© 2008, By J.G. Pohl, Principal, Integral Environmental Solutions (IES), Australia

© 2008, By J.G. Pohl, Principal, Integral Environmental Solutions (IES), Australia

Environmental Due Diligence

Be extremely careful when choosing an environmental consultant to carry out an environmental investigation or other similar work on your property. In one of our recent projects, our client's former consultant informed our client that their property was contaminated. In addition, our client’s former consultant informed Council that the property in question required an environmental Audit by a NSW EPA Accredited Site Auditor.

Hobby farm Owner to Develop his Land

The owner / builder of a small 0.7 hectare hobby farm wanted to develop his land. He had used the property for years by farming animals, such as cows, goats and horses. When the owner / builder originally purchased the hobby farm, the owner was provided with an environmental due diligence report, also called a Phase I & 2 Environmental Site Assessment (ESA) for the property. The Phase I & 2 report described historical usage as vacant, grazing, or unknown. A review of historic aerial photos indicated that no permanent structures were located onsite and it remained vacant during development of surrounding properties. The Phase I & 2 report concluded that the subject site may have been impacted from illegal dumping of building waste, dumping of fill, and pesticides / herbicides as evident by an area of dead grass on the property.

Based on the site history and field inspection, The Phase I & 2 report identified heavy metals, asbestos, petroleum hydrocarbons, pesticides, herbicides and poly-aromatic hydrocarbons (PAHs) as potential contaminants. Further investigation revealed some positive findings for heavy metals, PAHs and asbestos fragments.

Council Informs Owner to Remediate or Cleanup the Hobby farm

The owner / builder was informed by the local Council that he needed to remediate or cleanup his property before a Development Application (DA) could be granted. At that point in time, the owner / builder commissioned an environmental consultant to “fix the problem”. The consultant prepared a Remediation Action Plan (RAP) for the site, which provided guidance on how to remediate or cleanup the site. In addition, the consultant stipulated in the RAP the requirement for an environmental Audit of the Validation Report before construction commences.

Sleepless Nights

The owner / builder started to engage environmental consultants to carry out site remediation or cleanup. He thought he was close to getting this contaminated land issue out of his project’s way. To his amazement, instead of things getting better, he found that things were getting more complicated, consulting costs and project delays were escalating rapidly.

Stop the Bleeding

The owner / builder contacted us at IES for a consultation on his project, environmental issues and concerns. We were able to provide our client with immediate advice and discussed cost effective and viable options for moving forward. We took the job on, and immediately evaluated all environmental reports, corresponding data and previous project strategy.

We were mystified why a NSW EPA Accredited Site Audit requirement was included as a condition of the RAP. The 'Department of Urban Affairs and Planning State Environmental Protection (DUAP 1998) Policy 55 Remediation of Land (SEPP 55), planning guidelines for assisting planning authorities in dealing with land contamination, states that site audits are not mandatory at any stage of the planning process.

Site Audits are typically requested from the planning authority when a commercial or industrial site with significant contamination is being rezoned into a sensitive land use such as day care centre or residential with full soil access. In this case, the subject site is not grossly contaminated and is being developed where there is little opportunity for soil access.

In consideration of the absence of significant site contamination, we proposed Site Audit requirements were over conservative and unwarranted. IES successfully petitioned Council, had the Site Audit requirement removed from the RAP saving our client in excess of $65,000 and a year delay in project start up.

© 2008, By J.G. Pohl, Principal, Integral Environmental Solutions (IES), Australia

Sydney groundwater wells or bores have revealed the effects of decades of industrial contamination in the groundwater below Sydney's eastern suburbs.

Can contaminated groundwater affect my family’s or employees health?
Yes. A lesser known way that your family’s or employees health can be impacted is by the intrusion of colourless, odourless vapours that migrate into your home or offices living / work spaces from contaminated subsurface soil and groundwater. This effect of indoor air contamination is called vapour intrusion In the US, the Environmental Protection Agency (EPA) has targeted this source of indoor pollution due to the insidious nature of this silent killer.

What is Vapour Intrusion?
Vapour intrusion is the migration of volatile chemicals from the subsurface into overlying buildings. Volatile chemicals in buried wastes and/or contaminated groundwater can emit vapours that may migrate through subsurface solid and into overlying building airspaces. In most cases, the chemical concentrations are low, or depending on site-specific conditions, vapours may not be present at detectable concentrations.
In some cases, sampling near a known subsurface accumulation of vapours has identified indoor air impacts requiring action, and, in other cases, vapour sampling has been completed following an odour complaint in order to trace the source and identify appropriate mitigation measures. Each site is unique and no one approach is appropriate for all.

Health and Safety Concerns with Vapour Intrusion
- Indoor vapours may accumulate in occupied buildings to unhealthy levels
- Acute health effects
- Indoor odour problems
- Possible fire safety hazard
Vapour Intrusion Fact Sheet from US EPA
NSW Natural Resources - Water Quality in Eastern Suburbs
Causes of Vapour Intrusion
- Imperfect building construction
- Ventilation problems
- Heating / cooling system configuration
- Utility conduit entrances,
- Indoor air advection or diffusion
- Soil type
- Volatilisation of subsurface organic contaminants
in the vicinity of a building

How do I find out if I have a Vapour Intrusion Problem?
We at IES provide expert consulting services in all aspects of Vapour Intrusion issues by helping our clients find practical and defensible solutions to resolve disputes, achieve regulatory compliance, and protect and improve environmental quality. At IES, we can provide you with the following services related to Vapour Intrusion:

- Field Assessment & Analysis
- Vapour Intrusion Management Plans
- Engineering Controls
- Vapour Intrusion Rehabilitation
At IES, our experience in this area helps to ensure permanent, cost-effective, and safe solutions to indoor air vapour intrusion issues.

© 2008, By J.G. Pohl, Principal, Integral Environmental Solutions (IES), Australia

Read more on US Air Force PROACT site

© 2008, By J.G. Pohl, Principal, Integral Environmental Solutions (IES), Australia
Review of US Air Force C-17 Hangar Project, PCE (perchloroethylene) Spill Site (US EPA Site ID: SS-24)
This article is about the C-17 contaminated land remediation project I managed in 2003, a point in time in which a paradigm shift occurred for the contaminated land remediation industry.

During the many years I managed contaminated land for the Department of Defence, I realised that there had to be a better way to characterise and clean up contaminated land than the accepted practice of multiple mobilisations and static data gathering.

In 2002, I began educating my stakeholders about an innovative new way to approach contaminated land projects, which was dynamic site characterisation utilising real time probes for data collection and analysis. I presented my stakeholders with documentation from ASTM Standard - D6235-98, and US EPA Triad Approach methodology along with my extensive experience in managing Superfund sites. In addition, I was a member of the Interstate Technical Regulatory Council (ITRC) Sampling, Characterisation and Monitoring Team, with the task of developing a national guidance document of expedited site characterisation of contaminated land.

During this period of time, a new contaminated site in the footprint of a $28 million construction project fell into my hands. With construction of a new aircraft hangar for the C-17 transport planes, there was no time to waste in cleaning up the ground and groundwater in which the hangar was being built. A good overview of this project can be viewed in a presentation I presented to fellow ITRC members in Stowe, Vermont, August 2003.

George Hall, ITRC Program Advisor for the Sampling, Characterization and Monitoring team, concurred with the assessment regarding the success of the McGuire AFB FASTRAC method. “John Pohl’s recognition that the Triad Approach and other expedited site assessment methods could help solve the C-17 hangar dilemma was instrumental in advancing both the ITRC and the Air Force acceptance of this better way to assess contaminated sites.”

Read more on this innovative project in the Air Force Centre for Engineering and the Environment (AFCEE) Performance Based Management Program.

John Pohl's C-17 Interim Remedial Investigation presentation to Interstate Technical Regulatory Council (ITRC), Stowe, Vermont, August 2003.

Following John Pohl's C-17 Interim Remedial Investigation presentation to Interstate Technical Regulatory Council (ITRC), Stowe, Vermont, August 2003, it was incorporated into an ITRC Technical/Regulatory Guideline.

Donald Rumsfeld, US Secretary of Defense highlights Innovative Cleanup Strategy, McGuire Air Force Base, C-17 Interim Remedial Investigation.