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Published in August 2020 Focus on the Environment Newsletter

The Michigan Department of Environment, Great Lakes, and Energy (EGLE) recently promulgated state drinking water standards for seven per- and polyfluoroalkyl substances (PFAS).  Drinking water standards, also known as maximum contaminant levels (MCLs) are the maximum amount of a contaminant allowed in drinking water. When the amount of a contaminant in drinking water is higher than the MCL, the water supplier must take action such as treatment or follow-up testing. The new Michigan PFAS MCLs, shown on the below table, took effect on August 3, 2020.

Specific PFAS

CAS #

Drinking Water MCL Parts per Trillion (ppt)

Perfluorooctanoic acid (PFOA)

335-67-1

8

Perfluorooctanesulfonic acid (PFOS)

1763-23-1

16

Perfluorononanoic acid (PFNA)

375-95-1

6

Perfluorohexane sulfonic acid (PFHxS)

355-46-4

51

Perfluorohexanoic acid (PFHxA)

307-24-4

400,000

Perfluorobutane sulfonic acid (PFBS)

375-73-5

420

Hexafluoropropylene oxide dimer acid (HFPO-DA)

13252-13-6

370

The establishment of the new MCLs had an immediate effect on Michigan’s previously established generic groundwater cleanup criteria.  Generic cleanup criteria represent concentrations of a hazardous substance in different environmental media (groundwater, soil, and vapor) that allow appropriate risk management decisions regarding contaminated sites. As established under Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended [MCL 324.20120a(5)], state MCLs, once established, are also used as the basis of the generic cleanup criteria for groundwater used as drinking water.  Consequently, the new state drinking water standards of 0.008 µg/L (parts per billion) and 0.016 µg/L, respectively for PFOA and PFOS replaced the previously established residential and nonresidential drinking water cleanup criteria of 0.07 µg/L for the combined concentrations of PFOA and PFOS. The updated generic groundwater cleanup criteria for residential and non-residential groundwater were updated the same day the new MCLs went into effect.

There are currently no generic cleanup criteria for the other five PFAS compounds with recently established MCLs.  In other words, if you search the Michigan EGLE generic groundwater cleanup criteria table for any of the other five PFAS compounds (i.e., PFNA, PFHxS, PFHxA, PFBS, HFPO-DA), you won’t find them despite the fact that they now have MCLs. EGLE must go through the process set forth by statute and rule to establish generic cleanup criteria for the remaining five PFAS compounds. This is somewhat of a formality, however, as for all practical purposes, the MCLs will be considered generic cleanup standards until developed.

Published in August 2020 Focus on the Environment Newsletter

On December 2, 2020, the Environmental Protection Agency (EPA) will celebrate its 50th birthday. Nearly 50 years ago, on December 2, 1970, President Richard Nixon created EPA by executive order to consolidate in one agency a variety of federal research, monitoring, standard-setting, and enforcement activities to ensure environmental protection across the country.  Eight years prior, Rachel Carson, an inveterate birdwatcher published Silent Springs on the indiscriminate use of pesticides and the fear that without control fewer species of birds would be singing each spring.  Who can forget, our own Cuyahoga River catching fire in 1969?  The first Earth Day took place on April 22, 1970 in what was considered by some the start of the modern environmental movement.  Who knows what the next 50 years will bring for EPA and the environmental movement, but no one can argue that EPA has not been good for this country and the world. 

Published in the August 2020 Focus on the Environment Newsletter.

In our July 2020 newsletter, we introduced Ohio EPA’s pilot program on the use of virtual site visits (VSVs) for select categories of inspections.  Recently, I made the trip to a client’s facility and provided assistance conducting a VSV with Ohio EPA during a RCRA Post-Closure inspection.  Regardless of the type of VSV inspection, below are some helpful tips to prepare for and conduct the VSV.

  • Ohio EPA will contact the facility regarding their intent to perform a VSV and schedule a date/time for a trial run to test the audio and video equipment/software.  Ohio EPA uses the Microsoft Teams platform, so it is recommended you become familiar with its operation and test it ahead of the trial run.  During the trial run, the audio and video will be tested, however, there will not be a need to walk the facility.  Near the conclusion of the trial run, a mutually agreeable date/time for the actual VSV will be determined.  If not previously discussed, it is recommended that the facility ask the agency if there are specific areas of interest Ohio EPA was planning to cover during the VSV.
  • Following the trial test and prior to the VSV, it is recommended that the facility perform a mock VSV with other facility members observing remotely.  This will allow the person who is conducting the walk-through to develop an efficient travel path, identify any potential issues that need corrected, and ensure a strong audio/video signal throughout the walk.  If an area of the facility is encountered with a weak signal, you will have time to troubleshoot options for improving the signal.  At worst case, you will be able to provide Ohio EPA with a heads-up that certain portions of the VSV may lose audio and/or video.  A weak signal will freeze the video before the audio drops off.  If you find that the video freezes and remains frozen after passing through the area with the weak signal, manually turn off your camera feed (while remaining connected via audio) and then turn it back on to re-establish video.
  • At the start of the VSV, plan to spend a few minutes in an office area to re-iterate the agency’s areas of interest and prioritize certain items.  The VSV is typically scheduled for two hours and the agency expectation is to not run beyond this time to avoid scheduling conflicts with both the agency and facility.  If document review is part of the inspection, the agency will typically ask that certain documents are provided ahead of or after the VSV so as to not spend time searching or reviewing documents while live streaming. 
  • When conducting the VSV, it is recommended a group of at least two facility personnel perform the walk-over.  One person would be in charge of operating the video stream and would perform most of the talking.  The second person would lead the route and take notes.  The person operating the video feed may be somewhat distracted and not fully aware of their surroundings, therefore the second person also serves as a safety lookout.
  • There is typically a few second delay from saying something to when it is heard by others that are logged into the VSV.  Therefore, if two or more facility personnel are performing the walk-over and each is using their own device for audio, a few feet of distance should be maintained between them to avoid echo or difficulty hearing.  Only one person needs to operate a video feed, the other person on the walk-over should have only audio feed active.  Because Microsoft Teams allows use of an internet link for audio/video or a phone number for audio only, it is recommended that the facility person who is not leading the video stream use the phone number.  Often, the phone signal may be stronger than the internet link for audio/video so if the person who operates the video feed happens to completely lose signal, the other person can notify the agency of the temporary issue.  
  • Some devices have longer battery life than others.  It is recommended to have a full charge on the device that will run the video feed before the VSV begins and to also bring a backup battery pack.
  • Many facilities have proprietary operations.  Although the agency will typically provide copies of any screenshots they take during the VSV, it is recommended that the operator turn off the video feed or point the camera to the ground between locations.  Not only will this approach prevent potential for photographing proprietary operations, but it will also keep the VSV focused on the intended items, avoid straying from the planned walking path, and allow the facility personnel to be more alert on their surroundings when walking.
  • Many facilities are loud and may require hearing protection.  As such, it is recommended that ear buds (wireless or wired) be used for the audio interface rather than a speaker.  Although ear buds do not provide the same hearing protection as ear plugs, you may be able to convince your safety department to allow use of the ear buds in place of the ear plugs during the VSV.  Consideration of the time spent at a noisy area and the protection provided by the ear buds should be considered.  If additional hearing protection is unavoidable, the use of ear buds under muffs may be possible.  Do not hesitate to discuss this issue with Ohio EPA in the trial run call.  
  • Following the walk-over portion of the VSV, Ohio EPA will likely review their inspection checklist while the audio/video stream is still live.  If not, the facility personnel should request that it is reviewed prior to concluding the VSV.  By reviewing the checklist together, any potential misinterpretations or issues may be quickly clarified or addressed. 

The above tips should help for a smooth and productive VSV.  A follow up letter on the VSV will be provided by Ohio EPA, which will include the completed checklist, any screenshots taken, and outcome.  Ideally, this letter is provided within 30 days of the VSV.  If you don’t receive the letter within this timeframe, it is recommended to inquire on its status. 

Published in the August 2020 Focus on the Environment Newsletter.

Have you ever received an agency’s request for additional investigation and thought, “surely we’ve done this before?” You are not alone. Particularly on “lower priority” and long-running sites, involved parties can easily lose track of what has been done. Client, agency, and consulting staff turnover can make this even more likely. Cox-Colvin’s Data InspectorTM provides a solution to this problem, as demonstrated by recent projects

On a recent project, our client proposed a voluntary remedy to avoid a possible enforcement action that had been discussed for years. The regulatory personnel reviewing the proposal initially expressed concern that the proposed remedy was premature due to a lack of data on some exposure pathways. Our client’s representative had a feeling that the concerns had already been addressed and delivered boxes of historical documents to Cox-Colvin. Some of the reports dated back to the mid-1990s, well before the regulatory reviewers, and our client’s representatives, were involved with the project. After organizing and scanning the documents, we compiled laboratory data, GIS sampling locations, and reports into our Data InspectorTM data management system. A summary document was prepared and presented to the agency. Realizing how much investigation had already been completed, an occasionally tense dialogue became more conciliatory and the project is moving toward a mutually beneficial outcome. By importing the data and reports into Data InspectorTM our client can rest assured that they will not need to rely on that déjà vu feeling next time.

On another project, a historical industrial release migrated into the surrounding community. Through time, our client became increasingly suspicious that contaminant plumes from other sources had comingled with their release. Cox-Colvin was asked to review investigations conducted by neighboring industries that were in the public record. By compiling data from a multitude of investigations within and near the project area into a single database, a more refined conceptual site model was developed that indicated there were indeed multiple sources and responsible parties contributing to the contaminant plume. This approach had several benefits, including 1) cost savings in not needing to perform additional investigation, 2) avoiding the need to work out multiple access agreements to conduct sampling, 3) time savings in using already existing data, and 4) nearly 40 years of historical data that showed how conditions had changed and improved over time. Most importantly, the client was able to set realistic (while still protective) cleanup goals that avoid endless cleanups of unrelated plumes from off-site facilities.

Cox-Colvin prides itself on our decades-long client relationships. Our existing clients value our ability to identify and locate reports that were prepared for their predecessor’s predecessor. Whether the data is used to show that an area never had a release, to evaluate changes over time, or simply to prove that something was already investigated 30 years ago, having a single Data InspectorTM repository has been proven invaluable time and again.

On July 6, 2020, the Ohio Environmental Protection Agency (Ohio EPA) Division of Materials and Waste Management filed eight municipal solid waste (MSW) landfill rules with the Joint Committee on Agency Review.  The eight rules proposed for revision are:

  1. 3745-27-02 Permit to install
  2. 3745-27-05 Applicability and relation to other laws
  3. 3745-27-06 Sanitary landfill facility permit to install application
  4. 3745-27-07 Additional criteria for approval of sanitary landfill facility permit to install applications
  5. 3745-27-08 Sanitary landfill facility construction
  6. 3745-27-09 Sanitary landfill facility operating record
  7. 3745-27-11 Final closure of a sanitary landfill facility
  8. 3745-27-14 Post-closure care of sanitary landfill facilities

The public comment period will run until August 12, 2020. On that date, the Ohio EPA will hold a virtual public hearing on the rules. The link to the virtual hearing is at the Ohio EPA’s webex events site: https://ohioepa.webex.com/mw3300/mywebex/default.do?siteurl=ohioepa&service=6

Written comments can be submitted during the virtual public hearing or emailed to Michelle Mountjoy at michelle.mountjoy@epa.ohio.gov.

The Interstate Technology and Regulatory Council (ITRC) has released an online Risk Communication Toolkit.  The EPA defines “risk communication” as the process of informing people about potential hazards to their person, property, or community. It is a science-based approach for communicating effectively in situations of high stress, high concern, or controversy. Now more than ever, risk communication is front and center in our everyday lives and the timing of this document could not be better.

Navigating this new world due to COVID-19 has been a challenge to everyone, including Ohio EPA. To protect against the potential spread of COVID-19 while maintaining their mission to ensure compliance with environmental laws and regulations, Ohio EPA is piloting the use of virtual site visits (VSVs) for select categories of inspections (e.g., routine, screening, non-enforcement).  The first step in the process will be a pre-meeting conducted by Ohio EPA via phone/video conference to discuss logistics and necessary equipment. The actual inspection will be accomplished virtually, using a life streaming application in combination with photographs. During the virtual facility walk-through portion of the inspection, the facility contact will walk the Ohio EPA inspector through areas of the facility normally inspected using a camera phone connected to the internet.  Ohio EPA has prepared a one-page document providing an overview of the process, which, at the time of publication of this article, had not been posted on the Ohio EPA website. We plan to include a newsletter article summarizing a VSV experience in the upcoming months, so keep a lookout!  In the meantime, for more information contact Lindsay Johnson or Nick Petruzzi.

USEPA and others in the vapor intrusion (VI) field have been evaluating a variety of Indicators, Tracers, and Surrogates (ITS) to assess their use in predicting the best time to collect representative indoor air samples for vapor intrusion studies (Schuver, et. al., 2018).  The idea is that if a predictive combination of easily obtainable, low cost ITS can be identified, they could be used to improve the collection of actionable analytical data at a lower cost. 

For VI assessments, typical indicators include seasons of the year, wind speed, the difference between the indoor and outdoor temperatures (differential temperature), barometric trends, and the difference between sub-slab and indoor air pressure (differential pressure).  Last month, I reviewed two ambient factors that are potential contributors to changes in differential pressure – barometric pressure and temperature (indoor and external).  As is common in the industry, I obtained the barometric pressure and external temperature data from a remote weather station which was many miles from my site.  This month, I will compare the differential pressure data to an onsite weather station to see if we can tease out any details. 

Differential pressure is generally measured with a hand-held manometer by measuring sub-slab air pressure and indoor air pressure and taking the difference.  Recently, however, sensitive differential pressure sensors have become available as part of the “Internet of Things” (IOT) revolution.  These sensors can be connected to permanent sub-slab monitoring points, such as the Vapor Pin®, to collect and transmit differential pressure, temperature, and barometric pressure readings to the web at preset intervals.  They can also be used to set alarm point that will notify users of system faults or other unacceptable conditions.

This month (July 2020), I collected differential pressure using a sensor at our warehouse.  The sensor was connected to a Vapor Pin® and allowed to run continuously. The warehouse consists of 4,500 square feet, slab-on-grade with a common moisture barrier.  The ceiling height is approximately 22 feet, the walls and roof are constructed of insulated steel, and the building interior is heated by two gas fired furnaces hanging from the ceiling.  For this experiment, the differential pressure sensor measured and logged differential pressure and internal temperature.  External temperature and barometric pressure readings were obtained from both a remote weather station several miles from our warehouse and from an onsite weather station. 

Last month’s data indicated that the differential pressure was directly related to the internal temperature of the building and not so much to external temperature nor barometric pressure.  The latter observation was puzzling to me because I would have expected barometric pressure to be a primary driver of differential pressure.  My first inclination was that the barometric pressure at the site must be significantly different than that reported by the remote weather station.  To compensate for this, I rented an onsite weather station to log, among other things, barometric pressure and temperature.       

The two graphs below plot a segment of the collected data as differential pressure, exterior temperature, and interior temperature on one graph; and differential pressure and barometric pressure on the other graph.

Upon inspection of the graphs, two conclusions can be made with respect to differential pressure: 1) from July 8 through 14, the differential between the sub-slab environment and the indoor air space was slightly greater than 0, indicating that the flow of soil gas was upward into the warehouse most of the time; and 2) there is a slight diurnal fluctuation in differential pressure during the week.  

The graph of temperatures is quite revealing. Based on this week of data (which was consistent with readings collected throughout the month), the differential pressure tends to mirror the changes in internal temperature and external temperature from both the onsite and remote weather stations. The diurnal internal temperature and maximum differential pressure occurs around noon of each day. I suspect that this pattern is due to solar heating of the building. Although not the case last month, external temperature from both the onsite and remote weather stations appeared to be directly relatable to changes in differential pressure.

The graph of barometric pressure is also revealing. I had suspected that differential pressure would be most sensitive to changes in barometric temperature. However, as confirmation to last month’s data, there is no immediately discernable patterns in the differential pressure and barometric pressure readings, either collected onsite, or remotely.  It is interesting that the remote and onsite barometric pressure readings track one another very well but are shifted by about one inch of mercury.  I believe this may be a calibration issue associated with the onsite instrument. 

What these data demonstrate, in our case at least, is that the remotely obtained temperature data, which matches the onsite data during this time period, appears to be useful in predicting the differential pressure changes for this warehouse space.     

We must remember, however, that the conditions measured in the spring and summer months of Ohio, may not be representative of those in the fall and winter months.  As the weather changes and we move into the heating season, we will revisit this issue.

As we wait for the weather to change, we may set our sights on a surrogate for VI.  Stay tuned.

Reference:

Schuver, H, Lutes, C, Kurtz, J, Holton, C, Truesdale, RS. Chlorinated vapor intrusion indicators, tracers, and surrogates (ITS): Supplemental measurements for minimizing the number of chemical indoor air samples—Part 1: Vapor intrusion driving forces and related environmental factors. Remediation. 2018; 28: 7– 31. https://doi.org/10.1002/rem.21557  

Since 2002, a bona fide prospective purchaser (BFPP) of a brownfield property could avoid Federal liability for investigation and cleanup if they performed appropriate Due Diligence. This process typically begins with an All Appropriate Inquiry (AAI) or ASTM Phase I Environmental Site Assessment (ESA) performed prior to the purchase of a property. Until now, the only similar State of Ohio liability protection was through the Ohio Voluntary Action Program (VAP). Although the VAP has been a model program for redevelopment of heavily contaminated brownfield sites for 25 years, not every brownfield site is heavily contaminated, and participation in the VAP can be both costly and lengthy.

House Bill 168 (H.B. 168) establishes Ohio liability protection to match the Federal liability protection provided by standard AAI/ASTM Phase I ESAs. It also provides a much-needed change to prevent automatic voidance of protection under the VAP.

As summarized by the Ohio Legislative Commission H.B. 168 “establishes an affirmative defense that allows a bona fide prospective purchaser (BFPP) to claim immunity from liability for the costs associated with the state’s performance of investigational and remedial activities to address a release or threatened release of a hazardous substance from the BFPP’s facility.” In other words, it provides the same protection from state liability as is provided at the Federal level under CERCLA legislation.

H.B. 168 also makes an important change to the VAP that “eliminates the law that automatically voids a covenant not to sue under the VAP when a property subject to institutional controls or activity use limitations is not in compliance with those controls or limitations.” As an example, say that an employer generously began to provide on-site childcare for its employees without realizing that a commercial/industrial use restriction on the property meant that daycares were prohibited on their property. Under VAP rules, liability protection for the employer was automatically voided on the day the daycare opened. If they desire VAP liability protection they are now back at square one and need a new No Further Action (NFA) letter and Covenant Not to Sue (CNS) to regain their liability protection. Even if they can demonstrate that there is zero risk to the children and Ohio EPA is in full agreement that there is no risk, everyone’s hands are tied, and the CNS is void. With H.B. 168, this is changed so that the Director of Ohio EPA is authorized, but not required, to void a covenant when a property falls out of compliance.

So, as a post H.B. 168 prospective purchaser of an Ohio brownfield, should you take the BFPP route or the VAP route?

Every situation is unique, particularly in brownfield redevelopment. First, regardless of which route you choose, you want to have high quality, defensible assessments. Phase I ESAs have nearly become a commodity and, unfortunately, many lack the thoroughness and detail necessary to identify and address issues or even meet the AAI and ASTM standards. Second, a good environmental attorney will provide you pragmatic advice on the level of due diligence and liability protection you should have and can help you identify shortcomings in ESAs.

Presuming you have a strong project team and are eligible to enter the VAP (i.e. not subject to certain other programs or enforcement actions), we generally recommend VAP for the following:

  • Projects where a lender or buyer requires a VAP NFA or CNS,
  • Projects where grant funds require participation in the VAP,
  • Projects where a property owner desires liability protection from a release that they caused or contributed to (i.e. they cannot be a BFPP),
  • Projects that will likely be the subject of a regulatory enforcement action if not addressed voluntarily, and
  • Projects with a high level of risk, perceived risk, or public scrutiny, where written concurrence from Ohio EPA is beneficial.

In our experience, 95% of brownfield projects do not meet any of these criteria. While the VAP remains an option as a “gold standard” for risk aversion, it is often not our first recommendation.

All that said, there is a “but…”, and that is that simply having a Phase I and Phase II ESA does not guarantee you liability protection – no matter how well they were prepared. You must always remember your “continuing obligations.” In simple terms, even if you are not liable to investigate or cleanup contamination, you are required to protect occupants of your property from exposure and not do anything that would make things worse. Regrading contaminated soil, not securing or disposing drums of chemicals, changing stormwater drainage patterns, refusing access to regulatory agencies to investigate or cleanup, and failing to maintain engineering controls or remedial equipment can expose you to the liability you thought you had avoided. Regular checks that the fan on your vapor mitigation system is still running are easily forgotten, particularly when no regulatory agency is involved. Developing a clear and easy to follow Continuing Obligations Plan is an essential part of the BFPP process.

H.B. 168 passed with unanimous support and was signed by Ohio Governor Mike DeWine on June 16, 2020. The bill will take effect on September 14, 2020, with some of its provisions becoming applicable retroactively.

There are many benefits to brownfield redevelopment. If you own, or are considering purchasing, a brownfield property, give us a call and we will help you navigate the best path forward.    


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I am text block. Click edit button to change this text. Lorem ipsum dolor sit amet, consectetur adipiscing elit. Ut elit tellus, luctus nec ullamcorper mattis, pulvinar dapibus leo.http://san

Michigan PFAS Groundwater Cleanup Criteria Revised to Reflect Newly Added State MCLs

Published in August 2020 Focus on the Environment Newsletter The Michigan Department of Environment, Great Lakes, and Energy (EGLE) recently promulgated state drinking water standards for seven per- and polyfluoroalkyl substances (PFAS).  Drinking water standards, also known as maximum contaminant levels (MCLs) are the maximum amount of a contaminant allowed in drinking water. When the… Read More »

EPA Turns 50 This Year

  • By: George
  • Published in August 2020 Focus on the Environment Newsletter On December 2, 2020, the Environmental Protection Agency (EPA) will celebrate its 50th birthday. Nearly 50 years ago, on December 2, 1970, President Richard Nixon created EPA by executive order to consolidate in one agency a variety of federal research, monitoring, standard-setting, and enforcement activities to… Read More »

Helpful Tips Based on Participation in an Ohio EPA Virtual Site Visit

  • By: Nick
  • Posted: 08/25/20

Published in the August 2020 Focus on the Environment Newsletter. In our July 2020 newsletter, we introduced Ohio EPA’s pilot program on the use of virtual site visits (VSVs) for select categories of inspections.  Recently, I made the trip to a client’s facility and provided assistance conducting a VSV with Ohio EPA during a RCRA… Read More »

DATA déjà vu?

  • By: Nate
  • Posted: 08/24/20

Published in the August 2020 Focus on the Environment Newsletter. Have you ever received an agency’s request for additional investigation and thought, “surely we’ve done this before?” You are not alone. Particularly on “lower priority” and long-running sites, involved parties can easily lose track of what has been done. Client, agency, and consulting staff turnover… Read More »

Ohio EPA Proposes to Revise Eight Municipal Solid Waste Rules

On July 6, 2020, the Ohio Environmental Protection Agency (Ohio EPA) Division of Materials and Waste Management filed eight municipal solid waste (MSW) landfill rules with the Joint Committee on Agency Review.  The eight rules proposed for revision are: 3745-27-02 Permit to install 3745-27-05 Applicability and relation to other laws 3745-27-06 Sanitary landfill facility permit… Read More »

Timing is Everything – ITRC Releases Risk Communication Toolkit

  • By: George
  • The Interstate Technology and Regulatory Council (ITRC) has released an online Risk Communication Toolkit.  The EPA defines “risk communication” as the process of informing people about potential hazards to their person, property, or community. It is a science-based approach for communicating effectively in situations of high stress, high concern, or controversy. Now more than ever,… Read More »

Ohio EPA to Pilot Virtual Site Visits

  • By: Lindsay
  • Navigating this new world due to COVID-19 has been a challenge to everyone, including Ohio EPA. To protect against the potential spread of COVID-19 while maintaining their mission to ensure compliance with environmental laws and regulations, Ohio EPA is piloting the use of virtual site visits (VSVs) for select categories of inspections (e.g., routine, screening,… Read More »

New Ohio Law Encourages Brownfield Redevelopment

  • By: Nate
  • Since 2002, a bona fide prospective purchaser (BFPP) of a brownfield property could avoid Federal liability for investigation and cleanup if they performed appropriate Due Diligence. This process typically begins with an All Appropriate Inquiry (AAI) or ASTM Phase I Environmental Site Assessment (ESA) performed prior to the purchase of a property. Until now, the… Read More »

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