Prepared by:
Technical Assistance to Brownfields Communities Program

South & Southwest Hazardous Substance Research Centers
Georgia Tech Research Institute
Atlanta, Georgia

Second Edition, February 2001

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CONTENTS

• Preface/Acknowledgements
• About the Technical Assistance to Brownfields Communities Program
• Introduction
• Associated Laws and Regulations
• Components of the ESA Process
• Phase I Environmental Site Assessment Protocols
• Phase II Environmental Site Assessment
• Appendices
  • Appendix A: Guide to Contaminants Found at Typical Brownfield Sites
  • Appendix B: Factors to Consider Prior to Beginning the ESA Process
  • Appendix C: List of Common Environmental Abbreviations and Acronyms
  • Appendix D: Glossary
  • Appendix E: Sources of Information

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Preface and Acknowledgements

The information presented in this second edition is intended to provide the reader with a current general overview of the various issues related to conducting environmental site assessments for brownfield properties. The site assessment process can be complex, with the potential for a multitude of issues to be addressed prior to the purchase or redevelopment of brownfield sites. This training manual does not, and cannot, include all of the environmental conditions that may be encountered upon a property. The main purpose of this material is to provide the reader with basic information on what is usually addressed during a Phase I Environmental Site Assessment, and should raise the reader's awareness of typical assessment issues, and where to find additional information.

Much of the material included in this module comes from documents published by the U.S. Environmental Protection Agency, most notably Road Map to Understanding Innovative Technology Options for Brownfields Investigation and Cleanup, Second Edition (EPA OSWER, EPA 542-B-99-009). Additional material comes from The Role of Environmental Site Assessments in Property Transfers, a continuing education short course developed and offered by the Georgia Tech Research Institute. The American Society for Testing and Materials Standard Practices for Environmental Site Assessments have been referenced. Information from these documents has been synthesized and incorporated into this learning module.

This module also presents appendices that include a list of common acronyms used in the environmental site assessment process, a list of common contaminants found at brownfield sites, and contact and resource information. Underlined words are defined in the glossary in Appendix D.

About the Technical Assistance to Brownfield Communities Program

The Technical Assistance to Brownfield Communities Program (TAB) was established in 1998 by a grant from the U.S. Environmental Protection Agency to the five regionally established Hazardous Substance Research Centers. The mission of the TAB program is to provide no-cost, non-advocate technical assistance to municipalities and communities addressing brownfields issues. TAB can provide expertise in the areas of environmental engineering, economic development, regulatory compliance, environmental site assessments, and finance, among others. Since 1998, TAB has assisted over 40 municipalities and communities through its assistance and outreach efforts. Appendix E lists the TAB programs and their associated Hazardous Substance Research Center homes, and provides contact information for each.

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INTRODUCTION

The U.S. Environmental Protection Agency (EPA) has defined brownfields as abandoned, idled, or under-used industrial and commercial facilities where expansion or redevelopment is complicated by real or perceived environmental contamination. EPA established its Brownfields Economic Redevelopment Initiative to empower states, communities, and other stakeholders involved in economic revitalization to work together to accomplish the redevelopment of such sites. Many states and local jurisdictions also help businesses and communities adapt environmental cleanup programs to the special needs of brownfields sites.

Preparing brownfields sites for productive reuse requires the integration of many elements--financial issues, community involvement, liability considerations, environmental assessment and cleanup, regulatory requirements, and more--as well as coordination among many groups of stakeholders. The assessment and cleanup of a site must be carried out in a way that integrates all these factors into the overall redevelopment process. In addition, the cleanup strategy will vary from site to site. At some sites, cleanup will be completed before the property is transferred to new owners. At other sites, cleanup may take place simultaneously with construction and redevelopment activities. Regardless of when and how cleanup is accomplished, the challenge to any brownfields program is to clean up sites quickly and redevelop the land in ways that benefit communities and local economies.

PURPOSE

This training manual is designed to help the reader and future practitioner understand the basic elements of the Environmental Site Assessment (ESA) process and how these components relate to brownfields redevelopment. This manual will review the associated federal and state laws and regulations related to brownfields, review the purpose for conducting each phase of the ESA process, present protocols for each component of the ESA process, examine typical environmental concerns, explore various investigative techniques, and present issues to examine following completion of a site assessment.

The basic concepts presented in this manual will provide the reader with greater knowledge of the environmental issues that are fundamental in the redevelopment of brownfields. It will give municipal economic development officials the knowledge to put a proposal together for a consultant to bid on the investigation of a site and to understand the final report they will provide. A concerned citizen will be better able to understand potential environmental concerns associated with a particular property and be able to ask appropriate questions about conditions and potential cleanup options. By developing an understanding of the ESA process, stakeholders will be able to develop a scope of work that will quickly and effectively determine potential environmental problems at the site so they can move one step closer to the ultimate goal of redevelopment.

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ASSOCIATED LAWS AND REGULATIONS

Issues of conducting environmental site assessments for potentially contaminated property have yet to be fully addressed on the federal regulatory level. The majority of ESA policies and standards have originated from lending institutions, professional organizations, company policies, and state regulatory agencies. The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the Resource Conservation and Recovery Act (RCRA), both promulgated by the U.S. Environmental Protection Agency, have indirectly clarified the role of site assessments in property transfers. Even though neither of these Acts directly requires a site assessment be performed, they indirectly necessitate the action through the liability they impose on property owners and operators.

Federal Regulations

The Resource Conservation and Recovery Act (RCRA) of 1976 instituted regulations for the handling of hazardous wastes at currently operating facilities. It established a regulatory system to track hazardous substances from their generation to their disposal (i.e., cradle to grave). The law requires the use of safe and secure procedures in treating, transporting, storing, and disposing of hazardous substances. RCRA's goal is to prevent future releases of hazardous substances into the environment.

Under RCRA, procedures are required that may assist in the site assessment process. A RCRA Facility Assessment (RFA) is performed at a facility to determine the existence of any continuous or non-continuous releases of wastes. During the RFA, EPA or state regulators gather information on solid waste management units and other areas of concern at RCRA facilities, evaluate this information to determine whether there are releases that warrant further investigation and action, and determine the need to proceed to a RCRA Facility Investigation. A RCRA Facility Investigation (RFI) is conducted to gather sufficient data to fully characterize the nature, extent, and rate of migration of contaminant releases identified in the RCRA Facility Assessment. The data generated during the RFI is used to determine the potential need for corrective measures and to aid in the selection and implementation of these measures.

Even though RCRA addresses the current hazardous waste handling practices, when RCRA was enacted there were no laws that addressed the cleanup of releases to the environment that had already occurred. Because of the sheer number of past releases that the federal government was left to address, the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted. This 1980 law created a special tax-based trust fund, commonly known as Superfund, to be used to fund the investigation and cleanup of abandoned or uncontrolled hazardous waste sites. CERCLA contains provisions that hold past and present owners or operators of contaminated sites liable for the contamination and its cleanup. This liability is boundless and can be characterized as:

• Strict. If you fall within a defined class of owner or operator (generator) of a site containing hazardous substances or you were involved in the transport, storage, or disposal of hazardous substances, the government or a private party may be able to recover cleanup costs against you as a potentially responsible party (PRP), even though you may not have been responsible for the contamination.
• Joint and Several. This means that one or a combination of PRP's is liable for the total cleanup costs associated with a hazardous waste site. This means that the EPA can go after one PRP for the entire cost unless the PRP can prove some basis for cost allocation to other PRP's.
• Retroactive. By its very nature, CERCLA imposes liability for past acts. This means that an owner/operator of a contaminated site may be liable for the cleanup of acts that were legal when they occurred. This permits liability to be imposed for transactions that precede the effective date of the Act.
• Unlimited. The PRP's potential CERCLA liability includes all costs such as site investigation, remediation, restoration, health studies, public protection, and third party damages. These costs may be many times greater than the value of the property in question.
• Individual. CERCLA liability may be imposed on individuals or corporate employees if they were responsible for, or arranged for, the disposal of hazardous substances contrary to the law or best prevailing practices at the time of disposal.

Unless the owner/operator can effectively avoid liability by claiming to be an "innocent purchaser," he or she will be liable for cleanup. In order to be an innocent purchaser, the landowner or purchaser must be able to demonstrate:

• The property was acquired after the disposal or placement of the hazardous substances; and
• At the time the property was acquired, the purchaser did not know and had no reason to know that any hazardous substances were on the property.

In order to fulfill the second requirement above, the purchaser must prove that at the time of acquisition, he or she made all appropriate inquiry into the previous ownership and uses of the property consistent with good commercial or customary practice in an effort to minimize liability. This is commonly known as due diligence, and is performed through what is routinely called a Phase I Environmental Site Assessment (ESA).

Under CERCLA, the following criteria constitute appropriate inquiry:

• Any specialized knowledge or experience on the part of the purchaser;
• The relationship of the purchase price to the value of the property if uncontaminated;
• Commonly known or reasonably ascertainable information about the property;
• The obviousness of the presence or likely presence of contamination on the property; and
• The ability to detect contamination by appropriate inspection.

In 1996, CERCLA was amended by the Superfund Amendments and Reauthorization Act (SARA). The most significant impact on environmental site assessments was the inclusion of community "right-to-know" reporting and disclosure requirements. This requirement may assist the environmental site assessment process through easier accessibility to environmental release reports and spill reports.

Other Federal Environmental Regulations

Even though RCRA and CERCLA set the stage for completing an ESA in a property transfer for liability issues, there are other federal laws that may affect both liability issues and the outcome of the ESA. These laws include federal underground storage tank (UST) and aboveground storage tank (AST) regulations, the Clean Air Act (CAA), the Clean Water Act (CWA), and the Toxic Substances Control Act (TSCA) among others. These laws and regulations govern what levels of contaminants are allowed in the air, soil, and water at a facility, and give performance and specification standards for onsite equipment. These regulations could affect the outcome of the ESA by determining if the facility is in compliance with applicable environmental laws. Therefore, knowledge of what regulations may have governed previous site activities is part of completing a proper ESA.

State Regulations

The EPA typically gives the states a chance to manage their own environmental programs, such as RCRA, CERCLA, and USTs. According to federal statutes, each state must prove that their program is at least as stringent as the federal program in order for them to be permitted to manage a state level program. In many cases, state level programs are more stringent than the federal program. It is necessary to also be aware of the state regulations that may affect any past or present operations at the site being assessed.

State hazardous waste handling laws are the equivalent of the federal RCRA program. These regulations will determine how wastes are handled onsite and during an investigation. Most states have a state hazardous waste inventory list of sites within the state that have a known or suspected release of a regulated substance above a certain reportable quantity.

State Superfund programs are mirror images of the federal program. Typically, state CERCLA employees are contracted by the EPA to investigate potential National Priorities List (NPL) sites within a state. Therefore, when investigating how CERCLA will affect your site, most likely you will be contacting a state's environmental protection agency.

Many states have enacted laws that are the equivalent of the federal UST regulations. In many cases, state laws are more stringent. The level of stringency of a state program is usually dependent on varying geologic conditions including soil type, depth to groundwater, and source of drinking water. For instance, because Florida uses its groundwater as drinking water, its soil and groundwater cleanup levels for UST sites are stricter than those states that rely on surface water for drinking water. ASTs are typically regulated by the states, or more commonly, state fire marshals.

Local Laws

Individual counties or townships sometimes have their own environmental regulations. For instance, a county can be responsible for instituting a state program. In addition, local municipalities have their own regulations for fire and building codes. It is necessary to make sure that the influence of any local program is investigated prior to project initiation.

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COMPONENTS OF THE ESA PROCESS

Transaction Screening >

The purpose of the transaction screen is to define standards for conducting ESAs for commercial and industrial property with respect to CERCLA and petroleum products, with the goal of identifying recognized environmental conditions. In essence, the transaction screen process is an ESA by questionnaire. A series of questions is asked of the current property owner, any major past or present tenant of the property, and any past or present occupant of the property who is likely using, treating, disposing, or transporting hazardous substances on or off the property. At the end of the screening process, ideally it will be determined whether additional investigations (Phase I and/or Phase II) are necessary. However, since answers to the questionnaire are given by individuals some of who may have interests in the property and/or transaction, care should be taken when relying on the information provided to make final decisions.

In addition, the transaction screen consists of observing site conditions at the property and conducting limited research into certain government records and historical information. During the transaction screening process, the assessor conducts a limited review of the property in order to assess whether additional investigations (Phase I and/or Phase II) are necessary.

Completion of a transaction screen may satisfy one of the requirements to qualify for the innocent landowner defense under CERCLA.

Transaction Screening Protocol

The American Society for Testing and Materials (ASTM) has published a standard for conducting transaction screens. This standard sets forth a guide to completing a transaction screen questionnaire that is included in the publication. The questionnaire provides a checklist of questions to ask the owner and occupants of the subject site, as well as a guide to follow during the site visit and government records/historical information inquiry. It is a good guide for professionals just starting out in the environmental field, and may also be useful when there is only limited time available to investigate a site for potential contamination.

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Phase 1 Environmental Site Assessment

If a transaction screen has been conducted and the assessor concludes that additional investigations are warranted, the next step is a Phase I ESA. However, in many instances a transaction screen will not be conducted and a Phase I will be the starting point for an environmental assessment of the property. The objective of a Phase I is to determine, to the extent feasible, recognized environmental conditions in connection with a property. This involves an environmental review including: (1) a review of pertinent records of the site; (2) a site visit, (3) interviews with key site-related personnel, and (4) completing a report. The level of detail is far greater than what is included in the transaction screen. From this work, tentative conclusions or recommendations about the environmental condition of a site are developed. Based on the Phase I findings, the property transfer process will either be terminated or continued on to a more detailed level of investigation.

Records Review

The purpose of the records review is to obtain and review records that will help identify recognized environmental conditions in connection with the property. It is best, although not necessary, to complete the records review prior to conducting the site visit so that a site assessor will know what to look for when completing the site visit. The records review can also help determine whether the property is out of compliance with any environmental regulation. The records examination consists of reviewing several sources of information, including standard environmental records, additional state or local records, physical setting records, and historical use records.

Standard Environmental Records Sources

Standard Phase I ESA protocols require that certain environmental databases be reviewed to provide information on the property. These databases include lists of sites that are considered federal or state Superfund sites, sites that have released reportable quantities of hazardous materials, and sites that have been investigated by a federal or state environmental agency. Many of these protocols designate minimum search distances from a subject property for standard federal and state databases. A computerized search of these databases can be conducted by several database search companies for a fee (typically $100-$300). Some of the more commonly searched databases are listed below.

• National Priorities List: the National Priorities List (NPL) is EPA's list of the most serious uncontrolled or abandoned hazardous waste sites identified for possible long-term remedial response under Superfund. This list is updated yearly. Most states have also compiled a state NPL, usually referred to as a state hazardous waste site index, through the work of state environmental protection agencies.
• CERCLIS: the Comprehensive Environmental Response, Compensation, and Liability Information System list is a database that serves as the official inventory of federal Superfund hazardous waste sites. CERCLIS contains information about all aspects of hazardous waste sites, from initial discovery, to planned and actual site activities, to deletion from the NPL.
• ERNS: the Emergency Response Notification System database contains information on reported releases of oil and hazardous substances.
• RCRIS: the Resource Conservation and Recovery Information System database contains information on sites that generate, treat, store, or dispose of hazardous waste.
• LUST: the Leaking Underground Storage Tank program records contain an inventory of reported leaking USTs. Most states maintain such a file, but it is important to remember that these lists only contain reported UST leaks.
• UST: the Underground Storage Tank database contains a list of USTs registered with a state's environmental protection program. Older tanks that may have created environmental problems may not have been registered.

Additional state or local records can be utilized to supplement the federal and state sources identified above. However, one must determine whether they are reasonably ascertainable and have sufficiently useful, accurate or complete information in light of the objective. Types of local records include:

• Lists of landfills/solid waste disposal sites,
• Lists of hazardous waste/contaminated sites,
• Records of emergency release reports, and
• Records of contaminated public wells.

These records can be obtained from the following local sources:

• State Departments of Health and/or Environment,
• Fire Departments,
• City Planning Departments,
• Building Permit/Inspection Departments,
• Local/Regional Pollution Control Agencies,
• Local/Regional Water Control Agencies, and
• Local Electric Utility Companies (for PCBs).

Physical Setting Sources

Physical setting sources provide information about site topography, geology, and hydrogeology. These types of information are important in order to determine where hazardous substances (if present) would most likely migrate. If previous reports or records indicate that hazardous substances have been used or released at the site, it is strongly suggested that at least one additional (non-standard) source be reviewed during the ESA. The standard physical setting source map is a current United States Geological Survey (U.S.G.S.) 7.5 Minute Topographic Map (see example). Non-standard physical setting sources are U.S.G.S. and/or State Geological Survey groundwater, bedrock and surficial maps, and the Natural Resources Conservation Service soil maps.

Historical Use Information

The purpose of reviewing historical use information is to develop a history of the previous uses of the site and the surrounding area in an effort to identify potential environmental problems. Standard Phase I assessment practice requires all obvious uses of the property to be identified from the present back to the first development of the property or to 1940, whichever is earlier. Developed use includes agricultural or filled. Only as many sources needed to determine the historical use of the site and the surrounding area should be reviewed. A review of standard historical sources at less than an approximate five-year interval may not be necessary. If the specific use of the property does not appear to have changed over a period of time, it may not be necessary to check for alternate uses in between. If data is not readily available for a specific time period, it is necessary to identify "data gaps" in the report.

The following is a list of standard historical use information.

• Aerial Photographs
• Fire Insurance Maps (Sanborn Maps)
• Property Tax Files
• Recorded Land Title Records
• U.S.G.S. 7.5 Minute Topographic Maps
• Local Street Directories
• Building Department Records
• Zoning/Land Use Records
• Site Maps
• Newspaper Articles
• Records in Site Files
• Personal Knowledge of Owner or Occupants

SITE RECONNAISSANCE: WHAT DO YOU LOOK FOR?

The objective of the site reconnaissance is to observe the property and any structure(s) located on the property to determine the likelihood of environmental impact. The entire site must be observed, including the interior of buildings. If there are any areas that are not accessed, they must be specifically identified in the report. The investigator will look for potential contaminants and any signs of a release, spill, dumping, or disposal of hazardous substances onto the property.

General Site Setting/Site Overview

A sketch or map showing the site layout will be extremely helpful to the assessor. If any evidence of environmental concern is noted, it can be immediately located and documented on the map. Other items to be noted on the map are locations of various owners, operators, or tenants, improvements, land cover, topography, adjacent neighbors, and site utilities. A description of the structures or other improvements on the property must be noted during the site visit, including the number of buildings, number of stories each, approximate age of buildings, building use, and construction type of each building.

The topography of the site and the surrounding area should be noted at the time of the site visit. Topographic observations must be analyzed in connection with the geologic, hydrologic, and topographic information obtained from record reviews, interviews, or site observations. This analysis will help evaluate whether hazardous substances or petroleum products are likely to migrate to the property, or within or from the property, into soil and groundwater.

All roads adjoining and servicing the property, and all parking facilities should be identified during the site visit. Pay close attention to roads that dead-end within the property or at property boundaries. The source of drinking water for the property must be identified during the site walk through. The sewage disposal system for the site must also be determined during the site visit. If the sewage disposal system is an onsite septic system, an inquiry into the age of the system and its maintenance should be completed. Septic systems often serve as convenient, but improper, locations for hazardous waste disposal. The means of heating and cooling the buildings on the property, including the fuel source, must also be identified. These systems may operate on heating oil (stored in ASTs or USTs), gas, electric, or radiators from steam boilers fueled by gas.

Site Conditions: Operations and/or Maintenance Practices

One of the main determinants of whether potential environmental impacts will be present is the present and past use of the site and the surrounding properties. Investigation of the present use of the property visit should focus on the use, treatment, storage, disposal or generation of hazardous substances or petroleum products. During the site visit it is also imperative to observe adjacent properties to determine if any potential environmental conditions exist off-site that could impact the subject property. The observations of adjacent properties and the surrounding area should be made from the subject site or from a public right-of-way. Due to legal issues, no entry onto another person's property is advisable. Past uses of the subject site, adjacent properties and the surrounding area can be determined either via historical document review, interviews or visual observations.

Underground Storage Tanks

An underground storage tank, usually referred to as a UST, is a tank and any piping connected to the tank that has at least 10% of its combined volume underground. Requirements and definitions of USTs are found in Subtitle I of RCRA. These federal regulations apply only to USTs storing either petroleum or certain hazardous substances. The following kinds of tanks are not covered by the RCRA regulations:

• Farm or residential tanks of 1,100 gallons or less capacity holding motor fuel used for noncommercial purposes;
• Tanks storing heating oil used on the premises where it is stored;
• Tanks on or above the floor of underground areas, such as basements or tunnels;
• Septic tanks and systems for collecting storm water and wastewater;
• Flow-through process tanks; and
• Emergency spill and overfill tanks.

However, even though these USTs are not covered by RCRA, they may be covered under state or local regulations. In addition, unregulated USTs can cause contamination that would be regulated.

A UST is designed as a holding structure. Its total volume can range anywhere from 250 gallons to 100,000 gallons. A UST can be located either inside or outside a building and under pavement or grass. USTs are usually used to hold petroleum products, raw chemical materials, or waste products. USTs can be identified in the field by visually looking for a dispensing system, a man-way to the tank, an aboveground fill port, or a vent pipe (usually located running vertically up a building or canopy). Typically the number of vent pipes equals the number of USTs. Changes in pavement or surfacing, such as patched areas, may also indicate either a recently installed or removed UST, or recent work on piping and dispensing equipment. A surface spill occurring during the filling of the UST or during the dispensing of fuel can be evidenced by stained soil or pavement or stressed vegetation. A subsurface release to the soil or groundwater from a leaking UST usually cannot be determined without testing subsurface soil or groundwater. The location, contents (past and present), capacity, age, and structure of all USTs onsite should be determined either at the time of the site visit or from historical data reviews.

USTs can cause any of the following environmental conditions: surficial soil contamination due to overfilling or sloppy housekeeping; subsurface soil contamination due to a leak from the UST; surface water contamination due to leakage running off into storm drains or nearby surface water bodies; and groundwater contamination due to a release from a UST migrating into the site groundwater. The resulting impact depends on the site's geologic and topographic conditions, the type of contaminant, and the age of the release. Typical constituents of a release from an UST include: volatile organic compounds (VOCs); semi-volatile organic compounds (SVOCs); chlorinated compounds; polynuclear aromatic hydrocarbons [PAHs (commonly found in petroleum fuels, coal products, and tar)]; and lead (from leaded gasoline).

Aboveground Storage Tanks

An above-ground storage tank (AST) is a holding tank that has less than 10% of its volume underground. ASTs perform the same function as USTs. An AST's total volume usually ranges from 250 gallons to 60,000 gallons. However, because the AST is aboveground taking up useable space on a property, their sizes are usually limited to 10,000 gallons or less. Similar to an UST, ASTs can be located either outside or inside a building. By their nature, ASTs have a greater likelihood for surface spillage and therefore are usually located on a paved surface and sometimes within a diked area for secondary containment. The location, contents (past and present), capacity, age, and structure of all ASTs onsite should be determined either at the time of the site visit or from historical data reviews.

ASTs can easily be identified onsite. Typical ASTs look similar to a cylinder that is oriented horizontally. Some new ASTs look like a cube as all their safety features are housed internally. A surface spill occurring during the filling of the AST, during the dispensing of fuel, or by a leak can be evidenced by stained soil or pavement or stressed vegetation. It may be difficult to determine if a surface release has impacted the subsurface soil or groundwater without testing subsurface soil or groundwater. Typical constituents of a release from an AST include VOCs, SVOCs, chlorinated compounds, PAHs, lead, solvents, and specialty chemicals.

Hazardous or Non-Hazardous Waste Storage

Any storage of hazardous waste, non-hazardous waste, or petroleum products must be noted to the extent observed or identified. Storage can be in drums, tanks, or other containers. Drums often hold 55 gallons, but containers as small as 5 gallons should be noted during the site inspection. For any such storage, the location, material stored, type of container, storage conditions (i.e. on pallet, near drain), and container condition (i.e. leaking, rusted, etc.) should be noted. If the material stored is unidentifiable or unknown, it should be noted in the report. Due to safety concerns, do not attempt to smell or sample any unidentified materials.

Evidence of historical waste storage including stained soil or pavement, stressed vegetation, or pallets can be observed during the site inspection. A historical review of aerial photographs, operational reports, and databases can help determine if the facility has ever generated or stored hazardous or non-hazardous waste or had a release from the storage area. Current or historical waste storage can cause soil and groundwater contamination if improper handling or leaks have caused the release of hazardous, non-hazardous, or petroleum products onto the ground.

Hazardous or Non-Hazardous Waste Disposal

Hazardous waste disposal is defined as the final placement or destruction of toxic, radioactive or other wastes, surplus or banned pesticides or other chemicals, polluted soils, and drums containing hazardous materials from removal actions or accidental release. Acceptable disposal can be accomplished through the use of approved secure landfills, surface impoundments, land farming, deep well injection, ocean dumping, or incineration. Unacceptable disposal methods include, but are not limited to, the use of an unapproved landfill or improperly engineered surface impoundments, as well as burying material and burning material. A disposal method is unacceptable if local, state or federal law does not allow it, or if it can jeopardize the health, safety and welfare of the surrounding neighbors and environment.

Because waste disposal can occur in numerous ways there is no one indicator that disposal has taken place. When completing the site inspection, look for suspicious locations of drums or other storage containers, such as in the woods behind the property, which may indicate current or past disposal practices. Depressions and mounds in the earth may indicate a previous burial location. Piles of material, stained soil or pavement, or stressed vegetation can also indicate historical disposal locations. Wastes may have also been disposed of in pits, pond or lagoons. A historical review of aerial photographs, operational reports, and databases, as well as interviews can help determine if the facility has disposed of hazardous or non-hazardous waste, in either an acceptable or unacceptable manner. The current and historical hazardous and non-hazardous disposal practices are of importance as improper practices can cause soil and groundwater contamination.

Solid Waste

Solid waste can be normal refuse, bulky items, fill material or anything else defined by RCRA. Both present and past solid waste disposal should be noted during the site visit. Facility operators may provide current and past information on solid waste storage disposal practices. At the time of the site visit, current solid waste disposal practices are usually evidenced by solid waste storage containers. In an attempt to identify areas of past solid waste disposal, look for areas that are apparently filled or graded by non-natural causes or filled by material from an unknown origin, as well as mounds or depressions in the site topography.

Solid wastes can contain many physical and chemical materials. When solid wastes are disposed of they begin to decompose, releasing constituents into the surrounding soil. These constituents can then leach into the site groundwater and eventually migrate offsite.

Wastewater

Wastewater is spent or unused water from a home, a community, a farm, or an industry that contains dissolved or suspended matter. Wastewater can be generated during manufacturing or cleaning of a product, as well as from an industrial process. Wastewater is typically transported to its disposal point by a series of underground pipes. Discharge locations of wastewater include, but are not limited to, drains, ditches or surface water bodies. The discharge location may be onsite or offsite. All potential wastewater-generating activities should be noted in the report. It is important to note the source of the water, the potential dissolved or suspended matter included, the quantity of wastewater generated, any treatment of the wastewater, and its ultimate disposal point.

Information on current or historical wastewater generation is most easily obtained from the records review and interviews. Observe all drains, ditches, or surface water bodies located onsite and on immediately adjacent properties for a conduit, drain, or grate emptying into the area as this indicates potential discharge locations for wastewater. If liquid is discharging or standing in the area note its appearance, including color, floating material, foaming material, and odor. There is a potential for wastewater to be contaminated, which in turn could cause contamination at the disposal location.

Wells

Types of wells that may be present onsite include dry wells, irrigation wells, injection wells, abandoned wells, and monitoring wells. A well is a hole in the subsurface that vertically advances in depth. The diameter of a well can vary from 2-inches to 4-feet and the depth can range from a few feet to several hundred feet. A well can be cased, kept open by material such as polyvinyl chloride, or uncased. Additionally it can be covered over or open. Usually the exact make-up of a well is dependent upon its current or historical use. During the site inspection an attempt must be made to locate any well and determine its function.

Most wells can be identified visually during the site inspection. Any labeling (such as depth, installer, purpose) on the well should be documented. An assessor should attempt to obtain information on its depth, structural make-up, contents, and status (in-use or not) from the visual inspection. In addition, wells may be identified during interviews and the records review.

Wells are a concern because they may have been used as improper disposal locations for waste material. Because wells advance vertically they may act as a contamination conduit to the subsurface soil and groundwater.

Drains and Sumps

Drains and sumps act as mechanisms to transport and store liquids. Most drains and sumps are used for transport and storage of wastewater and waste products (such as waste oil and solvents). Drains are usually located in the floor system and evidenced by a grate covering. The diameter typically ranges from 1-inch to 1-foot with the depth dependant upon the system's purpose (transport or storage). Drains typically transport material from the generation point to a common collection, storage or disposal location. Sump diameters are usually larger than drains and range from one-half foot to several feet. Sumps are usually at least one-half foot deep but can be up to several feet in depth if utilized as a storage location. Because of their larger diameter, sumps usually have a solid cover. Sumps can be used as a temporary collection point that allows a certain volume of material to collect before it is pumped to the final storage location. Many times drains and sumps are used together in a larger collection system. Drains allow materials to be disposed at individual generation points and then transported to a sump that serves as a temporary storage point.

The presence of drains or sumps can be identified during the site visit by completing a careful visual inspection of the floor. If drains or sumps are identified, an inquiry into the age of the system, its operation, the materials utilized, and its maintenance should be completed as the system often serves as a convenient, but improper, location for hazardous waste disposal.

If the drain and/or sump system is not structurally intact, leakage of the transported material may occur into the surrounding soil. Long-term leaks from a drain or sump can result in contamination of the site groundwater due to vertical migration of the liquid.

Odors

Strong, pungent, or noxious odors must be identified during the site visit, as they may be indicators of improper disposal method or leakage of materials. In addition, an attempt to identify the source of the odors should be made. However, if at any time you or anyone else starts to feel physically ill from the odors, exit the area at once and notify appropriate site personnel. Historical odors may be identified from interviews and records review.

PCBs

Polychlorinated biphenyls (PCBs) are a group of toxic, persistent chemicals produced by the chlorination of biphenyl (a chemical). PCBs were commonly used in high voltage electrical transformers because they are effective in heat transfer and are fire resistant. PCB wastes are generated from metal degreasing, printed circuit board cleaning, gasoline, and wood preserving processes. The use of PCBs was banned in 1979. This ban caused most electrical companies to slowly replace PCB-containing transformers with non-PCB containing transformers. Therefore, PCBs are typically a concern at older sites.

Because PCBs are typically housed within another structure, their presence or previous presence usually is known from signs or other documentation such as historical site plans, records review or interviews. Look for labels noting PCB presence on or near electrical or hydraulic equipment including transformers, elevators, or lifts. Note that light ballasts may contain PCBs. If any PCB-containing material is located onsite document everything on the label and indicate whether or not the structure appears to be leaking.

PCBs can be a cause of soil contamination. By their structural nature, PCBs do not migrate quickly from the source area nor do they degrade quickly. This makes PCBs at older sites a main concern. Wetlands

According to the Clean Water Act, a wetland is an area that is inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances does support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs and similar areas.

Identifying wetlands is not typically a part of a Phase I ESA due to the detailed investigation that must be conducted. However, because the dredge and fill of wetlands is prohibited, it is important to attempt to determine if wetlands may exist on-site, especially if future site plans call for construction of new buildings. Particular soil characteristics (dark, loamy soil) and plants (marsh grasses, cattails, etc.) are the best identifiers of potential wetland areas. In addition, there are published maps of wetland data available from the U.S. Fish and Wildlife Service.

Radon

Radon is a colorless, naturally occurring, radioactive, inert gas formed by the radioactive decay of uranium atoms. Radon and its daughter products are considered hazardous substances under CERCLA. However, radon is naturally present in some soil. Most commercial Phase I site assessments will not include radon in the scope of work. However, financial institutions may require its inclusion. It is also becoming standard to test for radon in residential property transactions.

Because radon is a heavy gas it usually collects in basements or lower levels of a building. Radon is a concern because of its potential cancer causing effects. Radon cannot be detected in the field without the use of detection devices or analytical testing. For the purposes of the Phase I process, it is necessary to note all low lying site features or building structures where radon could collect. Also, published radon data is readily available from each state that provides a good baseline to determine whether radon is likely to be an issue and if analytical testing should be recommended.

Asbestos

Material is considered asbestos containing if it contains more than one-percent asbestos. Asbestos has been used in hundreds of products, but for ease of identification, the U.S. EPA has classified asbestos-containing materials (ACM) into three categories:

• Surfacing Material: ACM sprayed or troweled on surfaces (walls, ceilings, structural members) for acoustical, decorative, or fireproofing purposes including plaster and fireproofing insulation.
• Thermal System Insulation: Insulation used to inhibit heat transfer or prevent condensation on pipes, boilers, tanks, ducts, and various other components of hot and cold water systems, and heating, ventilation, and air conditioning (HVAC) systems. This includes pipe lagging and wrap; block, batt, and blanket insulation; cements and muds; and a variety of other products such as gaskets and ropes.
• Miscellaneous Materials: Other products and materials such as floor tile, ceiling tile, roofing felt, concrete pipe, outdoor siding, and fabrics.

It is possible to "suspect" that a material is or contains asbestos by visual inspection, but actual determinations can only be made by instrumental analysis.

Asbestos is more of a health issue than an environmental issue. When ACM breaks down it releases fibers into the air. When the fibers are breathed in they lodge in the lungs. A build up of the fibrous asbestos material may cause asbestosis of the lungs or other associated diseases that cause breathing difficulty and potentially even death.

Lead

Lead is a naturally-occurring heavy metal that is hazardous to health if breathed or swallowed. The hazard of lead in drinking water and lead-based paint can be evaluated best by analytical testing. The environmental hazards are not encompassed by Superfund's appropriate inquiry responsibilities. However, like asbestos, if there is a disposal of lead-containing substances on the site or in a facility, CERCLA liability may arise.

The use of lead in gasoline, paints, and plumbing compounds has been restricted or eliminated by Federal law. Older buildings may still contain lead-based paint. As the paint peels, is stripped, or naturally deteriorates, lead particles may accumulate on surfaces or be released into the air where they can be breathed or swallowed. In addition, lead is a concern in soil and groundwater due to prior releases from USTs or ASTs that contained leaded gasoline. Lead-acid batteries that may have been stored or recycled on-site may also pose a problem if they leak. Automotive repair facilities are a prime candidate for lead contamination.

It is very difficult to identify lead-based paint or lead in drinking water during a Phase I ESA without using screening equipment or analytical testing. In older buildings where lead-based paint is suspected, it is important to note the location, condition, and approximate square footage of the suspect material. The report should also note whether leaded gasoline was ever stored onsite.

Pesticides/Herbicides

A pesticide is a substance or mixture of substances intended to prevent or mitigate infestation by, or destroy or repel, any pest. Under the broad heading of pesticides, the following substances are included: insecticides, rodenticides, herbicides, disinfectants, fungicides, and biocides.

An herbicide is a chemical pesticide designed to control or destroy plants, weeds, or grasses. Over 1 billion pounds of conventional pesticides are sold annually in the United States, and they are used primarily for agricultural purposes, home and garden application, and forestry and industry purposes.

If conducting a site assessment for pesticides on an agricultural property, there are several important things to note. Prior to 1900 pesticides were not used. Before 1945, many heavy metals served the purpose of controlling pest infestation, and it was only after 1945 that synthetic organic pesticides became widely used, with the resulting increase in the number of pesticides developed. The following table indicates common pesticides used on particular agricultural products.

Agricultural Crop	Common Pesticides Used
Vegetables	DDT, Dieldrin, Endrin
Old Orchards	Lead, Mercury, Arsenic, DDT, Dieldrin
Grapes	Copper, DDT
Strawberries	Vorlex
Tobacco	EDB, Arsenic, DDT, Chlordane, Heptachlor
Turf	DDT, Heptachlor, Chlordane, Dieldrin

Areas associated with agricultural activity where contamination may be found include farm dumps (usually a ravine or steep grade, or at edges of the property), and pesticide mixing areas. Right-of-ways including power lines, gas lines, telephone lines, railroads and roadways are also common areas where pesticides have been extensively used. Utility companies in the 1950s began using pesticides to control plant growth under power lines. Prior to the 1940s, railroads used waste oils, salts, arsenic compounds, and burning as methods to control vegetation. Highway departments used various mixtures of pesticides and oils and fuels, specifically lindane, DDT, sevin, and malathion.

Other areas of concern where pesticides have been and are still extensively used are drive-in theaters (rodent and weed control), wetlands (mosquito control), and golf courses (weed and insect control).

Because of their chemical structure, pesticides and herbicides accumulate in fat cells and therefore can lead to poisoning of animals and/or humans if levels become too high. The past or present use of pesticides or herbicides on a property usually can be determined from site history and from historical documentation, such as process methods.

Interviews

The objective of interviews is to obtain information indicating potential environmental conditions on a site that have not been previously discovered through other methods or to confirm information already obtained. Questions pertaining to historical use of the site, presence of previous environmental reports, site operations, and pertinent records should be asked to determine if there are potential environmental conditions on the property. Persons to be interviewed should be contacted prior to the site visit and then interviewed in-person during the site reconnaissance. If the site is vacant, previous managers and occupants should be interviewed prior to the site visit. It is important to clearly document and include in the report all interviews by noting the time and location of the interview, the name of the interviewer(s) and interviewee(s), the questions asked, and answers given.

Persons to be interviewed include:

• Site Manager: the property owner should identify a person with good knowledge of the use and physical characteristics of the property. Usually this person is the property manager, plant supervisor, or head maintenance person. Sometimes the site manager simply acts as a figurehead and is not very knowledgeable about site activities. In this case, ask him/her who would have the most knowledge of the site.

• Occupants: an attempt should be made to interview a reasonable number of site occupants to determine if they have any knowledge of activities that may pose a threat to the environmental condition of the property. A major occupant is any occupant using at least 40% of the leasable area of the property or any anchor tenant when the property is a shopping center. If there are five or fewer occupants, a reasonable attempt should be made to interview a representative of each one. If there are more than five occupants, the major occupants and those that are likely to have an environmental impact should be interviewed. No matter how many people are interviewed, always note who the site occupants are in the report. Residential occupants do not need to be interviewed. However, if the property has non-residential uses, interviews should be conducted.

• Local Government Officials: Since local government agencies work in the immediate area where the site is located, they sometimes have in-sight into activities that may affect the environmental conditions of the property. A reasonable attempt should be made to interview at least one staff member of any one of the following types of local government agencies:
  • Local fire department that serves the property.
  • Local health agency or local/regional office of state health agency serving the area in which the property is located.
  • Local agency or local/regional office of state agency having jurisdiction over hazardous waste disposal or other environmental matters in the area in which the property is located.

Report

The report should include documentation to support analyses, opinions, and conclusions included in the report. All information sources should be documented in a manner such that it could be reproduced at a later date. The report should include a description of all environmental conditions observed on the site. In addition, the environmental professional's opinion of whether the environmental conditions will cause an impact on the property or the surrounding area should be addressed. All deletions or deviations from generally accepted standards, the client's standards, or the previously agreed-upon scope of work should be noted in the report. If information was not obtained state the reason why.

The report must have a findings and conclusions section that states either no evidence of recognized environmental conditions in connection with the property was found, or notes the exceptions to this statement. It is important to detail the suspected areas of environmental impact as much as possible in order to allow the user to determine what the next step should be. Some clients want recommendations for additional work included in this section.

Finally, the report should identify the person(s) completing the report, and should be signed by the person preparing the report and the person who reviewed the report. In addition, the user of the report must be told the qualifications of the environmental professional. The qualifications can either be included in the report or delivered separately to each user.

PHASE I ENVIRONMENTAL SITE ASSESSMENT PROTOCOLS

In order to assure that the ESA process is completed in compliance with accepted commercial and professional standards, several companies and organizations have developed protocols for various phases of the ESA process. The most often cited protocol was developed by the American Society for Testing and Materials (ASTM).

ASTM has published a standard practice document for Phase I site assessments, which is the most widely used standard in the United States for completing an assessment. The purpose of this standard is to define good commercial and customary practice for conducting an environmental site assessment of a property with respect to the range of contamination within the scope of CERCLA as well as petroleum products. The standard describes the records review process, the site reconnaissance process, the interview process, and the evaluation and report preparation process.

At this time, the U.S. EPA has not issued its own protocol for conducting site assessments, and any guidance the EPA may provide would come under regulatory actions addressing contamination under RCRA or CERCLA.

Many states have begun to implement stringent regulations addressing the sale or purchase of contaminated property. An increasing number of states have existing or proposed requirements for site investigations and cleanup prior to the sale of commercial, industrial, and in some cases residential property. Typically, state environmental protection agencies also provide guidelines for an owner/operator or potential purchaser to follow when investigating and remediating a brownfield property under Voluntary Cleanup Programs (VCP). If the guidelines are followed the state agency may release the party from further liability of environmental contamination that was identified during the investigation.

Many companies, especially banks, have developed their own protocols for use when assessing property. Each company has a different perspective on how environmental conditions affect their purchase, development, or financing of property. Therefore, it is critical that before the ESA process is started all parties involved know what standard will be used and make sure that all elements are completed in the appropriate manner.

Where Do We Go After Phase I ESA?

Deciding on the next appropriate step following a Phase I ESA can be difficult and is usually made after consultation with the various parties involved. In some cases, enough information is gathered from the Phase I to know that the site is contaminated to the extent that the cost of cleanup is too great for the expected use and benefits of a developed site. In other cases, the extent of contamination may not be as bad as expected and the cost of cleanup is manageable.

In many cases, potential environmental concerns are identified during the Phase I ESA process but it is uncertain whether contamination actually exists onsite, and if so, to what extent. In these cases, a client usually asks for a limited sampling plan (Phase II ESA) to be conducted to further explore the site.

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PHASE II ENVIRONMENTAL SITE ASSESSMENT

The next level of an ESA is the Phase II Environmental Site Assessment. This is the start of the field investigation that is needed in order to determine the nature and extent of contamination, and if the known or suspected impacts to the environment are above regulatory levels and will need corrective action. Phase II utilizes information compiled during Phase I to develop a detailed, site-specific sampling and analysis strategy that will target suspected or known site contamination. The goal of the sampling strategy is to identify particular hazardous or non-hazardous constituents that may be present at the site, to evaluate the extent of contamination and its risk implementation, if any, and to estimate the financial impact to parties pursuing the transaction.

The ESA process is sometimes thought to be a discrete set of steps that happen in all cases. However, the process presented here is just that, a process. Depending on the particular set of conditions, the user must determine what components of the ESA process should be completed. For instance, if a previous site assessment was completed and it was determined that contamination exists onsite, the project may begin with specific Phase II sampling. However, for a new site where nothing is known, the general process presented below is usually followed.

Sampling Plan

Prior to a site investigation, a sampling plan must be completed which addresses all areas to be identified. The plan should be approved and agreed upon by all stakeholders prior to project initiation. For each area to be investigated, the plan should include equipment to be used, number of samples to be collected, laboratory analyses to be completed, disposal methods, depth assumptions, turn-around-times for laboratory analysis, suspected constituents/problems, decontamination procedures, and all assumptions. The sampling plan may include the following issues:

• Surface and subsurface soil sampling and analysis;
• Groundwater sampling and analysis;
• Surface water sampling and analysis;
• Waste sampling and analysis - piles, pits, ponds, lagoons, landfills, building components;
• Underground storage tank testing;
• Geophysical investigation;
• Air quality studies; and
• Other: asbestos, radon, PCBs, pesticides.

Technologies

Numerous technology options are available to assist those involved in brownfields assessment. EPA's Technology Innovation Office (TIO) encourages the use of innovative and cost-effective technologies to characterize and clean up contaminated sites. Innovative technologies for evaluating the nature and extent of contamination and for addressing the cleanup of brownfields sites hold promise for reducing the cost of cleanup and accelerating the cleanup schedule--potentially producing significant benefits to brownfields stakeholders by reducing barriers to redevelopment that add to costs, or time schedules, or create uncertainties. When factors such as lower cost, increased environmental protection, and improved effectiveness are considered, innovative technologies frequently are more cost-effective and provide better and more efficient cleanup than established treatment technologies. Often, they also are more acceptable to communities.

Innovative does not mean unproven. An innovative technology is a technology that has been field-tested and applied to a hazardous waste problem at a site, but lacks a long history of full-scale use. Information about its cost and how well it works may be insufficient to support prediction of its performance under a wide variety of operating conditions. Nevertheless, innovative technologies are being used in many cleanup programs to assess contamination and to treat a variety of hazardous substances and petroleum products that have been released into the environment.

An emerging technology is an innovative technology that is currently undergoing bench-scale testing, in which a small version of the technology is tested in a laboratory.

An established technology is a technology for which cost and performance information is readily available. Only after a technology has been used at many different sites and the results fully documented is that technology considered established. The following general information presents different technologies that can be used to assess contamination or sources of contamination during a Phase II environmental site assessment. This list is not exhaustive and is provided to show that there are a number of choices for sampling different media.

Buried Objects

• Ground Penetrating Radar (GPR)
  GPR is a technology that emits pulses of electromagnetic energy into the ground to measure its reflection and refraction by subsurface layers and other features, such as buried objects. GPR can be helpful in locating USTs, utility lines, backfilled areas, determining geologic and hydrogeologic conditions, and occasionally delineating floating product.
• Electromagnetic (EM) Induction
  EM induction is a geophysical technology used to induce a magnetic field beneath the earth's surface, which in turn causes a secondary magnetic field to form around nearby objects that have conductive properties, such as ferrous and nonferrous metals. The secondary magnetic field is then used to detect and measure buried debris. EM can be useful for locating buried objects (metal and non-metal), obtaining geologic and hydrogeologic information, and, on rare occasions, delineate residual and floating product.
• Infrared Monitor (IR)
  An infrared monitor is a device used to monitor the heat signature of an object and thereby detect buried objects in soil.
• Seismic Reflection and Refraction
  Seismic reflection and refraction is a technology used to examine the geophysical features of soil and bedrock, including geophysical profiles as well as debris, buried channels, and other features. Seismic methods can be used to determine depth and thickness of geologic strata, determine depth to groundwater, estimate soil and rock composition, and help resolve fracture location and orientation.

Geophysical Profiles

• Direct Push Sampling
  Direct push sampling is a technique in which a sampling tube is hydraulically pushed or driven into the subsurface, collecting material as it advances. The sampling tubes are usually 2 to 4 feet in length and can provide a continuous sample of the subsurface material. The environmental specialist or geologist will log the type of material (i.e. clay, course sand, etc.) collected at each sampling interval and collect a representative sample from the material for laboratory analysis. The volume of soil and the sampling jars needed will depend on the laboratory analysis to be used. The type of laboratory analysis conducted is contingent on the suspected type of contaminants. Direct push sampling can occur only in unconsolidated sediments where bedrock is not present. This technique can be used when sampling for any constituent (VOCs, SVOCs, PCBs, PAHs, etc.)
• Seismic Reflection and Refraction (see above)

Soil

Soil Screening

• Flame Ionization Detector (FID)
  A flame ionization detector (FID) measures the change of signal as a hydrogen-air flame ionizes analytes. A FID can be used alone to give a total reading of ionized contaminants in parts per million (ppm). When used in this setting, the FID is a screening tool for soil contamination. It can give a general idea whether soil is slightly or grossly impacted based on the total reading. However, note that there is not a direct relationship between the contaminant levels identified with a FID and those obtained during laboratory analysis of the soil. In addition, the FID cannot identify individual contaminants. Because a FID can detect phenols, phthalates, PAHs, VOCs, and petroleum hydrocarbons, a reading could come from the presence of any one of these individual contaminants or a combination of them. A FID can also be used in conjunction with a gas chromatograph to identify and quantify the individual constituents causing the soil contamination.
• Photoionization Detector (PID)
  Similar to a FID, a photoionization detector measures the change of signal as analytes are ionized by an ultraviolet lamp. It can be used alone to give a general idea of levels of soil contamination, but it cannot identify the individual constituents that are present. The PID can detect VOCs and petroleum hydrocarbons. A PID can also be used in conjunction with a gas chromatograph to identify and quantify the individual constituents causing the soil contamination.

Soil Sampling

• Direct Push Sampling
  This is a technique in which a sampling tube is hydraulically pushed or driven into the subsurface, collecting material as it advances. This technique can be used when sampling for any constituent (VOCs, SVOCs, PCBs, PAHs, etc.).
• Soil Gas Survey
  Soil gas consists of gaseous elements and compounds that occur in small spaces between soil particles. Such gases can move through the soil, depending on changes in atmospheric pressure. During a soil gas survey a small hole (diameter less than 1 inch) is advanced to the desired depth. A small tube from a PID or FID is placed into the hole so the soil gas can travel up the tube to the ionization device. After ionization, the gas enters into a portable gas chromatograph (GC) that identifies and quantifies the individual organic compounds on the basis of molecular weight, characteristic fragmentation patterns, and retention times. The results of a soil gas survey give a general quantification and location of the constituents of soil contamination at the site. Soil gas surveys are applicable when the suspected contaminants are VOCs and/or SVOCs.
• Immunoassay Test Kits
  Immunoassay is an innovative technology used to measure compound-specific reactions to individual compounds or classes of compounds. The reactions are used to detect and quantify contaminants. In-field portable test kits using this method are available for the following compounds or groups of compounds: benzene, toluene, ethylbenzene, and xylene (BTEX), PCPs, PCBs, PAHs, pesticides, explosives, and metals. In order to use immunoassay testing effectively, one must know or have a strong suspicion what contaminant is in the soil, as well as where it is.
• Colorimetric Kits
  Colorimetric refers to chemical reaction-based indicators that are used to produce compound reactions to individual or classes of compounds. The reactions, such as visible color changes or other easily noted indications, are used to detect and quantify contaminants. In order to use colorimetric kits effectively as a testing method, the user must know or have a strong suspicion what contaminant is in the soil, as well as where it is. Colorimetric kits can be used to analyze for organic and explosive contaminants.
• Laser-Induced Fluorescence/Cone Penetrometry
  Laser-induced fluorescence/cone penetrometry is a field screening method that couples a fiber optic-based chemical sensor system to a cone penetrometer mounted on a truck. It is most effectively used when petroleum contamination is present.
• X-ray Fluorescence (XRF)
  An x-ray fluorescence analyzer is a self-contained, field-portable instrument, consisting of an energy dispersive x-ray source, a detector, and a data processing system that detects and quantifies individual metals or groups of metals.

Groundwater

• Drilling
  The objective of drilling a monitoring well into groundwater is to detect pollutants that may have entered an aquifer. Typically, a hollow stem auger (see picture) is used to penetrate the surface and reach the water table, the well is screened and cased, and samples are collected. It is important to locate a monitoring well appropriately, taking into consideration the direction of groundwater flow, location of any contaminant spills, nature of the contaminant (if known), and subsurface geology including depth to groundwater based on available information. Detailed protocols have been developed by testing laboratories, government environmental agencies, and trade organizations to ensure that samples are properly collected and analyzed.
• Direct Push Sampling (see above)
• Immunoassay Test Kits (see above)
• Colorimetric Kits (see above)
• Laser-Induced Fluorescence/Cone Penetrometry (see above)

Miscellaneous

• Air
  Infrared Monitor (IR): a device used to monitor the heat signature of an object, as well as sample air.
• Asbestos
  Polarized Light Microscopy (PLM): PLM is an analytical method using polarized light to identify optical properties of asbestos mineral. Results are specific for the type of asbestos mineral, and a laboratory should also provide the percentage of asbestos in a sample.
• Lead
  X-ray Fluorescence (XRF): a self-contained, field-portable instrument, consisting of an energy dispersive x-ray source, a detector, and a data processing system that detects and quantifies individual metals or groups of metals.

DATA INTERPRETATION: WHAT DO THE RESULTS MEAN?

Once the Phase II has been completed, the process of interpreting the data generated begins. This may be a complex process involving experts in the field of regulatory compliance, public health, risk assessment, finance, environmental remediation, site development, and legal affairs. There is no standard protocol to follow that will indicate that the site is or is not suitable for development. Decisions to purchase a property or to begin cleanup and redevelopment efforts will be made based on the input of the parties involved. Some of the factors to consider before taking the next step are:

• How much contamination is present?
• Is the contamination manageable; i.e., will it naturally attenuate itself over time, will it migrate off site with groundwater and impact other sites?
• Is the cost to remediate greater than the value of the property?
• Will purchase of the property open the new owner to environmental liability for the cleanup of the site?
• Will the return on the investment outweigh the cost to clean and redevelop the property?
• Will the time required to clean the site cause unacceptable delays in the redevelopment process?

Phase II ESA Protocols

ASTM has developed a standard for conducting Phase II ESAs. This guide covers a framework for employing good commercial and customary practices in conducting a Phase II environmental site assessment of a parcel of commercial property. The objective of conducting a Phase II ESA is to evaluate the recognized environmental conditions identified in the Phase I ESA or transaction screen process. The standard provides guidance for developing the scope of work, completing assessment activities, evaluating the data, interpreting results, and preparing the report.

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APPENDIX A:
GUIDE TO CONTAMINANTS FOUND AT TYPICAL BROWNFIELDS SITES

The following table identifies activities that may have caused contamination at brownfields sites. The table summarizes contaminants that are related to such activities and identifies sources for the contaminants; however, it is not an exhaustive list of contaminants that can be found at a brownfield site. Identifying contaminants that may be present should be determined on a site-by-site basis. Such determination should be conducted thoroughly and carefully. Information for this table was compiled from several sources, including various EPA Guides to Pollution Prevention for selected industries.

Past Activities Typically Conducted at Brownfield Sites	Typical Contaminants
Agriculture	VOCs, arsenic, copper, carbon tetrachloride, ethylene dibromide and methylene chloride, pesticides, insecticides, herbicides, grain fumigants
Automotive refinishing and repair	Some metals and metal dust, various organic compounds, solvents, paint and paint sludges, scrap metal, waste oils
Battery recycling and disposal	Lead, cadmium, acids, nickel, copper, zinc, arsenic, chromium
Chloro-alkali manufacturing	Chlorine compounds, mercury
Coal gasification	PAHs, sulfur compounds, cyanide, aluminum, iron, lead, nickel, chromium
Cosmetics manufacturing	Heavy metals, dust, solvents, acids
Dry cleaning activities	VOCs such as chloroform and tetrachloroethane, various solvents, spot removers, fluorocarbon 113, perchloroethylene
Dye facilities	2-naphthylamine, 4-aminobiphenyl, benzidine
Electroplating operations	Various metals such as cadmium, chromium, cyanide, copper, and nickel
Glass manufacturing	Arsenic, lead
Herbicide manufacturing and use	Dioxins, metals, herbicides
Hospitals	Formaldehyde, radionuclides, photographic chemicals, solvents, mercury, ethylene oxide, chemotherapy chemicals
Incinerators	Dioxin, various municipal and industrial waste, ash, ordnance compounds, metals
Landfills - municipal and industrial	Metals, VOCs, PCBs, ammonia, methane, household products and cleaners, pesticides, various wastes, hydrogen sulfide
Leather manufacturing	Toluene, benzene
Machine shops/metal fabrication	Metals, VOCs, dioxin, beryllium, degreasing agents, solvents, waste oils
Marine maintenance industry	Solvents, paints, cyanide, acids, VOC emissions, heavy metal sludges, degreasers
Munitions manufacturing	Lead, explosives, copper, antimony, unexploded ordnance (UXO)
Paint/ink manufacturing	Metals (such as chromium, cadmium, lead, and zinc), VOCs, chloroform, ethylbenzene, solvents, paints, inks
Pesticide manufacturing	VOCs, arsenic, copper, pesticides, insecticides, herbicides, fungicides, xylene, chlorinated organic compounds, solvents
Petroleum refining and reuse	Petroleum hydrocarbons, BTEX, fuels, oil and grease
Pharmaceutical manufacturing	Lead, various organic chemicals, organic solvents
Photographic manufacturing and uses	Silver bromide, methylene chloride, solvents, photographic products
Plastics manufacturing	Polymers, phthalates, cadmium, solvents, resins, chemical additives, VOCs
Printing industry	Silver, solvents, acids, waste oils, inks and dyes, photographic chemicals
Railroad yards	Petroleum hydrocarbons, VOCs, BTEX, solvents, fuels, oil and grease, lead, PCBs
Research and educational institutions	Inorganic acids, organic solvents, metals and metal dust, photographic waste, waste oil, paint, heavy metals, pesticides
Scrap metal operations	Various metals (such as lead and nickel), PCBs, dioxin, transformers
Semiconductor manufacturing	Metals, VOCs, carbon tetrachloride, degreasing agents, solvents
Smelter operations	Metals (such as lead, copper, and arsenic)
Underground storage tanks	Solvents, metals, POLs, BTEX, gasoline, diesel fuel
Wood pulp and paper manufacturing	Chlorinated organic compounds, dioxin, furans, chloroform, resin acids
Wood preserving	Creosote, PCP, arsenic, chromium, copper, PCBs, PAHs, beryllium, dioxin, wood preservatives, zinc

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APPENDIX B
FACTORS TO CONSIDER PRIOR TO BEGINNING THE ESA PROCESS

What is known about the site?

• Current or historical operations, use of hazardous wastes, owner/operators?
• List of hazardous chemicals used on-site?
• Boundaries of the site?
• Historical reports?

What records exist that indicate potential contamination and past use of the property?

• Have other environmental actions occurred (such as notices of violation)?
• Has an environmental audit been conducted?
• Are there accident or maintenance records available that indicate a release has occurred?

What level of site assessment is needed to identify the types and extent or the absence of contamination?

• The less that is known about a site, the greater the amount of investigation necessary to characterize the site.
• If previous environmental reports have identified potential areas of contamination or confirmed them, it may be more cost effective to complete a Phase I and II together at the first step.

Is the site located in an area targeted for redevelopment?

• Are there any redevelopment plans available for review?
• Does the owner/operator, tenant, or state-planning agency know of future development plans?

Is the site being considered for cleanup under a Federal or state Superfund cleanup initiative?

• If the answer is yes then contact the appropriate regulatory agency immediately. You do not want to jeopardize a positive relationship with regulators or the benefits from potential cost savings.

Are there federal, state, local, or tribal regulatory requirements for site assessment?

• Is there a state voluntary cleanup program (VCP)?
• What agency (Federal, state, local, or tribal) would be responsible for managing oversight of cleanup?
• Knowing who is responsible prior to implementation of the Phase I process helps ensure compliance, as well as identifies a point of contact for communication.

What are the special needs and concerns of the community?

• How can we encourage community involvement?
• How will the community make its views known?
• What environmental conditions will the community accept?

What environmental conditions are unacceptable or will hinder planned redevelopment and reuse?

• Determine what media (i.e. surface soil or water, groundwater) will impact redevelopment.
• Determine what level of contamination, if any, will affect the planned reuse?
• Look at levels of risk associated with planned reuse (i.e. residential, commercial, industrial).

If the site shows evidence of contamination, who and what will be affected?

• Is there a health risk?
• If so, who will potentially be impacted? How will they be notified?
• Will the evidence of contamination halt the transaction or redevelopment?
• Who will pay for the cleanup?

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APPENDIX C
LIST OF COMMON ENVIRONMENTAL ABBREVIATIONS AND ACRONYMS

A

• AA - Atomic Absorption
  
• ACGIH - American Conference of Governmental Industrial Hygienists
  
• ACL - Alternate Concentration Limit
  
• ACM - Asbestos-Containing Material
  
• ACO - Administrative Consent Order
  
• AHERA - Asbestos Hazard Emergency Response Act
  
• ANSI - American National Standards Institute
  
• ALJ - Administrative Law Judge
  
• AOC - Area of Contamination
  
• API - American Petroleum Institute
  
• AQCR - Air Quality Control Regions
  
• ARAR - Applicable or Relevant and Appropriate Requirements
  
• ARCS - Alternative Remedial Contracting Strategy
  
• ASFE - Association of Engineering Firms Practicing in the Geosciences (formerly known as the Association of Soil and Foundation Engineers
  
• ASHARA - Asbestos School Hazard Abatement Reauthorization Act
  
• ASHRAE - American Society of Heating, Refrigerating, and Air-Conditioning Engineers
  
• AST - Aboveground Storage Tank
  
• ASTM - American Society for Testing and Materials
  
• ATSDR - Agency for Toxic Substances and Disease Registry (U.S. DHHS)
  

B

• BACT - Best Available Control Technology
  
• BAT - Best Available Technology
  
• BCT - Best Conventional Technology
  
• BDAT - Best Demonstrated Achievable Technology
  
• BNA - Bureau of National Affairs
  
• BOD - Biochemical Oxygen Demand
  
• BPATT - Best Practicable Available Treatment Technology
  
• BPCTCA - Best Practical Control Technology Currently Available
  
• BPT - Best Practicable Technology
  
• BTEX - Benzene, Toluene, Ethylbenzene, Xylene
  

C

• CAA - Clean Air Act
  
• CAPA - Critical Aquifer Protection Area
  
• CCA - Chromated Copper Arsenate
  
• CD - Consent Decree
  
• CDC - Centers for Disease Control and Prevention
  
• CEQ - Council on Environmental Quality
  
• CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act
  
• CERCLIS - Comprehensive Environmental Response, Compensation, and Liability Information System
  
• CERI - Center for Environmental Research
  
• CESQG - Conditionally Exempt Small Quantity Generator
  
• CFC - Chlorofluorocarbon
  
• CFR - Code of Federal Regulations
  
• CGI - Combustible Gas Indicator
  
• CGL - Comprehensive General Liability
  
• CHCM - Certified Hazard Control Manager
  
• CHMM - Certified Hazardous Materials Manager
  
• CIH - Certified Industrial Hygienist
  
• CLU-IN - EPA Hazardous Waste Cleanup Information Web Site
  
• CMS - Corrective Measure Study
  
• CO - Consent Order
  
• COD - Chemical Oxygen Demand
  
• CPG - Certified Professional Geologist
  
• CPSC - Consumer Product Safety Commission
  
• CSP - Certified Safety Professional
  
• CWA - Clean Water Act
  
• CWT - Centralized Waste Treatment
  
• CZMA - Coastal Zone Management Act
  

D

• D&B - Dunn & Bradstreet
  
• DAF - Dilution/Attenuation Factors
  
• DDT - Dichlorodiphenyltrichloroethane
  
• DEIS - Draft Environmental Impact Statement
  
• DMR - Discharge Monitoring Report
  
• DNAPL - Dense Nonaqueous Phase Liquid
  
• DO - Dissolved Oxygen
  
• DOD - Department of Defense
  
• DOE - Department of Energy
  
• DOI - Department of the Interior
  
• DOJ - Department of Justice
  
• DOT - Department of Transportation
  
• DQO - Data Quality Objective
  

E

• EA - Environmental Audit
  
• EDB - Ethylene Dibromide (gasoline additive)
  
• EHS - Extremely Hazardous Substance
  
• EIL - Environmental Impairment Liability
  
• EIS - Environmental Impact Statement
  
• EPA - Environmental Protection Agency (U.S.)
  
• EPCRA - Emergency Planning and Community Right to Know Act (a.k.a. SARA Title III)
  
• ERC - Emission Reduction Credit
  
• ERD - Emergency Response Division (of OERR)
  
• ERNS - Emergency Response Notification System
  
• ESA - Endangered Species Act
  
• ESA - Environmental Site Assessment
  
• ESP - Electrostatic Precipitation
  

F

• Fannie Mae - Federal National Mortgage Association
  
• FAR - Federal Acquisition Regulations
  
• FBC - Fluidized Bed Combustion
  
• FDIC - Federal Deposit Insurance Corporation
  
• FEIS - Final Environmental Impact Statement
  
• FGD - Flue Gas Desulfurization
  
• FHSA - Federal Hazardous Substances Act
  
• FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act
  
• FINDS - Facility Index System
  
• FNMA - Federal National Mortgage Association ("Fannie Mae")
  
• FNSI - Finding of No Significant Impact (a.k.a. FONZI)
  
• FOIA - Freedom of Information Act
  
• Freddie Mac - Federal Home Loan Mortgage Corporation
  
• FS - Feasibility Study
  
• FSP - Field Sampling Plan
  
• FWPCA - Federal Water Pollution Control Act
  
• FWQC - Federal Water Quality Criteria
  

G

• GAO - Government Accounting Office
  
• GC - Gas Chromatography
  
• GC/MS - Gas Chromatograph/Mass Spectrometry
  
• GEP - Good Engineering Practice
  

H

• HAZMAT - Hazardous Material
  
• Hazwoper - Hazardous Waste Operations and Emergency Response
  
• HC - Hydrocarbon
  
• HCFC - Hydrochlorofluorocarbon
  
• HEPA - High Efficiency Particulate Air (filtration)
  
• HMTA - Hazardous Materials Transportation Act
  
• HOC - Halogenated Organic Compound
  
• HRS - Hazard Ranking System
  
• HSWA - Hazardous and Solid Waste Amendments (1984 amendment to RCRA)
  
• HUD - Housing and Urban Development (Department of)
  
• HWDMS - Hazardous Waste Data Management System
  

I

• ICP - Inductively Coupled Plasma
  
• IDLH - Immediately Dangerous to Life or Health
  
• IG - Inspector General
  
• IPM - Integrated Pest Management
  
• IRIS - Integrated Risk Information System
  
• ITR - Innovative Technology Requirement
  
• ITT - Innovative Treatment Technology
  

L

• LAER - Lowest Achievable Emission Rate
  
• LBP - Lead-Based Paint
  
• LCP - Local Contingency Plan
  
• LDR - Land Disposal Restrictions
  
• LEPC - Local Emergency Planning Committee
  
• LLRWPA - Low-Level Radioactive Waste Policy Act
  
• LNAPL - Light Nonaqueous Phase Liquid
  
• LNG - Liquefied Natural Gas
  
• LQG - Large Quantity Generator
  
• LTRA - Long Term Remedial Action
  
• LUST - Leaking Underground Storage Tank
  

M

• MCL - Maximum Contaminant Level
  
• MCLG - Maximum Contaminant Level Goal
  
• MEK - Methyl Ethyl Ketone
  
• MEP - Maximum Extent Practicable
  
• MOA - Memorandum of Agreement
  
• MOU - Memorandum of Understanding
  
• MPRSA - Marine Protection, Research, and Sanctuaries Act
  
• MS - Mass Spectrometry
  
• MSDS - Material Safety Data Sheet
  
• MSHA - Mine Safety and Health Administration
  
• MSW - Municipal Solid Waste
  
• MSWLF - Municipal Solid Waste Landfill Facility
  
• MTBE - Methyl Tertiary Butyl Ether
  
• MTR - Minimum Technology Requirements
  

N

• NAAQS - National Ambient Air Quality Standards
  
• NAPL - Nonaqueous Phase Liquid
  
• NBAR - Nonbinding Preliminary Allocation of Responsibility
  
• NCP - National Contingency Plan
  
• NEIC - National Enforcement Investigations Center
  
• NEPA - National Environmental Policy Act
  
• NESHAP - National Emission Standards for Hazardous Air Pollutants
  
• NFPA - National Fire Protection Association
  
• NFRAP - No Further Response Action Planned
  
• NIOSH - National Institute for Occupational Safety and Health
  
• NOAA - National Oceanic and Atmospheric Administration
  
• NOx - Nitrogen Oxide
  
• NOV - Notice of Violation
  
• NPDES - National Pollutant Discharge Elimination System
  
• NPDWS - National Primary Drinking Water Standards
  
• NPL - National Priorities List
  
• NRC - National Response Center
  
• NRC - Nuclear Regulatory Commission
  
• NRT - National Response Team
  
• NSPS - New Source Performance Standards
  
• NTP - National Toxicology Program
  
• NWPA - Nuclear Waste Policy Act
  

O

• O&M - Operations & Maintenance
  
• OAQPS - Office of Air Quality Planning and Standards (U.S. EPA)
  
• OECM - Office of Enforcement and Compliance Monitoring (U.S. EPA)
  
• OERR - Office of Emergency and Remedial Response (U.S. EPA)
  
• ORM - Other Regulated Material
  
• OSC - On-Scene Coordinator
  
• OSHA - Occupational Health and Safety Administration
  
• OSW - Office of Solid Waste (U.S. EPA)
  
• OSWER - Office of Solid Waste and Emergency Response (U.S. EPA)
  
• OTA - Office of Technology Assessment (U.S. EPA)
  
• OVA - Organic Vapor Analyzer
  
• OWPE - Office of Waste Programs Enforcement (U.S. EPA)
  

P

• PA/SI - Preliminary Assessment/Site Inspection
  
• PAH - Polynuclear Aromatic Hydrocarbons
  
• PBMS - Performance-Based Measurement System
  
• PCB - Polychlorinated Biphenyl
  
• PCDD - Polychlorinated Dibenzo-p-Dioxins
  
• PCDF - Polychlorinated Dibenzofurans
  
• PCM - Phase Contrast Microscopy
  
• PCP - Pentachlorophenol
  
• PE - Professional Engineer
  
• PEL - Permissible Exposure Limit
  
• PG - Professional Geologist
  
• PHE - Public Health Evaluation
  
• PHSA - Public Health Service Act
  
• PID - Photoionization Detector
  
• PLM - Polarized Light Microscopy
  
• PMN - Pre-Manufacturing Notices
  
• POTW - Publicly Owned Treatment Works
  
• PPB - Parts Per Billion
  
• PPM - Parts Per Million
  
• PPQ - Parts Per Quadrillion
  
• PPT - Parts Per Trillion
  
• PRP - Potentially Responsible Party
  
• PVC - Polyvinyl Chloride
  

Q

• QA/QC - Quality Assurance/Quality Control
  
• QAPP - Quality Assurance Project Plan
  
• R
  
• RA - Remedial Action
  
• RACT - Reasonably Available Control Technology
  
• RAM - Real-Time Air Quality Simulation Model
  
• RBCA - Risk-Based Corrective Action
  
• RCRA - Resource Conservation and Recovery Act
  
• RCRIS - Resource Conservation and Recovery Information System
  
• RD - Remedial Design
  
• RD/RA - Remedial Design and Remedial Action
  
• RFA - RCRA Facility Assessment
  
• RFI - RCRA Facility Investigation
  
• RI/FS - Remedial Investigation/Feasibility Study
  
• ROD - Record of Decision
  
• RPAR - Rebuttable Presumption Against Registration
  
• RQ - Reportable Quantity
  
• RRT - Regional Response Team
  
• RTC - Resolution Trust Corporation
  

S

• SAB - Science Advisory Board
  
• SARA - Superfund Amendments and Reauthorization Act
  
• SCAP - Superfund Comprehensive Accomplishments Plan
  
• SCS - Soil Conservation Service
  
• SDWA - Safe Drinking Water Act
  
• SEAM - Superfund Exposure Assessment Manual
  
• SEM - Scanning Electron Microscopy
  
• SERC - State Emergency Response Commission
  
• SETS - Superfund Enforcement Tracking System
  
• SIC - Standard Industrial Classification
  
• SIP - State Implementation Plan
  
• SMCL - Secondary MCL
  
• SMCRA - Surface Mining Control and Reclamation Act
  
• SMOA - Superfund Memorandum of Agreement
  
• SNUR - Significant New Use Rule
  
• SO2 - Sulfur Dioxide
  
• SOCMI - Secondary Organic Chemical Manufacturing Industry
  
• SPCC - Spill Prevention Control and Countermeasure
  
• SQG - Small Quantity Generator
  
• STEL - Short-Term Exposure Limit
  
• SVE - Soil Vapor Extraction
  
• SVOC - Semi-volatile Organic Compound
  
• SWDA - Solid Waste Disposal Act
  
• SWMU - Solid Waste Management Unit
  
• SWTCP - Surface Water Toxic Controls Program
  

T

• TC - Toxicity Characteristics
  
• TCA - Trichloroethane
  
• TCE - Trichloroethylene
  
• TCLP - Toxicity Characteristic Leaching Procedure
  
• TEM - Transmission Electron Microscopy
  
• THC - Total Hydrocarbons
  
• TLV - Threshold Limit Value
  
• TOC - Total Organic Contaminants
  
• TOX - Total Organic Halogens
  
• TPH - Total Petroleum Hydrocarbons
  
• TPQ - Threshold Planning Quantity
  
• TRI - Toxic Release Inventory
  
• TSCA - Toxic Substances Control Act
  
• TSD - Treatment, Storage, and Disposal Facilities
  
• TSP - Tri-Sodium Phosphate
  
• TSP - Total Suspended Particulates
  
• TSS - Total Suspended Solids
  

U

• UIC - Underground Injection Control
  
• USACE - U.S. Army Corps of Engineers (a.k.a. The Corps)
  
• USDA - U.S. Department of Agriculture
  
• USFS - U.S. Forest Service
  
• USFWS - U.S. Fish and Wildlife Service
  
• USGS - U.S. Geological Survey
  
• UST - Underground Storage Tank
  

V

• VCP - Voluntary Cleanup Program
  
• VOC - Volatile Organic Compound
  

W

• WQA - Water Quality Act (Federal)
  
• WQMP - Water Quality Management Plan
  

X

• XRF - X-Ray Fluorescence
  

Top of page

APPENDIX D
GLOSSARY

Absorption: the passage of one substance into or through another.

Adsorption: the adhesion of molecules of gas, liquid, or dissolved solids to a surface. The term also refers to a method of treating wastes in which activated carbon removes organic matter from wastewater.

American Society for Testing and Materials (ASTM): sets standards for many services, including methods of sampling and testing of hazardous waste and media contaminated with hazardous waste.

Applicable or Relevant and Appropriate Requirement (ARAR): cleanup standards, standards of control, and other substantive environmental protection requirements, criteria, or limits promulgated under Federal or state law that specifically address problems or situations present at a CERCLA site. ARARs are major considerations in setting cleanup goals, selecting a remedy, and determining how to implement that remedy at a CERCLA site. ARARs must be attained at all CERCLA sites unless a waiver is attained. ARARs are not national cleanup standards for the Superfund program. See also Comprehensive Environmental Response, Compensation, and Liability Act and Superfund.

Aquifer: an underground rock formation composed of such materials as sand, soil, or gravel that can store groundwater and supply it to wells and springs.

Aromatics: organic compounds that contain 6-carbon ring structures, such as creosote, toluene, and phenol, which often are found at dry cleaning and electronic assembly sites.

Bedrock: the rock that underlies the soil; it can be permeable or non-permeable.

Borehole: a hole cut into the ground by means of a drilling rig.

Brownfields: abandoned, idled, or under-used industrial and commercial facilities where expansion or redevelopment is complicated by real or perceived environmental contamination.

BTEX: term used for benzene, toluene, ethylbenzene, and xylene-volatile aromatic compounds typically found in petroleum products, such as gasoline and diesel fuel.

Cadmium: a heavy metal that accumulates in the environment. See also Heavy Metal.

Clean Air Act (CAA): a Federal law passed in 1970 that requires the U.S. Environmental Protection Agency (EPA) to establish regulations to control the release of contaminants to the air to protect human health and environment.

Cleanup: term used for actions taken to deal with a release or threat of release of a hazardous substance that could affect humans and/or the environment. The term sometimes is used interchangeably with the terms remedial action, removal action, response action, or corrective action.

Clean Water Act (CWA): amendment to the Federal Water Pollution Control Act of 1972, which set the basic structure for regulating discharges of pollutants to U.S. waters. This law gave EPA the authority to set effluent standards on an industry-by-industry basis and to set water quality standards for all contaminants in surface waters.

Colorimetric: refers to chemical reaction-based indicators that are used to produce compound reactions to individual compounds, or classes of compounds. The reactions, such as visible color changes or other easily noted indications, are used to detect and quantify contaminants.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA): Federal law passed in 1980 that created a special tax that funds a trust fund, commonly known as Superfund, to be used to investigate and clean up abandoned or uncontrolled hazardous waste sites. CERCLA required for the first time that EPA step beyond its traditional regulatory role and provide response authority to clean up hazardous waste sites. EPA has primary responsibility for managing cleanup and enforcement activities authorized under CERCLA. Under the program, EPA can pay for cleanup when parties responsible for the contamination cannot be located or are unwilling or unable to perform the work, or take legal action to force parties responsible for contamination to clean up the site or reimburse the Federal government for the cost of the cleanup. See also Superfund.

Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS): database that serves as the official inventory of Superfund hazardous waste sites. CERCLIS also contains information about all aspects of hazardous waste sites, from initial discovery to deletion from the National Priorities List (NPL). The database also maintains information about planned and actual site activities and financial information entered by EPA regional offices. CERCLIS records the targets and accomplishments of the Superfund program and is used to report that information to the EPA Administrator, Congress, and the public. See also National Priorities List and Superfund.

Confining Layer: a geological formation characterized by low permeability that inhibits the flow of water. See also Bedrock and Permeability.

Contaminant: any physical, chemical, biological, or radiological substance or matter present in any media at concentrations that may result in adverse effects on air, water, or soil.

Creosote: an oily liquid obtained by the distillation of wood that is used as a wood preservative and disinfectant and often is found at wood preserving sites.

Dense Nonaqueous Phase Liquid (DNAPL): one of a group of organic substances that are relatively insoluble in water and denser than water. DNAPLs tend to sink vertically through sand and gravel aquifers to the underlying layer.

Dioxin (DDT): any of a family of compounds known chemically as dibenzo-p-dioxins. They are chemicals released during combustion. Concern about them arises from their potential toxicity and the risk posed by contamination in commercial products. Boilers and industrial furnaces are among the sources of dioxins.

Disposal: the final placement or destruction of toxic, radioactive or other wastes; surplus or banned pesticides or other chemicals; polluted soils; and drums containing hazardous materials from removal actions or accidental release. Disposal may be accomplished through the use of approved secure landfills, surface impoundments, land farming, deep well injection, ocean dumping, or incineration.

Electromagnetic (EM) Geophysics: refers to technologies used to detect spatial (lateral and vertical) differences in subsurface electromagnetic characteristics. The data collected provide information about subsurface environments.

Electromagnetic (EM) Induction: a geophysical technology used to induce a magnetic field beneath the earth's surface, which in turn causes a secondary magnetic field to form around nearby objects that have conductive properties, such as ferrous and nonferrous metals. The secondary magnetic field is then used to detect and measure buried debris.

Emerging Technology: an innovative technology that currently is undergoing bench-scale testing. During bench-scale testing, a small version of the technology is built and tested in a laboratory. If the technology is successful during bench-scale testing, it is demonstrated on a small scale at field sites. If the technology is successful at the field demonstrations, it often will be used full scale at contaminated waste sites. As the technology is used and evaluated at different sites, it is improved continually. See also Established Technology and Innovative Technology.

Enforcement Action: an action undertaken by EPA under its authority granted under various Federal environmental statutes, such as CERCLA, RCRA, CAA, CWA, the Toxic Substances Control Act (TSCA). For example, under CERCLA, EPA may obtain voluntary settlement or compel potentially responsible parties (PRP) to implement removal or remedial actions when releases of hazardous substances have occurred. See also Comprehensive Environmental Response, Compensation, and Liability Act, Potentially Responsible Party, and Removal Action.

Environmental Site Assessment (ESA): the process by which it is determined whether contamination is present on a site.

Established Technology: a technology for which cost and performance information is readily available. Only after a technology has been used at many different sites and the results fully documented is that technology considered established. The most frequently used established technologies are incineration, solidification and stabilization, and pump-and-treat technologies for groundwater. See also Emerging Technology and Innovative Technology.

Exposure Pathway: the route of contaminants from the source of contamination to potential contact with a medium (air, soil, surface water, or groundwater) that represents a potential threat to human health or the environment. Determining whether exposure pathways exist is an essential step in conducting a baseline risk assessment.

Ex-Situ: "moved from its original place;" excavated or removed.

Flame Ionization Detector (FID): an instrument often used in conjunction with gas chromatography to measure the change of signal as analytes are ionized by a hydrogen-air flame. It also is used to detect phenols, phthalates, polynuclear aromatic hydrocarbons (PAH), VOCs, and petroleum hydrocarbons

Gas Chromatography: a technology used for investigating and assessing soil, water, and soil gas contamination at a site. It is used for the analysis of VOCs and semivolatile organic compounds (SVOC). The technique identifies and quantifies organic compounds on the basis of molecular weight, characteristic fragmentation patterns, and retention time. Recent advances in gas chromatography that are considered innovative are portable, weatherproof units that have self-contained power supplies.

Ground-Penetrating Radar: a technology that emits pulses of electromagnetic energy into the ground to measure its reflection and refraction by subsurface layers and other features, such as buried debris.

Groundwater: water found beneath the earth's surface that fills pores between such materials as sand, soil, or gravel and that often supplies wells and springs. See also Aquifer.

Hazardous Substance: as defined under CERCLA, a hazardous substance is any material that poses a threat to public health or the environment. The term also refers to hazardous wastes as defined under the Resource Conservation and Recovery Act (RCRA). Typical hazardous substances are materials that are toxic, corrosive, ignitable, explosive, or chemically reactive. If a certain quantity of a hazardous substance, as established by EPA, is spilled into the water or otherwise emitted into the environment, the release must be reported. Under the legislation cited above, the term excludes petroleum, crude oil, natural gas, natural gas liquids, or synthetic gas usable for fuel.

Hazardous Waste: Under RCRA, a waste may be considered hazardous if it is ignitable (i.e., burns readily), corrosive, or reactive (e.g., explosive). Waste may also be considered hazardous if it contains certain amounts of toxic chemicals. In addition to these characteristic wastes, EPA has also developed a list of over 500 specific hazardous wastes. Hazardous waste takes many physical forms and may be solid, semi-solid, or even liquid.

Heavy Metal: refers to a group of toxic metals including arsenic, chromium, copper, lead, mercury, silver, and zinc. Heavy metals often are present at industrial sites at which operations have included battery recycling and metal plating.

Herbicide: a chemical pesticide designed to control or destroy plants, weeds, or grasses.

Hydrocarbon: an organic compound containing only hydrogen and carbon, often occurring in petroleum, natural gas, and coal.

Hydrogeology: the study of groundwater, including its origin, occurrence, movement, and quality.

Hydrology: the science that deals with the properties, movement, and effects of water found on the earth's surface, in the soil and rocks beneath the surface, and in the atmosphere.

Immunoassay: an innovative technology used to measure compound-specific reactions (generally colorimetric) to individual compounds or classes of compounds. The reactions are used to detect and quantify contaminants. The technology is available in field-portable test kits.

Infrared Monitor: a device used to monitor the heat signature of an object, as well as to sample air. It may be used to detect buried objects in soil.

Inorganic Compound: a compound that generally does not contain carbon atoms (although carbonate and bicarbonate compounds are notable exceptions), tends to be more soluble in water, and tends to react on an ionic rather than on a molecular basis. Examples of inorganic compounds include various acids, potassium hydroxide, and metals.

Innovative Technology: a process that has been tested and used as a treatment for hazardous waste or other contaminated materials, but lacks a long history of full-scale use and information about its cost and how well it works sufficient to support prediction of its performance under a variety of operating conditions. An innovative technology is one that is undergoing pilot-scale treatability studies that usually are conducted in the field or the laboratory and require installation of the technology, and provide performance, cost, and design objectives for the technology. Innovative technologies are being used under many Federal and state cleanup programs to treat hazardous wastes that have been improperly released. See also Emerging Technology and Established Technology.

Insecticide: a pesticide compound specifically used to kill or control the growth of insects

In-Situ: "in its original place," or "on-site;" unexcavated and unmoved. In situ soil flushing and natural attenuation are examples of in situ treatment methods by which contaminated sites are treated without digging up or removing the contaminants.

Landfill: a land disposal site for nonhazardous solid wastes at which the waste is spread in layers compacted to the smallest practical volume.

Laser-Induced Fluorescence/Cone Penetrometer: a field screening method that couples a fiber optic-based chemical sensor system to a cone penetrometer mounted on a truck. The technology can be used for investigating and assessing soil and water contamination.

Lead: a heavy metal that is hazardous to health if breathed or swallowed. Its use in gasoline, paints, and plumbing compounds has been sharply restricted or eliminated by Federal laws and regulations.

Leaking Underground Storage Tank (LUST): the acronym for "leaking underground storage tank." See also Underground Storage Tank.

Light Nonaqueous Phase Liquid (LNAPL): one of a group of organic substances that are relatively insoluble in water and are less dense than water. LNAPLs, such as oil, tend to spread across the surface of the water table and form a layer on top of the water table.

Mass Spectrometry: an analytical process by which molecules are broken into fragments to determine the concentrations and mass/charge ratio of the fragments. Innovative mass spectroscopy units, developed through modification of large laboratory instruments, are sometimes portable, weatherproof units with self-contained power supplies.

Medium: a specific environment -- air, water, or soil -- which is the subject of regulatory concern and activities.

Mercury: a heavy metal that can accumulate in the environment and is highly toxic if breathed or swallowed. Mercury is found in thermometers, measuring devices, pharmaceutical and agricultural chemicals, chemical manufacturing, and electrical equipment.

Monitoring Well: a well drilled at a specific location through which groundwater can be sampled at selected depths and studied to determine the direction of groundwater flow and the types and quantities of contaminants present in the groundwater.

National Priorities List (NPL): EPA's list of the most serious uncontrolled or abandoned hazardous waste sites identified for possible long-term remedial response under Superfund. Inclusion of a site on the list is based primarily on the score the site receives under the Hazard Ranking System (HRS). Money from Superfund can be used for cleanup only at sites that are on the NPL. EPA is required to update the NPL at least once a year

Natural Attenuation: an in-situ approach to cleanup that uses natural processes to contain the spread of contamination from chemical spills and reduce the concentrations and amounts of pollutants in contaminated soil and groundwater. Natural subsurface processes, such as dilution, volatilization, biodegradation, adsorption, and chemical reactions with subsurface materials, are allowed to reduce concentrations of contaminants to acceptable levels.

Organic Chemical or Compound: a substance produced by animals or plants that contains mainly carbon, hydrogen, and oxygen.

Pesticide: a substance or mixture of substances intended to prevent or mitigate infestation by, or destroy or repel, any pest. Pesticides can accumulate in the food chain and/or contaminate the environment if misused.

Phase I Environmental Site Assessment: an initial environmental investigation that is limited to a site visit, historical records search, and interviews to determine ownership of a site and to identify the kinds of chemical processes that were carried out at the site. A Phase I does not include any sampling.

Phase II Environmental Site Assessment: an investigation that includes tests performed at the site to confirm the location, quantity, and identity of environmental hazards. The assessment includes preparation of a report that includes recommendations for cleanup alternatives.

Phase III Environmental Site Assessment: the third-step in the assessment process that includes the removal of contaminated materials from a site and their legal disposal.

Photoionization Detector (PID): a nondestructive detector, often used in conjunction with gas chromatography, that measures the change of signal as analytes are ionized by an ultraviolet lamp. The PID also is used to detect VOCs and petroleum hydrocarbons. See also Portable Gas Chromatography.

Plume: a visible or measurable emission or discharge of a contaminant from a given point of origin into any medium.

Polychlorinated Biphenyl (PCB): a group of toxic, persistent chemicals, produced by chlorination of biphenyl, that once were used in high voltage electrical transformers because they transfer heat well while being fire resistant. These contaminants typically are generated from metal degreasing, printed circuit board cleaning, gasoline, and wood preserving processes. Further sale or use of PCBs was banned in 1979.

Polynuclear Aromatic Hydrocarbon (PAH): a chemical compound that contains more than one fused benzene ring. They are commonly found in petroleum fuels, coal products, and tar.

Potentially Responsible Party (PRP): an individual or company (such as owners, operators, transporters, or generators of hazardous waste) that is potentially responsible for, or contributing to, the contamination problems at a Superfund site. Whenever possible, EPA requires PRPs, through administrative and legal actions, to clean up hazardous waste sites they have contaminated

Radon: a colorless, naturally occurring, radioactive, inert gaseous element formed by radioactive decay of radium atoms.

Release: any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, leaching, dumping, or disposing into the environment of a hazardous or toxic chemical or extremely hazardous substance, as defined under RCRA.

Removal Action: usually a short-term effort designed to stabilize or clean up a hazardous waste site that poses an immediate threat to human health or the environment. Removal actions include removing tanks or drums of hazardous substances that were found on the surface and installing drainage controls or security measures, such as a fence at the site. Removal actions also may be conducted to respond to accidental releases of hazardous substances. CERCLA places time and money constraints on the duration of removal actions.

Reportable Quantity (RQ): the quantity of hazardous substances that, when released into the environment, can cause substantial endangerment to public health or the environment. Under CERCLA, the Federal government must be notified when quantities equaling or exceeding RQs specified in regulations are released.

Resource Conservation and Recovery Act (RCRA): a Federal law enacted in 1976 that established a regulatory syst