In my last article I talked about some of the wackier comments I have heard from owners and agents related to environmental consulting and site remediation, so it’s only fair to high-light a few I have read or heard from other consultants (reworded slightly as needed for discretion). Without prejudice to the original consultant, etc. here are a few of the more memorable ones.
“The slight groundwater exceedance for TCE (Trichloroethylene) is not considered to be significant, and no further site investigation is required.” Consultants’ conclusion in a Phase 2 report provided by the vendor for a prospective purchaser of an industrial property with ‘localized TCE impacts’.
Solvent related contaminants, especially DNAPLS like TCE can be tricky to investigate and understand. Their presence, extent, fate and migration can be difficult to accurately predict. Solvent-related contamination can lead to costly remediation, litigation and in some cases, especially groundwater, the impacts and liability remains for decades. Detailed investigations, employing modern real time detection methods can determine whether the ‘slight exceedance’ is actually localized and manageable, or if it represents the tip of the proverbial iceberg. For this purchaser the ‘comfort’ letter they obtained from the prior consultant was significantly cheaper than the additional investigation we advised, and was acceptable to their bank for purchase financing at that time. Unfortunately for the new owner, the property was subsequently found to be part of a widespread plume of contaminated groundwater, suspected to originate from one or more industrial sources at or near the subject site.
“The subject building is heated by natural gas; therefore no fuel storage tanks have ever been present at the property.” Consultants’ conclusion in a Phase 1 report provided for review by a prospective purchaser of a commercial building and property.
A prime example of reporting unfounded assumptions based on insufficient research. In this case, basic research would have confirmed the building dated to the 1930’s and natural gas service was not available until the 1960’s. A cursory site inspection should have revealed the presence of vent and fill pipes for the still-present heating oil tanks. Buyers beware - not every consultant is good, and given the usual tight budgets and time frames, not every good consultant’s report is as good as it could be.
“No environmental concerns are present, since the Site has operated without incident as an apartment complex since 1978. No further investigation is considered necessary” Consultants’ conclusion in a Phase 1 report provided for review by a prospective purchaser of a large multi-unit residential property.
The consultant’s report failed to include the lengthy on-site industrial history prior to the residential redevelopment, including a dry cleaner’s, two retail gas stations, a fuel tank farm and a paint manufacturer. I won’t discredit a fellow professional, but how does this get missed by any competent assessor? Watch out for broad conclusions based on limited historical research.
“A Potentially Contaminating Activity (PCA) was identified with (off-Site) adjacent residential dwellings; as the homeowners may potentially have applied lawn pesticides. This represents a potential environmental concern for the Site.” Consultants’ conclusion in a Phase 1 report provided for an undeveloped residential property.
In my opinion, this overly conservative conclusion is questionable for the exact opposite reason to the deficiencies noted above. In this particular case the PCA the consultant refers to is defined by provincial regulation as ‘Pesticides Manufacturing, Processing, Bulk Storage and Large-Scale Applications’ – which is clearly not the case here. These recommendations appear designed to create more work for the consultant; which leaves a bad impression with clients everywhere.
By: Bill Leedham, P. Geo., CESA
Bill is the Head Instructor and Course Developer for the Associated Environmental Site Assessors of Canada (www.aesac.ca); and the founder and President of Down 2 Earth Environmental Services Inc.
*The views and opinions expressed in "The Instructors Blog" are those of the author and do not necessarily reflect those of Associated Environmental Site Assessor of Canada Inc. and/or its directors and employees
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