EVEN 4100 Environ Sampling & AnalysisAnnouncements

indoor labs in ECCE 1B47

HAZWOP first lecture/lab – Wed, Sept 2, ECCE 1B47 second lecture – Thur, Sept 3, here

Labs first lab – Wed, Sept 9 field trip (on foot) for Phase I ESA assume you need all safety equipment and

clothing

Environmental Media of ConcernSolid

soil, sediment, bedrock building materials, containers

Liquid surface water ground water mixtures

Gas ambient air, indoor air soil vapor

Biota

Contaminants of ConcernOrganic compounds Inorganic compounds

Contaminants of ConcernOrganic compounds

volatile organic compounds solvents (e.g., acetone, alcohols)C O

C

C

C

O

H H

H

H H

H

OHC

CH3

H3C

CH3

Contaminants of ConcernOrganic compounds

volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons

(e.g., TCE, PCE)

Contaminants of ConcernOrganic compounds

volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons

(e.g., trichloroethene, tetrachloroethene)C C

Cl

H

Cl

Cl

C C

Cl

Cl

Cl

Cl

Contaminants of ConcernOrganic compounds

volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons (e.g., TCE, PCE) petroleum constituents – gasoline

BTEX

Contaminants of ConcernOrganic compounds

volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons (e.g., TCE, PCE) petroleum constituents – gasoline

BTEX (benzene, toluene, ethylbenzene, xylenes)

CH3

H2C

CH3

CH3

CH3

benzene

xylenes

ethylbenzene

toluene

Contaminants of ConcernOrganic compounds

volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons (e.g., TCE, PCE) petroleum constituents – gasoline

BTEX (benzene, toluene, ethylbenzene, xylenes) methyl tert-butyl ether H3C C

CH3

CH3

OCH3

Contaminants of ConcernOrganic compounds

volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons (e.g., TCE, PCE) petroleum constituents – gasoline

BTEX (benzene, toluene, ethylbenzene, xylenes) methyl tert-butyl ether

ketones (methyl ethyl ketone) refrigerants (chlorofluorocarbons)

Contaminants of ConcernOrganic compounds

volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons (e.g., TCE, PCE) petroleum constituents – gasoline

BTEX (benzene, toluene, ethylbenzene, xylenes) methyl tert-butyl ether

ketones (methyl ethyl ketone) refrigerants (chlorofluorocarbons)

analysis by GC/MS

Contaminants of ConcernOrganic compounds

volatile organic compounds solvents (e.g., acetone, alcohols) chlorinated hydrocarbons (e.g., TCE, PCE) petroleum constituents – gasoline

BTEX (benzene, toluene, ethylbenzene, xylenes) methyl tert-butyl ether

ketones (methyl ethyl ketone) refrigerants (chlorofluorocarbons)

analysis by gas chromatography/mass spectrometry

EPA Method 8260

Contaminants of ConcernOrganic compounds

semi-volatile organic compounds solvents (chlorinated benzenes)

Cl

ClCl

Contaminants of ConcernOrganic compounds

semi-volatile organic compounds solvents (chlorinated benzenes) petroleum constituents – diesel, fuel oil

PAHs

Contaminants of ConcernOrganic compounds

semi-volatile organic compounds solvents (chlorinated benzenes) petroleum constituents – diesel, fuel oil

polycyclic aromatic hydrocarbons (naphthalene, phenanthrene, styrene, etc.)

CH2

Contaminants of ConcernOrganic compounds

semi-volatile organic compounds solvents (chlorinated benzenes) petroleum constituents – diesel, fuel oil

polycyclic aromatic hydrocarbons (naphthalene, phenanthrene, styrene, etc.)

pesticides, herbicides organochlorine compounds (e.g., DDT) organophosphate compounds (e.g., malathion) triazine compounds (e.g., atrazine)

ClClCl

Cl Cl

H

S

P

O

O

OO

S

O

O

N

N

N

NH

NH

Cl

Contaminants of ConcernOrganic compounds

semi-volatile organic compounds PCBs

Contaminants of ConcernOrganic compounds

semi-volatile organic compounds polychlorinated biphenyls (PCBs;

Arochlor nnnn)

Contaminants of ConcernOrganic compounds

semi-volatile organic compounds polychlorinated biphenyls (PCBs;

Arochlor nnnn) dioxins and furans

2,3,7,8-tetrachlorodibenzo-p-dioxin tetrachlorodibenzofuran

O

Cl

ClCl

Cl

O

O

Cl

ClCl

Cl

Contaminants of ConcernOrganic compounds

semi-volatile organic compounds polychlorinated biphenyls (PCBs;

Arochlor nnnn) dioxins and furans

2,3,7,8-tetrachlorodibenzo-p-dioxin tetrachlorodibenzofuran

analysis by GC/MS EPA Method 8270

Contaminants of Concern Inorganic compounds

metals metalloids

Contaminants of Concern Inorganic compounds

metals copper, zinc, lead cadmium, mercury, silver aluminum, manganese chromium

metalloids arsenic, selenium antimony

Environmental Site AssessmentComprehensive Environmental Responsibility, Compensation, and Liability Act (CERCLA), 1986(“Superfund”)

Environmental Site AssessmentComprehensive Environmental Responsibility, Compensation, and Liability Act (CERCLA), 1986(“Superfund”)

Liability strict – wrong-doers are liable for damages

without requiring proof of negligence joint and several – any and all of wrong-

doers can be forced to pay for all damages in cases of indivisible harm (proportion of total harm attributable to each wrong-doer cannot be determined)

Environmental Site AssessmentCERCLA liability

current property owners responsible for contamination cleanup regardless of responsibility for contamination

property owners, lenders, and lessees can potentially be held liable (civil and criminal)

prospective property owners must complete “due diligence” assessments to avoid liability

Environmental Site AssessmentWhat is due diligence for CERCLA?

Phase I ESA commercial and industrial real estate demonstrates lack of liability; allows “innocent

landowner” defense important for brownfield sites requires “all appropriate inquiry” by purchaser

Environmental Site AssessmentWhat is “All Appropriate Inquiry”? requirements for property

owner defenses under CERCLA

federal minimum standards for conducting ESAs

additional requirements beyond ESAs

environmental liens market value versus purchase

price analysis maintenance of institutional

and engineering controls in future

Environmental Site AssessmentWhat is a Phase I ESA?

assessment of potential or existing environmental liabilities of a site

real estate transactions brownfield sites

components site visit (including neighboring properties) review of operating records, zoning permits interviews historical aerial photography identification of “recognized environmental

conditions” (no sampling)

ASTM E1527-13 (on course web site here)

Environmental Site AssessmentsPhase I ESA

ASTM E1527-13

Environmental Site AssessmentWhat are “Recognized Environmental Conditions” (RECs)? “…Presence or likely presence of any

hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of release…into structures on the property or into the ground, groundwater, or surface water of the property.”

petroleum? excluded from CERCLA; not part of AAI included in ASTM E1527-13

Environmental Site AssessmentExamples of RECs

underground storage tanks (current or former)

even if no leaks have been reported oil and gas wells or tanks significant soil staining attributable to

spills observed leaks (drums, tanks, etc.) floor drains with staining adjacent property with identified

contamination dry cleaning (on site or adjacent) adjacent landfill

mining waste rock piles ordraining adits

Environmental Site AssessmentExamples of RECs

farm and ranch land dumps, cattle dipping vats improper pesticide use

Current/former auto dealerships/repair shops

Commercial properties with current/former septic systems

Previously demolished buildings asbestos in soil

Oily sheen on surface water Leaking electrical transformers

Environmental Site AssessmentHistorical RECs (HRECs)

conditions that would qualify as RECs that have been properly remediated

“no further action” status (may still be considered a REC) depends on site-specific cleanup levels example: petroleum storage tank formerly on

site, removed, contaminated soil removed, regulatory agency approves remediation result

Environmental Site AssessmentsWho hires environmental consultants to do Phase I ESAs? purchasers of commercial and

industrial properties owners of commercial and

industrial properties tenants of commercial and

industrial properties attorneys government agencies non-profit organizations

Environmental Site AssessmentsWho can conduct a Phase I ESA? ESAs be conducted under

supervision of an “Environmental Professional”

Professional Engineer Professional Geologist

3+ years experience B.S. degree in science/engineering

5+ years experience Anyone with 10 years of

experience Strongly recommend that the

Environmental Professional conduct site reconnaissance and interviews with owners

Environmental Site AssessmentPhase I ESA steps

client-provided information historical research regulatory agency research interviews

property owners site personnel

site reconnaissance subject property and adjacent properties assess topography, drainage, groundwater

flow direction report

Environmental Site AssessmentClient-provided information

title records known environmental liens activity and use limitations (AULs) “specialized knowledge” about

environmental problems “commonly known” information “reasonably ascertainable” information valuation reduction for environmental

issues owner, occupant, lessee, property

manager information reason for performing Phase I ESA

Environmental Site AssessmentHistorical research

search of records regarding contamination required distances based on site type,

contaminant type adjacent to property 1 mile

up-gradient sources back to “first developed use or 1940,

whichever is earlier” database research companies

historical aerial photos and topographic maps fire insurance maps land titles; zoning and building permit records mining claims

time resolution of about 5-year intervals

Environmental Site Assessment Interviews

conducted by Environmental Professional must include key personnel

current site owner current site manager current occupants and lessees

abandoned properties must interview adjacent property owners

questions current use, chemicals on site knowledge of previous use knowledge of environmental investigations

Environmental Site AssessmentSite reconnaissance

should be done by Environmental Professional

entire property (to extent practical) interior

maintenance areas chemical storage and use areas boiler rooms

exterior document any access limitations

locked rooms, gases, dangerous access snow cover

identify RECs document with photographs

Environmental Site AssessmentReport

describe purpose and scope of services document all findings

list RECs identified identify information gaps

were standards met? assess significance of gaps relative to RECs

provide opinions regarding RECs recommend additional investigation for

RECs list environmental concerns outside of

Phase I scope section 13.1.5 has partial list

declare certification as Environmental Professional

Environmental Site AssessmentPitfalls

Phase I ESAs often regarded as a commodity

lowest bidder regardless of quality example: Argo Mine, Boulder County

clients may not prioritize delivery of information

potentially different opinions about RECs caution regarding

“reliance letters” letter from one party to

another allowing reliance on previousPhase I ESA report

Environmental Site AssessmentsPhase I ESA

example:Valmont Butte,Boulder, Colorado

report

Environmental Site AssessmentBrownfield sites CERCLA property where re-

use or re-development is complicated by the presence or perceived presence of environmental contamination

potential liability limits remediation of under-used or abandoned properties

neighborhood blight reduced value of

surrounding property

Environmental Site AssessmentBrownfields Redevelopment – Small Business Liability Relief and Revitalization Act, 2002 liability protection for purchasers and

owners of contaminated property must conduct “all appropriate inquiry” to

qualify for liability protection other versions of innocent landowners

bona fide prospective purchaser purchaser unaware of another’s claim to property

title contiguous property owner

owner unaware of contamination from adjacent property

ability to apply for grants to pay for property remediation and re-development

Environmental Site AssessmentBrownfields grant

example:Elysian Park,Jamestown, Colorado

proposal

Environmental Site AssessmentsPhase II ESA

assessment of expected environmental liabilities of a site

sampling and analysis type, distribution, and extent of hazardous

substances components

Sampling and Analysis Plan Quality Assurance Project Plan Health and Safety Plan Report – purpose, summary of sampling and

analysis, health risk assessment, data validation, results and recommendations

ASTM E1903-11