**Q. For an environmental site assessment, the table from ASTM 1527 shows different
values for the minimum search distances, depending on the kind of list. Which
motive causes the differences?
A. The presumed likelihood of serious contamination
**Q. On submodule 13D, I was wondering where and who came up the volume of
oil vs time to report the spill values. It seems like pretty arbitrary volume
vs times. What sort of research was completed for these values?
A. Just a more or less arbitrary regulation. 55 gallons is the standard drum
for industrial liquids
** Q. So the overall message with environmental site assessments and audits
is "don't be wrong"? Are there any provisions similar to type II differing
site conditions in construction contracts for site contamination, or is the
assessment company always responsible? I realize the purpose of the ASTM guidelines
is to prevent this, but crap happens.
A. Yes it does. That is why you always follow applicable codes and standards.
**Q. Are there environmental firms that specialize in audits? Or is this sideline
work for most of them? Some firms specialize, although it is part of the practice
for large firms.
**Q. Are most audits that are done specific to one area of compliance? Example:
Solid waste management or spill reporting? Or, are audits normally of the entire
firm's environmental compliance?
A. Usually everything, if it is dictated by corporate policy. Might be specific
if the company had a special permit or legal issue.
** Q. I found the whole topic of site assessment very intriguing, because I
do site inspections as part of my job. My work is more straightforward than
this but still the premise is similar. You wrote:
Suppose you are assessing a site and don't see much and are about to go home.
But someone tells you that there was a PCB incinerator located a quarter a mile
upwind. So maybe you should take some soil samples for PCBs or Dioxins. It sounds
like a fair amount of detective work needs to go into your decisions of what
tests to run and how far away to look for contaminants. Do site assessors rely
on public documents such as property records to tell them that (for eg.) the
shop down the block use to be a dry cleaner, or a chrome plating co, 5 years
ago?
A. Yes, that is what the ASTM document tells you. The first step in a through
site assessment is checking all the ownership maps, including historical data.
The local fire department and environmental agencies should have data on industrial
operations and violations.
** Q. Also, when doing environmental audits, do consultants look at employee
health and safety, or does that get left up to OSHA?
A. Most environmental audits for corporations do the employee health and safety
too,
**Q. My question is in reference to Environmental Site Assessments. I have
heard of Phase I, Phase II, and Phase III Environmental Site Assessments. What
are these terms referring to? Is it just the depth of the ESA or are there specific
circumstances when one or more of these would be required
A. Those are from ENVE 651 and refer to RBCA see:Risk Based Corrective Action
(RBCA) and Risk-based Concentrations (RBC) http://www.faculty.uaf.edu/ffrap/ENVE_651/Module09/Submodule9B/Submodule_9B_1.htm
*Q. Also, when I was reading through sub module 13C about site assessments and
the ethical responsibilities regarding extra investigations I immediately thought
of a former co-worker who took those risks all the time. She is no longer an
employee (she changes careers), but the consulting firm is still 'cleaning up
her mess' from her inadequate investigations at sites. While this may not be
present everywhere, in MN it seemed that in certain Pollution Control Agency
regions, the PCA person wasn't as diligent as in others and I wonder if consultants
think of this when they propose site closure or limited investigations. Does
something like this hurt the consultant or the property owner more? For example,
if the PCA person is lax and the consultant takes advantage of this and doesn't
take care of something that they should. The property owner sells and the new
owner notices something is wrong and in the meantime a new PCA person is in
charge… Who's responsible? The current owner assumed since the PCA and
consultant signed off on the property that it was ok but it isn't. Just curious.
A. Good questions for a cynical soul like me. But remember, consultants get
paid for the hours they spend on a project. In that case, they want to do a
through job. Clients may know this, and force the price down so the consultant
can't do a good job. Most often, in my observation, it is just plain sloppiness
combined with a nebulous scope of work and the fact that none of us have x-ray
vision.
* Q. Question about environmental audit: whats the point of auditing the brand
new, not yet operating plant? What they normally do in Russia - they do the
design project evaluation considering the environmental legislation first and
then they check up the working plant.
A. It is always easier to change something before it is built. Almost all construction
in the US has a detailed review long before construction starts.
Q. I found this module interesting. I have seen one of the audits in a pesticide
and fertilizer company back in India. I don't exactly remember the nature of
this audit. I was a trainee there during the summer holidays. But I saw that,
suddenly just a week or so before the audits the entire functioning of the plant
became so efficient. So in essence my question is, Can audits for environmental
compliance be believable most of the times?Also, I believe although there are
lots of rules and regulations pertaining these environmental audits, interpersonal
relationship and generally the PR(public relations) official from the company
that influences these audits a lot. This is my experience in just one chemical
plant. Would it be incorrect to generalize this observation.
A. That's a good point. An unannounced inspection is libel to "catch"
more errors, but will not have the cooperation of the plant. If you want to
get something done, you need improvement. Sharp auditors can find the problems.
Also, many audits will find the paperwork problems.
Q. I have a question about real world application. Now I have gone through
most of the classes you have offered and I feel that I could if needed gather
a healthy amount of information about regulations and criteria concerning environmental
issues, but I would feel leery about fully trusting my applicability. In the
real world, how is a site assessment conducted within an environmental company?
Are there teams of individuals with specializations (like the PA/SI team and
the RI/FS team) or are there generally outlined procedures and one person tackles
an assessment? I realize I should just call and find out but before I do so,
if you could give me an idea of what to expect (and look for in a company) that
would be helpful. I imagine that the more assessments one can do, the more comfortable
with them one becomes. Are green thumbs out of college usually paired with a
veteran?
A. That depends on the company. It takes several years of experience; say 3
or 4, before one could be reasonably trusted to work independently, even with
a strong education.
Q. One amazing rule about the oil spill is, there is minimum limit for oil
spills in land for which one don't have to report to national response center
but if very small quantity, lets assume 100ml, is spilled in big water bodies
then still one has to report about the spill. Small quantity of oil in the rivers
like Chena will get diluted/spread very quickly so it will not be possible to
clean it out and it is not going to make water so polluted that it will harm
people who use it or fishes which are in the river. I think depending upon the
volume of flow in the river or size of the lake and the quantity of spill; the
rules should have been made. Is this rule made because oil contains benzene
in it and may be harmful if it is taken?
A. A good question. Recreational users spill lots of fuel on the river. But
yes, if it is a spill of any size, it must be reported. Some oil companies report
thousands of spills each year, many less than a gallon. It's the law. The penalty
for reporting a trivial spill is just the time it took to make the phone call
and write the report. The fine for not reporting it is huge.