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22 LOGISTICS AND MANAGEMENT OF MULTIFACILITY ENVIRONMENTAL ASSESSMENTS THROUGHOUT THE UNITED STATES Daniel F. Buss, Associate Camp Dresser & McKee Inc. Milwaukee, Wisconsin, 53217 INTRODUCTION The Comprehensive Environmental Response Compensation and Liability Act (CERCLA) holds previous or current owners of property strictly liable for contamination on their property regardless of how long it has existed or who has caused it. The Superfund Amendment Reauthorization Act (SARA) of 1986 creates a means by which an "innocent landowner" can escape liability of owning contaminated property by inquiring into past ownership and users of the property (USEPA, 1991).' Such avenues of inquiry have been called environmental audits and environmental assessments. Whereas the audit will focus more on compliance issues, the environmental assessment is structured to discover contamination problems with the property. Although not required under Federal law, various states either require or recommend the performance of environmental assessments when commercial, industrial and certain residential properties are purchased. Therefore, liabilities associated with ownership of contaminated property have influenced the decision-making process when transferring property. Site specific substantive information must be reviewed to determine the environmental condition of property. In many situations, information relating to environmental issues is nonexistent, or its applicability questionable due to its age and analytical methodology. Therefore, difficulties in obtaining reliable historical environmental information can impact the environmental assessment process and, therefore, the property transaction. Environmental assessments in support of property transactions must be performed within a very short period. When multifacilities in different states are involved, management and coordination functions are increased to ensure schedules, budget, protocol and quality control procedures are followed. This paper will discuss general procedures implemented by CDM in performing multifacility environmental assessments throughout the United States. It will also discuss potential pitfalls in the environmental assessment process that can impact schedule, budget, and goals of the environmental assessment. METHODOLOGY A systematic approach was used by CDM when performing the environmental assessments. This approach followed the general steps presented in Figure 1. Initially, the scope of work and contractual responsibilities were developed between the client and CDM's Client Officer. Terms of the agreement generally requiring negotiation were limitation of liability and/or indemnification, tasks considered beyond the standard tasks performed for a Phase I environmental assessment, and cost. The scope of work for the environmental assessments covered standard "due diligence" areas for Phase I environmental assessments and was tailored to focus on environmental issues specific to operations at each property. During the initial planning stage, property specific issues to be emphasized during the environmental assessment were discussed with the client and included in the scope of work. Examples of work elements that were considered additional to the standard Phase I environmental assessment tasks generally involved subsurface investigations, asbestos surveys, underground tank investigations and indoor air quality analysis. Since these tasks required collection and laboratory analysis of environmental samples, this work was initiated as soon as possible during the environmental assessment. Sensitivity requirements and assessment protocol were discussed with the client at the initial planning phase of the assessment. Each facility representative was contacted by the client's assessment 47th Purdue Industrial Waste Conference Proceedings, 1992 Lewis Publishers, Inc., Chelsea, Michigan 48118. Printed in U.S.A. 191
Object Description
Purdue Identification Number | ETRIWC199222 |
Title | Logistics and management of multifacility environmental assessments throughout the United States |
Author | Buss, Daniel F. |
Date of Original | 1992 |
Conference Title | Proceedings of the 47th Industrial Waste Conference |
Conference Front Matter (copy and paste) | http://e-archives.lib.purdue.edu/u?/engext,43678 |
Extent of Original | p. 191-198 |
Collection Title | Engineering Technical Reports Collection, Purdue University |
Repository | Purdue University Libraries |
Rights Statement | Digital object copyright Purdue University. All rights reserved. |
Language | eng |
Type (DCMI) | text |
Format | JP2 |
Date Digitized | 2009-12-10 |
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Capture Details | ScandAll 21 |
Resolution | 300 ppi |
Color Depth | 8 bit |
Description
Title | page 191 |
Collection Title | Engineering Technical Reports Collection, Purdue University |
Repository | Purdue University Libraries |
Rights Statement | Digital copyright Purdue University. All rights reserved. |
Language | eng |
Type (DCMI) | text |
Format | JP2 |
Capture Device | Fujitsu fi-5650C |
Capture Details | ScandAll 21 |
Transcript | 22 LOGISTICS AND MANAGEMENT OF MULTIFACILITY ENVIRONMENTAL ASSESSMENTS THROUGHOUT THE UNITED STATES Daniel F. Buss, Associate Camp Dresser & McKee Inc. Milwaukee, Wisconsin, 53217 INTRODUCTION The Comprehensive Environmental Response Compensation and Liability Act (CERCLA) holds previous or current owners of property strictly liable for contamination on their property regardless of how long it has existed or who has caused it. The Superfund Amendment Reauthorization Act (SARA) of 1986 creates a means by which an "innocent landowner" can escape liability of owning contaminated property by inquiring into past ownership and users of the property (USEPA, 1991).' Such avenues of inquiry have been called environmental audits and environmental assessments. Whereas the audit will focus more on compliance issues, the environmental assessment is structured to discover contamination problems with the property. Although not required under Federal law, various states either require or recommend the performance of environmental assessments when commercial, industrial and certain residential properties are purchased. Therefore, liabilities associated with ownership of contaminated property have influenced the decision-making process when transferring property. Site specific substantive information must be reviewed to determine the environmental condition of property. In many situations, information relating to environmental issues is nonexistent, or its applicability questionable due to its age and analytical methodology. Therefore, difficulties in obtaining reliable historical environmental information can impact the environmental assessment process and, therefore, the property transaction. Environmental assessments in support of property transactions must be performed within a very short period. When multifacilities in different states are involved, management and coordination functions are increased to ensure schedules, budget, protocol and quality control procedures are followed. This paper will discuss general procedures implemented by CDM in performing multifacility environmental assessments throughout the United States. It will also discuss potential pitfalls in the environmental assessment process that can impact schedule, budget, and goals of the environmental assessment. METHODOLOGY A systematic approach was used by CDM when performing the environmental assessments. This approach followed the general steps presented in Figure 1. Initially, the scope of work and contractual responsibilities were developed between the client and CDM's Client Officer. Terms of the agreement generally requiring negotiation were limitation of liability and/or indemnification, tasks considered beyond the standard tasks performed for a Phase I environmental assessment, and cost. The scope of work for the environmental assessments covered standard "due diligence" areas for Phase I environmental assessments and was tailored to focus on environmental issues specific to operations at each property. During the initial planning stage, property specific issues to be emphasized during the environmental assessment were discussed with the client and included in the scope of work. Examples of work elements that were considered additional to the standard Phase I environmental assessment tasks generally involved subsurface investigations, asbestos surveys, underground tank investigations and indoor air quality analysis. Since these tasks required collection and laboratory analysis of environmental samples, this work was initiated as soon as possible during the environmental assessment. Sensitivity requirements and assessment protocol were discussed with the client at the initial planning phase of the assessment. Each facility representative was contacted by the client's assessment 47th Purdue Industrial Waste Conference Proceedings, 1992 Lewis Publishers, Inc., Chelsea, Michigan 48118. Printed in U.S.A. 191 |
Resolution | 300 ppi |
Color Depth | 8 bit |
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