Phase I and II Exam 1

Edwards Aquifer

30 TAC 213

Site photos

Always get a shot looking at the entrance of the property that shows as much of the site as possible. Take general site photos that show structures and general conditions. Take photos that also show the surrounding properties - views looking North, South, East and West. Take photos of specific issues - any tanks, containers or drums, on-site transformers, underground utilities, streets, etc.

Laboratory Analysis

Based on methodologies prescribed by EPA in their guide: SW 846 - Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. Published to "standardize" analysis for RCRA compliance. Widely used now for almost all lab analysis. For my Phase I and II ESA course, you will need to know lab analysis numbers for Exam 2! Laboratory Analysis Based on methodologies prescribed by EPA in their guide: SW 846 - Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. Published to "standardize" analysis for RCRA compliance. Widely used now for almost all lab analysis. Laboratory Analysis Each analysis method can be for a single analyte, OR it may be for several analytes. Analytes are also called parameters, constituents, or individual contaminants. Example: run an analysis only for mercury (Hg) OR run an analyte list for 8 metals that includes mercury + 7 more analytes.

Reporting

The Report must contain: Scope of services Findings recognized environmental conditions Historic recognized environmental conditions De minimus conditions Professional opinion of potential impacts to the property Conclusions Statement that says: ◦ No evidence of recognized environmental conditions Or ◦ The following recognized environmental conditions were identified:...... Deviations from the ASTM standard Any additional services that were performed as a part of the Phase I (asbestos, lead-based paint, lead in drinking water, etc.) References Signature Qualifications Appendices ◦ Site Location Map ◦ Site Plan ◦ Site Photographs ◦ Regulatory Database Records ◦ Historical Data ◦ Interview Data ◦ Special contractual conditions between client and consultant

State Superfund Listing

The Texas Commission on Environmental Quality (TCEQ) State Superfund Registry identifies potential hazardous facilities or areas that may constitute an imminent and substantial endangerment to public health and safety or the environment. State equivalent to CERCLIS and NPL

Tribal Records

The USGS provides maps depicting Indian administered lands greater than or equal to 640 acres. The EPA provides listings of leaking underground storage tanks and registered USTs on Indian Land.

Trimetrogon aerial

This is an assemblage of three photographs taken at the same time, one vertical and two high obliques, in a direction at right angle to the line of flight. The obliques, taken at an angle of 60° from the vertical, sidelap the vertical photography, producing composites from horizon to horizon.

Reliance

When a report is issued for a client, typically, the report is prepared solely for that client and no one else has the right to rely on the information in the report. When you are asked to grant reliance, you are essentially stating that the new entity has access to your professional liability insurance should they determine that you missed something. Keep in mind, the new "client" may not want the Phase I for the same reasons as the original client and therefore your data may not be suitable for their purpose.

De minimis condition

a condition that does not present a threat to human health or the environment and generally would not be the subject of an enforcement action if brought to the attention of a gov't agency. de minimis conditions are not recognized environmental conditions nor controlled recognized environmental conditions.

Organochlorines

very toxic (universal poison), very persistent in the environment. Examples: ◦ Pesticides: DDT, chlordane, lindane, heptachlor, endosulfan,aldrin, dieldrin, endrin, mirex, and pentachlorophenol) ◦ Chemical Industry: Vinyl Chloride: largest use is for the production of polyvinylchloride (PVC) (13billion KG or 13 million tons). Solvents: Chloromethanes = chloroform, dichloromethan, dichloroethene, trichoroethane (several billion KG produced annually). Precursors (chlorodifluoromethane and tetrafluoroethene) are used to make Teflontm Polychlorinated biphenyls (PCBs) were once commonly used electrical insulators and heat transfer agents. PCBs were replaced by polybrominated diphenyl

Organophosphates

very toxic, but not persistent in the environment. Irreversibly inhibits acetylcholinesterase, causing accumulation of acetylcholine (neurotransmitter) in the body. Examples: Pesticides: diazinon, malathion chlorpyrifos. Nerve Gases: soman, sarin, tabun, VX Herbicides: tribufos,

Environmental professional

—a person meeting the education, training, and experience requirements as set forth in 40 CFR §312.10(b)...reprinted in Appendix X2. Environmental Professional - must: (i) hold a current Professional Engineer's or Professional Geologist's license and have 3 years of full-time relevant experience; or (ii) be licensed or certified to perform environmental inquiries and have 3 years of full-time relevant experience; or (iii) have a Baccalaureate or higher degree in engineering or science and 5 years of full-time relevant experience; or (iv) have 10 years of full-time relevant experience. (3) An environmental professional should remain current in his or her field through participation in continuing education or other activities. (4) A person who does not qualify as an environmental professional under the foregoing definition may assist in the conduct of all appropriate inquiries in accordance with this part if such person is under the supervision or responsible charge of a person meeting the definition of an environmental professional provided above when conducting such activities.

Sanborn fire insurance maps

◦ Available in central city "core" areas only ◦ Not available for rural or outlying areas. ◦ Show names of businesses with locations outlined. ◦ May show storage tanks, gas stations, etc.

ESA's

◦ ESAs came about primarily for real estate transactions. ◦ Financial institutions who loaned $$$ for commercial real estate had the potential to be held liable for environmental issues on a property if the buyer defaulted on the loan. (under CERCLA - owner/operator clause) What kinds of things would you want to know about a property? ◦ What was this site in the past? ◦ When was it developed? ◦ What kinds of operations have taken place, now or in the past? ◦ What kinds of chemicals may have been present, now or in the past? ◦ Did the facility operate prior to rules?(ex haz waste) ◦ Does the facility have any permits now? ◦ Does the facility have any violations now?

Federal / State Facilities

◦ Exempt from compliance with most environmental regulations. ◦ Some of the worst polluters we have are federal facilities! Hanford Rocky Flats Federal Facilities Compliance Act - 1992 ◦ Act that amended the RCRA ◦ Required all federal facilities to comply with applicable federal and state hazardous waste laws, ◦ Waived federal sovereign immunity under those laws, and allowed the imposition of fines and penalties. ◦ Also required DOE to submit an inventory of all its mixed waste and to develop a treatment plan for mixed waste.

Retail/Commercial

◦ Malls ◦ Strip centers ◦ Office buildings ◦ Hotels ◦ Restaurants ◦ Gas Stations / Lube Centers ◦ Grocery Stores Retail / Commercial - Typical Concerns ◦ Emergency generators (diesel fuel) ◦ Backup power supplies ◦ Tenants Dry cleaners, dentist offices, photo developing, ◦ Pool & maintenance chemicals ◦ Contracted Maintenance ◦ Grease Traps

Industrial (light to heavy)

◦ Manufacturing ◦ Auto body repair ◦ Metal fabrication ◦ Scrap metal recycling ◦ Meat packing, hide tanning ◦ Fleet Vehicle Maintenance ◦ Rental Car Facilities ◦ Truck Stops ◦ Landfills ◦ Water & Wastewater Treatment ◦ TSD Facilities Industrial (light to heavy) - Typical Concerns ◦ Chemical use & disposal ◦ Generator IDs & permits ◦ USTs/ASTs ◦ Waste Disposal

ASTM standard scope of work

◦ Regulatory Database Review Federal, State and Local ◦ Historical Research of the Property (1940) Aerial photos, historic maps, city directories, fire insurance maps, chain of title, interviews with knowledgeable personnel (cannot use title alone) ◦ Site visit Covers entire property & all buildings/structures ◦ Report

Geoscience

◦ The science of the Earth and its origin and history, ◦ the investigation of the Earth's environment and its constituent soils, rocks, minerals, fossil fuels, solids, and fluids, and ◦ the study of the natural and introduced agents, forces, and processes that cause changes in and on the Earth as applied with professional judgment to develop ways to utilize, economically, those natural and introduced agents, forces, and processes for the benefit of the public.

Aerial photos

◦ Typically every decade from 1940 to present ◦ Site should be centered in the photo ◦ Looking at site and surrounding properties Looking for evidence of: ◦ Soil disturbance ◦ Previous structures or development ◦ Pits, ponds or lagoons ◦ Agricultural usage

Agricultural / Ranchland

◦ Vacant ◦ Crops ◦ Grazing ◦ Homesteads Agricultural / Ranchland - Typical Concerns ◦ Pesticide / herbicide use ◦ Waste disposal ◦ On site fueling

Other Historical Sources

◦ any source or sources that are credible to a reasonable person and that identify past uses of the property. ◦ includes, but is not limited to: Miscellaneous maps, Newspaper archives, Other records, Interviews with persons knowledgeable about the property owner and/or occupants.

CERCLA LIABILITY

◦ under CERCLA (Comprehensive Environmental Response, Compensation and Liability Act - Superfund) ◦ The owner of contaminated property pays to clean it up. If you buy it, you clean it up!

RCRA LIABILITY

◦ under RCRA (Resource Conservation & Recovery Act) ◦ Created 'CRADLE TO GRAVE' responsibility for hazardous waste. If you generate it, it's yours forever!

MIXING RULE

◦ under RCRA (Resource Conservation & Recovery Act) ◦ Mixing a hazardous waste with a non-hazardous waste makes the whole thing HAZARDOUS! Dilution is NOT the solution to pollution!

Nerve agents

Classified as weapons of mass destruction by the UN (UN Resolution 687, April 1991) ◦ G-series (developed by Germany, G stands for Germany, and lettered A, B, C, etc.) ◦ V-series (developed by the British, V stands for Victory, Venomous, or Viscous) Approximately 10-fold more poisonous than sarin. Production and stockpiling was outlawed by the Chemical Weapons Convention of 1993 (took effect April 29, 1997). Poisoning by a nerve agent leads to contraction of pupils, profuse salivation, convulsions, involuntary urination and defecation, and eventual death by asphyxiation as control is lost over respiratory muscles. Some nerve agents are readily vaporized or aerosolized and the primary portal of entry into the body is the respiratory system. Nerve agents can also be absorbed through the skin, requiring that those likely to be subjected to such agents wear a full body suit in addition to a respirator.

Biologicals

Coliform Bacteria ◦ Total coliform (includes e coli, total amount) ◦ Fecal coliform (almost exclusively e coli, how much is fecal matter?) ◦ Fecal Streptococcus (fecal bacteria from wildlife, how much is animal fecal matter and what animal does it belong to?) Mold / Fungus ◦ Always associated with excess moisture Bloodborne Pathogens ◦ Medical wastes (generally Hepatitis B & HIV) •2/1/2017 •13 Total coliform bacteria are a collection of relatively harmless microorganisms that live in large numbers in soils and the intestines of man and warm- and cold-blooded animals. Fecal coliform bacteria (subset), live in the intestines of man and warm-blooded animals. Most common: Escherichia coli. The presence of fecal coliform bacteria in aquatic environments indicates that the water has been contaminated with the fecal material of man or other animals. Also indicates potential contamination by other bacteria or viruses. Examples: typhoid fever, viral and bacterial gastroenteritis, and hepatitis A.

Consolidated Permits

30 TAC 305

Sludge use, transport and storage

30 TAC 312

Municipal solid waste

30 TAC 330

Underground injection control

30 TAC 331

Industrial solid waste and municipal hazardous waste

30 TAC 335

TRRP

30 TAC 350

Metals

8 RCRA Metals most common ◦ As, Ba, Cd, Cr, Pb, Hg, Ag, Se 13 Priority pollutant metals + Ba ◦ Antimony (Sb), As, Ba, Be, Cd, Cr, Cu, Pb, Hg, Ni, Ag, Se, Thallium (Ti), Zn Method: EPA 6010 / 7000 In general, metals: Are MUCH denser than water Stay adsorbed to soil particles Do not easily dissolve into water with a neutral or slightly alkaline pH. Dissolve easily in acidic waters and will stay in solution until the pH increases.

Carbamates

Carbamates - less toxic, less persistent in the environment. Reversibly inhibits acetylcholinesterase. Examples: Pesticides: aldicarb (Temik), carbofuran (Furadan), carbaryl (Sevin), ethienocarb, fenobucarb (Bassa , BPMC), oxamyl and methomyl Polyurethanes***: "urethane" is the common name for ethyl carbamate , but it not a component of polyurethanes. Preservatives: Iodopropynyl butylcarbamate is used in wood & paint preservatives and cosmetics. Human Medicine: antinoeplastic drugs (chemotherapy) and chlolinesterase inhibitors

The degree to which a pollutant affects water quality is largely dependent on:

Density relative to water (groundwater) and Solubility of the substance in water

Innocent landowner defense

Innocent landowner defense states that if a party has performed "due diligence" in trying to determine if a property is environmentally impacted prior to purchase and this due diligence does not reveal potential problems, then the purchaser is not held liable by EPA for expenditure of the superfund to clean up the site. Purchaser is innocent if s/he neither knew nor had reason to know that any hazardous substance was released or disposed at the site. Purchaser must conduct all appropriate inquiry into the previous ownership and uses of the property consistent with good commercial or customary practice. New regulations went into effect Nov 1, 2006. Following Table is a comparison of old and new standard. Major differences: ◦ Qualifications for who can perform Phase I ◦ No more than 5-year data gaps in history. a person who did not know and had no reason to know of impact prior to acquisition; a gov't entity which acquired site by eminent domain or condemnation; a person who acquired the site by inheritance or bequest.

Types of Pollutants / Wastes

Metals Hydrocarbons - Fuels, Solvents, Oils PCBs Pesticides / Herbicides Water Quality - BOD, COD, DO, pH Biologicals - mold, fungus, bacteria, coliform Asbestos Radon

Nitrate/nitrite/nitrogen

Nitrogen-containing compounds act as nutrients in streams and rivers. Nitrate reactions [NO3-] in fresh water can cause oxygen depletion (fish kills). Major sources: ◦ municipal and industrial wastewater ◦ septic tanks ◦ feed lot discharges ◦ animal wastes (including birds and fish) ◦ discharges from car exhausts. Bacteria in water quickly convert nitrites [NO2-] to nitrates [NO3-].

Oil pollution act (OPA)

OPA (1990) streamlined and strengthened EPA's ability to prevent and respond to catastrophic oil spills. A trust fund financed by a tax on oil is available to clean up spills when the responsible party is incapable or unwilling to do so. The OPA requires oil storage facilities and vessels to submit to the Federal government plans detailing how they will respond to large discharges. EPA has published regulations for aboveground storage facilities; The Coast Guard has done so for oil tankers. The OPA also requires the development of Area Contingency Plans to prepare and plan for oil spill response on a regional scale.

Relevant experience

Participation in the performance of all appropriate inquiries investigations, environmental site assessments, or other site investigations that may include environmental analyses, investigations, and remediation which involve the understanding of surface and subsurface environmental conditions and the processes used to evaluate these conditions and for which professional judgment was used to develop opinions regarding conditions indicative of releases or threatened releases (see §312.1(c)) to the subject property.

The nasty nine

Pentabromodiphenyl ether This PBDE congener, sometimes referred to as "penta," was used as a flame-retardant in foam upholstery and furnishing. Octabromodiphenyl ether polybrominated diphenyl Chlordecone Insecticide Lindane An agricultural insecticide also used to treat head lice and scabies in people Alpha-hexachlorocyclohexane One of the persistent chemical waste products produced by making Lindane Beta-hexachlorocyclohexane Another of the persistent chemical waste products produced by making Lindane PFOS The company 3M used PFOS to make Scotchgard fabric Hexabromobiphenyl A polybrominated biphenyl, or PBB, Pentachlorobenzene

What constitutes "DUE DILIGENCE" for the innocent landowner defense???

Phase I Environmental Site Assessment

Radon

Radon Radioactive gas, colorless, odorless. Estimated to cause 21,000 lung cancer deaths per year in U.S. Second leading cause of lung cancer (after smoking). Daughter product of naturally-occurring uranium in rock & soils. Measured in picoCuries/Liter of air (pCi/L). Addition 7 cancer cases/year for non-smokers No known safe level, but 4 pCi/L is action level. Radon in Texas Radon Analysis Short term testing: 48-96 hours. Long term testing: up to 90 days. Canisters (charcoal) trap the radon particles that enter the canister. Analyzed by laboratory for the concentration of radon particles.

State Cleanup Standards

TCEQ (Texas Commission on Environmental Quality) established a risk-based program called the Texas Risk Reduction Program (TRRP). No clean-up to background (often ZERO) Leave small amounts of contaminants in place because they will not cause harm to human health or the environment. Select clean-up levels based on property use (commercial/industrial versus residential) TCEQ established two sets of cleanup standards for impacted properties: ◦ Clean up to drinking water standards ◦ Clean up to 100 x the drinking water standards Both are protective of human health and the environment.

TCEQ Sign/Seal Requirements

TCEQ's established regulations for the public practice of geoscience in conformance with the Act affect: 30 TAC 213 - Edwards Aquifer 30 TAC 305 - Consolidated Permits 30 TAC 312 - Sludge Use, Disposal & Transport 30 TAC 330 - Municipal Solid Waste 30 TAC 331 - Underground Injection Control 30 TAC 335 - Industrial Solid Waste & Municipal Hazardous Waste 30 TAC 350 - Texas Risk Reduction Program (TRRP)

Hydrocarbon Analysis Methods

TPH - Total Petroleum Hydrocarbons: For hydrocarbon analysis. Tells us how many mg/kg of hydrocarbons is present. More hydrocarbons=longer chain lengths. Doesn't tell us which kind of hydrocarbons are present. ◦ TX1005: TPH method in Texas. BTEX - Benzene, Toluene, Ethylbenzene, Xylenes 8020: Subset of VOC's. 4 constituents within VOC's. They are common additives in gasoline. Very short list out of VOC's dealing with gasoline. PAH - Polycyclic Aromatic Hydrocarbons 8270 or 8310: Subset of SVOC's. 16 analytes. Just looking for diesel. VOCs - Volatile Organic Compounds 8260: 156 analytes. Are common additives within gasoline. Very expensive but tells us exactly which hydrocarbons are present. Tests for lighter hydrocarbons which tend to evaporate quickly. They have a shorter chain length. SVOCs - Semi-volatile Organic Compounds 8270: 237 analytes. Mid-range chain lengths. Includes PAH.

Vertical aerial

Taken with the camera pointed as straight down as possible (+/- 3° from the plumb line). Characteristics: 1. Lens axis is perpendicular to the earth's surface. 2. Covers a relatively small area. 3. Shape of the ground area covered approximates a square or rectangle. 4. If terrain is flat, distances and directions may be very accurate. 5. Relief is not readily apparent.

Low oblique aerial

Taken with the camera inclined about 30° from the vertical characteristics: 1. It covers a relatively small area. 2. The ground area covered is a trapezoid, although the photo is square or rectangular. 3. The objects have a more familiar view, comparable to viewing from the top of a high hill or tall building. 4. No scale is applicable to the entire photograph, and distance cannot be measured. Parallel lines on the ground are not parallel on this photograph; therefore, direction (azimuth) cannot be measured. 5. Relief is discernible but distorted. 6. It does not show the horizon.

High oblique aerial

Taken with the camera inclined about 60° from the vertical characteristics: 1. It covers a very large area (not all usable). 2. The ground area covered is a trapezoid, although the photo is square or rectangular. 3. Distances and directions are not measured on this photograph for the same reasons that they are not measured on the low oblique. 4. Relief may be quite discernible but distorted as in any oblique view. The relief is not apparent in a high altitude, high oblique. 5. The horizon is always visible.

Comprehensive Environmental Response, Compensation and Liability Information System (CERCLIS)

The CERCLIS lists and identifies suspected contamination sites throughout the nation. CERCLIS contains information on sites identified by the US EPA as known or suspect abandoned, inactive, or controlled hazardous waste sites that may require cleanup. NFRAP - former CERCLA site with No Further Remedial Action Planned

Emergency Response Notification System (ERNS)

The ERNS list is a national database used to collect information on reported releases of oil and hazardous substances.

Polychlorinated biphenyls (PCB's)

Commercial mixtures are clear, light yellow or dark color, and range from oily liquids to waxy or hard solids. Chlorine atoms give a high the compounds density (1.15 - 1.60). fire resistant (high flash-point:170-380 °C). Vapors are heavier than air, but aren't explosive. Electrical conductivity is very low Resistance to thermal breakdown is extremely high. Very resistant to a range of oxidants and other chemicals Remain chemically unchanged even in the presence of oxygen, or some active metals, at high temperatures (up to 170 °C), and for protracted periods. PCBs are practically insoluble in water; however, they dissolve easily in hydrocarbons, fats, and other organic compounds, and they are readily adsorbed by fatty tissues. aromatic hydrocarbons produced by chlorination of biphenyl compounds. highly stable, non-flammable compound produced commercially by Monsanto Chemical Company, used primarily for insulation fluids in capacitors and transformers. degree of chlorination of the biphenyl molecule controls the volatility, solubility and persistence of PCBs in the environment. Routes of exposure for animal populations are limited to ingestion and inhalation. Studies show that PCBs bioaccumulate, especially in fatty tissues, and that after termination of exposure, PCB concentrations do not return to pre-exposure levels. Method: EPA 8082

U.S. Chemical Weapons Stockpile

Contains nerve agents, and blister (mustard) agents. (Mustard was used extensively in World War I. Nerve agents were first used by Iraq in war with Iran.) U.S. stockpile has a variety of munitions and bulk containers. Nerve agents in the U.S. stockpile include: ◦ Tabun (GA): ethyl-N, N-dimethyl phosphoramidocyanidate (also contains cyanides). ◦ Sarin (GB): isopropyl methyl phosphonofluoridate (also contains fluorine,) - non-persistent ◦ VX: O-ethyl-S-[2-diisopropyl aminoethyl]methylphosphonothiolate (also contains sulfur) - persistent Highly toxic or lethal in both liquid and vapor forms. (Liquid at room temp & pressure) Destruction operations produce contaminated or hazardous waste streams that must also be dealt with in the disposal process.

Landowner liability protections

Contiguous Property Owner Liability Protection - person owns property that has been impacted by an adjoining contaminated site owned by another party. Bona Fide Prospective Purchaser Liability Protection - purchaser made all appropriate inquiries into previous ownership and uses prior to purchase. May still be eligible for liability protection even if impact discovered - certain conditions must be met. Facility must have been purchased after 1/11/02. A purchaser must obtain an ESA that has been completed using "All Appropriate Inquiry" prior to purchase of the property in order to quality for LLPs!

Regulatory Database

Data required for a database search: ◦ Property name ◦ Property address ◦ Property size ◦ Latitude/longitude (you can find this yourself) ◦ Zip code ◦ Answers to the User Questionnaire

Regulatory agencies

EPA - Environmental Protection Agency TCEQ - Texas Commission on Environmental Quality Local Agencies - Municipalities, Counties

Brownfields

EPA defined them and created a program to help with redevelopment: An abandoned, idle or under-used property with real or perceived environmental contamination. The Plus Side....Focusing on redevelopment of Brownfields preserves "greenfields" and curtails "urban sprawl". The Minus Side....Environmental issues can add costs to a proposed project. The Brownfields Program includes multiple funding sources: Grant program. Municipalities and other local governments can apply for up to $200,000 in grants for Phase I and Phase II investigations. Revolving Loan Fund. Low interest revolving loan fund that can be used to remediate brownfields. This RLF is available to many entities including local governments and developers. Regulations involved: CERCLA - Comprehensive Environmental Response, Compensation and Liability Act ("Superfund"). Created to address abandoned sites that pose public risk. RCRA - Resource Conservation and Recovery Act. Created to address management and disposal of solid and hazardous waste. TSCA - Toxic Substance Control Act. Created to determine and regulate the public risk of a chemical before it is introduced in commerce. Agencies involved: EPA - Environmental Protection Agency TCEQ - Texas Commission on Environmental Quality Local Agencies - Municipalities, Counties Substances covered: Asbestos, Gasoline, LBP (interior). Solvents, metals, hydrocarbons, etc. Suspect operations on-site or adjacent to site. Soils & Groundwater Impacts. Suspect operations: Manufacturing Metal Works Vehicle Service/Maintenance Equipment maintenance/storage Railroad operations/tracks......

Municipal Setting Designations

Enacted by the state legislature for TCEQ in September 2003. (House Bill 3152, 78th Legislature, 361.801) An MSD is a state designation that restricts current and future use of groundwater at the property to non-potable only. Restriction is a city ordinance enforceable by the city and filed in the property records. The MSD allows cleanup activities to be less costly, but still protects human health and the environment. An MSD can do the following: Raises the cleanup standards to an economically feasible level. Still protects human health, the environment and groundwater resources. Allows faster/cheaper redevelopment, bringing higher property values and more tax revenues.

Freedom of information act (FOIA)

FOIA provides specifically that "any person" can make requests for government information. Citizens who make requests are not required to identify themselves or explain why they want the information they have requested. The position of Congress in passing FOIA was that the workings of government are "for and by the people" and that the benefits of government information should be made available to everyone. All branches of the Federal government must adhere to the provisions of FOIA with certain restrictions for work in progress (early drafts), enforcement confidential information, classified documents, and national security information.

RRC Sign/ Requirements

Groundwater Advisory Unit Injection Permit Types and Information Environmental Permit Types and Information Operator Cleanup Program Voluntary Cleanup Program Brownfields Response Non Point Source Program

Water quality

Hardness (as CaCO3) Nitrate / Nitrite (organic & inorganic) Temperature DO - dissolved oxygen (present in all water, higher in "active" vs "still" waters) BOD - biochemical oxygen demand (results from microbial breakdown of organics in water) COD - chemical oxygen demand (extraction of O2 from water due to chemical reactions). pH Biologicals

Asbestos

Naturally occurring mineral composed of fibrous silicates (Ca, Mg SiO2) Crystalline structure Parallel bundles of fibers Physical disturbance results in separation of bundles into smaller bundles or individual fibers called fibrils. Perfect lengthwise cleavage with length-towidth ratio of 3:1. Physical characteristics include: ◦ Chemical resistance ◦ Bacterial resistance ◦ Incombustibility ◦ Thermal insulating ability ◦ Electrical insulating ability ◦ Mechanical strength ◦ Flexibility ◦ Good friction & wear characteristics Asbestos used in 3,600 products Fiber concentrations range from 1% to 100% First used in US in early 1900s to insulate steam engines. Not used extensively until early 1940s, then for 30 years. 66% of products are asbestos-cement products such as flat, corrugated or siding sheets; rain piping; high-pressure piping. Asbestos Textiles & Filtration Products Asphalt Flooring, vinyl floor tiles, pavings, road surfaces Brake linings, clutch facings, gaskets, reinforced plastics High temperature applications Adhesives & cements •2/1/2017 •17 Condensation Control - on steel, concrete and other building surfaces, underside of sinks to prevent condensation. Fireproofing - on structural materials, beams, and columns for insulation and fireproofing Thermal Insulation - on anything where flow of heat needs to be restricted Acoustical Control - in any area where noise reduction was desired. Products containing asbestos are still widely available today. NAFTA has increased the number of asbestos-containing products imported into the U.S. You must sample the material unless it is: Wood Glass Metal Concrete foundations need not be sampled, but concrete pipes, siding & wallboard should be sampled. Asbestos Analysis Polarized Light Microscopy - PLM with visual area estimation

Atrazine

One of the most widely used agricultural pesticides in the U.S. 80 million pounds annually applied before and after planting to control broadleaf and grassy weeds. Primarily on corn, sorghum, and sugarcane, and is applied most heavily in the Midwest. May be used on residential lawns in Florida & the southeast. EPA aquatic ecosystem level of concern = 10 ppb (60-day period) Widespread use makes it the most common pesticide contaminant of ground and surface water: ◦ Approximately 75% of stream water and about 40 % of all groundwater samples from agricultural areas tested in an extensive U.S. Geological Survey study contained atrazine. A half million pounds of atrazine return to the earth in rainfall and snow in the United States every year. Studies in both the US and in Europe have shown that atrazine can travel as much as 600 miles from the point of application, contaminating even otherwise pristine habitats Atrazine was found in 80% of drinking water samples taken in 153 public water systems. (NRDC) All 20 watersheds sampled in 2007 and 2008 had detectable levels of atrazine, and 16 had average concentrations above the level that has been shown to harm plants and wildlife. (NRDC) •February 17 •February 17 Atrizine is now scientifically found to cause hermaphroditism and chemical castration in frogs. 75% of frogs expose are chemically castrated - meaning they cannot reproduce. (UC Berkeley's Tyrone B. Hayes, professor of integrative biology) ◦ "These male frogs are missing testosterone and all the things that testosterone controls, including sperm. So their fertility is as low as 10 percent in some cases, and that is only if we isolate those animals and pair them with females," he said. "In an environment where they are competing with unexposed animals, they have zero chance of reproducing." 10% or more that turn from males into females - something not known to occur under natural conditions in amphibians - can successfully mate with male frogs but, because these females are genetically male, all their offspring are male. ◦ "When we grow these guys up, we will get anywhere from 10 to 50 % females," Hayes said. "In a population, the genetically male females can decrease or wipe out a population just because they skew sex ratios so badly."

Substances covered

Petroleum hydrocarbons (gasoline, diesel, waste oil, etc). Solvents, Metals, PCBs, Pesticides / Herbicides

Licenses?

Phase Is: Currently, no licensing is required to perform Phase I ESAs - but you must meet the qualifications requirements in ASTM 1527 Phase IIs: Texas Board of Professional Geoscientists requires a licensed Geoscientist or Engineer to supervise, sign and seal!

Interviews

Primary manager Occupants (for non-residential properties) Ask for pertinent documents (site plans, previous reports, permits, etc.) Potential or pending litigation

Temperature

Temperature changes beyond natural seasonal fluctuations can disrupt aquatic ecosystems. "Normal" temperature ranges for each stream depend on geographic area and overall climate. ◦ Warm water stream: >89oF. ◦ Cold water streams: <68oF Summer heat can cause fish kills in ponds because high temperatures reduce available oxygen in the water.

Purpose of the ASTM standard

The practice that constitutes "all appropriate inquiry" into the previous ownership and uses of the property consistent with good commercial or customary practice. This practice is intended for use on a voluntary basis by parties who wish to assess the environmental condition of commercial real estate. No implication is intended that a person must use this practice in order to be deemed to have conducted inquiry in a commercially prudent or reasonable manner in any particular transaction. Nevertheless, this practice is intended to reflect a commercially prudent and reasonable inquiry. This practice is designed to assist the user in developing information about the environmental condition of a property and as such has utility for a wide range of persons, including those who may have no actual or potential CERCLA liability and/or may not be seeking the innocent landowner defense. No implication is intended that it is currently customary practice for residential tenants of multifamily residential buildings, tenants of single-family homes or other residential real estate, or purchasers of dwellings for one's own residential use, to conduct an environmental site assessment in connection with these transactions. Thus, these transactions are not included in the term commercial real estate transactions, and it is not intended to imply that such persons are obligated to conduct an environmental site assessment in connection with these transactions for purposes of appropriate inquiry or for any other purpose.

pH

Typical range protective of freshwater ecosystems: 6.0 - 9.0 Runoff from agricultural, domestic, and industrial areas may contain iron, aluminum, ammonia, mercury or other elements. The pH of the water determines the toxic effects of these substances. ◦ (4 mg/l of iron at 4.8 = no toxic effect) ◦ (0.9 mg/l of iron at pH 5.5 = fish kill) The steps involved in water and wastewater treatment require specific pH levels. In order for coagulation (a treatment process) to occur, pH and alkalinity must fall within a limited range. Chlorination, a disinfecting process for drinking water, requires a pH range that is temperature dependent.

Hardness/Alkalinity

Typically expresses as bicarbonate (HCO3), carbonate (CaCO3), and hydroxide ions (Ca(OH)2) A measure of a wastewater's capacity to neutralize. Alkalinity will tend to neutralize acids formed during coagulation

Negligence

You job, regardless of whether you work for the buyer or the seller, is to do the job correctly and to the best of your ability. The firm you work for must carry professional liability insurance. This insurance covers honest mistakes that can be made. However, it does NOT cover sloppy, careless or negligent work. You must perform the work to the same standard that other professional in the industry use. If you don't, you are negligent. If you are negligent, the client will likely sue the company (for insurance) and you (personally). One single lawsuit will ruin your reputation in the profession and you will likely have to find another career.

Natural Pesticides

pyrethrin (chrysanthemums), rotenone (bean plant), sabadilla (mexican lilly), nicotine (from tobacco plants)

Becky's rules of maps

1. North is always up (unless you just can't make it fit on a standard page size). 2. You always put a north arrow on the map. 3. If it is not to scale, put "not to scale" on the map. If it is, then put the scale on it (text or scale bar). 4. When determining what maps to put it, anyone should be able to drive to the site based on the location maps in the report. 5. Always include a legend if you use symbols or abbreviations. 6. You should identify the adjoining property uses for your site plan.

User questionnaire

(1.) Environmental cleanup liens that are filed or recorded against the site (40 CFR 312.25). Are you aware of any environmental cleanup liens against the property that are filed or recorded under federal, tribal, state or local law? (2.) Activity and land use limitations that are in place on the site or that have been filed or recorded in a registry (40 CFR 312.26). Are you aware of any AULs, such as engineering controls, land use restrictions or institutional controls that are in place at the site and/or have been filed or recorded in a registry under federal, tribal, state or local law? (3.) Specialized knowledge or experience of the person seeking to qualify for the LLP (40 CFR 312.28). As the user of this ESA do you have any specialized knowledge or experience related to the property or nearby properties? For example, are you involved in the same line of business as the current or former occupants of the property or an adjoining property so that you would have specialized knowledge of the chemicals and processes used by this type of business? (4.) Relationship of the purchase price to the fair market value of the property if it were not contaminated (40 CFR 312.29). Does the purchase price being paid for this property reasonably reflect the fair market value of the property? If you conclude that there is a difference, have you considered whether the lower purchase price is because contamination is known or believed to be present at the property? (5.) Commonly known or reasonably ascertainable information about the property (40 CFR 312.30). Are you aware of commonly known or reasonably ascertainable information about the property that would help the environmental professional to identify conditions indicative of releases or threatened releases? For example, as user, (a.) Do you know the past uses of the property? (b.) Do you know of specific chemicals that are present or once were present at the property? (c.) Do you know of spills or other chemical releases that have taken place at the property? (d.) Do you know of any environmental cleanups that have taken place at the property? (6.) The degree of obviousness of the presence of likely presence of contamination at the property, and the ability to detect the contamination by appropriate investigation (40 CFR 312.31). As the user of this ESA, based on your knowledge and experience related to the property are there any obvious indicators that point to the presence or likely presence of contamination at the property?

Hydrocarbons

(typically not soluble in water) FLOATERS: Fuels ◦ Gasoline, Diesel, Jet Fuel, Kerosene, etc Oils ◦ Motor oil, cutting oil, lube oil, hydraulic fluid ◦ Tar & asphalt Solvents ◦ Chlorinated (halogenated) carbon chains ◦ Ex: Trichloroethene, dichloroethene, vinyl chloride SINKERS: NAPL - Non-Aqueous Phase Liquid Includes chlorinated compounds and petroleum hydrocarbon products LNAPL - less dense than water (generally petroleum hydrocarbon liquids, such as gasoline (petrol), diesel, jet fuel, crude, etc.) FLOATER DNAPL - more dense than water (chlorinated compounds, solvents, etc.) SINKER

Site visit

1. Current Site Use 2. Hazardous/Petroleum substance storage on site 3. Past Site Use 4. Current Use of Adjoining Properties 5. Past Use of Adjoining Properties 6. Current and Past Use of Surrounding Area (typically for ½ mile) 7. Geologic, Hydrogeologic & Topographic Conditions 8. General Description of structures, boundaries and roads. 9. Water and sewer services Take Photos!!!! 10. Hazardous/Petroleum substance storage on site (interior) 11. Storage Tanks 12. Odors 13. Pools of Liquid 14. Drums/Containers 15. Unlabeled Containers 16. PCB-containing equipment 17. Heating/Cooling equipment 18. Stains or Corrosion 19. Drains or Sumps 20. Hazardous/Petroleum substance storage on site (exterior) 21. Pits, Ponds Lagoons 22. Stained soil or pavement 23. Stressed vegetation 24. Solid waste disposal 25. Industrial wastewater disposal 26. Septic systems 27. Water wells

Becky's rules of photos

1. Get a wide angle shot of the site entrance. 2. Get 2-3 pictures of the general site (wideangle shots with lots of terrain). 3. Get shots down each study boundary, including the adjacent properties. 4. Get shots of obvious utilities - they can be great landmarks. 5. Get detailed shots of specific items or anything unusual. 6. You need a photo log - record the direction of each photo and why you took it. Photos serve two main purposes: 1. Reminders for YOU about what you saw in the field 2. Communication for your CLIENT about what you saw in the field

Becky's rules of reporting

1. Use your regulations summaries to ensure you are technically correct! 2. Include not only your team name, but the names of all team members on the cover page. 3. No first person! 4. No passive voice! 5. Write the body of the report first, then conclusions and recommendations. Final step is the executive summary. 6. Nothing goes in the executive summary that has not be written and explained in the body of the report. 7. Duplication of data leaves room for mistakes. Minimize duplication in the report format wherever possible. 8. Be thorough, but brief. Use bullets and tables as much as possible. 9. If the report doesn't address it, then it will be assumed that you didn't do it. Therefore, if you looked for something and didn't see it, you must say you didn't see it! 10. Include pertinent data and discussion thereof in the body of the report. Put supporting data in Appendices. •2/1/2017 •8 11. Include pertinent data and discussion thereof in the body of the report. Put supporting data in Appendices. 12. You must include the names of the individuals that you interviewed at the site. 13. You must put a sentence in pointing the reader to each table, figure and appendix. 14. Spell out every acronym or abbreviation the FIRST time you use it. 15. Fully justify the text - no ragged right margins please! 16. You NEVER need the phrase "in order to"......please delete it from your report! 17. Do not use words like ALL, ALWAYS, AND NEVER. Unless you want to wind up in jail. 18. No plagiarizing - if you copy data from a webpage, cite it. 19. You must spell out numerals if they start a sentence! You should approach ANY class report as if it will be the ACTUAL report for the project. That means you cannot leave anything blank and the report should be as close to perfect as possible. There are a number of automatic features in any report template that I provide, including the automatic generation of the table of contents (TOC). Be careful when you edit - don't delete automatic formatting or numbering, as that will cause errors in the TOC. Editing Insert all of your data, then edit to the most succinct form possible. USE SPELL CHECK! Verify that all section numbers are sequential. Verify that all page numbers are sequential and correct. Verify that all table numbers are sequential and correctly referenced in the text. Verify all headers and footers. Make sure that each figure included in the report is referenced in the text and that the figure numbers in the text references match the actual figures. Make sure that each attachment included in the report is referenced in the text and that the attachment number or appendix number where the attachment is located is correct. Check the references page and make sure to include any additional references you use. Once the edits are complete: Check page breaks (don't leave orphans, or big blank spaces) Once the page breaks are set, you will need to update the table of contents. Verify by spot-checking that the pages numbers listed in the TOC match those in the report.

The dirty dozen

According to the Stockholm Convention on Persistent Organic Pollutants (POPs), 9 of the 12 most dangerous and persistent organic chemicals are pesticides. Four main categories: 1. herbicides 2. fungicides 3. insecticides 4. bactericides •2/1/2017 •8 1995 - UNEP called for global action on POPs (defined as chemical substances that persist in the environment, bio-accumulate through the food web, and pose a risk of causing adverse effects to human health and the environment). Intergovernmental Forum on Chemical Safety (IFCS) and the International Programme on Chemical Safety (IPCS) prepared an assessment of the 12 worst offenders, known as the dirty dozen. THE DIRTY DOZEN: Name Type 1 Aldrin organochlorine 2 Chlordane organochlorine 3 Dieldrin organochlorine 4 Endrin organochlorine 5 Heptachlor organochlorine 6 Hexachlorobenzene organochlorine 7 Mirex organochlorine 8 Toxaphene organochlorine 9 Polychlorinated biphenyls (PCBs) PCBs 10 DDT organochlorine 11 Polychlorinated dibenzo-p-dioxins ("dioxins") dioxins 12 Polychlorinated dibenzofurans furans 9 more added in 2010

Environmental cleanup lien

An environmental lien is a financial instrument that takes the form of a charge, security or encumbrance on title to a property. The presence of a lien, used to secure payment of a cost or debt arising from past response actions or cleanup on a property, suggests that environmental conditions exist—or have existed—onsite.

Clean Air Act (CAA)

Don't put it up the stack. CAA regulates air emissions from area, stationary, and mobile sources. This law authorizes EPA to establish National Ambient Air Quality Standards (NAAQS) to protect public health and the environment. The goal of the Act was to set and achieve NAAQS in every state by 1975. The setting of maximum pollutant standards was coupled with directing the states to develop state implementation plans (SIP's) applicable to appropriate industrial sources in the state. The Act was amended in 1977 primarily to set new goals (dates) for achieving attainment of NAAQS since many areas of the country had failed to meet the deadlines. The 1990 amendments to the Clean Air Act in large part were intended to meet unaddressed or insufficiently addressed problems such as acid rain, ground-level ozone, stratospheric ozone depletion, and air toxics. The result: Permitting for almost all types of industrial discharges into air. Some are permits by rule, some require the full permitting process Ambient Air Quality Standards (NAAQS) for hazardous air pollutants (HAPS): ◦ Sulfur Oxides (Sox), ◦ Nitrogen Dioxide / Nitrogen Oxides (NOX), ◦ Ozone, ◦ Carbon Monoxide, ◦ Lead, ◦ Particulate Matter. State Implementation Plans (SIPs)

17 Targeted Chemicals

EPA developed the 33/50 Program targeting 17 chemicals reported to the Toxic Release Inventory (TRI). ◦ Voluntary reduction for the use/release of 17 chemicals. ◦ Used 1988 TRI data as a baseline, the EPA sought to achieve: 33% national reduction in releases by 1992 50% reduction (750 million pounds) by 1995 ◦ Companies were asked to set their own reduction goals. ◦ The 1995 goal was surpassed - 55% or 824 million pounds . •2/1/2017 •11 Benzene Cadmium & Compounds Carbon Tetrachloride Chloroform Chromium & Compounds Cyanides Lead & Compounds Mercury & Compounds Methyl Ethyl Ketone Methyl Isobutyl Ketone Methylene Chloride Nickel & Compounds Tetrachloroethylene Toluene Trichloroethane Trichloroethylene Xylenes

controlled recognized environmental condition

a recognized environmental condition resulting from a past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory authority (for example, as evidenced by the issuance of a no further action letter or equivalent, or meeting risk-based criteria established by regulatory authority), with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls). (See Note 2.) A condition considered by the environmental professional to be a controlled recognized environmental condition shall be listed in the findings section of the Phase I Environmental Site Assessment report, and as a recognized environmental condition in the conclusions section of the Phase I Environmental Site Assessment report. (See Note 3.) NOTE 2—For example, if a leaking underground storage tank has been cleaned up to a commercial use standard, but does not meet unrestricted residential cleanup criteria, this would be considered a controlled recognized environmental condition. The "control" is represented by the restriction that the property use remain commercial. NOTE 3—A condition identified as a controlled recognized environmental condition does not imply that the environmental professional has evaluated or confirmed the adequacy, implementation, or continued effectiveness of the required control that has been, or is intended to be, implemented.

Pesticides

affect the nervous system, disrupt nerve cell transmission

Resource Conservation and Recovery Information System (RCRIS) List

an EPA database of facilities that generate and/or transport hazardous waste. This list also serves to track the status of hazardous waste treatment, storage, and/or disposal (TSD) facilities regulated under RCRA and TSD facilities that are currently conducting or have conducted corrective actions (CA). Hazardous waste generators CORRACTS - facilities subject to corrective action under RCRA TSD - treatment, storage and disposal facilities (hazardous waste)

Historical Recognized Environmental Conditions

an environmental condition which in the past would have been considered a REC, and may or may not be considered a current REC.

Phase II ESA

an environmental investigation that includes sampling and analysis of soils and/or groundwater. ◦ Performed to evaluate the potential environmental conditions identified during a Phase I ESA, usually for soils and groundwater; ◦ Provide sufficient information regarding nature and extent of impacts for business decisions (depending on scope of work); ◦ Provide a level of knowledge sufficient to satisfy the innocent landowner defense; ◦ Evaluate soils, groundwater, surface water, sediments, etc. ◦ May also include asbestos, lead-based paint, PCBequipment, etc. Scopes and cost vary significantly based on: ◦ Site conditions ◦ Types of contaminants present ◦ Presence / absence of groundwater Costs range from $5000 - $30,000 (or more) Average Timeframe: 6-12 weeks Laboratory analysis is approximately 50% of the cost Other subcontractors (like drillers) are another 15% - 20%

Phase I ESA

an initial environmental review of a property. ◦ Does not include sampling and analysis of soils or groundwater. ◦ Sometimes includes asbestos, radon, lead paint, wetlands or other related investigations. Your job is to identify whether or not there is a potential for adverse environmental impact to a site. The issue may: Come from onsite or offsite, Come from current or historical operations, Be the result of bad or inaccurate info. Phase I Environmental Site Assessments Your job is to find the potential issues for your site, then determine (to the best of your ability) whether they present a real threat to your site or not. If you determine that the issue is a potential threat to your site, then you will recommend a Phase II investigation. Performed to the industry standard ASTM E1527 standard to preserve the "innocent landowner defense" for the purchaser under CERCLA liability. Regulations under CERCLA brownfields dictate All Appropriate Inquiry (AAI) standards for Phase Is, as of November 1, 2006. Require: ◦ Regulatory database search ◦ Historical profile to 1940 ◦ Site visit Average Cost: $2500 - $3000 depending on the site. Average Timeframe: 3-4 weeks ASTM = (American Society for Testing and Materials) The ASTM standard was revised at the end of 2013. Changes include: ◦ New term: Controlled REC - an example would be a site with an institutional control, property use restrictions, engineering controls, etc. ◦ New requirement to address vapor migration ◦ Minor changes are in user responsibilities, industrial/manufacturing properties and appendices

Resource Conservation and Recovery Act (RCRA)

dont put it anywhere else. proper management of hazardous and non-hazardous solid waste. RCRA gave EPA the authority to control hazardous waste from the "cradle-to-grave." This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA also set forth a framework for the management of non-hazardous wastes. Facilities may have many regulatory responsibilities under RCRA, including obtaining permits, identifying and listing hazardous waste, adhering to proper procedures when transporting or disposing of waste, developing risk management plans, and maintaining records. •12/9/2016 •6 The 1986 amendments to RCRA enabled EPA to address environmental problems that could result from underground storage tanks (USTs) storing petroleum and other hazardous substances. RCRA focuses only on active and future facilities and does not address abandoned or historical sites (see CERCLA). HSWA—Federal Hazardous and Solid Waste Amendments (1984), required phasing out land disposal of hazardous waste ("land ban"). Some of the other mandates of this strict law include increased enforcement authority for EPA, more stringent hazardous waste management standards, and a comprehensive UST program. The result: Defined solid and hazardous waste Standards for landfill design and construction (as well as permitting) Standards for hazardous waste handling facilities (treatment, storage and disposal - TSD - facilities) Created "Cradle to Grave" responsibility for wastes. Created rules for Underground Storage Tanks Also created the "Mixing Rule" - mixing a non-hazardous waste with a hazardous waste is prohibited.

safe drinking water act (SWDA)

dont put it in a hole in the ground

Clean Water act (CWA)

dont put it up the pipe. The Act established the basic structure for regulating discharges of pollutants into the waters of the United States and gave EPA the authority to implement pollution control programs such as setting wastewater standards for industry. CWA also set water quality standards for all contaminants in surface waters. The Act made it unlawful for any person to discharge any pollutant from a point source into navigable waters, unless a permit was obtained under its provisions. It also funded the construction of sewage treatment plants under the construction grants program and recognized the need for planning to address the critical problems posed by nonpoint source pollution. The result: Permitting for all types of discharges into waters of the U.S. ◦ NPDES - industrial ◦ NPDES - storm water ◦ Section 404 - dredge & fill material Funding for the construction of wastewater collection systems and treatment facilities Water quality standards for surface waters Storm water pollution prevention

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

if you already put it in the ground, dig it up. Superfund. CERCLA or "Superfund" (December 11, 1980) Created a tax on the chemical and petroleum industries that was put into a trust fund ($1.6 billion over five years,). Provided broad Federal authority to clean up uncontrolled or abandoned hazardous-waste sites as well as accidents, spills, and other emergency releases of pollutants that may endanger public health or the environment. EPA initiates cleans up of "orphan" sites when potentially responsible parties cannot be identified or located, or when they fail to act. EPA was given power to seek out those parties responsible for any release and assure their cooperation in the cleanup. EPA is authorized to implement the Act in all 50 states and U.S. territories. Superfund site identification, monitoring, and response activities in states are coordinated through the state environmental protection or waste management agencies. CERCLA: established prohibitions and requirements concerning closed and abandoned hazardous waste sites; provided for liability of persons responsible for releases of hazardous waste at these sites; and established a trust fund to provide for cleanup when no responsible party could be identified. The law authorizes two kinds of response actions: Short-term removals, where actions may be taken to address releases or threatened releases requiring prompt response. Long-term remedial response actions, that permanently and significantly reduce the dangers associated with releases or threats of releases of hazardous substances that are serious, but not immediately life threatening. These actions can be conducted only at sites listed on EPA's National Priorities List (NPL). CERCLA also enabled the revision of the National Contingency Plan (NCP). The NCP provided the guidelines and procedures needed to respond to releases and threatened releases of hazardous substances, pollutants, or contaminants. The NCP also established the NPL. CERCLA was amended by the Superfund Amendments and Reauthorization Act (SARA) on October 17, 1986. The Result: Orphan sites are evaluated to determine public health risk. Cleanup is initiated while EPA searches for responsible parties. PRPs are asked to repay the federal funds (superfund) expended for cleanup of their site. Innocent landowner defense resulted from this pursuit of PRPs. •12/9/2016 •8 The Result: Created a trust fund to clean up abandoned hazardous-waste sites (orphan sites) Orphan sites are evaluated to determine public health risk. Cleanup is initiated while EPA searches for potentially responsible parties (PRPs). PRPs as then asked to either participate or repay the superfund for the cleanup. Created the "innocent landowner defense" Defined "due diligence" as a Phase I Environmental Site Assessment (ESA)

Herbicides

may be selective (kill only a certain type of plant) or non-selective (kill every plant that contact) Contact -kill only the plant parts on which the chemical is deposited. Typically very water soluble (Reward, Weed-e-Rad) Systemic - absorbed either by roots or foliage and translocated to tissues that did not receive application. Many are growth regulators (Atrazine, Auxins - Agent Orange: 2,4,D + 2,4,5 T, Roundup) Soil sterilant - degrades rapidly, may be highly water soluble. (Liqua Thol K) Herbicide Analysis: 8151

Synthethic pesticides

organochlorines, organophosphates, carbamates ◦ Analytical method: 8082