to 1940, whichever is earlier) Title search Aerial photographs Fire insurance maps Local street directories Property tax records Zoning records Building permits • Government agency records review (ASTM: federal and state records [dis‑ cretionary: local]; the Rule: federal, state, tribal, and local) NPL CERCLIS RCRA lists ERNS State hazardous waste site (e.g., Superfund) lists Solid waste disposal sites © 2008 by Taylor & Francis Group, LLC 7966.indb 48 10/19/07 6:49:01 AM A Proper Beginning 49 Underground storage tank (UST) list—Not mandated by the Rule Leaking UST (LUST) list—Not mandated by the Rule • Property and area reconnaissance (With limited exceptions, mandated by the Rule to include adjoining properties; observations only of the adjoining properties) Current use Prior use Hazardous substances present Signs of property misuse Effluence and air emissions Waste disposal techniques Surface water Transformers Surrounding area use • Interviews Owners—Mandated by the Rule Past owners and occupants—Mandated by the Rule; as needed to obtain information pertinent to the site Site residents Site personnel (e.g., commercial and industrial) Neighboring or nearby property owners or occupants—Man‑ dated by the Rule at abandoned properties Local government officials Remember, the Rule is mandated, and the ASTM is recommended There has also been a trend toward the review of hazardous building materials (e.g., asbestos) and special resources The depth of coverage in each topic varies, and requirements continue to evolve Some institutions mandating a site assessment will group surveys by category in order to aid in the decision‑making process as to the required depth of an assessment Categories may include undeveloped land, resi‑ dential property, com­mercial property, and industrial property On the other hand, incongruous notions that undeveloped land must be evaluated for asbestos in building materials or that developed land must be evalu‑ ated for endangered species are included in some institutions’ required protocols Others clarify different property types and specific procedures for each Table 3.1 restates and clarifies the minimum components, based on property category Special resource concerns generally involve raw land, but they may include developed land as well (e.g., an historic building that cannot be altered or destroyed, or an archaeological site associated with a building that cannot be expanded onto the site) If the client requires the inclusion of a special resources evaluation, seek clari­fication as to which issues must be addressed To assist the client, determine the intended use for the property Table 3.2 lists many of the special resources investigations that may be requested under varying circumstances © 2008 by Taylor & Francis Group, LLC 7966.indb 49 10/19/07 6:49:01 AM 50 Environmental Site Assessment Phase I Table 3.1  Recommended Components of a Phase I Environmental Site Assessment, According to Property Category Raw Land Residential Commercial Industrial Physical setting   Topography   Geology   Hydrogeology   Hydrology Historic usage of the property   Title search   Aerial photographs   Fire insurance maps   Local street directories   Property tax records   Building permits Regulatory agency listing   NPL   CERCLIS   RCRA   ERNS   State hazardous waste sites   Solid waste disposal sites   Underground storage tanks (USTs)   Leaking USTs (LUSTs) Site reconnaissance   Current use   Prior use   Signs of property misuse   Surface water   Transformers   Surrounding area usage   Hazardous substance storage   Waste disposal techniques Interviews   Owner   Past owners and occupants   Site residents   Site personnel   Local government officials X X X X X X X X X X X X X X X X X X X X X — X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X — — X X X X X X — — X X X X X X X X X X X X X X X X X — — — X X X X — X X X — X X X X — X X © 2008 by Taylor & Francis Group, LLC 7966.indb 50 10/19/07 6:49:02 AM A Proper Beginning 51 Table 3.2  Special Resources Threatened and endangered species Critical and unique habitats Buildings/structures of historic value Archaeological resources Wetlands Wild and scenic rivers Coastal dunes and beaches Various sources Different Phases A Phase I environmental site assessment (ESA) is the initial research phase for assessing a property It is where historic information and documenta‑ tion is compiled and analyzed This is the speculative stage in which all the information gathered may contain only one piece of information that could generate questions or other avenues requiring further investigation Feelers are sent in many directions, keeping in mind that anything and everything is possible Possibilities are subjected to speculation, based on experience, common sense, and logic Probability for property contamination—high, medium, or low—is the end result Although sampling is rarely performed in this phase, some clients require some sampling for asbestos, a token sam‑ pling of the groundwater, air samples for radon in buildings, and/or lead sampling of the drinking water A Phase II ESA involves more detailed research and/or speculative sam‑ pling During the Phase I ESA, an investigation may disclose a moderate to high probability that there is preexisting contamination on the property or that development may have an impact on the en­vironment At this point, it is only a probability Further investigation and/or sampling are indicated This requires greater time and cost ex­penditures Additional research and information gathering, not normal in a Phase I ESA, may involve the aid of a private investigator to track suspicious activi‑ ties, or it may involve a time‑consuming, in‑depth au­dit of the administrative management records Where special resources have been researched, a Phase II ESA may also require the aid of a nature biologist to study the habitat Sampling may range from collecting water samples from within a small, easily accessed pond to groundwater sampling It may consist of composting the top inches of surface solid to core drilling down to uncontaminated geological substrates An asbestos building evaluation is generally included in a Phase II survey, but the clients might require an ab­breviated asbestos evaluation during a Phase I ESA This should be as­certained during the scope of work clarification In short, a Phase II ESA involves more time and money expendi­tures than the speculative Phase I Its principal intent is to “confirm or deny suspicions.” © 2008 by Taylor & Francis Group, LLC 7966.indb 51 10/19/07 6:49:02 AM 52 Environmental Site Assessment Phase I A Phase III ESA follows on the heels of a Phase II after suspi­cions have been confirmed The problem has been identified—the contaminant is known Now, the questions remain: How bad is it? and How much will it cost to clean it up? Extensive sampling is in­dicated Keep in mind, the con‑ taminant may have come from an adja­cent property, down a river, or through ground migration from one area to another The possibilities are infinite, and sampling may go well beyond the property boundaries Generally, once this stage is reached, a plan of action to reduce the liability is developed Cleanup is the best alternative, but containment and ongoing monitoring could mini‑ mize the cost and control the liability All factors are considered A Phase III may require extensive soil sampling to determine the extent of contamination Groundwater monitoring may also be indicated where migration has been extensive Sampling of ponds and sediment may be required, or vegetation sampling may be indicated where an airborne con‑ taminant may have entered the food chain (e.g., fluorine contamination in grazing pastures) Many Phase III assessments become part and parcel of a cleanup For instance, formaldehyde contamination of the soil has been confirmed on the premises of a cosmetics manufacturing plant The property is 100 feet above a major aquifer that supplies water to more than seven hundred thousand people The soils are porous and geology fractured, serving as a recharge zone for the aquifer The potential that the formaldehyde will contaminate the aquifer is high The owners may opt to put in a groundwater monitoring well to determine if the aquifer has been compromised; if it has not, removal is begun immediately, avoiding costly core sampling They will take samples during the cleanup to confirm or deny completion The differences between the various phases are not black and white Because the extent of coverage completed during Phase I ESAs varies from one to the next, the same applies to the other phases In most cases, however, an investigation is terminated upon completion of the Phase I assessment A Phase I may also be referred to as a Level 1, Category 1, or preliminary survey Roman numerals and Arabic numbers are sometimes interchange‑ able, but the investigative involvement is consistently “one.” Limitations A comprehensive Phase I environmental site assessment is limited to the availability and completeness of historic data and to physical obstructions that mask visual clues Activities performed on the sly are not subject to historic discovery Eyewitnesses may not be willing to talk, or they may not be accessible An inability to properly interpret the collected data may also be a limitation Tracking the past becomes more difficult with the passage of time Evidence disappears Stories become distorted Records are destroyed or lost A building or other such ground cover (e.g., asphalt roads, surface water, or a shed) may conceal an area that has signs of contamination For instance, © 2008 by Taylor & Francis Group, LLC 7966.indb 52 10/19/07 6:49:02 AM A Proper Beginning 53 a shed may have been built on top of sinking ground cover as a disguise to what really is hidden below In such cases, only damage to the property and invasive sampling would identify a problem, and neither is feasible without other indicators A partial Phase I environmental site assessment will be limited accord‑ ingly Many times, just one little obscure piece of information may cause the consultant to embark down a few more trails, not originally anticipated, in order to discover an unknown The chances for such a discovery are mini‑ mized with an abbreviated scope of work Details about the Property Where is the property? Get the city and address, if there is an address Zip code information, if not given by the client, will have to be obtained at a later date, when initiating a regulatory agency records review Some clients may give a generalized description They may provide street coordinates, land‑ marks, or survey lot and block descriptions The latter information can be used to locate the property on a plat Others will even offer a legal property description These may or may not be helpful Figure 3.1 is a sample legal description, created in the late 1800s, that has yet to be located by the owners or taxed by the county tax assessor What type of property is it? It may be raw land, farmland, or grazing land Or it may be zoned residential, commercial, or industrial What is the present use of the property? It may be property with no appar‑ ent use It may be used for cattle ranching, or it may be used as the site of a dry cleaning operation Alarm bells are warranted particularly where there are industrial activities An assessment of a manufacturing operation may also involve an extensive chemical or process audit What is the number and size of buildings on the property? Where were they constructed, and what structural materials were used? An old steel stor‑ Figure 3.1  Legal description of a plot of land that has yet to be located by the pres‑ ent owner (A vara is an old Texas unit of measure that is equivalent to 33.3 inches, a little less than a yard.) © 2008 by Taylor & Francis Group, LLC 7966.indb 53 10/19/07 6:49:03 AM 54 Environmental Site Assessment Phase I age shed on a concrete foundation is easier to assess than an industrial com‑ plex with three‑ and four‑story buildings, all constructed at different times and of different materials The client’s responses to the preceding questions are vital, along with the purpose and scope of work, to ascertain how much time the job will take Consultants generally have a set hourly fee for investigation and report preparation time With the time projection, hourly rate, and research fees, the consultant may determine project costs Once the terms have been agreed upon, reconfirm the property location Get the names of contacts in order to gain access to the property and the buildings on the property Request pertinent records and reports, and ask for disclosure of whatever details and information the client may be privy to that may impact the outcome of the investigation Plan and Organize Once there is an understanding of purpose and scope of work, an investi‑ gative checklist of components should be created and a method developed for keeping the information together The checklist evolves; each time an assessment is performed, the checklist gets larger An observation regarding items not mentioned on a checklist, something previously not considered, is a good investigator’s stock-­in‑trade A properly organized management plan will help you avoid endless hours of searching all recesses of the office, home, and automobile Such a scenario is like driving a car that will go only in reverse It is not im­possible to move forward without a plan, but things can be distracting and difficult without a systematic approach and diligence The latter will improve with the passage of time and with experience A Tailored Checklist A checklist should serve as a tool to keep track of (1) that which has been completed; (2) that which must be completed; (3) assigned component tasks; and (4) deadlines It is to be used as a guide If there is more than one person performing the job, all participants should receive their own checklist from a designated, singular “team leader.” An Organized Management Plan Once the checklist has been developed, the investigation could turn up mountains of documents, data, sketches, and notes Organize a method for keeping track of these A common, single resting place for all the information may consist of a three‑ring binder, organizer expansion file, or paper file box Be sure to clearly label the name of the property if you are performing more than one assessment at a time If a map or plat is too large to be placed in the © 2008 by Taylor & Francis Group, LLC 7966.indb 54 10/19/07 6:49:04 AM A Proper Beginning 55 designated resting place, reference its location As the information is entered into its appointed location, it should be so noted on a composite checklist, which should always remain in the common resting site for the paperwork Color‑coded project folders are another alternative File folders can be purchased in a number of colors, and each job or cate­gory of investigation may be color coded Begin the Paper Shuffle Standard requests for assistance from other parties should be first on the agenda Some documents and information may take weeks to obtain This alone could be the greatest deterrent to completing an assessment on a timely basis Start on the requests as soon as possible A Title Search All Phase I site assessments involve a title search, and a title search is best performed by a title search company or an experienced individual It is pos‑ sible for anyone to perform a title search, but the learning curve is steep A first-time search may inadvertently be easy and direct, but many are not Hopelessness sets in after hours of retrieving 28‑pound ledgers, shelved up to 10 feet overhead Tracking parceled land and multiple owners is time con‑ suming and requires some knowledge of how to read a deed of trust and to identify an environmental disclosure One day in the county courthouse will dispel any thoughts one may have to cut corners The cost of having an experienced person perform the search is well worth the expense Depending on the state and the extent of the search, a title search may cost anywhere from $150 to $500 Occasionally, a more compli­cated one will cost as much as $800 or $1,000 After you obtain all perti­nent information from the client, call your title search company for pricing, and include this in the cost of the assessment A search may typically be completed within a few days, but some of the larger firms or busier individuals may require two to three weeks Degree of difficulty may further extend the amount of time required to complete the search The following are a few of the factors that constitute a difficult title search: (1) property that has changed hands every other year; (2) property that is in a county that was incor­porated and broken off from another county (e.g., requiring visitation to several county courthouses for one title search); and/ or (3) property that has been owned by people with a name similar to other property owners (e.g., Joe Smith) Some county courthouses have the more recent title information listed on computer Recent means five to ten years Some title search companies/individuals are required to maintain “errors and omissions” (i.e., professional liability) insurance Although the insur‑ ance is expensive and does increase the cost of a search, it allows for a degree of assurance to the credibility and completeness of a search © 2008 by Taylor & Francis Group, LLC 7966.indb 55 10/19/07 6:49:04 AM 56 Environmental Site Assessment Phase I Small companies or individual consultants may be as good as or better than the larger firms They generally have a track record prior to starting their own business and not survive unless they continue to provide a quality, conscientious service Oftentimes, an individual maintaining a sole proprietorship also provides a more personable service at a reduced rate FOIA Requests The acronym FOIA stands for Freedom of Information Act A FOIA request is generally required by most federal and state governments and some local agencies Once it has been decided how extensive an inquiry is going to be, a FOIA request should be completed and the request clearly stated, along with the details necessary for the agency to retrieve the correct information The response may take anywhere from two to four weeks The more complicated requests take six to eight weeks For instance, a request for aerial photos from the Department of Agriculture in Salt Lake City takes a standard six weeks, assuming the requestor has provided adequate information The most fre‑ quently requested FOIAs include regulatory agency listings, building per‑ mits/certificates of occupation, health/safety and environmental compliance records, tax records, and environmental permits An example of an FOIA that may require extensive turnaround time is a request for information concerning PCB content in specific transformers identified around the site This information may be requested from the local utility company Sometimes the information is readily available on computer, but more often than not, it will require the deployment of a worker to look at the transformer and take a sample The sample goes to a laboratory, and this may take up to several weeks FOIA management is becoming routine business Many government agen‑ cies have a designated individual whose sole responsibility is to respond to and/or coordinate FOIA requests, and many of them charge a fee For instance, regional EPA offices have a designated “FOIA officer.” The office generally charges for computer time and number of printout pages On the other hand, some local agencies respond within a few days and require only a verbal request Not only they provide the appropriate infor‑ mation, at no charge, but they will sometimes provide a written response as well This latter scenario, however, is rare Don’t expect it! Documents Some of the more complicated ESAs (e.g., purchase of industrial property) will require an audit of documents that may be obtained from the owner or user of the property Gathering these documents may take some time, and the person assigned to this task will appreci­ate some lead time Some of the information may be forwarded for your review prior to the site visit Documents that may be on your list include: (1) building blueprints; © 2008 by Taylor & Francis Group, LLC 7966.indb 56 10/19/07 6:49:04 AM A Proper Beginning 57 (2) asbestos inspection reports; (3) environmental site assessment reports; (4) permits; (5) registration records; (6) material safety data sheets; (7) safety and health survey reports; (8) environmental permits and reports; and (9) records of regulatory violations These will be discussed in later chapters Develop a Sketch of the Site After developing a checklist, collect pertinent maps and then sketch the site and surrounding area on a copy This technique provides a frame of refer‑ ence, and a sketch helps the thought pro­cesses Considerable information can be presented schematically Maps Obtain a street map that shows the property and surrounding area, and get a property record map for the site The street map may be any map with the streets, rivers, lakes, and position of your property relative to the surround‑ ing properties Ideally, the map will show a minimum 2‑mile radius around the property under investigation City and county street maps are generally good sources Yet, you may find the need to use two or more in order to cover enough area Some properties may be in two separate counties or may be so large as to require more cover‑ age than that allowed by one map A Chamber of Commerce, Department of Transportation, or commercial street finder map will in many instances and is easy to locate The map will be used as a basic tool for taking notes prior to and during the site visit The consultant may prefer one that also has the relative block numbers This information will be necessary when attempting to locate the position of reg‑ ulatory agency listings A drive through the neighborhood to look for each address is a time‑consuming alternative Commercial street finders have not been developed for many small communities and towns If no street finder is available, you may have to go to local businesses for assistance in locating listed sites or drive around searching for them, drawing their location onto your map as you go All properties will have a property record map that is updated annu‑ ally These maps are in the form of a plat map or unrecorded tax map A plat is prepared for incorporated property (e.g., a residential development or property within city limits), and an unrecorded tax map is completed for property that is not incorporated (e.g., rural, undeveloped land) Both can be located at the tax appraisal office, and the incorporated property plat can be found at the county courthouse A walk‑in visit is generally required Expect to pay copy fees Property record maps are blueprint‑size schematics depicting property boundaries, dimensions, and present owners Some property record maps have addresses, and the surrounding property information may also be © 2008 by Taylor & Francis Group, LLC 7966.indb 57 10/19/07 6:49:04 AM 58 Environmental Site Assessment Phase I helpful For instance, an adjacent property contains what appears to be an old convenience store or gas station The property record map shows owner‑ ship in the corporate name of Gasoline Alley Convenience This indicates a probable existing or preexisting gasoline station that is likely to have an underground storage tank and should be checked for evidence of such dur‑ ing the area reconnaissance A property tax appraisal is an abbreviated summary of property acreage and sizes of buildings It will provide a sketch and dimensions of build‑ ings on the property Although not always accurate, appraisals can serve as a basic reference point The appraisal may be picked up at the tax appraisal office, along with the property record map Once the maps have been collected, copy the street map and enlarge the section of the property record map, while maintaining the integrity of the boundaries A couple of copies each will allow for notes and corrections Sketch the Area This step is not necessary and may be inconvenient if the prop­erty is at a considerable distance from the office, but if proximity will allow, this step can be well worth a short trip to the site Visualization of adjacent and sur‑ rounding property uses, activities, and structures can be simplified by using this method Property structures and relative positions are available for easy reference, and the composite picture is on two drawings See Figures 3.2 and 3.3 for examples With the site maps in hand, visit the site and surrounding area Do not plan on spending an excessive amount of time doing this A more thorough site reconnaissance will be performed at a later date It may be helpful to deploy an assistant to perform this duty A second pair of eyes with a differ‑ ent frame of reference and set of experiences may also be helpful Challenge the assistant’s diligence Give the assistant a checklist of items and make it clear that there may be more than those items found on the list The checklist is limited Some investigators become fixated with a checklist and fail to observe items or circumstances that are out of the ordinary Don’t rely on a checklist alone The purpose of this initial visit is to establish a visual reference and iden‑ tify areas that may require further research Finding out that additional research is needed at the time of the actual site recon­naissance may result in time delays and a duplication of document reviews The client already wants the report completed yesterday, so the extra time you spend generating an initial impression will have been time well spent Sketch the property Depict property boundaries, building bound­aries, surface water, unmarked streets and fence lines, evidence of effluence and air emissions, locations of transformers (identifying them by number on the transformer or pole, if possible), and activities Information concerning the © 2008 by Taylor & Francis Group, LLC 7966.indb 58 10/19/07 6:49:05 AM A Proper Beginning 59 Vacant bldg (Lumber yard) nts e apartm stockpiled 5-gallon auto paint shop machine shop steel drums gasoline station office bldg bank wrecked autos fiberglassing exhaust stack ting metal pla exhaust stack Figure 3.2  Sample property map used for quick sketch and notes concerning the usage of and noteworthy items on adjacent properties and in the vicinity Items should be noted that may require a closer look during the site/area reconnaissance PCB content of transformers may take time A request for this information should be made as soon as possi­ble Drive around the area Sketch the apparent land usage, existing commer‑ cial activities, and industrial activities by type Note strange or questionable structures and/or landmarks located in the surrounding areas as well as on the site Summary Get a good start and keep your records organized A methodical approach will clear the mind and allow for a more focused investiga­tion Begin each Phase I environmental site assessment with a four­-step guide: © 2008 by Taylor & Francis Group, LLC 7966.indb 59 10/19/07 6:49:09 AM 60 Environmental Site Assessment Phase I dark staining under pole transformer 78932 Hard pack soil adjacent bldg Copy Center subject property 4-story vacant bldg transformer 34603 heavy traffic 5th Street brick exterior, vinyl floors, exhaust stack, signs of fire on 2nd & 3rd floors, doors boarded gravel road transformer I6072 transformer 5003I Lavaca Street c y traffi one wa Figure 3.3  Sample quick sketch and notes taken during a drive around a property (Items noted should provide direction when planning the actual site reconnaissance.) Step 1: Assess the client’s purpose and scope of work Step 2: Plan and organize by developing a checklist and a system to keep track of the voluminous amount of material gathered Step 3: Initiate information requests This should include, but not be lim‑ ited to, a title search, Freedom of Information Act requests for govern‑ ment agencies, and other documents that will take time to collect Step 4: Develop a sketch of the property and surrounding area If prox‑ imity allows for a short drive through the area, this step can be a time‑saver, but it is not required The intent of this chapter has been to clarify and provide direc­tion The succeeding chapters detail specifics © 2008 by Taylor & Francis Group, LLC 7966.indb 60 10/19/07 6:49:10 AM ... Work An environmental site assessment may also be referred to as an environ‑ mental audit, environmental evaluation, pre-acquisition site assessment, real estate environmental study, environmental. .. 6:49:01 AM 50 Environmental Site Assessment Phase I Table? ?3. 1  Recommended Components of a Phase I Environmental Site Assessment, According to Property Category Raw Land Residential Commercial... measure that is equivalent to 33 .3 inches, a little less than a yard.) © 2008 by Taylor & Francis Group, LLC 7966.indb 53 10/19/07 6:49: 03 AM 54 Environmental Site Assessment Phase I age shed on a concrete