Chapter Property and Area Reconnaissance Introduction A site and area reconnaissance is performed to observe existing conditions and activities These conditions and activities may or may not have been pre‑ viously identified through other means If they are not previously identified, the investigator attempts to find potential sources of environmental contamina tion not previously encountered and evaluate possible means by which the soil and water may become contaminated Sometimes a site visit will confirm suspicions At other times, it will open new avenues for further investigation Although the process may appear to be quite straightforward, such an attitude can result in oversights Some environmental professionals like to use a checklist One must keep in mind, however, that checklists can be lim‑ iting, and they often require illogical observations (e.g., conditions of ponds in a rural environment) A site inspection requires common sense, an analytical mind, and persis‑ tence If something appears out of place, it probably is An old dirt road over‑ grown with vegetation has a reason for being, and it should be questioned Although many of these issues are discussed within this chapter, the realm of possibilities is limited only by one’s imagination Published recommenda‑ tions and mandates can be limited in scope, but the environmental profes‑ sional should not limit the scope The ASTM Standard recommends a visual inspection of the subject prop‑ erty, with no specific requirement to inspect adjoining properties with the exception of noting anything actually observed from the subject property The Rule requires a visual inspection of the subject property and adjoining properties If, however, for some reason a visual inspection cannot be per‑ formed, the environmental professional should perform one of, or a combi‑ nation of, the following: • Visually inspect the subject property via another method (e.g., obser‑ vations by air) or from an alternate vantage point (e.g., walk the prop‑ erty line) • Document efforts taken to gain access to the subject property • Document the use of other sources of information to determine the existence of potential environmental contamination 137 © 2008 by Taylor & Francis Group, LLC 7966.indb 137 10/19/07 6:50:18 AM 138 Environmental Site Assessment Phase I • Express an opinion about the significance of the failure to conduct a site inspection on the ability of the environmental professional to identify conditions indicative of releases or threatened releases The discussions within this chapter go beyond what is recommended by ASTM or mandated by the All Appropriate Inquiries Rule It is up to the environmental professional to limit or extend the search Reconnaissance of the Property A site reconnaissance is a thorough investigation of the grounds and all buildings on the property Chapter contains the methodology for evaluat‑ ing buildings, which may be accomplished during the grounds inspection All activities performed in and around the buildings have an impact on the property, and the property may have had other uses than were derived from the historic usage background search, presented in Chapter Plan the visit The site investigator may require special equipment For instance, an eight‑hour walk‑through of a densely vegetated, 200‑acre lot, on a hot, humid day may require a machete, lightweight and heavy duty boots, a long‑sleeved shirt, a water jug, a backpack, and some form of self-defense (e.g., mace) along with paper, writing implements, and a camera If planning to collect samples, take the necessary equipment Think in terms of accessi‑ bility, consolidation of supplies, and reduced bodily discomforts Area diagrams are a must They include a copy of the plat and area map Plan on getting them dirty, marking them up extensively (e.g., locating 55‑gallon drums), and taking extensive notes (See Figure 7.1.) Too many or a lack of proper supplies can result in extended reconnais‑ sance time Taking too much can cause a logistics juggling act Taking too little may necessitate an additional trip to retrieve needed items and can be time consuming Always carry a clipboard and writing implements Notes will get wet and dirty Use permanent markers or pencils that will not bleed, resulting in unreadable information Prior to departing for the site, review collected information Take notes during the planning stages for the site reconnaissance and generate ques‑ tions The review should include, but not be limited to, the following: • • • • Environmental setting Historic usage of the property Building records Regulatory agency listings The investigator should attempt a visual evaluation of every square foot of the property, but it is not always feasible to walk an entire area To overstate © 2008 by Taylor & Francis Group, LLC 7966.indb 138 10/19/07 6:50:18 AM Property and Area Reconnaissance 139 north prevailing winds Spencer Street low t raffic soil, of cked lope ree s rd pa native er , deg and s ew l weed sses tank ary s allon sanit gra 50-g hlor ) tric rain I,I,I- contain ent d efflu spill (no raffic 5th Street t erate mod ary sanit nt ch re appa tains al s emic CHEMICAL PACKAGING PLANT (vacated) te ncre f in co o tches evidence pa ible round poss derg un ge stora tank allon 500-g cid w/spill a ic sulfur ction dike prote r sewe ed t ress dist on 8’ ou ing tati vege build rom f nce ne fe cyclo imeter r @ pe h of patc tation vege dead lding l bui meta igh 5’ h ound m dirt Figure 7.1 Search of property Notes taken during site reconnaissance for signs of environmental conditions that may have a negative impact on the property the obvious, a flat, barren 1‑acre plot of land is easier and less time consum‑ ing than a 1,000‑acre parcel of property with gullies and thick vegetation When it is not feasible to investigate every foot of a property, minimum coverage should include the following: • • • • Around the perimeter of the property All surface water routes, including dry creek beds All roads, paved and unpaved All areas that are reasonably accessible © 2008 by Taylor & Francis Group, LLC 7966.indb 139 10/19/07 6:50:19 AM 140 Environmental Site Assessment Phase I Some of the more common techniques used to ensure adequate coverage of “accessible land” include the following: • Parallel coverage—Property can be walked in parallel patterns, with 5‑ to 20‑foot separations from the center The distance from each cen‑ terline should depend on the ground visibility • Expanding circles/squares—Property can be walked by starting at the center and walking outward in a methodical fashion This may involve a walk around a high point or an accessible portion Property with a central focal point (e.g., a hill) with a shape conducive to this approach is the most likely candidate for this technique Last, prior to departure to the site, contact the people designated as the contact for the property They will want to be kept informed if the investiga‑ tor is not to be escorted, and they will require notification if the investigator needs an escort Once on site, the investigator must be aware of all possibilities and then some The succeeding items are those most frequently included on an item‑ ized checklist, along with a few other considerations generally overlooked or ignored Topographic Conditions The topographic conditions of the site and surrounding areas should be observed and compared with the topographic maps for the area These will most likely be similar, but topographic maps are not updated frequently A comparative analysis will disclose outdated maps Dated information becomes highly important, especially where there is the likelihood for migration of hazardous substances and/or petroleum products through the soil or into surface water and groundwater In some instances, the city may have recently contracted for planimetric ground con‑ touring of the area Planimetric maps are typically more detailed than topo‑ graphic maps and generally more dated General Description of Structures, Roads, and Fences All structures and other improvements or usage passageways should be described and identified on a schematic of the property The size and number of buildings should be estimated (and confirmed later) along with approximate construction date, number of stories, and probable usage (See Figure 7.2.) Dirt roads, foot paths, streets, and parking facilities provide information as to type, volume, and pathways of travel Fences and walls confine areas that may have had a designed purpose and subsequent use Each item should be identified on the schematic © 2008 by Taylor & Francis Group, LLC 7966.indb 140 10/19/07 6:50:20 AM Property and Area Reconnaissance 141 Figure 7.2 Old, abandoned structure with asbestos-containing transite siding Inside Structural Observations Whether a building is complete or only partial, an effort should be made to observe in-structure impact components that may be indicators of envi‑ ronmental contamination This should include, but not be limited to, the following: • Means of heating and cooling (e.g., gas, oil, or electric): If gas or oil were used, you should locate the storage tank/container • Stains and corrosion: If stains and/or corrosion are observed, you should question the source or cause • Drains and sumps: If there are floor drains and/or sumps (i.e., a pit for draining, collecting, or storing liquids), you need to question their intent and use Although an industrial building generally poses a greater concern than a residence, illegal dumping and illegal drug labs occasionally occur in residences Signs and symptoms of environmental contamination in any structure should result in further investigation at a later date © 2008 by Taylor & Francis Group, LLC 7966.indb 141 10/19/07 6:50:20 AM 142 Environmental Site Assessment Phase I Septic Systems Especially in rural environments, waste is managed by some form of ground waste management system, whether it is conventional leaching fields, leach‑ ing chambers, or aerobic systems Many of today’s waste disposal systems are engineered, but the older systems may have been installed in ground that allows the wastewater to percolate down to the subsurface water table (e.g., aquifer) or run off into surface water (e.g., streams) Some structures, past and present, are built on the cheap, with a big hole in the ground, not unlike an outhouse without a collection system The environmental profes‑ sional should determine, by records or interviews, the age and type of sys‑ tem installed—if one was installed Sanitary Sewers The location of all sanitary sewers should be noted One should also iden‑ tify the drain locations, because sanitary sewer water typically does not get treated while being emptied into a river, stream, or creek beds These are paths whereby runoff of surface water containing hazardous substances and petroleum products may depart the property The river, stream, or creek bed into which the sanitary sewer water emp‑ ties may be on the property or on environmentally sensitive adjoining prop‑ erties For this reason, the destination of associated sewer water should also be determined Water Wells Today, the installation of water wells is a controlled process Twenty years ago, it was not Now, the well‑drilling operator is required by law to cement the surface casing and/or cement intervals where inter-aquifer transfer may occur The intent is to prevent travel of soil contaminants from one segre‑ gated geologic layer to the next or to the groundwater In the past, the driller was not required to comply with any of these procedures, thus older wells pose a greater threat to the groundwater than those more recently installed in accordance with acceptable practices For a rendering of a poorly installed water well, see Figure 7.3 Abandoned wells may pose a problem as well Besides providing a hot spot for someone to fall into, abandoned wells may serve as an easy means for ille‑ gal dumping of hazardous materials The well water may be associated with an aquifer that is used by others who may unknowingly drink the contami‑ nated water A small community using well water may develop an increased incidence of an exotic illness The occurrence of miscarriages and/or deformed fetuses may increase A rare debilitating disease may affect large numbers of a community A rare form of cancer may prevail Sometimes these latter sce‑ narios are the only reason for suspicion within a given population © 2008 by Taylor & Francis Group, LLC 7966.indb 142 10/19/07 6:50:20 AM Property and Area Reconnaissance 143 Open Top no protection from dumping and debris Rope and Bucket direct access to groundwater surface soil sand and gravel Unprotected Surface Area no concrete pad to protect from surface contaminants Porous Curbing potential for subsurface contamination rock formation water formation Figure 7.3 Depiction of unprotected well (Source: Partial extraction from Texas Department of Health: Individual Home Water Supplies Austin, Texas Stock No 2-105, Oct 1970, p 18.) There have been cases where abandoned wells doubled for a septic sys‑ tem Household waste has been innocently piped out to a big hole in the ground Although human waste generally breaks down to a non-hazardous substance, there is a potential for conveyance of the parasites and bacteria in feces Other wastes also may have been disposed of, such as household paint products or motor oil Some second-world countries still have systems in which the water wells are not encased and adequately separated from the community septic system They have no more than a hole into which household and septic waste is discharged Next to the waste hole is an unprotected water © 2008 by Taylor & Francis Group, LLC 7966.indb 143 10/19/07 6:50:22 AM 144 Environmental Site Assessment Phase I well These countries have a lot of problems with diseases conveyed by fecal matter All water wells should be evaluated and the possibilities considered Fur‑ ther research may be indicated after the site visit Drinking Water Sources and Quantity The drinking water may come from personal water wells, cisterns, or city supplies The city water source may be a lake, reservoir, river, or aquifer Today, personal water wells are initially analyzed for quality, and unless the owner is suspicious, the well may not get checked again Contamination may occur subsequent to the initial check, but the owner or potential buyer may not be aware of the contaminant If there is reason to be suspicious, the investigator may collect a sample of the water and have it analyzed for the suspect hazardous substance This may require collection of the water in a sterile, quart‑sized, glass jar with inert sealing material Prior to collection, information concerning the methodology for taking the sample and means for shipping it should be confirmed with the analytical laboratory that will perform the analysis A cistern is a water retention device, built into the ground, for collection and storage of bathing and/or drinking water It may be a rain collection container at the base of a roof drain spout It may be a primitive hole in the ground, or it may be an insulated, contained bladder built into the ground An abandoned cistern may serve as a means for contaminant disposal, or it may even be physically dangerous (e.g., a child could fall in) Some older cisterns contained lead sealant, a source for lead contamination of the envi ronment (See Figure 7.4.) The city water may be on an old system, and lead solder may have been used in some of the soldered joints where there are metal pipes, or lead pipe may even be present The city can provide information concerning lead con‑ tent of the supply lines The lines leading from the supply main may also have lead Lead content in the water can be determined as per Chapter If the results of a sample from a home or other building exceed the acceptable limit of 15 ppb (parts per billion), this should be compared with the supply line analysis performed by the municipality Debris Many properties that have yet to be developed have become a convenient dumping ground Dumping is generally in the form of household junk and motor oil, but industrial dumping may occur as well Domestic dumping may include old tires, auto parts or whole automobiles, plastic jugs, paper, roofing material (possibly containing asbestos), cleaning product containers, unused paint, and so on (See Figure 7.5.) © 2008 by Taylor & Francis Group, LLC 7966.indb 144 10/19/07 6:50:22 AM Property and Area Reconnaissance 145 Figure 7.4 Old cistern found around an old, vacant cabin Figure 7.5 Domestic debris with asbestos-containing roof shingles © 2008 by Taylor & Francis Group, LLC 7966.indb 145 10/19/07 6:50:24 AM 146 Environmental Site Assessment Phase I Industrial dumping comes in all sizes, shapes, and forms Containers gen‑ erally are not labeled and certainly are not traceable A number of scenarios are possible As the cost of industrial disposal increases, the temptation for illegal dumping increases Chemical Storage Containers/Drums Today, all chemical storage containers that are shipped directly from a manufac turer or distributor must be labeled with the trade name, manufacturer, and specific hazards associated with the chemical Labels provide information as to chemicals used on site in a manufacturing operation Take notes, even if there appears to be no associated problem with the containers Sometimes a container is not labeled Labels may get damaged in ship‑ ment, worn away by weather, torn off through rough handling, or eaten away by chemicals (e.g., sulfuric acid dripping down the side of a glass bottle) Some of the worst hazardous waste sites within the United States contain hundreds of thousands of such drums Many leak, and the chemicals in two adjacent containers may not be compatible In other words, they may leak out, mix with one another, and result in a fire or explosion, or react with one another to produce a toxic gas Some may have a residue in the lid, around the opening, causing an explosion when the container is opened For example, oxidized hydrogen peroxide crystals formed in the cap of a storage container have been known to explode simply by the friction of turning the cap Likewise, the drum may never have had a label A chemical may have been transferred from a marked container to an unmarked container A drum may contain only water or it may contain explosives Unmarked drums that no one can identify should be handled with extreme caution, and unless properly trained to manage unknowns, the environmental professional should seek the aid of someone experienced in management of unknown containers Sometimes the contents of drums are known, but their whereabouts are unknown For instance, witnesses know that several mercury‑containing drums were buried in a field, but they not know their exact location Steel drums have a “maximum life expectancy” of fifty years, and locating suspected burial sites requires speculation and extensive soil sampling (i.e., a Phase II assessment) Some may also be detected by the use of a magnetometer Do not be surprised to find drums in the middle of undeveloped land After three hours walking beautiful country property you may begin to wonder why you are spending so much time with no findings Then you bust out into an opening and find rusting drums oozing with black goop You just never know (See Figure 7.6.) Soil Mounds Backfill is identified by obvious disturbances in the surface of the soil In a field of vegetation and/or grass, newly placed backfill will have nothing © 2008 by Taylor & Francis Group, LLC 7966.indb 146 10/19/07 6:50:24 AM 152 Environmental Site Assessment Phase I Smell the surface water (but not drink it) Does it have an odor? If so, describe the odor in your notes Understand, however, that no two people will describe a given odor the same way Although there may be complaints of foul-tasting water, avoid the temptation to taste the water Simply note others’ comments Odd smells and/or tastes should be further investigated Surface Impoundments According to the EPA, a surface water impoundment is a contained surface enclosure (e.g., pits, ponds, and lagoons).1 Surface water impoundments may be used as settling ponds for separating particulates and/or chemicals from water In industry, surface impoundments have been used to contain con‑ taminated wastewater In 1986, the EPA reported that there were more than 195,000 waste treatment surface impoundments nationwide The breakdown was as follows:2 • • • • • • Oil/gas related: 65% Mining: 10% Agriculture: 9% Industrial: 8% Municipal: 1.2% Other: 6.8% An additional 3,200 surface impoundments were associated with known hazardous waste management facilities for treatment, storage, and disposal purposes Then, too, some facilities discharged their wastes directly into nearby surface waters.2 Cities may have surface impoundments to which initial street and soil runoff is conveyed for evaporation, leaving behind the contaminants These contaminants may then be cleaned up and properly disposed of, or in the past they have been left behind when the need no longer existed (See Figure 7.12.) Where a surface impoundment is (or was) present, there may be (or were) hazardous substances improperly contained Further investigation is indi‑ cated, and the EPA has published A Manual for Evaluating Contamination Potential of Surface Impoundments, which provides more in‑depth guidance.l Aboveground Structures Other than Buildings Aboveground structures include, but are not limited to, chemical storage con‑ tainers, chemical treatment vats, railroad tracks, sheds, and storage facilities Aboveground butane storage containers generally provide a fuel source for heating and cooking Improper connections and/or management may result in an explosion, leveling buildings and other structures in the imme‑ diate vicinity © 2008 by Taylor & Francis Group, LLC 7966.indb 152 10/19/07 6:50:27 AM Property and Area Reconnaissance 153 Figure 7.12 Depiction of a surface impoundment with a liner that is leaking haz‑ ardous substances into the ground Chemicals may be contained within large metal storage containers Find out what they hold Look for corrosion, leaks, and spills Check for secondary spill containment structures (e.g., dikes and concrete pads) In a sawmill, where wood was being treated with pentachlorophenol, the surface water and groundwater were becoming contaminated as the wood came off the treatment line and was stacked on the unprotected ground next to a stream The soil was not only sandy but highly porous, and the stream was within 20 feet of the off-load stacking area Railroad cars frequently carry chemicals A derailment or an unobserved leak of contents may result in the release of hazardous substances The area around railroad tracks should be inspected Storage facilities are generally no more than an old wood shack The structure itself may not pose a problem, yet it may be used to isolate hazardous substances from the main building Many flammable chemicals are kept in shacks These should be checked for content (past and present), leaks, and spills If any of these appear to be a potential problem, note the structure of the shack, the surfacing material, and the proximity to other points of interest on the property All aboveground structures should be noted Further investigation may be required Signs of Subsurface Structures Subsurface structures include sanitary sewers, underground transformer vaults, gas/oil pipelines, and underground storage tanks Most will have © 2008 by Taylor & Francis Group, LLC 7966.indb 153 10/19/07 6:50:29 AM 154 Environmental Site Assessment Phase I some form of visible structure that can be identified The older they are and the longer they have been obsolete, the greater the chance that the investiga‑ tor is looking for a “needle in a haystack.” Sanitary sewers should be located and plotted on the area diagram They may be used by those on site or in the periphery for illegal dumping of haz‑ ardous waste, or they may provide a conduit for hazardous ground contami‑ nants to travel from a remote site to other properties Gasoline may enter into a crack in the sanitary sewer, travel up the line into someone’s home around an ignition source, and explode Structures may contain hazardous chemicals that have traveled from a remote area There may be an odor There may be illnesses Yet, there is no immediately apparent source, and the chemical may go unidentified without a clue as to where it came from or what it might be This requires a little more investigation Transformer vaults are buried in the ground They are compartmentalized and may have several transformers Gas and oil pipelines are frequently identified by a warning sign posted every 100 feet along the easement, or by long stretches of ground where trees and bushes have not grown, which are more apparent from the air The pre‑ viously trenched ground appears to have been disturbed and is frequently differentiated from the surrounding terrain Leaks may be associated with odor or discoloration Underground storage tanks may be in use at present, or they may have been closed, with the access port sealed and covered with soil or concrete If not obsolete, they should have relief valves and monitoring ports, but not assume they When looking for signs of existing underground storage tanks, examine the grounds for closure plates, adapters for usage, attach‑ ments, and vents If an underground storage tank has been abandoned, the owner may have gone through proper closure procedures or may have left the tank with chemicals still in it, with or without sealing the openings These open‑ ings are your evidence of its existence If the owner has sealed the open‑ ings and covered the evidence, the obvious signs become more elusive In such a case, the ground around the buried tank may show signs of set‑ tling, or additional cement may have been poured over the access ports (See Figure 7.13.) Ground that has been dug and loosely backfilled may settle, creating a concave appearance on the surface If there was an asphalt or concrete covering, this material may show signs of cracking If a surfacing material (e.g., concrete) existed prior to an underground storage tank installation, the owner may have had to jack hammer through the material and redo the sur‑ face after installation In the latter situation, the new surface will vary from the old Note these observations Today, underground storage tanks are protected from corrosion and leaks by one or more of the various methods available, and some may have a backup concrete vault Gasoline underground storage tanks must undergo © 2008 by Taylor & Francis Group, LLC 7966.indb 154 10/19/07 6:50:30 AM Property and Area Reconnaissance 155 Figure 7.13 Vacated building in a small town The concrete patches are an indica‑ tion of prior service station gasoline pump usage at this located routine leak testing and are reported to the EPA equivalent for the state in which the tanks were installed However, many have not been reported; some have been in the ground for more than fifty years and others for as long as one hundred years These are probably steel, are without protection, and most likely are leaking Leaks may be due to corrosion, damage to the tank, or inadequate fit‑ tings Corrosion occurs with evaporation and water settling Damage can occur “upon installation,” when the tank is placed on a sharp, hard object; when excessive weight or pressure is applied to the exterior of the tank from aboveground activities and inadequate protection; or if the tank had prior damage (e.g., cracks) Inadequate fittings may result in corroded seals, improper seals, or damaged seals/fittings Odors Be particularly alert to odor; and, remember, not all hazardous chemicals smell bad The presence of an odor that does not have an explanation should trigger further investigation If you smell “something,” not plan to return later to investigate Note the type of odor, the intensity, and the source If you have time, try to track it down while the odor is still present Otherwise, olfactory fatigue will occur, and you may not be able to: (1) smell the chemical, (2) track its source, or (3) differentiate the odor from others © 2008 by Taylor & Francis Group, LLC 7966.indb 155 10/19/07 6:50:31 AM 156 Environmental Site Assessment Phase I Figure 7.14 Effluent pipe in the background, discharging from the building onto the surface, and a septic drain in the foreground Effluence from Buildings Effluence is a liquid or solid material that is being discharged from a building or process structure It may be a hazardous industrial chemical, human waste, or uncontaminated water It may be discharged through a pipe into a well or water source, or it may be discharged through a hole in the wall to the ground outside It may pour, or it may dribble This is how lakes and streams were pol‑ luted prior to passage of strict regulatory requirements (See Figure 7.14.) Effluence of any kind should be noted Track down the source Determine the use of all open‑ended pipes that have no explained usage, even if there is no discharge at the time of the site reconnaissance Further review and search for information may be indicated Air Emissions Contaminated air may be exhausted from a building through a stack or through a vent on the side of a building, or be forced outside A system may © 2008 by Taylor & Francis Group, LLC 7966.indb 156 10/19/07 6:50:31 AM Property and Area Reconnaissance 157 be sophisticated and have an associated air scrubbing unit, or it may be a simple pedestal fan, blowing contaminants out the window As with efflu‑ ence, the air emissions will require further investigation Signs of Mining/Quarry Activities Hazards associated with mining activities have to with the type of mining in progress For instance, granite will oftentimes have radon, and limestone will have silica Radon is a radioactive hazard that can cause lung cancer, and silica dust can cause a debilitating lung disease The investigator will need to know not only the type of mining but also the processes and procedures common to the industry Figure 7.15 depicts the site of an old quarry—land that has since been developed Figure 7.15 Remains of a quarry, with some of the area having received soil from a remote location Additional research was needed to ascertain the source of the soil © 2008 by Taylor & Francis Group, LLC 7966.indb 157 10/19/07 6:50:31 AM 158 Environmental Site Assessment Phase I A common source of groundwater contamination around mines is acid‑bearing water Water that extracts minerals from the mine wastes is referred to as “acid mine drainage.” Water passes through sulfide mineral components of the tailings (e.g., the unused portion of the extracted, mined resource), spoil piles, or the mine/quarry itself Then, the sulfide is oxidized to sulfuric acid This may occur anywhere the sulfide content of the soil is high Quarry activities are generally noisy and oftentimes dusty Past opera‑ tions have used spent oil to keep down the dust and debris on the dirt roads Some have had PCBs and other hazardous materials in the oil Find out what type of material is being extracted from the land and what will be done with the resulting hole Some obsolete holes are used for the disposal of wastewater sludge—hazardous and/or non‑hazardous material Electrical Supply System Electrical supply systems use transformers to increase or decrease the elec‑ tricity delivered to a site These transformers contain a coolant used to con‑ tain polychlorinated biphenyls (PCBs) PCBs are a suspected liver carcinogen that is retained in the body for long periods of time They accumulate in the body and remain in the fatty tissue for extended periods of time Thus, it only adds to the body burden It is not readily metabolized or eliminated The transformers may contain from trace amounts [5 ppm (parts per mil‑ lion)] to 5,000 ppm of PCBs in the oil It is nonflammable; therefore, it has been an excellent substance for use with electrical delivery systems In 1975, PCBs were outlawed for use in new transformers However, transformers may have a life expectancy of as much as one hundred years, and the older transformers have a high probability of PCB content PCB‑containing oil does not pose a health hazard unless it gets into the groundwater or is inhaled, absorbed through the skin, or drunk Leaks and spills may result in airborne exposures and/or be a source of skin contact and absorption PCB‑containing oil is not an EPA concern unless the amount of PCB is greater than 50 ppm As long as the material is contained within the transformer and there are no leaks, exposure is a low probability There are several types of transformers: (1) pole mounted, (2) pad mounted, and (3) underground vaulted The pole‑mounted types may be clearly marked, “No PCBs.” However, they may not be marked, or they may have a sticker that requires a magnifying glass to read The electric company that owns the transformer may have records as to PCB content (See Figure 7.16.) However, they generally not You may request a field evaluation by the electric department, but it may come back with no more information than you had prior to the request Where the con‑ tent is unknown and there is a need to know (i.e., the transformer is leaking onto the site), a sample collection and analysis can be requested from the electric company or a sample may be taken of the leaked material Leaks gen‑ erally occur around the seals, including the seals on top of the transformer © 2008 by Taylor & Francis Group, LLC 7966.indb 158 10/19/07 6:50:32 AM Property and Area Reconnaissance 159 Figure 7.16 Pole-mounted transformers stored in the back of a storage shed in the country in a residential environment All old and new transformers are stored on cracked concrete pad The oil is under pressure Damage to the integrity of the transformer may occur as well Reports of transformers being subject to target practice are not unheard of The pad‑mounted transformers not always have a fluid Temporary construction site transformers not contain “oil,” and the external cabinet is generally locked on all pad‑mounted transformers Those pad‑mounted transformers that have oil may also leak around the seals A few drops may look like a puddle, and oil stains are generally observed around the con‑ crete pad on which the transformer has been mounted (See Figure 7.17.) Underground vaults generally contain multiple transformers, each with different PCB content in the oil Although some vaults are partially under‑ ground and accessible for visual inspection, many are under heavy manhole covers A special tool and/or equipment may be required to open the cover This should be done by the electric company Once again, look for leaks and damage to the integrity of the unit Cemeteries Potential pollutants from deteriorated caskets include embalming fluid (e.g., formalin), metals (e.g., arsenic was used for embalming during the Civil War era), salts, and microorganisms For each body buried, there is an average of about quarts of formalin in the grave site Formalin is a 38% aqueous solution of formaldehyde with 15% methanol Because it is © 2008 by Taylor & Francis Group, LLC 7966.indb 159 10/19/07 6:50:33 AM 160 Environmental Site Assessment Phase I Figure 7.17 Pad-mounted transformer with “No PCB” label water soluble, the formaldehyde‑bearing formalin may easily migrate to the groundwater Consider the following theoretical situation The formalin has migrated horizontally to your property, which is located adjacent to the cemetery This is a country setting, and your client decides to install a water well He pen‑ etrates the previously impermeable layers of rock and soil, but the well is not properly sealed during penetration The well, thus, creates a means for formalin contamination of the groundwater (See Figure 7.18.) Although the above scenario is not a recorded event as of this publica‑ tion, there have been isolated reports of microbial diseases originating in graveyards In Germany during the late 1800s, people living near cemeteries were reported to have a higher incidence of typhoid fever than the normal population This was attributed to proximity to graveyards The investigator should also be alert to the potential for a client to install a water well on property adjoining a cemetery A new well may provide a con‑ duit for the migrated contaminant to enter the groundwater, or the ground‑ water may already be contaminated Minimum distances between cemeteries and drinking water wells have been legislated in England, France, and Hol‑ land—300 feet, 328 feet, and 164 feet, respectively.3 © 2008 by Taylor & Francis Group, LLC 7966.indb 160 10/19/07 6:50:33 AM Property and Area Reconnaissance 161 Figure 7.18 Tombstone in an old cemetery with deteriorated grave markers poten‑ tially dating back to the Civil War era, in the mid to late 1800s Other Note any objects or conditions that appear to be out of the ordinary or the presence of which you cannot explain This may include, but not be limited to, the following: • • • • • • • • Drainage pathways and erosion plains Evidence of old structures Outcroppings, stockpiles, and embankments Heavy equipment Monitoring wells Gas wells Pesticides and/or herbicides Tire tracks in the soil Many of these will not jump out and scream, “I am here!” They must be derived from careful observation © 2008 by Taylor & Francis Group, LLC 7966.indb 161 10/19/07 6:50:34 AM 162 Environmental Site Assessment Phase I Figure 7.19 Property tax map used for sketching usage and noteworthy items asso‑ ciated with adjacent properties Reconnaissance of Adjacent Properties Adjacent properties may have an impact on the targeted property Ground contamination of one property may migrate to the grounds and/or drinking water of another Draw a diagram of the area, and identify relevant informa‑ tion on your area drawing or an area map The succeeding subjects should be addressed (See Figure 7.19.) Property Usage Property usage is an indicator for what hazardous materials may be used in the area Adjacent properties may be undeveloped or developed; the developed properties may be residential, commercial, or industrial Unde‑ veloped property may be used for local dumping If so, note what appears to © 2008 by Taylor & Francis Group, LLC 7966.indb 162 10/19/07 6:50:35 AM Property and Area Reconnaissance 163 be dumped on these properties Note the location of signs of solid waste or liquid dumping The type of commercial/industrial usage should be specified, especially where it may be associated with hazardous substances As will be discussed in Chapter 10, different commercial/industrial activities use different known waste products and hazardous chemicals in their processes For instance, a chrome‑plating operation will use chromic acid, and battery recycling plants will use large quantities of lead Even the construction business generates hazardous waste Be wary of these processes Remember, the adjacent properties also have a history However, inves‑ tigation of adjacent properties could cost considerable time Thus, it is not feasible to undertake such an investigation unless your reconnaissance or interviews give you a reason to suspect something If further investigation is indicated, recommend that it be performed Understand, however, that your client may be reluctant to pay extra for you to follow your hunch But if the owner ignores your recommendation, you will be on record as having noted the potential problem Storage Tanks and Drums Note the presence of storage tanks and drums Locate and check the integ‑ rity of all aboveground and underground gasoline storage tanks, butane tanks, chemical tanks, and drums The underground storage tanks will be easy to identify as those associated with existing gasoline stations Obsolete gasoline stations are not as obvious, as in Figure 7.13 Aboveground storage tanks are easily identified An attempt should be made to identify the contents The contents will generally be noted on the outside of the container, along with warning labels The owner may be reluc‑ tant to allow access and/or supply information Sometimes underground industrial chemical storage tanks can be identi‑ fied, but it can be difficult without access to the property or information from workers or management at the location The information may be helpful, but obtaining it may require additional finesse Very few investigators go this far Effluent and Air Emissions Note sources of effluence and air emissions on the adjoining properties The effluent from an adjoining property could contaminate the property being assessed and depreciate its value The composition of the effluent may not be identifiable without sampling Note its location and the effect it appears to have on the environment Air emissions are generally visible A stack is a definite indicator Not so obvious is the pipe or hole in the wall where something other than just air is being emitted into the atmosphere Many materials that are exhausted into the air have a color Some appear steam‑like or result in a distortion of © 2008 by Taylor & Francis Group, LLC 7966.indb 163 10/19/07 6:50:35 AM 164 Environmental Site Assessment Phase I image when one looks through it Look for the exit hole, pipe, tube, or stack The type of operations being performed at this location will provide a clue as to the type of substance being exhausted Whatever is being exhausted may impact the surface soils and water The end result may be contaminated drinking water and pasture lands For example, air emissions of hydrogen fluoride into pasture land could result in dental deterioration, an inability of the livestock to properly chew the grass, and the ultimate deterioration in the health of the livestock Reconnaissance of the Surrounding Areas The areas surrounding the site are typically evaluated through record reviews However, some sites that could have an impact on the property are not on record The records are based on an owner complying with registra‑ tion requirements and/or citations based on discrepancies noted by a neigh‑ bor or compliance officer A quick drive around the vicinity of the site could uncover some of the not‑so‑obvious activities that could impact the property For instance, all dry cleaning operations should be on the RCRA Notifier’s list They are not all listed Sketch these suspected sites on an area drawing or map Where they may lead to probable contamination of the ground and/or groundwater, note means for the contaminant to potentially reach the assessment property (See Figure 7.20.) Summary Information gathered up to this point may be used as an aid to assist the inspector in developing a plan of attack The property should, at a minimum, be inspected for the following: • • • • • • • • • • • • • Topographic conditions General description of structures, roads, and fences Sanitary sewers Water wells (e.g., obsolete wells) Water sources (e.g., lake reservoir, operated by the city) Debris (e.g., construction waste) Chemical storage drums (e.g., 55‑gallon steel drums with liquid con‑ tents and no labels) Soil mounds Ground depressions Distressed, stained soil (e.g., oil stains) Poor or no vegetation (e.g., no growth in the center of a grassy field) Dead wildlife (e.g., dead coyotes around a pond) Evidence of surface water contamination (e.g., oil film on the surface of the water) © 2008 by Taylor & Francis Group, LLC 7966.indb 164 10/19/07 6:50:36 AM Property and Area Reconnaissance 165 Figure 7.20 Local street map used to sketch usage and noteworthy items of the sur‑ rounding area • Surface impoundments (e.g., unlined impoundment in porous soil) • Aboveground structures other than buildings (e.g., storage vessels) • Signs of subsurface structures (e.g., gas/oil pipelines and underground storage tanks) • Odors (e.g., pungent odor in the soil) • Effluence from the building(s) • Air emissions • Ground irregularities • Signs of mining/quarry activities • Electrical supply system • Cemeteries Any given property does not exist separate and apart from the influence of adjacent properties One should also take a look at the adjoining areas, including the following: © 2008 by Taylor & Francis Group, LLC 7966.indb 165 10/19/07 6:50:37 AM 166 Environmental Site Assessment Phase I • Property usage • Storage tanks and drums • Effluent and air emissions More distant properties may affect the property through contaminated soils, groundwater, and surface water Property usage should be checked for areas within a given radius of the site A minimum ½-mile radius from the boundaries of the site should be visually inspected, if not by foot, by a slowmoving vehicle References U.S EPA: A Manual for Evaluating Contamination Potential of Surface Impound‑ ments Office of Drinking Water, Washington, DC, 1978, p Groundwater Protection Unit Staff: Ground‑water Quality of Texas—An Overview of Natural and Non‑affected Conditions TWC Report 89‑01, Texas Water Commis‑ sion, Austin, TX, Mar 1989, pp 124–5 Ibid., p 112 © 2008 by Taylor & Francis Group, LLC 7966.indb 166 10/19/07 6:50:37 AM ... Because it is © 2008 by Taylor & Francis Group, LLC 79 66.indb 159 10/19/ 07 6:50:33 AM 160 Environmental Site Assessment Phase I Figure? ?7. 17? ??Pad-mounted transformer with “No PCB” label water soluble,... Taylor & Francis Group, LLC 79 66.indb 149 10/19/ 07 6:50:26 AM 150 Environmental Site Assessment Phase I Figure? ?7. 10 Hardened, cracking wastewater sludge taken from landfill not be readily apparent... non‑potable groundwater and be conveyed to other properties © 2008 by Taylor & Francis Group, LLC 79 66.indb 151 10/19/ 07 6:50: 27 AM 152 Environmental Site Assessment Phase I Smell the surface