I Just Want to Do a Phase II Environmental Site Assessment
We have that telephone call quite often. The caller usually says, “Look, just give me an estimate for a Phase II Environmental Site Assessment. I don’t want to do a Phase I.” To which we respond, “Okay, so you have already had a Phase I done?” “No, but I know it was a gas station.” At which point we explain how skipping the Phase I risks omitting information and data which could affect the type of testing you do in the Phase II.
Due Diligence
We further explain that in so doing, the caller may not be exercising due diligence in determining if the site is or could be contaminated from usage of the itself or properties in the vicinity. Why the concern about due diligence? Well, if due diligence is exercised via a Phase I and, if required, a Phase II, and contamination is found later on, Superfund (CERCLA, Comprehensive Environmental Response, Compensation, & Liability Act, www.epa.gov) is supposed to cover the cleanup. Considering cleanups can start at less than $50,000 and run into the millions, that is nothing to take lightly.
What Could be Omitted on the Site Itself?
Let’s use the gas station example. A gas station today is not necessarily a gas station yesterday. In the 1950’s to mid-1970’s, a gas station was normally a full service station, not the convenience store that sells gasoline and diesel fuel today. Not only did they sell fuel from underground storage tanks, but they quite often dumped used oil, chlorinated carburetor cleaner, and other petroleum based wastes into a used underground storage tank. And, yes, those tanks leaked just like the fuel tanks. At the end of the day, they often hosed down the floor of the repair shop and squeegeed it out the door onto the pavement, grass, dirt, road, and storm drains. Oh, by the way, they also had hydraulic oil tanks underground for the lifts, which also leaked.
A lot of the details on the site usage would be missed by jumping to a Phase II. The operations above raise the need to include used oil, solvents, hydraulic oil, and heavy metals from the used oil in the Phase II. But guess what? Prior to it becoming a service station in 1960, it was part of a former celery field for 30 years where every pesticide available was used. And that is an even bigger omission. One would not necessarily have discovered that by skipping the Phase II.
How about the Vicinity?
Well, it turns out, there was a perchloroethylene (perc) contaminated dry cleaner right across the street. But it is clear across the street, who cares? You should because that contamination could have migrated to your site and you could end up bearing the cleanup cost. And by the way, the ASTM E 1527 -13 Standard E-27 for Phase I’s (www.astm.org) considers that an adjacent property – the road offers no separation. Oh, and right down the street was a paint and body shop which was less than meticulous in handling and disposing solvents and paints. Matter of fact, the groundwater plume from that operation is now at the edge of your site.
Conclusion
So that should be enough information for you to decide that skipping a Phase I is not a good idea. If you do, the consequences may be more than you can stand – emotionally and financially!
Further Assistance
If you need any help, Environmental Safety Consultants (www.escflorida.com) is here. We are a Florida licensed environmental engineering company with a CIH on staff. We have the credentials and experience to help you complete your industrial hygiene project.
We are just a telephone call (800-226-1735) or an e-mail away (escinc@verizon.net). Contact us today!
first and as a last resort personal protective equipment (PPE). Why is PPE considered a last resort? Because it is the last line of defense. If it fails, your workers may be ex-posed to hazardous airborne concentrations. Therefore, OSHA prefers that the hazard be eliminated or reduced to a level that is either nonhazardous or is as low as reasonably achievable.
Assuming that you are in charge of Safety, you need to control the selection and must make sure that the players understand the objective. You want to be clear and concise. For example, you may advise the players that our objective is to determine if our painters applying the primer and finish coats are being overexposed to methylene chloride. They spray the paints off and on for a total of six hours during their eight hour shift five days a week. We have exhaust ventilation in the paint spray booths and they wear full facepiece air purifying respirators equipped with organic vapor filters piggybacked with particulate filters. Assuming the respirators have the proper protection factor, what are they exposed to if the respirator fails or they do not don it properly? We want to know what the airborne methylene chloride concentration is on an eight hour time weighted average (TWA) basis and on a fifteen to thirty minute short-term basis. Does it exceed the limits of OSHA (
The specific industrial hygiene testing depends on the source of the hazard and the operation. In general, the first step is to define the objective of the testing. For example, the objective may be to determine if there is an oxygen deficient atmosphere in a chemical vat during a cleanout operation. Details are needed on the operation to establish the testing approach. For the vat example, the operation may involve two maintenance employees who clean out the vat during a four hour period once a week. The vat is emptied and dried out on Friday. On Monday, the two employees are lowered down into the vat after donning personal protective equipment. They use absorbent cleaning towels and an innocuous cleaner. The next step is to determine how the objective will be met.
Another option for an operation that is established and being used is to monitor the complaints or adverse health conditions. Then those are compared to potential health impairments identified on the Safety Data Sheet. This may actually tell you what the constituent of most concern is. Take note that we are not recommending this approach since it can put workers at unacceptable risk. However, we have had enough years in the field that tell us processes are often established and used regularly without the proper evaluation.
Let’s say the operation is spray painting a finished metal part before shipping. The part comes into the paint spray booth already deburred and sanded. It is ready to paint. The operation involves the following tasks:
The application of the term recognition in the industrial hygiene field is the identification of a hazard. It may be one that is obvious and you are familiar with or it may be hidden and unknown to you. An example of a known obvious hazard would be a dust cloud surrounding a worker dry sawing concrete. Most people would recognize the dust as being a potential respiratory hazard and many would take it a step further and recognize that the silica most likely in the dust can cause silicosis. On the other hand, a hidden hazard may be an oxygen deficient atmosphere in a confined space. You cannot see the oxygen deficiency and you may not be aware that it is a potential hazard. However, the atmosphere could result in asphyxiation and death.
Many of the industrial hygiene hazards in construction are the same as in manufacturing. However, certain sources are more unique or prevalent due to the nature of construction. Examples are concrete installation, finishing, and removal; paver installation; remodeling and demolition involving lead based lead paint, asbestos containing materials, bird feces, mold, and bacteria; digging in soil; and painting.
There are a lot of different kinds of environmental permits. Here are just a few: