Environmental
Environmental Audit Approach
Regulatory data need to be
meticulously sifted and tell tale signs in the field interpreted meaningfully
OHC will
essentially follow the ASTM E 1527 guidelines in the completion of the
audits. The elements of such audits are summarized as follows:
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A visit to
investigate the subject site and neighboring areas with respect to
potential environmental contamination, hazardous materials violation or
illegal dumping.
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A review
of available geological and groundwater information.
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A records
search to determine past ownership and historical use of the subject
site.
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A review
of applicable local, state and federal records to identify use,
generation, storage, treatment or disposal of hazardous materials and
determine if any release of such materials has occurred at the subject
site and its vicinity.
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An
analysis of historical aerial photographs to determine prior land use of
the subject site and the adjacent areas.
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Interviews
with regulatory and utility personnel to determine spill incidents and
use and storage of potentially hazardous materials.
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A written
report documenting the findings and conclusions of the audit.
OHC has completed environmental audits of large acreage projects for school
boards and various private companies and is thus familiar with the necessary
steps to ensure that a proper due diligence effort as defined under the
'innocent landowner defense amendment' of 1989 to CERCLA is accomplished. In
particular, care will be taken to ensure the proper limits used in the
radius search and the search distances used in relation to the geometry of
the potential school sites under consideration. Elongated geometry will
require a different search distance approach to that potential problem
facilities along the long axis extremum are flagged. Simply using the center
point may miss potential problem facilities at the edges.
Interviews will be conducted with owners and related personnel to obtain
current and past contamination information relating to the site. Specific
questions will be asked regarding past hazardous chemical use, underground
storage tanks, use of herbicides and pesticides and any accidental spills.
Existing structures, tell tale vent or pads or any structure than will
provide any information regarding possible hazardous material use will be
noted. Any surrounding facility personnel will also be interviewed to
provide as much information as possible regarding the history of the
potential school site. The field visit will also encompass the nature of the
surrounding area and the various facilities that have a potential to impact
the potential county site.
A review of historical aerial photography will be conducted to identify any
potentially hazardous material use in the potential school site and its
vicinity. Although hazardous materials per se are not readily discernible on
aerial photography, changes in land use are discernible, such as barren land
within or adjacent to vegetated areas which suggests stress or other
disturbances. Junk yards, heavy industrial land use such as chemical
processing plants are readily discernible. The aerial photographs of the
site and the surrounding areas are scrutinized for any such "odd"
signatures. Any signature or area determined to be unidentifiable or suspect
is usually field investigated.
The regulatory records will be reviewed for the potential school site and
the vicinity being flagged as a facility of concern. The National Priorities
List for Superfund Sites, the CERCLA, ERNS, TSD and RCRA small and large
quantity generator lists, and the State and local UST and LUST databases
will all be searched. This will identify hazardous waste sites, leaking
underground storage tank sites and small/large quantity generators of
hazardous waste and the impact these may have on the potential school site.
The detailed contamination assessment reports and remedial actions
pertaining to flagged problem facilities in the vicinity of the potential
county site will be scrutinized and summarized in the audit to provide
complete and meaningful information to the Manatee County Government and
excerpted copies also provided to substantiate the inferences and
conclusions made in the audit report.
As farm and pasture land is often selected as potential school sites,
particular attention will be paid to the issue of arsenic dips in such
areas. Arsenic dips in farm and pasture land have been provided immunity
with respect to liability and as such need to be carefully evaluated as the
Manatee County Government will have to bear the expense of remedial actions
if it becomes necessary.
Again, considering the location and the acreage involved, a good possibility
of wetlands being involved exists. OHC has wetland certified staff to ensure
proper identification and evaluation of this import aspect of the
environmental audit.
OHC's expertise in indoor air quality, radon, asbestos and lead surveys will
be used in providing information regarding the potential need for such
detailed studies.
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