More specifically the investigation will: 

• provide adequate data to support a transaction or warrant further investigation
• clarify the level of environmental risk and liability associated with past and current practices and state a professional opinion, based on available information, of steps necessary to reduce or eliminate the environmental risk of impairment and associated financial liabilities

Phase 1 Environmental Services consist of the following six tasks:

Task 1 - On-Site Survey

The purpose of the on-site survey is to visually inspect the property, buildings, associated structures, equipment, and operational and management procedures for actual or potential sources of environmental contamination or impairment and identify accessible and visible environmental features.  In addition to looking at the current situation, information gathered, can in many cases, be an indication of past contamination or indicative of inappropriate procedures. Some of these past activities, left unattended, could become a source of future environmental impairment and liability. The site survey attempts to collect available information that will clarify any current or potential environmental risks associated with the site.  Generally, a site survey will vary in scope and complexity from one property to another.

The following items, at a minimum and as applicable, will be assessed during the site survey:

• interview management personnel about current and past equipment, processes and procedures that are or may have released pollutants into the environment or may pose a potential risk or release;
• locate point source discharges and existing control devices or lack thereof
• identify hazardous materials, hazardous waste and chemical storage areas, and waste streams and estimate the quantities and volume of each
• interview management personnel about environmental regulatory compliance including record keeping, reporting, testing, and safety programs
• locate and identify above and below ground storage tanks and piping; report on tank material, age, contained material, leak protection, testing, registration, etc
• list fuel-dispensing equipment, fill ports, vent pipes
• identify electrical equipment suspect of, or confirmed to contain PCBs. Report on leak containment, electrical protection, regulatory compliance, etc
• note the potential for asbestos-containing materials in facilities
• note the potential for radon gas in facilities
• note the potential for lead-based paint in facilities
• note the potential for, or presence of, lead-containing plumbing piping
• identify management and engineering practices, procedures and structures implemented to eliminate or reduce known contamination environmental risk (spill control, containment devices or the lack of, etc.)
• locate and identify lagoons, pretreatment units, impoundments, retention basins, dumps, pits, dry wells
• check for signs of illegal dumping
• look at drainage patterns, ditches, streams, storm and sanitary sewers
• inquire about pesticide and herbicide application practices
• look for stained soil, odor, fouled water, obvious spills, and impaired vegetation
• locate and identify groundwater production and monitoring wells.

Task 2 - Surrounding Land Use Survey

The purpose of the surrounding land use survey is to identify potential off-site sources of contamination that could have an environmental impact on the site, or off-site areas that could be impaired by the subject site.

The following elements will be considered during the surrounding land use survey:

• any known environmental features or potential sources of pollution that, because of magnitude, proximity, and/or transport mechanisms, could have the potential to adversely impact the subject site; and 

• proximity to sensitive ecological areas, floodplain, wetland, wildlife refuges, coastal zones, surface water, wells and drinking sources, residential and industrial areas, schools, zoning and land use that would be at potential risk of contamination from the subject site because of the type and magnitude of the subject site's operations, its proximity, and/or presence of transport mechanisms.

Task 3 - Historical Review

This task involves the search of available and readily obtainable historical documents and information to determine past uses of the property including land and improvements that might suggest a potential for environmental impairment.

The following sources of information, as available, will be considered:

•  available geotechnical studies, surveyor reports, etc.;

• chain of ownership included in the title search report;

• historical aerial photographs;

• personnel knowledgeable of the property history.

Task 4 - Regulatory Review

This task includes inquiry with governmental agencies that may have jurisdiction over environmental matters in regard to past or present activities at the site or surrounding sites that may have current or future implications.

The following sources of information, as available, will be considered:

Federal Sources 

NPL - National Priority List

EPA has prioritized sites with significant risk to human health and the environment. These sites receive remedial funding under the Comprehensive Environmental Response Conservation and Liability Act (CERCLA).

CERCLIS - Comprehensive Environmental Response,   Compensation, and Liability Information System

CERCLIS is a database used by the EPA to track activities conducted under the Comprehensive Environmental Response and Liability Act (CERCLA, 1980) and the amendment the Superfund Amendments and Reauthorization Act (SARA, 1986). Sites to be included are identified primarily by the reporting requirements of hazardous substances Treatment, Storage and Disposal (TSD) facilities and releases larger than specific Reportable Quantities (RQ), established by EPA. 

Using the National Oil and hazardous Substance Pollution Contingency Plan (National Contingency Plan) the EPA sets priorities for cleanup. The EPA rates National Contingency Plan sites according to a quantitative Hazard Ranking System (HRS) based on the potential health risk via any one or more pathways: groundwater, surface water, air, direct contact, and fire/explosion. 

The EPA and state agencies seek to identify potentially responsible parties (PRP) and ultimately Responsible Parties (RP) who can be required to finance cleanup activities, either directly or through reimbursement of federal Superfund expenditures.

 NFRAP - No Further Remedial Action Planned sites  

As of February 1995, CERCLIS sites designated 'No Further Remedial Action Planned' NFRAP have been removed from CERCLIS.  NFRAP sites may be sites where, following an initial investigation, contamination was not found, contamination was removed quickly without the site being placed on the NPL, or the contamination was not serious enough to require Federal Superfund action or NPL consideration.  EPA has removed these NFRAP sites from CERCLIS to lift unintended barriers to the redevelopment of these properties. This policy change is part of EPA's Brownfields Redevelopment Program to help cities, states, private investors and affected citizens promote economic redevelopment of unproductive urban sites.

 FEDFAC - Federal Facilities

As part of the CERCLA program, federal facilities with known or suspected environmental problems, the Federal Facilities Hazardous Waste Compliance Docket is tracked separately to comply with a Federal Court order.

ERNS - Emergency Response Notification System

The ERNS is a national computer database used to store information on unauthorized releases of oil and hazardous substances. The program is a cooperative effort of the Environmental Protection Agency, the Department of Transportation Research and Special Program Administration's John Volpe National Transportation System Center and the National Response Center.

There are primarily five Federal statutes that require release reporting the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) section 103; the Superfund Amendments and Reauthorization Act (SARA) Title III Section 304; the Clean Water Act of 1972 (CWA) section 311(b)(3); and the Hazardous Material Transportation Act of 1974 (HMTA section 1808(b).

SETS - Site Enforcement Tracking System (SETS)

When expanding Superfund monies at a CERCLA (Comprehensive Environmental Response, Compensation and Liability Act) Site, EPA must conduct a search to identify parties with potential financial responsibility for remediation of uncontrolled hazardous waste sites. EPA regional Superfund Waste Management Staff issue a notice letter to the potentially responsible party (PRP). The status field contains the EPA ID number and name of the site where the actual pollution occurred.

DO - Enforcement Docket System (DOCKET) / Consent Decree Tracking System (CDETS)

DOCKET tracks civil judicial cases against environmental polluters, while CDETS processes court settlements, called consent decrees. 

CD - Criminal Docket System (C-DOCKET)

The Criminal Docket System is a comprehensive automated system for tracking criminal enforcement actions. C-Docket handles data for all environmental statutes and tracks enforcement actions from the initial stages of investigations through conclusion.

RCRA - RCRA Violators List (CORRACTS)

The Resource Conservation and Recovery Act (RCRA) of 1976 provides for "cradle to grave" regulation of hazardous wastes. RCRA requires regulation of hazardous waste generators, transporters, and storage/treatment/disposal sites. Evaluation of potential violations, ranging from manifest requirements to hazardous waste discharges, is typically conducted by the US EPA. This database is also known as Corrective Action Report (CORRACTS). If enforcement is required, it is typically delegated to a state agency. 

Commonwealth of Pennsylvania

SP - Pennsylvania Superfund Sites  

Pennsylvania Department of Environmental Protection, Bureau of Waste management, Hazardous Sites Cleanup Program maintains a list of Pennsylvania Superfund Sites.

SW - Solid Waste Facilities  

Pennsylvania Department of Environmental Protection, Bureau of Solid Waste Management  issues permits and regulates Solid Waste facilities in the Commonwealth of Pennsylvania. 

LT - Leaking Underground Storage Tanks  

The Storage Tank and Spill Prevention Act (Act 32 of 1989, as amended) was signed into law on July 6,1989. The law establishes a comprehensive regulatory program for both above ground and underground storage tanks and facilities. It allows the Department of Environmental Protection (DEP) to develop environmental protection programs to prevent and clean up storage tank product releases and spills. The act includes both enforcement provisions and strong reliance on the private sector to implement the major program elements. In case of a release, the owner or operator must report a confirmed release to the appropriate DEP regional office within 2 hours as required by the Corrective Action Process regulations adopted on August 21, 1993 (25Pa Code Chapter 245.305). The Commonwealth of Pennsylvania, Department of Environmental Protection, Bureau of Water Quality Management, Division of Storage Tanks, Site Remediation and Enforcement Section and the Environmental Cleanup Program, Storage Tanks Section administer the program including maintaining a List of Confirmed Releases in Pennsylvania.

Operating Permits 

Various agencies issue operating permits or regulate the handling, movement, storage and disposal of hazardous materials and require mandatory reporting.  The inclusion in this section does not imply that an environmental problem exists presently or has in the past.

RCRA-G - Resource Conservation and Recovery Information System - Generators  

The Environmental Protection Agency regulates generators of hazardous material through the Resource Conservation and Recovery Act (RCRA). All hazardous waste generators are required to notify EPA of their existence by submitting the Federal Notification of Regulated Waste Activity Form (EPA Form 8700-12) or a state equivalent form. The notification form provides basic identification information and specific waste activities. 

Status Codes:

L - Generators who generate at least 1000 kg/m of non-acutely hazardous waste or 1 kg/m of acutely hazardous waste.

S - Generators who generate 100 kg/mo but less than 1000 kg/mo of non-acutely hazardous waste.

 T - Transporter.

RCRA-D - Resource Conservation and Recovery Information System - Treatment, Storage & Disposal  

The Environmental Protection Agency regulates the treatment, storage, and disposal of hazardous material through the Resource Conservation and Recovery Act (RCRA). All hazardous waste TSD facilities are required to notify EPA of their existence by submitting the Federal Notification of Regulated Waste Activity Form (EPA Form 8700-12) or a state equivalent form as well as part A (EPA form 8700-23) and Part B of their Hazardous Waste Permit Application.

Status Codes:

I  -  Incinerator

T  -  Storage/Treatment facility other than
       Incinerator

D  -  Land Disposal Facility  

SARA - SARA Title III, section 313 (TRIS)  

Title III of the Superfund Amendments and Reauthorization Act, Section 313, also known as Emergency Planning and Community Right-to-Know Act of 1986 requires owners or operators of facilities with more than 10 employees and that are listed under Standard Industrial Classification (SIC) Codes 20 through 39, to report the manufacturing, processing or use of more than a threshold of certain chemical or chemical categories listed under section 313. This data base is also known as Toxic Release Information System (TRIS). 

NC - Nuclear Regulatory Commission Licensees  

The Nuclear Regulatory Commission, Office of Nuclear Material Safety and Safeguards has been mandated (10 CFR Ch 1.42) to protect the public health and safety, the common defense and security, and the environment by licensing, inspection, and environmental impact assessment for all nuclear facilities and activities, and for the import and export of special nuclear material.

PCB - PCB Waste Handlers Database 

The U.S. Environmental Protection Agency tracks generators, transporters, commercial stores and/or brokers, and disposers of PCB's in accordance with the Toxic Substance Control Act.

PCS - Permit Compliance System  

PCS is a database which contains data on National Pollutant Discharge Elimination System (NPDES) permit holding facilities. PCS was developed by The U.S. Environmental Protection Agency to meet the information needs of the NPDES program under the Clean Water Act. PCS tracks permit, compliance, and enforcement status of NPDES facilities.

AFS - AIRS Facility System  

AFS contains emissions and compliance data on air pollution point sources tracked by the U.S. EPA and state and local environmental regulatory agencies. There are seven "criteria pollutants" for which data must be reported to EPA and stored in AIRS: PM10 (particulate matters less than 10 microns in size), carbon monoxide, sulfur dioxide, nitrogen dioxide, lead, reactive volatile organic compounds (VOC), and ozone.

AFS replaces the former Compliance Data System (CDS), the National Emission Data System (NEDS), and the Storage and Retrieval of Aeromatic Data (SAROAD).

PE - Section Seven Tracking System (SSTS)  

SSTS evolved from the FIFRA and TSCA Enforcement System (FATES). SSTS tracks the registration of all pesticide producing establishments and tracks annually the types and amounts of pesticides, active ingredients, and devices that are produced, sold, or distributed each year.

FIFRA - FIFRA/TSCA Tracking System/ National Compliance Database (FTTS/NCDB)  

NCDB supports implementation of the Federal Insecticide, Fungicide and Rodenticide Control Act (FIFRA) and the Toxic Substance Control Act (TSCA).

FFIS - Federal Facilities Information System (FFIS)  

Federal Facilities Information System (FFIS) contains a list of all Treatment, Storage, and Disposal Facilities (TSDs) owned and operated by federal agencies.

CICIS - Chemicals in Commerce Information System (CICIS)

Chemicals in Commerce Information System contains an inventory of chemicals manufactured in commerce or imported for Toxic Substances Control Act regulated commercial purposes. CICIS allows EPA to maintain a comprehensive listing of over 70,000 chemical substances that are manufactured or imported and are regulated under TSCA.

FINDS - FINDS EPA Facility Index System  

The U.S. Environmental Protection Agency maintains an index system of all facilities which are regulated or have been assigned an identification number for other purposes.

UT - Underground Storage Tanks  

The Commonwealth of Pennsylvania, Department of Environmental Protection, Bureau of Water Quality Management, Division of Storage Tanks regulates (Act 32 of 1989) above ground and underground storage tanks containing regulated substances, with exceptions for farm and residential tanks of 1,100 gallons or less; heating oil storage tanks of 3000 gallons or less for consumptive use on the premises; septic tanks; regulated pipeline facilities; flow-through process tanks; surface impounds, pits, ponds or lagoons; and any tank whose capacity is 110 gallons or less and certain other exceptions.

City/County Health Department

City/County Office of Emergency Services

Local Fire Department

Sewage Treatment Facilities

Task 5 - Data Evaluation

This task involves the evaluation of all data collected during the phase 1 investigation and will appear in the final report as a narrative.

 The evaluation will include the following:

• a summary of findings which describes current environmental features of the site and the surrounding area and perceived past environmental and historical conditions;

• a discussion of regulatory compliance and liability assessment both on and off the site;

• a discussion of actual or potential on-site and off-site contamination.  This discussion will include the potential impact to environmental target areas such as residential areas, wetlands, coastal zones, etc;

• recommendation for additional investigation, (phase 2 testing and assessment, if warranted), to further quantify risk; and

• management procedure or structures that are in place or if put in place could eliminate or reduce the risk of environmental impairment.

Task 6 - Report Preparation

The final task for the phase 1 investigation is the preparation of a written report.  This report will include a concise presentation of all information gathered during the investigation, presented in a logical progression.  The report will summarize the significant findings by expanding on each task, identifying actual and potential environmental impairment, risks and liabilities.  Recommendations for additional testing,  investigation, and/or remediation as applicable, will be included.  Regardless of how clean a site may appear, the level of investigation and review that was the basis for the conclusion must be a part of the evaluation in order to establish appropriate inquiry for a defense as an innocent landowner under CERCLA.

The report will include, when applicable, photographs taken during the audit to document the phase 1 environmental assessment and the environmental features of the site and facility.

Phase 2 Environmental Services

Phase 2 Environmental Services, when deemed necessary by the client, include detailed investigation, sampling, and testing of perceived environmental problems, and are discussed under the sampling and monitoring services page of this web site.

Phase 3 Environmental Services

Phase 3 Environmental Services, when deemed necessary by the client, include remediation of confirmed environmental problems and are discussed under the site services page of this web site.

Special and Limited Scope Audits

When requested by the Client, EHC will establish a scope of services for performance of a limited scope audit when the perceived risk by the client is considered to be low or when the Client wishes to utilize specific auditing guide documents such as those published by ASTM.  Additionally, special scope audits which address specific physical or operational aspects of a facility or site are routinely performed by EHC Associates.