Environmental Site Assessments | LCA

Environmental Site Assessments

LCA Environmental provides consulting and support in several areas regarding property assessment and corrective action. Our experienced team provides top-of-the-line services including:

Dry Cleaner Investigations – Proprietary Leak Detection

Early identification of dry cleaning chemical releases is the primary component in minimizing the environmental and financial impact.

Physical identification of known or potential leak, spill or release points or sources is critical to control of on-going, environmentally risky retail or commercial tenants, such as dry cleaning facilities, or in obtaining site closures or remedial plan implementations. Some of these sources can be identified during an on-site audit. Engineering controls to mitigate future releases can be designed.

LCA provides turnkey services in source/process identification, design of release controls, subsurface investigation, and/or oversight of remedy implementation of onsite dry cleaner operations. LCA can also assist in development of specifications for new tenant facilities or lease spaces with maximum release containment in mind or training of property managers overseeing dry cleaners.

Dry cleaner investigations often require more thorough evaluations than usually encountered in most commercial property transfers. For operating dry cleaning facilities, LCA often recommends a compliance audit that focuses on a facility’s adherence to applicable regulations and permit conditions. LCA may recommend a subsurface vapor survey and/or subsurface sampling inside the dry cleaner’s space as part of thorough due diligence. LCA strongly recommends the patented PerTectVapor Trap™ system.

Environmental Site Assessment – Phase I, II, III & IV Site Assessments, Risk Assessments & Site Remediation

Whenever commercial real estate is bought or sold, offers and price adjustments are often based on the environmental status of the property.

If environmental contamination is discovered after the sale, the new owner may be held jointly and/or severally liable for cleanup costs. In some instances, the cost of extensive investigation or environmental cleanup alone can exceed the property’s normal market value. Since a high percentage of assessed gas stations and drycleaners are found to have some degree of impacted soils and/or groundwater at the site, it is particularly important to closely examine properties that contain or have contained these types of businesses.

LCA is an expert in the environmental evaluation of commercial property. LCA’s services range from reviewing public records and other available property information to conducting on-site testing, sampling, and laboratory analysis. LCA has experience with sites throughout the country, ranging from single-site purchases to acquisitions and divestitures of multi-site real estate portfolios, business chain buyouts, pre-development land purchase, Brownfield redevelopments, etc.

Typically, one senior professional is assigned the task of coordinating logistics on multiple-site projects. This coordinating professional serves as the point of contact for the client and insures uniformity of report format and consistent interpretation of environmental findings.  LCA also advises clients during regulatory negotiations to help understand environmental risks, liabilities, and associated costs and operational impacts.

An environmental assessment can consist of multiple phases, with the scope of each project depending on the client’s business objectives. Typical assessment phases include:

•  Phase I – Phase I Environmental Site Assessment – conducted in general conformance with ASTM 1527-05 and may include multiple additional business environmental risk items.

•  Phase II – Soil, Groundwater and Surface Water Contamination Assessment – investigates the specific recognized environmental conditions identified in the Phase I ESA and generates hard data.

•  Phase III – Remedial Investigation and/or Opinion of Remediation Cost Estimates – builds on the documentation created in Phase II and seeks to determine the extent and severity of an identified contamination problem.

• Phase IV – Remediation System Design and Cleanup Execution – incorporates all the findings of the first three phases of investigations to design a cost-effective cleanup of the property.

Engineering and Remedial System Design

LCA is a Texas registered professional Engineering Firm and provides sealed, signed original construction specifications and system designs whenever appropriate.  LCA also reviews pre-existing client-provided engineering drawings and specifications and provides engineering opinions.

Landfill Investigations & Methane Monitoring

LCA prepares soil, groundwater and trash management plans (SGTMP) to allow construction work to safely proceed through landfills.

Regulations prevent the casual disturbance of closed landfills, whether the site was a fully-permitted disposal facility or an unregulated dump.  Specifications for activities such as drilling bridge piers, burying new sewer lines and other related work are a LCA specialty.

Enclosed structures above closed landfills normally require some sort of methane monitoring system, such as the patented PerTect Vapor Traps™, which LCA often incorporates into its mitigation designs.

Leaking Petroleum Storage Tank Management

LCA and its staff have over 20 years of experience in petroleum and chemical underground storage tanks (UST) management, including installation/upgrades, removals and cleanups.

To deal with leaking petroleum storage tanks (LPSTs), LCA is a TCEQ-registered Corrective Action Specialist and retains three full-time licensed Corrective Action Project Managers (CAPMs) on staff.

Tanks and Line Testing 
LCA arranges testing and measurement services to determine whether commercial underground storage tank/lines are tight. The latest precision testing techniques are used and conform to the requirements of National Fire Protection Association and both EPA and TCEQ guidance.

LCA also arranges testing and measurement services for evaluating corrosion systems, analyzing corrosion failures, and designing corrosion protection systems. Corrosion is one of the major causes of failure of petroleum or chemical USTs and drycleaning solvent storage tanks.

Tank Removal and Corrective Action
UST removal will typically be followed by sampling and investigation and corrective action or cleanup, if the tank is shown to have been leaking. For more information click here.

Oil and Gas Production Impact Evaluation

LCA examines properties for brine impact to soil and shallow groundwater, as well as petroleum impacts.  If impacts are noted, LCA also develops remediation or mitigation plans.

The Texas Railroad Commission regulates most environmental activities at Oil and Gas properties.  Impacts from potentially hazardous commercial materials that are utilized at production facilities may come under the jurisdiction of the Texas Commission on Environmental Quality.

Soil and Groundwater Investigations and Cleanup

LCA is frequently called in by clients who have passed the comfort zone or capability limits of a less-experienced consultant and now needs LCA’s assistance to make the hard decisions.

Surface water is also included in this service category.  Subsurface investigations often begin as Phase II ESAs, but LCA often investigates industrial or heavy commercial facilities where some amount of contamination is already known or strongly suspected. Sampling and lab testing can quickly become an expensive item, and a large part of the value LCA brings to a project is project managers who know when to say when.  This is the sort of judgment that only comes from years of problem solving.

Waste Management – Hazardous/Municipal/Special

The most important first step in any waste management program is to minimize the amount of waste that is generated or must be disposed.

During property assessments, LCA’s professionals are experts at selecting equipment and investigation/sampling techniques that produce a minimal amount of investigation-derived waste (IDW).

Hazardous Wastes

The Resource Conservation and Recovery Act (RCRA) and the Hazardous and Solid Waste Amendments of 1984 (HSWA) provide a comprehensive regulatory framework for permitting, storage/handling of hazardous materials and corrective action. LCA professionals help clients comply with regulations promulgated under RCRA and HSWA.

Spent perchloroethylene (the main solvent used in dry cleaning), for example, is a RCRA-listed hazardous waste. Depending on the quantity of solvent stored/disposed, a commercial tenant may require RCRA permitting.  LCA provides permitting support for a variety of small/large quantity generators.

Municipal Wastes

The majority of remodeling/construction wastes will be municipal solid waste (MSW).  LCA carefully segregates bulk waste material on the basis of lab results and professional judgment.  This prevents a client from over-paying for disposal due to incorrectly classifying wastes into a more expensive class.

Special Wastes

Under certain conditions, petroleum wastes from a LPST site may be special wastes.  Asbestos-containing material, as from abatements, is a special waste.

Texas Risk Reduction Program (TRRP)

The Texas Risk Reduction Program, or TRRP, is the overlying procedural umbrella for all environmental program areas in Texas.

sgmp2This unifying guidance provides consistent methodologies for investigating environmental impacts from any source.  A key aspect of TRRP is the inclusion of look-up tables of protective concentration levels (PCLs) which provide default values of maximum chemical concentrations that can exist in the different media (e.g. soil or water) without requiring further corrective action.

Innocent Owner/Operator Program (IOP)

The IOP is very similar to the older Voluntary Cleanup Program.  The primary difference is that in the VCP, the property where the contamination originated or is located must be enrolled in the program.

leaks4In the IOP, a property that has become contaminated exclusively by migration from some other location can also receive a Certificate of Completion that releases the present owner from liability for the contamination that can be traced back to a specific off-site responsible party.

The burden of proof (i.e., the amount of detailed site investigation) is normally greater than for most other environmental program areas.

Municipal Setting Designations (MSD)

The newest regulatory program available to owners of contaminated properties is only available in those Texas cities that have passed a local ordinance permitting a restriction on the use of shallow groundwater.

stormwater2In essence, if all of the exposure pathways to contamination have been eliminated by cleanup or other means, and the only potential human exposure pathway that remains is for contaminated groundwater, a MSD will put a local restriction on the use of that groundwater so that further cleanup is not required.

Significant study is required to convince both the local municipal jurisdiction (typically, a city’s environmental department) and the TCEQ that contamination on the site has been fully delineated.  Notification of all potentially involved neighboring properties where the contaminated groundwater might be present or could migrate is also required.

Petroleum Storage Tank (PST) Program

The Petroleum Storage Tank (PST) program is one of the more familiar in Texas.

leaks2The PST program originally had its own investigation requirements and cleanup standards, and these were sometimes different than for other environmental program areas.

Since 2003, new releases from underground tanks are first investigated under updated PST program protocols to determine if an actual release has occurred, but additional investigations and any clean up are in accordance with TRRP requirements.

Underground Injection Control (UIC) Wells

The UIC program is a delegated EPA program.  UIC wells require extensive study support documentation before permits are issued by TCEQ.

PID_wellWhen wells have served their intended purpose, particularly shallow disposal wells, they are investigated under TRRP and closed.  This often involves the installation of soil borings and groundwater monitoring wells to insure the UIC wells did not release material into subsurface soil strata or water bearing zones other than as designed.

Voluntary Cleanup Program

The Voluntary Cleanup Program is the first and oldest program in Texas that provides regulatory and liability relief for property owners who clean up contaminated property on their own initiative.

pipe_trenchA VCP Applicant may not be the person or entity that originally caused the contamination, but it must be a person or entity that comes after in the chain of ownership.  When completed, the owner will receive a Certificate of Completion from the TCEQ that breaks the chain of liability for the current owner as well as all future owners (again, except for the owner who actually caused the contamination).

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