Michael Bernstein

Industrial Archaeology and Environmental Assessments

Phase I Environmental Assessment (EA) is an investigation whose objective is to identify potential environmental concerns, which may be characterized by sampling and analysis during a Phase II EA. Phase I EA investigates the current and historic presence and management of hazardous materials, hazardous waste, asbestos, polychlorinated biphenyls, wastewater, storage tanks, and other items of interest. Soil and groundwater contamination is the ultimate concern. In the practice of environmental due diligence associated with real property transactions, industrial archaeology becomes a for-profit endeavor conducted in an unsympathetic arena.

Introduction

Phase I Environmental Assessment (EA) is the initial evaluation of the environmental quality or integrity of a real property. It is triggered by a proposed transaction (e.g., purchase, foreclosure, or refinancing) and is a standard requirement of the lender, buyer, investor, or other party who has a financial interest in the pending transaction. Should the Phase I EA identify potential concerns, a Phase II EA may be performed in order to characterize those potential concerns by sampling and laboratory analysis. Actions may be taken to mitigate or remediate actual concerns that are confirmed by the results of the Phase II EA. This work is part of the risk-management process known as due diligence, where the data objectives and work product are prescribed by the needs of commercial enterprise and the regulatory domain in which it takes place.

The scope of work for Phase I EA consists of field observations and office research. Limited sampling of asbestos-containing materials (ACMs) is commonly included. Indoor air quality, noise, and similar issues related to workplace exposure lie within the realm of industrial hygiene and are not included in the Phase I EA nor are health-related issues of sanitation. Lead-based paint, lead in drinking water, radon, and mold are considerations in most Phase I EA scopes of work for multifamily residential properties but generally not for industrial or commercial properties.

Identifying potential soil and groundwater contamination is the ultimate objective of Phase I EA. The Phase I report's conclusions and recommendations state whether and why soil, groundwater, surface water, or waste samples should be collected during a Phase II EA. The Phase II scope of work indicates where and how many samples of which substance will be collected, how the samples will be collected, and the chemical parameters for each sample analysis. The analytical results of the Phase II investigation are considered in the context of the applicable regulations and client requirements in order to evaluate whether further action should be recommended.

EAs are applied science and engineering that can dramatically complicate—or terminate—a proposed mutimillion-dollar property transaction. For that reason, any of the parties involved may be hostile to the assessment work and to the assessor. Generally viewed by the borrower, lender, or broker as an impediment to business, the experienced environmental consultant knows that science and engineering are only half the battle. The business context in which this work occurs is a vital consideration that must be understood and addressed but, hopefully, without sacrificing the consultant's personal or professional integrity.

Although industrial archaeology is but one facet of this work, environmental consulting provides the opportunity for persons to earn livings in a profession that includes industrial archaeology. Another advantage of this field is that scientists and engineers of various disciplines can find employment in this capacity.

This article is a primer that presents and discusses the basic what, where, how, and why of Phase I EAs at industrial and commercial properties. The regulatory context in which the work is performed is mentioned only in passing.

Phase I Environmental Assessment Defined

In the author's definition, Phase I EA is a geographic inventory of historic and existing features and conditions of potential environmental concern. The elements of the definition are explained below.

Geographic

The location of the feature or condition of potential environmental concern is fundamental. Geographic context is a vital consideration because it may indicate whether further investigation is warranted or even feasible.

Historical information without geographic specificity can be problematic and may raise more questions than it answers. For example, historic reference to a dry cleaner formerly located in a shopping center is an immediate potential concern, but Phase II subsurface investigation cannot proceed in a cost-effective manner unless the exact tenant space can be identified.

Historical information with geographic specificity may mitigate a potential concern. For example, if the location of an old underground storage tank (UST) is now occupied by a building that has a basement and a subbasement, an argument can be made that the UST and the contaminated soil that may have been associated with it were necessarily removed during excavation of the basements.

If collection of soil and groundwater samples is recommended on the basis of property history, accessibility of the proposed sampling locations must be evaluated before Phase II work is proposed. Analysis of the composite geography of the present-day property and the historic property should reveal whether locations of interest are accessible to drilling, or whether they are now obstructed by newer buildings, overhead power lines, underground utilities, or other limiting features or hazards. Accessibility may also determine the type of sampling equipment that can be used.

Inventory

Phase I EA seeks to develop information regarding a list of standard items of interest, such as aboveground storage tanks (ASTs) and USTs; the storage and use of hazardous materials; the generation, storage, and disposal of hazardous waste; PCB-containing electrical equipment; hydraulic equipment; ACMs; wastewater; and other considerations.

Historic and Existing

Phase I EA is concerned with historic (discontinued) operations and historic (demolished) structures more so than present-day activities and facilities, since most contamination originated as releases that occurred in past decades. Table 1 identifies and comments upon standard sources of historical information that may be used by the Phase I environmental assessor.

Table 1. Standard Historical Research Materials: Advantages and Disadvantages
Research Material	Advantages	Disadvantages
Photographs
Aerial photographs¹	Unbiased images of physical reality, usually available from multiple sources	Usefulness may be limited by small scale, poor clarity, or obscuring vegetation
Ground-level photographs	Scale and closeness of view	arely available
Non-Photographic Depictions
Plans and drawings²	Site specific; the most detailed source of information	Unless a plan or drawing is labeled "as built," uncertainty may arise as to whether the plan or drawing depicts what was intended to be built or what actually was built
USGS topographic maps³	Availability	Scale and infrequency of revision
Geologic quadrangle maps⁴	Depict quarries and pits that may have become landfills	Relatively few historic geologic quadrangle maps were prepared
Fire insurance maps⁵	Very valuable; depict features (storage tanks, substations, transformer vaults, etc.), note operations (painting, fueling, plating, etc.), and portray interior building spaces	Poor clarity of the electronic versions provided by commercial vendors, and, like any map, fire insurance maps only show what the surveyor identified and the mapmaker decided to include
Street maps and atlases⁶	More commonly available than fire insurance maps	Much less technical detail than a fire insurance map
Navigation charts⁷	Useful for identifying waterfront facilities and the possible placement of fill along shorelines	Not readily available
Promotional plans and maps⁸	Plans and maps prepared for the promotion of local industries or specific industrial projects can be very useful	Not common
Textual Materials
City directories⁹	Very valuable, especially if all three sections are included (alphabetical listing by business name, listing by business category, and block-by-block listing of occupancy by street address)	The information is only as good as the canvassers and compilers were diligent, and company names do not necessarily indicate the actual nature of the operations
Telephone directories¹⁰	A useful alternative to city directories, especially if the classified business section is included	Produced as throw-away items on inexpensive and therefore frail paper, telephone directories are not as common as hard-cover city directories
Business directories¹¹	Useful for identifying and categorizing manufacturers	Not common
Real estate directories¹²	Useful for identifying property owners in time	Not common
Geotechnical reports	Logs prepared for foundation engineering studies may indicate the presence of fill or waste deposits	Not often available
Company-employee periodicals¹³	May include photographs of facilities, descriptions of operations, locations of structures, etc.	Usually limited to large manufacturers
General industry publications¹⁴	Useful for generic information	Not site specific
Government publications¹⁵	Official accounts of major projects and programs	Not common or readily available
Public records and reports	Fire departments, building departments, and other local governmental offices may have useful information	Municipal records may be discarded after a set period of time or may be archived and not readily available
Company archives and histories¹⁶	May include photographs of facilities, descriptions of operations, locations of structures, etc.	Usually limited to large manufacturers
Product literature¹⁷	Product catalogs and users' manuals may identify the chemical constituents of trade-named products	Usually limited to large manufacturers
Regulatory agency databases	May identify, for example, registered hazardous waste generators previously located at the subject property	Subject to interpretative abuse by parties who dismiss otherwise known establishments of concern because they are not listed sites
Personal Interviews
Facility personnel	Very site-specific information that may not have been documented	May be unreliable due to faded memories or workers' fear of being fired for making a serious disclosure
County and municipal officials	Site-specific information from a governmental source	Officials may be reluctant to provide information for fear of making a disclosure that results in financial loss and, therefore, political consequences

Fire insurance maps are so valuable to the environmental assessor that the Sanborn Map Company of Pelham, New York, has been acquired by Environmental Data Resources, Inc., of Milford, Connecticut (a commercial vendor of environmental regulatory agency databases). Factory Mutual Insurance Company of Norwood, Massachusetts, continues to prepare site-specific fire insurance maps of industrial plants.

The release of a chemical substance is an event in time. The forward projection of the event's consequences through time is an important concept. The barely detectable leakage of product from a UST may constitute a negligible release in the context of a single week, but the leakage may become significant if it continues for months or years. The cumulative impact over time must be considered. The passage of time also provides an opportunity for the contaminant to reach groundwater and, subsequently, migrate horizontally, which increases the area and volume of the contamination and increases the potential for impact to adjoining properties owned by other persons. Time is also one of several factors that provide the opportunity for certain organic chemicals to degrade, which can result in the presence of chemicals of greater toxicity than the substance that was originally released.

Features and Conditions

A feature is an object, such as a UST. The condition is the environmental impact (or the lack thereof) associated with the feature, such as soil or groundwater contamination associated with the UST. The body of contaminated soil and the plume of contaminated groundwater could also be considered features, but it is useful to differentiate cause from effect. Corrosion of a steel storage tank, spalling of the concrete cradle that supports an AST, cracks in a masonry spill-containment wall, and similar states with respect to the physical integrity of a feature are also conditions.

Potential Environmental Concern

Unless gross and obvious contamination is present, a potential environmental concern is just that—a potential concern. It becomes an actual concern if analytical results for samples collected during a Phase II EA indicate the presence of regulated substances at concentrations of regulatory significance. Careful reference to an uncharacterized feature or condition as a potential concern avoids the creation of a stigma that can follow a property and negatively affect its value, to the detriment of the owner and the consultant.

For example, the identification of an abandoned UST would certainly constitute a potential concern if conditions associated with the tank have not been evaluated. If the tank is shown not to have involved leakage or spillage, then the UST is not an environmental concern at that time. As an abandoned tank, however, it may constitute a regulatory concern.

Why Perform a Phase I Environmental Assessment

Phase I EAs are performed in order to identify potential environmental concerns and to estimate the financial cost of characterizing those potential liabilities in the context of a proposed real-estate transaction. Awareness of the business context in which the work is happening is a prevailing consideration. Table 2 identifies the various transactions that trigger a Phase I EA and discusses the rationale.

Table 2. Transactions That Trigger a Phase I EA and Rationale
Transaction	Rationale for the EA
Purchase loan or refinancing	Lender needs to know whether the dollar value of the property is depreciated by environmental impairment. Lender needs to make a proactive effort to protect its investment from potential regulatory enforcement actions and to prevent the financial difficulties that could befall the borrower from unforeseen costs for environmental problems.
Collateralized loan	A borrower offers a property as collateral to acquire another property. Environmental impairment would reduce the dollar value of the collateral. The presence or absence of impairment would also be an important factor in the lender's decision to foreclose and take possession of the collateral if the borrower fails to repay the loan.
Direct investment or acquisition	A pension fund, real-estate investment trust, or other investor purchases a property with its own money. Environmental impairment is still an important consideration because the investor will eventually want to sell the property and must manage it until that time.
Predemolition/redevelopment	Transformers, storage tanks, asbestos, etc., must be removed prior to demolition. Appropriate actions must also be taken if contaminated soil or buried waste would be encountered during redevelopment.
Divestiture	A co-owner wants to sell. All of the owners need to know whether contamination is present at the time of divestiture, so that the divestor can be held responsible for a share of the liability if impacts are present. Should no contamination be identified, the divestor will be able to assert that any contamination identified in the future was due to a release that occurred after the sale.
Rental preoccupancy	A prospective tenant needs to know whether contamination already exists at the property. Should contamination be identified, the incoming tenant has demonstrated that the contamination was a pre-existing condition for which they are not liable.
Rental prevacancy	A vacating tenant needs to know whether contamination is present at their departure time. If no contamination is identified, they will be able to assert that contamination identified in the future is attributable to a later tenant. Should contamination be identified, the objective is to characterize it and identify the potentially responsible parties so that the departing tenant is not exposed to open-ended liability.

If potential impairment is identified, the client needs an estimated cost for a Phase II EA to characterize the potential concern. The results of the Phase II EA would be used to estimate the cost to mitigate or remediate, based on the client's criteria and regulatory requirements (see figures 1–7).

Figure 1. Local area of the U.S. Geological Survey Norristown, Pennsylvania, topographic quadrangle (surveyed 1894, edition of July 1895, reprint of July 1908), depicting the original building of Merion Worsted Mills Inc. (built 1891) on the Schuylkill River in West Conshohocken, Montgomery County, Pennsylvania (suburban Philadelphia).

Figure 2. South side of the original (eastern) building of Merion Worsted Mills, with boiler room at left. Predemolition activities at this time included the removal of various items identified during the Phase I Environmental Assessment, including three heating oil USTs, transformers, capacitors, much friable asbestos, and abandoned drums of industrial oils. The fill in which one of the USTs rested contained an abundance of "blob top" beverage bottles (c. 1900), embossed with the names and addresses of brewers and soda bottlers located in Conshohocken, Norristown, and Philadelphia. Photo by author, Dec. 1990.

Figure 3. North side of the original building of Merion Worsted Mills. Photo by author, Dec. 1990.

Figure 4. South sides of the central and western buildings of Merion Worsted Mills, with boiler room and chimney (right), an early three-story addition (center), and a more recent masonry block addition (far western end). Storage bays known as "the catacombs" extended laterally along an axial corridor beneath the first floor of the early addition. The adjoining railroad tracks were the Reading Division of the Philadelphia & Reading Railroad. Photo by author, Dec. 1990.

Figure 5. Demolition of the original building of Merion Worsted Mills. The boiler room (in front of the chimney) was the first structure to be removed in order to allow for the salvaging of machinery before general demolition proceeded. Photo by author, Jan. 1991.

Figure 6. Demolition of Merion Worsted Mills. Photo by author, Jan. 1991.

Figure 7. Demolition of Merion Worsted Mills. Photo by author, Jan. 1991.

Phase I Environmental Assessment: Features

Underground Storage Tanks

USTs are always a major item of interest, since they can involve bulk quantities of hazardous substances, lie within the subsurface, are not directly observable, and are often regulated. Their locations, contents, capacities, ages, materials of construction, and other details must be determined. If Phase II drilling is to take place around an existing UST, the tank's dimensions and alignment must also be determined so that the tank will not be struck. If reliable plans are not available, a geophysical survey by magnetometer or ground-penetrating radar would be necessary. Construction material is important; a fiberglass UST will not corrode, but a magnetometer will not respond to it. The UST contents must be determined so that proper analytical parameters can be selected. An alternative to soil sampling and analysis is integrity testing of the UST system (i.e., the tank and the associated piping). In the most common method, a microphone is placed below the product level and a vacuum is applied. A "bubbling" sound means that a defect exists below the product level, while failure to hold the vacuum without a bubbling sound means a defect exists above the product level.

Even if the given UST is not regulated (i.e., registration and certain improvements are not required), the tank may become regulated if a release is determined to have occurred. Although the tank itself is obviously the primary feature of interest, releases can also occur from piping leakage, dispenser leakage or spillage, and tank overfilling spillage.

The definition of a UST is also important. For example, a tank enclosed inside a sand-filled vault in the basement of a building is a UST by regulation because the tank and the floor beneath it are not visible or accessible for visual detection of a leak. Despite the fact that the tank is located inside a building and is not surrounded by soil of the outside environment, it is a UST by definition and is therefore subject to applicable regulations.

As always, the time factor is important. Boilers may be fired with natural gas at the time of the Phase I property visit, but a determination must be made as to whether the boilers have always been fueled with natural gas or whether abandoned fuel oil USTs might be present or might have been present and were later removed.

Aboveground Storage Tanks

ASTs are also a major item, since they too can involve bulk quantities of hazardous substances. ASTs are less problematic than USTs, since they are directly observable and do not rest within the subsurface. However, because an AST is a surface feature, its context must be evaluated. The manner in which a release from the AST might migrate is an important consideration. If the AST is located inside a building, notation must be made as to whether it lies near a floor drain, a trench drain, a loading dock, or other routes by which a release could migrate. If the AST is located on the exterior grounds, notation must be made as to whether it is underlain by soil or pavement, whether it is located near a storm sewer inlet, whether it is elevated or rests directly on the ground, etc. If the AST has secondary containment (e.g., a poured-concrete curb, a masonry block wall, or a steel basin), the integrity of the secondary containment must be visually assessed. If the containment has a valve to release storm water, the outfall area should be examined for possible evidence of a release of contaminated storm water.

Hazardous Materials

Other than those stored in tanks, hazardous materials most often occur as liquids stored in steel drums and cans. The locations where the materials are/were stored and used as well as the manner and processes in which they are/were stored and used must be identified and assessed. The assessor also needs to evaluate how leakage or spillage might have migrated and impacted the environment. Materials management practices that were common in the past must be taken into account, and the possible presence of substances that are no longer manufactured or marketed (PCBs, DDT, etc.) must be considered.

Bulk quantities of hazardous materials may have been dispersed throughout the plant, or they may have been stored at discrete locations. Containers that may have been present at any location at any time are difficult to pursue, but centralized storage areas can be targeted for study. Former drum storage areas and rooms may be identified by the presence of safety lighting fixtures, walk-in vaults, depressed floors, curbs across doorways, fire doors, wall fans, sumps, trench drains that direct floor drainage out of the room, scuppers, grounding wires, blow-out walls that direct and vent the energy of an explosion, and latent clues as simple as rust rings on the floor.

A detached shed or a concrete pad at a remote location may be a former drum storage area that was so located in order to isolate flammable materials.

Additional research may be necessary in order to identify the generic constituents of an old trade-named product. Present-day trade names may present an environmentally friendly face, but some old ones are suggestive in ways that might be frowned upon today. For example, Lethane 384 Special was a synthetic insecticide concentrate whose name bragged of the product's lethal quality (due to its cyanide content).¹⁸ A transformer manufactured by Kuhlman Electric Company and labeled "Safe-T-Kuhl" boasted of its safety from overheating, thanks to the PCB content of its oil.

Labeling on an old container may be both revealing and secretive. A good example is the labeling on a steel container of Flit brand insecticide, in this case manufactured by Esso Standard Oil Company of Linden, New Jersey. The side panel states that the product contains 2% technical chlordane, 0.05% lindane, 25% Aromin (a trade-named proprietary substance identified on the label only as "insecticidally active petroleum hydrocarbons"), and refined petroleum distillate. While chlordane and lindane are standard parameters for pesticides analysis, additional research or analysis for a broad suite of parameters would be necessary in order to identify the remaining proprietary and unspecified constituents of Flit.

Chlorinated solvents, which include degreasers and dry cleaning fluid, are hazardous materials of perennial concern. Degreasers are commonly found in parts washers used in maintenance shops, machine shops, tool and die shops, and similar areas where metal parts need to be cleaned of cutting fluid, lubricant, coolant, grease, etc. A typical parts washer, called a solvent circulator, is a rectangular steel basin mounted on top of a steel drum. The solvent is circulated from the drum, through the basin, and back into the drum. Other types of less-common parts washers include immersion units (in which the parts are submerged in standing solvent) and vapor degreasers (in which the parts are exposed to vapor generated by the heating of standing solvent). All these devices generate waste solvent and contaminated sediment, whose fate must be investigated. Chlorinated solvents can pass through concrete and asphalt, so the presence of floors and pavement does little to mitigate potential concern in the event of a release.

Hazardous Waste

Questions that pertain to hazardous materials likewise pertain to hazardous waste. The assessor needs to learn what it was, and where and how it was generated, stored, and disposed of. Most hazardous wastes are regulated under the federal Resource Conservation and Recovery Act.

Bulk quantities of wastes may be associated with heavy industrial facilities, and they might not have traveled far. Waste foundry sand or smelter slag may have been used as fill around the site. A steel mill may have had an onsite landfill for ash, scale, and other wastes. Coke ovens and coal gasification plants generated residual wastes such as breeze and tars, which may have been buried on the property. Sludge from a galvanizing plant or other plating works may have been discharged to a now-filled lagoon or drummed for local burial. Tank and still bottoms from a petroleum refinery may have been used as landfill on the site. Analysis of the terrain of such sites may reveal suspicious topographic features and relationships that suggest the presence of waste deposits.

Bulk industrial waste may also have been purposefully employed. Proposed redevelopment plans for a property located in Bucks County, Pennsylvania, called for the removal of a turnaround berm of the former Philadelphia & Reading Railroad. Construction of a railroad berm was an ideal opportunity to conveniently transport and usefully dispose of bulk industrial waste. Excavation of a section to expose the interior structure and composition of the berm revealed a stratum of heavy slag. Analysis of the slag indicated the presence of high concentrations of chromium and nickel, suggesting that the slag may have been derived from tool-grade or weapons-grade steel at one of the specialized mills or foundries located in nearby Philadelphia. Although the concentrations of total metals were high, further analysis revealed that concentrations of leachable metals were low. Little environmental impact was anticipated, therefore, and the slag could be managed as a nonhazardous residual waste.

Polychlorinated Biphenyls

PCBs are a fire retardant and insulator material that can be present in the dielectric fluid contained in transformers, capacitors, breakers, switches, and other liquid-cooled electrical equipment manufactured prior to July 1979.¹⁹ Trade names on manufacturer's plates (most commonly, Dykanol, Inerteen, Aroclor, Askarel, and Pyranol) indicate the presence of PCBs at the time of the equipment's manufacture. The fluid in old transformers may have been replaced in order to reduce the PCB content for regulatory purposes. Manufacturer's labels are particularly important in the case of capacitors, since they are sealed vessels whose fluid is not accessible to sampling. Transformers located on the exterior grounds warrant scrutiny with respect to their possible proximity to storm sewer inlets and other potential receptors and routes of migration in the event of a release.

By regulation, a transformer is classified as PCB, PCB-contaminated, or non-PCB, depending upon the PCB concentration. The oil originally placed in some transformers contained PCBs by design, while the oil in other transformers contained PCBs by default. In the former case, PCB was added to the bulk oil supply because specifications called for it. Although specifications for the next series of transformers did not call for PCBs, those transformers were filled with the remaining PCB-containing oil. The bulk supply continued to be replenished with additional oil as dispensing continued, but no more PCB was added. The result was that the concentration of PCBs in the bulk supply gradually diminished as dispensing continued. The word "non-PCB" does not necessarily mean "no PCBs"; by regulation, it means the PCB concentration is less than 50 parts per million. PCBs are specifically addressed by the federal Toxic Substances Control Act.

PCBs may also be present in the hydraulic fluid in elevators and vehicle lifts of sufficient age, as discussed below.

Hydraulic Equipment

Hydraulic equipment can include elevators, dumbwaiters, trash compactors, carton balers, manufacturing machinery (presses, punches, etc.), dock levelers in truck bays, in-ground truck scales, in-ground vehicle maintenance lifts, and other pieces of equipment. If old enough, hydraulic fluid is suspect for having PCBs. Even if free of PCBs, most hydraulic fluid is a petroleum product that would still constitute a concern if released to the environment. Modern aboveground equipment, such as compactors and balers, poses little potential concern unless it adjoins a storm-sewer inlet or a floor drain.

Hydraulic equipment that includes subsurface components, primarily elevators and vehicle lifts, poses the greatest potential concern. Elevators that service floors one through four (five at the most) are typically hydraulic. Elevators that service higher floors are cable drawn. The mechanical room must be examined for possible leakage of hydraulic fluid from the reservoir and for the presence of floor drains. Hydraulic elevator pistons typically retract into the subsurface, although they telescope aboveground in certain systems. The elevator pit must be examined for possible hydraulic fluid releases, drains, and sumps. If a sump is present, a determination must be made as to whether it is a fully enclosed concrete basin or whether its bottom opens to the environment. If a floor drain, a sump with a gravity outflow pipe, or a sump pump is present, the receptor must be identified. Whether the system is old enough for PCBs to be present must also be determined. If a release to the subsurface has occurred through the piston, remediation is hardly possible until the building is demolished.

A vehicle lift may be a single-piston or multiple-piston unit. If a lift has a history of failure to hold pressure or a history of needing the addition of fluid, a subsurface leak is likely. Unless reliable plans are available, the problem lies in the danger of striking the in-ground reservoir or mechanism while drilling for soil samples. Sampling the fluid that remains in the hydraulic system for PCB analysis is not particularly meaningful, since the original fluid may have been lost to the subsurface. Most inoperable lifts were simply abandoned in place.

Asbestos

Asbestos is primarily a potential concern in buildings constructed in or before the 1980s. It was used in a wide range of building materials and machinery components, and may be encountered in many locations and systems within a building. It was used as an inert filler or base in many materials in addition to its infamous uses for fireproofing and insulation. Asbestos-related activities during a Phase I EA are typically limited to observations of readily accessible and visible portions of a building and some sampling.

The U.S. Environmental Protection Agency, some states, and some major counties and cities certify asbestos building inspectors and other categories of asbestos workers. Regulations extend from the federal level (including the Asbestos Hazard Emergency Response Act) to the municipal level (for example, the City of Philadelphia's Asbestos Control Regulation).

An ACM is friable or nonfriable. Friable materials pose the greatest concern since they are more vulnerable to being damaged and more likely to release fibers that will become airborne. ACMs may be damaged by water, fire, air erosion, impact, abrasion, vibration, and other means. Damage can involve dislodgment, delamination, disintegration, etc.

ACMs are divided into three basic categories: surfacing material, thermal system insulation, and miscellaneous materials. Good examples of surfacing materials are sprayed-on fireproofing on steel beams and "popcorn" textured soundproofing material on ceilings. Pipe wrap and boiler lagging are classic examples of thermal system insulation. Certain ceiling tiles and vinyl floor tiles are common miscellaneous materials.

ACMs take many forms, some of which can be misidentified or overlooked. Thick black panels in which electrical components are often mounted look like slate but are, in fact, a monolithic ACM.²⁰ Pipe insulation that looks like corrugated cardboard is an ACM generically called "aircell." ²¹ The vibration damper on an air duct may look like white burlap, but it is actually a woven asbestos fabric. Suspended pipe runs in buildings constructed during the 1970s may be insulated with fiberglass, but pads placed between the pipes and the saddles on which the pipes rest may consist of very friable asbestos.

A careful asbestos building inspector uses generic terminology in the absence of information that identifies the trade name or manufacturer of a given product. In particular, the universal but incorrect practice is to refer to all rigid boards and panels as "Transite."²² In fact, Transite is a trade name for certain products manufactured by Johns-Manville; however, Johns-Manville is not the only company that manufactured such products.²³ In the absence of labels, specifications, or plans identifying the given material as a Johns-Manville product, the material should be referred to by its generic description—cementitious ACM or cement-asbestos material. In addition to flat and corrugated sheets, Transite was produced as flue pipe, industrial vent pipe, pressure pipe, conduit, sewer pipe, water pipe (hence the asbestos contamination of some municipal water supplies), pipefittings, and perforated acoustical panels for sound control.

Johns-Manville also produced suggestively trade-named insulation products including Asbesto-Sponge felted sheets and blocks (a spongy, laminated material especially resistant to mechanical abuse), Asbesto-Sponge felted pipe insulation, Vitribestos sheets for lining smokestacks and flues, Asbestocel pipe insulation, and Asbestocel sheets and blocks (for insulating boilers, drying rooms, and warm air ducts).²⁴ Less revealing trade names for other Johns-Manville asbestos-containing products include Superex block insulation and pipe insulation (calcined diatomaceous silica bonded with asbestos, for use in power plants, furnaces, ovens, kilns, etc., to 1900o F), Marinite (an industrial sheet material similar to Transite but lighter in weight), Fibro-Cel (an insulating kiln filler composed of diatomaceous silica and long-fiber asbestos for use to 1800o F), and Trancell (cementitious panels for enclosing bus bars, transformers, switches, and other electrical equipment) (see Figures 8–14).²⁵

Figure 8. Manufacturer's product data sheet for an indestructible type of asbestos-containing electrical panel. "Asbestos Ebony," data sheet EL-1, Feb. 1946, Johns-Manville, series of product data sheets collated Jan. 1952, New York, N.Y.

Figure 9. Manufacturer's product data sheet for a commonly encountered form of asbestos-containing pipe insulation, generically called "aircell," for temperatures to 300°F. "Pre-Shrunk Asbestocel Pipe Insulation," data sheet IN-260, May 1947, Johns-Manville, series of product data sheets collated Jan. 1952, New York, N.Y.

Figure 10. Manufacturer's product data sheet for one of many forms of Transite, a particularly successful product whose registered trade name is commonly but erroneously used in the generic sense. "Flat Transite Asbestos Sheets," data sheet BMT-200, Mar. 1948, Johns-Manville, series of product data sheets collated Jan. 1952, New York, N.Y.

Figure 11. Manufacturer's product data sheet for a less common form of asbestos-containing pipe insulation for temperatures to 700°F. "Asbesto-Sponge Felted Pipe Insulation," data sheet IN-210, Aug. 1949, Johns-Manville, series of product data sheets collated Jan. 1952, New York, N.Y.

Figure 12. Manufacturer's product data sheet for an asbestos-containing liner for smokestacks and flues. Note the asbestos-containing cement identified in the diagram. The "Aertite coating" and "85% magnesia blocks" also noted on the diagrams are other J-M products, the former being an asphaltic-asbestos plastic and the latter consisting of carbonate of magnesia and asbestos. "Vitribestos Sheets," data sheet IN-53, Aug. 1950, Johns-Manville, series of product data sheets collated Jan. 1952, New York, N.Y.

Figure 13. Manufacturer's product data sheet for another form of asbestos-containing pipe insulation for temperatures to 1900°F. "Superex Pipe Insulation," data sheet IN-230, Dec. 1949, Johns-Manville, series of product data sheets collated Jan. 1952, New York, N.Y.

Figure 14. Manufacturer's product data sheet for asbestos-containing millboard. Note the statement that the boards can be sawed—a sure way to release airborne asbestos fibers, unless done underwater. "J-M Asbestos Millboard," data sheet IN-110, Jul. 1951, Johns-Manville, series of product data sheets collated Jan. 1952, New York, N.Y.

ACMs associated with the structural components of a building (such as Transite wall panels or fireproofing on a steel deck) are sometimes referred to as asbestos-containing building materials (ACBMs) in order to differentiate them from ACMs used in machinery that are not integral to the building structure. The latter are exemplified by the Asbeston series of products formerly manufactured by Uniroyal Textile, a division of Uniroyal Inc. of Winnsboro, South Carolina.²⁶ These products included lap (felted asbestos for use as insulation on wires and cables), roving (a single strand of untwisted asbestos for use as insulation on wires and cables), yarn (twisted roving used as the base material for woven and braided finished products), cord (twisted yarn for use in high-temperature manufacturing processes), thread (smoothed yarn used for sewing and fastening other asbestos textiles), cloth (woven yarn used in many industrial applications), tape (woven fabric for use as insulation in the electrical industry), tubing (braided or woven yarn used as sleeves for cables and wires), wick (twisted roving or felted asbestos used as a packing material and caulk), rope (twisted or braided wick used as packing, sealing, or gasket material), and felt (nonwoven sheets, tapes, and rolls used as the base material for finished products). Asbestos textile is perhaps most commonly encountered as vibration dampers on air ducts, which dissipate the energy of vibrations generated by air handlers so that the annoying sounds of machinery and flexing sheet metal do not reverberate throughout the building.

The most unusual occurrence of asbestos yet encountered by the author was associated with a boiler room located inside a building that was constructed during the 1950s. The false ceiling in this room proved to be the bottom of a void space that was filled with loose, friable asbestos. Because the boiler room was located on a middle floor, the overlying floor needed to be insulated from the heat. The lower height of the ceiling, in comparison to the ceilings in the adjoining rooms, was the clue.

Wastewater

Unless good as-built plumbing plans are available from the time of the subject building's original construction, wastewater can be particularly problematic. Components of the generation, collection, treatment, and disposal system may not be accessible or may no longer be discernable, and establishments that originally had on-site disposal systems may have been connected to the municipal sanitary sewerage system later. Wastewater-related features of interest include the following:

Floor drains are circular, square, or rectangular openings in a floor, covered with a grate, which may occur anywhere. A floor drain in a detached structure (e.g., a maintenance shed or a transformer vault) may discharge directly to the environment since secondary or remote structures were commonly bypassed for connection to the sewerage system.
Trench drains are elongate, rectangular troughs covered with a grate that are commonly found in vehicle maintenance shops and industrial facilities. They simply provide greater areal coverage than a floor drain. Trench drains often discharge to a sump, which traps extraneous matter that may have become entrained.
Sumps are typically in-ground concrete basins that may be square, rectangular, or cylindrical and may be intended to contain spillage, collect groundwater that enters a basement or an elevator pit, or capture extraneous matter entrained in the flow from a floor drain or trench drain, etc. A sump may retain all it receives, or it may discharge to a receptor. If a sump pump or gravity outflow pipe is present, the receptor must be identified. The integrity of the sump must also be considered. A sump located in the floor of an elevator pit may have an open bottom that allows entry and later outflow of shallow groundwater in order to relieve hydrostatic pressure around the pit.
Oil-water separators are typically multiple-chambered, rectangular, in-ground concrete basins whose purpose is to separate oily wastewater into its oil and water fractions. The oil is retained, while the water is usually discharged to a receptor that must be identified. Oil-water separators are most often associated with floor drainage at vehicle maintenance shops, and they commonly appear as two side-by-side covers in a rectangular concrete pad. The covers provide access to the chambers so that sediment and oil can be removed.
Septic systems are typically associated with lavatory waste, but the assumption must not be made that only lavatory waste was discharged to a septic system located at an industrial or commercial property. Septic systems occur in a broad range of designs, from a simple perforated concrete leaching tank to a system that includes a series of tanks and an array of distribution arms. Septic systems at nonresidential properties are immediate potential concerns.
Settling basins are typically in-ground concrete chambers that allow particulate matter to fall out of the waste stream so that downstream components do not become clogged with solid matter. They are usually associated with a process. The first chamber of an oil-water separator coincidentally functions as a settling basin.
Surface impoundments may be waste storage lagoons, settling basins, cooling water ponds, treatment basins, or other bodies of process-related surface water. Early impoundments were commonly unlined or inadequately lined. They are an uncommon but immediate potential concern.
Outfalls are open-mouth pipes that discharge effluent to the ground surface or to surface water. An outfall may be as small as a 2-inch-diameter perimeter drain from a septic field, discharging to a creek, or as large as a 4-foot-diameter pipe, discharging industrial effluent to a river.

The key consideration with regard to wastewater at a commercial or industrial property is the history of wastewater generation and disposal. A facility's current connection to the municipal sanitary sewerage system does not necessarily indicate that the facility has always been connected to the municipal system, in whole or in part. Connection of the executive office lavatories to the municipal sewer is not assurance that the oil-water separator in the maintenance garage was also connected. In the absence of historic plumbing plans, the sewerage authority should be contacted in order to learn when the subject property (in whole or in part) was connected, or when billing for service began, or when the sewer main was laid in the adjoining street. If the facility was operating before municipal sanitary sewerage service was available, then the waste must have been discharged to some type of on-site disposal system—an immediate potential concern.

Air Emissions

Air emissions are primarily a regulatory compliance issue; however, processes that generate air emissions may also generate wastes. For example, metal particulates captured in an air-pollution control device associated with a welding operation may be a hazardous waste. Filters associated with a spray painting operation may also constitute a hazardous waste.

Under rare circumstances, air emissions can result in soil contamination. The author assessed a plant located in Middlesex County, New Jersey, which manufactured heat-sensitive indicator labels that changed color upon exposure to specific temperatures, thereby indicating whether the treated objects had been adequately heat processed. An area of the property was conspicuously devoid of vegetation. This area was so distinct as to be visible on aerial photographs. The only feature associated with this barren area was the outfall of a roof drain. Process stacks and vents were present on the roof in the area tributary to the drain. The assessment concluded that particulates containing heavy metals were accumulating on the roof and being discharged to the ground via storm-water drainage, contaminating the soil beyond the tolerance of the vegetation.

Storm Water

Storm water may be the means by which a surface release can migrate, making it an item of interest. The presence and locations of storm-sewer inlets are important if transformers, ASTs, or chemical storage areas are located on the exterior grounds. The assessor needs to determine whether the inlets discharge to a creek, to a detention or retention basin, or another receptor.

Inlets with circular grates (particularly on Long Island, N.Y.) may be dry wells, especially when they occur in clusters. Commonly, dry wells on Long Island are intended to introduce as much storm water as possible to the subsurface in order to recharge freshwater aquifers and thereby discourage saltwater intrusion.

Wells

Two types of wells are of particular interest to the environmental assessor: dry wells and injection wells. Under certain circumstances, a water supply well may also be a concern.

A dry well is a large-diameter well (commonly a section of concrete storm-sewer pipe) that purposefully terminates above the water table so that it opens to unsaturated material that can accept the drainage. Its function is to deliver drainage (usually storm water) to the subsurface. Because they are direct and immediate conduits to the subsurface, dry wells are always an item of interest. The assessor must note whether a storm water dry well is located in the proximity of a transformer, an AST, a drum storage area, or another feature that could pose a concern in the event of a release. Some dry wells receive sewage directly, while others function as overflow receptors (see Figures 15–17).²⁷

Figure 15. Overflow dry well associated with a cesspool. Because the dry well's function is to dissipate its contents within the subsurface, it is a feature of immediate potential environmental concern if located at a commercial or industrial property. Diagram from Robert M. Starbuck, Questions and Answers on the Practice and Theory of Sanitary Plumbing, Vol. I, Drainage and Venting (Hartford, Conn.: R.M. Starbuck & Sons, Inc., 1954), p. 88.

Figure 16. Sewage dry well filled with percolating material. The vented filler material creates surface area within the void space of the well, in order to provide the opportunity for aeration and decomposition of organic waste. Diagram from Robert M. Starbuck, Questions and Answers on the Practice and Theory of Sanitary Plumbing, Vol. IV, Drainage and Venting. (Hartford, Conn.: R.M. Starbuck & Sons, Inc., 1954), p. 20.

Figure 17. Containment and discharge system for floor drainage from a hazardous materials storage room, c. 1958. Two floor drains are depicted, with a third drain set within a trench drain. "C.O." is a clean-out port (for removal of obstructions). The drains discharge to an underground separator tank. Overflow from the tank is discharged to a storm sewer inlet (M.H. = manhole). The 898.42-foot elevations noted at two of the floor drains and the 892.7-foot invert elevation, noted in the inlet, reflect the gradient necessary for gravity flow. See SIAN Fall 2005 for sectional diagram of the tank and a photograph of the tank pump-out port.

Dry wells for the removal and disposal of incidental spillage or leakage may be present inside a building. For example, some maintenance establishments are equipped with walk-down pits to provide mechanics and inspectors with access to the undersides of cars, trucks, buses, locomotives, and aircraft. Dry wells (and drains or sumps) may be present in the floors of maintenance pits, alignment pits, dynamometer pits, machine pits, or similar features.

Injection wells are similar to dry wells but are used for purposeful (not incidental) waste disposal. They are rare and are generally prohibited. A sump whose vertical dimension is greater than its horizontal dimension may be classified as an injection well under Environmental Protection Agency criteria, with all the accompanying regulatory complications.

The author assessed a facility located in Sedgwick County, Kansas, which manufactured actuators for aircraft. The proprietor operated a solvent reclamation still in an effort to reduce the quantity of hazardous waste being generated and the expense associated with its disposal. The author was alarmed when informed that cooling water (albeit noncontact) was circulated through coils in the still before being discharged to an unpermitted, 20-foot-deep injection well. The integrity of the coils had never been evaluated, and effluent had never been sampled for analysis. Although cooling water circulated under positive pressure, the opportunity remained for solvent to enter the cooling water system. Local geology consisted of porous and permeable riverine deposits, which would facilitate the rapid migration of contamination. The proprietor's defense—that the prior owner of the business installed the injection well—would not enable the current owner to escape liability.

Under rare circumstances, a water supply well can be the means by which contamination is introduced to an area that would otherwise have remained uncontaminated. An example is the small machine shop located in Bucks County, Pennsylvania, which the author assessed. In the absence of municipal services, the property had been developed with its own water well and septic system. Later, the aquifer was determined to be contaminated with chlorinated solvents, so the well was no longer used for potable supply. However, the water continued to be used for flushing toilets and for hand washing. The discharge of contaminated groundwater to the septic system resulted in contamination of the soil that would otherwise have remained unimpacted. Similar cases have involved irrigation wells used for landscaping purposes.

Phase I Environmental Assessment: Additional Considerations

The Subject Property

A given property consists of an area of land and the improvements (if any) located upon it. First to be established are the subject property's boundaries and the specific improvements that are subject to the EA. A property plan, site plan, plot plan, tax map, or some other depiction of the property's boundaries must be obtained.²⁸ Importantly, there may be a difference in ownership between the buildings and the lands. Any of the lands or buildings at a commercial property (especially a shopping mall property that includes outlots and detached outbuildings) may or may not be subject to the assessment, depending upon ownership and the assets involved in the transaction.

A good example of a complication due to differences in ownership is an auto service establishment occupying a nonsubject (occupant-owned) building that lies on subject (leased) land. In-ground hydraulic lifts, waste oil USTs, and oil-water separators are nonsubject improvements because they are components of the nonsubject building and are owned by the occupant, but they rest within subject land and may impact it. Such cases are good material for legal counsel.

Adjoining Properties

It is vitally important to consider the properties that adjoin the subject property. It is essential to learn whether contamination might have migrated onto the subject property from an off-property source via groundwater, storm-water runoff, or other means. This is important, not only in answering the basic question of whether contamination may be present but also in enabling liability for the contamination to be assigned to others. Under regulatory programs now in place in many states, the owner of a property that has been impacted by contamination that demonstrably originated as a release at an off-site location, on a property owned by others, is not liable for taking remedial actions. Under these programs, even a highly contaminated nonsource property can be bought and sold without liability on the part of the buyer or lender. However, obtaining a release of liability from the regulatory agency requires the completion of an investigation demonstrating that the on-property impacts are attributable to an off-property source.

Even if a property owner would not be liable because the contamination originated elsewhere, difficulties and liability may still arise. An example would be the construction of a new building that includes a basement and a subbasement. If the excavation encounters groundwater, it will probably need to be dewatered during the course of construction. The most expedient course of action would be to discharge the water to a creek or storm sewer. If the groundwater is contaminated, it may have to be containerized, transported, treated, and disposed of as a waste. The owner of the contaminated nonsource property may take legal action to recover costs, assuming the source can be legally established and assuming the responsible party still exists and has money or insurance. Continuing complications could arise if sumps located in the subbasement or elevator pits will collect and discharge the contaminated groundwater to the storm or sanitary sewer. The owner of the nonsource property has become exposed to liability because the contaminated groundwater was disturbed by capturing and redirecting it to a receptor.

Difficulty can also arise when the contamination at a property may have both onsite and offsite sources. Say groundwater at a property is contaminated with leaded gasoline and methyl tertiary butyl ether (MTBE), a gasoline additive that came into use during the late 1970s. A gasoline UST was located on the subject property during the 1960s, so the subject property cannot be excluded as a potential source. A service station has been located across the street from the 1960s until the present time at an up-gradient location. The subject property cannot be the sole source of the contamination; the service station is also a likely contributor. Apportionment of liability in this case would involve legal counsel and interaction with the regulatory agency.

Informers

If an employee offers to betray his or her employer, the assessor must proceed with care but should investigate the allegation. If the assessor determines that the employee did in fact disclose a potential concern, the assessor should try to protect the informer by stating in the report that the concern was discovered by the investigator.

An employee at an auto parts manufacturing plant located in Wayne County, Michigan, offered to show the author an unpermitted asbestos disposal area, located in the woods behind the plant. The waste was an experimental insulation for automobile air conditioning systems and dated from the early 1970s. The author did not ask for the employee's name and agreed that the employee would not be recognized in a lineup. The disposal area was confirmed but was cited in the report as having been discovered by the author. The client then acknowledged prior knowledge of the dump, which had been withheld from the assessor. The author appeared to the client to have done a thorough job, and the informer was protected.

A worker at a steel-rerolling mill in Venango County, Pennsylvania, told the author that drums containing waste were deliberately concealed in a particular building. Routine inspection confirmed the concealment of 110 drums of hazardous paint-related waste and nonhazardous oily waste. The worker then told the author about the burial of drums on the property—a potentially very serious issue, particularly because the plant adjoined a large stream. The buried drums were not revealed by other means of inspection, so the report could only attribute the alleged finding to an informer. Because this property had many environmental concerns, the loan was denied, the mill went into bankruptcy, and the author's employer was not paid.

Environmental vs. Regulatory

An environmental concern involves contamination of the environment. A regulatory concern does not necessarily involve actual contamination; it may be an administrative issue. For example, conventional photo-developing systems generate silver-containing waste. If the waste has been discharged to a septic system, it is a probable environmental concern because contamination has likely resulted. If the waste has always been discharged to the municipal sanitary sewer, but the sewerage authority requires a discharge permit or a silver-removal system that has not been obtained, it is only a regulatory concern.

ASTM vs. the Client and the Assessor

The American Society for Testing and Materials (ASTM) of West Conshohocken, Pennsylvania, has issued a standard (E1527–05) for Phase I Environmental Site Assessments.²⁹ However, any given client may have their own scope of work that is more stringent or less stringent than ASTM. Asbestos is not included in the standard.

Under the ASTM standard, a potential environmental concern is called a recognized environmental condition or a REC. The author would prefer the causative feature to be differentiated from the resultant condition. A REC that has been resolved (such as a leaking UST case that has received "no further action" approval from the regulatory agency) is called a historical recognized environmental condition. Use of the word "historical" in this term often causes confusion; many persons assume it means a REC that is associated with a historic structure or operation, rather than a former REC that is no longer a REC. To the author's further displeasure, the ASTM definition of an "adjoining" property includes a property that would be contiguous if not for the presence of an intervening public thoroughfare. The author prefers properties to be explicitly identified as contiguous or noncontiguous. An intervening street can have significant consequences: underground utility lines or the backfill in which they rest can capture and redirect shallow groundwater contrary to the apparent direction of groundwater flow.

Transformer Trickery

A trick that some owners play with old transformers is to replace the oil and immediately sample it for PCB analysis. The PCB concentration in such a sample will be low, of course, so the owner will readily offer those analytical results to the assessor. Residual PCBs always remain; they will mobilize through time and gradually become disseminated throughout the new oil. Analysis of a sample collected months or years after the oil has been changed will reveal a higher PCB concentration. This sample reveals the true PCB status of the transformer. To expose this deception, an assessor must learn the date on which the oil was changed as well as the date on which the sample was collected.

Mercury Miscellanea

Miscellaneous items of interest include switches, barometers, gauges, thermometers, and other industrial devices that contain elemental mercury. Mercury switches are the most common of these devices. In the industrial setting, the mercury-containing glass cylinders are most often located inside metal housings embossed with the trade name Mercoid Switch (The Mercoid Corporation of Chicago, Illinois). When exposed to air, mercury will slowly vaporize, requiring the use of a portable mercury vapor analyzer. It will also break into countless minute "blebs," which are very mobile and can become irretrievably incorporated into porous flooring (especially wood).

Dry Cleaners

Many, if not most, Phase I EAs involve commercial properties, many of which are shopping centers. Most shopping centers have or have had a dry cleaner—an immediate potential concern, due to the use of a chlorinated solvent (perchloroethylene or PCE).

The assessor must learn whether a dry cleaner is or was present. Such a determination can be difficult for a shopping center that has had hundreds of tenants in dozens of spaces over several decades. City directories are useful for identifying historic dry cleaners at shopping centers, but business names can be problematic. The assessor needs to know whether ABC Cleaners was just a drop-off/pick-up counter or whether dry cleaning actually took place there. Even confirmation that dry cleaning did take place at the property is still not enough. The assessor needs to determine which tenant space was occupied by the dry cleaner. A clue may be a small fuel oil UST outside the rear of a particular tenant space, since some dry cleaners used oil-fired boilers to generate steam for their garment presses (even if natural gas was used for space heating the building). Some laundromats are former dry cleaners whose proprietors converted to a simpler but related business. Old labels on fuse panels may identify dry cleaning machines. Old certificates of occupancy may locate a historic dry cleaner.

Dry cleaning machines generate waste solvent, solvent-contaminated condensate water, solvent-contaminated sludge, and solvent-contaminated lint. Collection vessels for the condensate are often open-top buckets that can overflow. Some proprietors treat and dispose of condensate through devices that consist of charcoal filters equipped with atomizers, but inadequate maintenance or careless use of these devices can result in contamination. Lint on the ground outside the rear of a dry cleaner may suggest that the proprietor has been hosing off the filters. If the shopping center is or has been equipped with a septic system, the presence of a dry cleaner is an even greater potential concern. Contamination is associated with the majority of dry cleaning establishments. Dry cleaners are so problematic that some state regulatory agencies have established registry databases and programs for them, and the State of California is in the process of banning PCE dry cleaning machines.

Rarities and Oddities

On rare occasions, the assessor may encounter a floor that consists of small crosscut wood blocks, measuring approximately 4 by 4 in., underlain by sand on a concrete slab. In 18 years of fieldwork, the author has seen these blocks at only two facilities (located in Pennsylvania and Ohio), both of which manufactured small metal parts and dated from the 1940s and 1950s. The idea was to prevent the damage that would have occurred to finely machined tools and dies, had they fallen on a concrete floor. In order to discourage fungus and insects, these blocks were treated with a preservative (typically copper, chromium, and arsenic) at the time of their manufacture. If slated for removal and disposal, the blocks should be analyzed for heavy metals, PCBs, semivolatile organic compounds, and arsenic.

Although uncommon, a certain type of transformer coolant can actually pose a greater potential concern than the PCBs it was intended to replace. The author has encountered transformers that were manufactured during the 1980s by Niagara Transformer Corporation of Buffalo, New York, and cooled by Nirasol—a coolant manufactured by Diamond Shamrock Corporation under the trade name Perclene TG.³⁰ It consists of transformer-grade PCE. Although a release of PCB-containing fluid would constitute a concern, transformer oil is a relatively heavy substance that is not especially mobile in the environment and will penetrate only a shallow depth into a concrete floor. PCE, however, can pass through concrete and is relatively mobile. A release of Nirasol might actually constitute a greater concern than a release of PCB fluid.

Forbidden Words and Careful Writing

Any, all, ever—these words should not be used in a report. Rarely, if ever, will the assessor have sufficient time, information, access, and budget to draw such absolute conclusions. If a dispute arises, opposing legal counsel will seize upon such wording.
Sewage, sewer, and sewerage—these words should not be used interchangeably. Sewage is the waste. A sewer is the pipe that carries the waste. Sewerage is the network of sewers or the provision of this service. For example, sewage generated at the subject property is discharged to the sanitary sewer located beneath Main Street, which is a component of the municipal sanitary sewerage system.
State what was observed—findings must be carefully worded. If a report notes that no transformers were observed on the subject property, the statement is still true even if many transformers are later discovered to be present. The assessor did not see the transformers and, thus, made an error. If, however, the report stated that no transformers were present on the subject property, then, upon discovery of transformers, the statement becomes indefensibly wrong.

Personal and Professional Ethics and Interests

The type of client can greatly affect the ethical arena in which the assessor is working. Clients who manufacture a product usually have an understanding of the material world and may have experienced interaction with regulatory agencies. If a potential concern is identified, a manufacturing client will ask to see the evidence. If the evidence is valid, the client will usually concede the point. Financial institutions, however, have a one-dimensional perspective (money); they may attempt to influence the assessor and reduce any conclusions or recommendations. This pressure can affect the assessor's personal and professional ethics.

Unfortunately, in the practice of environmental due diligence, industrial archaeology is only a means to an end. An environmental assessor who has an interest in industrial archaeology may be at a paradoxical disadvantage. The data objectives and results are concerned with industrial history only so far as they do or do not reveal a financial liability. The director of a county redevelopment authority was aware of the author's familiarity with a certain industrial site; the author had recently published a journal article about the site, and the director had purchased and distributed copies of the journal to various officials. The author even attended the dedication of a redeveloped portion of the site at the director's invitation. Nevertheless, the author's proposal for environmental work at the remainder of the site was not accepted, despite the fact that the author's employer was qualified and experienced. Perhaps the director was concerned that the author might delay the redevelopment effort and increase its costs by promoting the preservation of certain historic structures.

Conclusions

Industrial archaeology has application in the commercial world, which provides gainful employment to engineers and scientists from multiple disciplines. Environmental assessment work can provide students of industrial archaeology with legal and timely site access and with historical information that they may find personally and professionally rewarding.

Notes

^1.� Victor Dallin, "Aerial Photograph of Philadelphia, PA, Taken May 14, 1926" (Location unknown: Dallin Aerial Surveys, 1926).

^2.�Block Plan, Sun Shipbuilding Co., Chester, PA, drawing No. P.E.30-C, Department No. 82, Sketch No. 9010-AG-17 (Chester, Penn.: Sun Shipbuilding Company, 16 Dec. 1916); Merchant Shipbuilding Corp., Bristol, PA, Location of Water and Steam Lines, Oil and Suction Lines, No. K-195 (Bristol, Penn.: Merchant Shipbuilding Corp., 28 Jun. 1918); The Wm. Cramp & Sons S. & E.B. Co., Power and Plant Dep't., General Plan of Property Showing Building Numbers, File P-2356 (Philadelphia, Penn.: William Cramp & Sons Ship & Engine Building Co., 3 Apr. 1932).

^3.�Pennsylvania-New Jersey, Philadelphia Quadrangle, surveyed 1894 (Washington, DC: U.S. Geological Survey, Apr. 1898, reprint Aug. 1908); New Jersey-New York, Paterson Sheet, surveyed 1887, 1889, and 1897 (Washington, DC: U.S. Geological Survey, Feb. 1903, reprint Oct. 1909); New York, Brooklyn Quadrangle, surveyed 1888–89 and 1897 (Washington, DC: U.S. Geological Survey, Feb. 1900, reprint Nov. 1908).

^4.�Topographic and Geologic Atlas of Pennsylvania No. 27, Pittsburgh Quadrangle (Harrisburg, Penn.: Dept. of Internal Affairs, 1929), 236 pp.; Geology and Mineral Resources of the Honeybrook and Phoenixville Quadrangles, Pennsylvania, Geological Survey Bulletin, no. 891 (Washington, DC: Department of the Interior, 1938), 145 pp.; Topographic and Geologic Atlas of Pennsylvania No. 5, New Castle Quadrangle (Harrisburg, Penn.: Department of Internal Affairs, 1929), 238 pp.

^5.�Insurance Map of Boston, Massachusetts, Including Breed's Island, East Boston and Charlestown, Vol. 5 (Pelham, N.Y.: Sanborn Map Co., 1927, revised May 1932), 64 pp.

^6.�Atlas of the City of Philadelphia, 23rd and 41st Wards (Philadelphia, Penn.: G.W. Bromley & Co., 1920), 30 plates; Real Estate Atlas of the Cities of East Orange and Orange, and the Town of West Orange, N.J. (Philadelphia, Penn.: Franklin Survey Co., 1932), 37 plates; Manhattan Land Book (New York, N.Y.: G.W. Bromley & Co., 1934), 188 plates.

^7.�Delaware River, Philadelphia, PA., to Trenton, N.J., navigation charts, 16 Nov. 1921, drawer 61, folder C, file No. 5873, U.S. Engineer Office, Philadelphia, Penn., 12 sheets; Delaware River, Philadelphia to Delaware Bay, Survey of 1942, navigation charts, 30 Apr. 1943, drawer 356, file No. 17103, U.S. Engineer Office, Philadelphia, Penn., and U.S. Army Map Service, Washington, DC, 12 sheets; Delaware River, Philadelphia to Trenton, Survey of 1951, 29 Jun. 1951, drawer 324, drawing nos. 25000—25011, U.S. Army Corps of Engineers, Philadelphia, Penn., 11 sheets.

^8.�Map of a Part of the City of Philadelphia and the Delaware and Schuylkill Rivers within the City Limits, Philadelphia (Philadelphia, Penn.: Dept. of Wharves, Docks and Ferries and the Port of Philadelphia Ocean Traffic Bureau, 1923); Plan of Fort Mifflin Shipbuilding Company, Philadelphia, Penna (Philadelphia, Penn.: Fort Mifflin Shipbuilding Co., 24 Jul. 1917) [plan accompanying common stock offering].

^9.�1944 Honesdale, PA. Directory Including Hawley and White Mills (Binghamton, N.Y.: Calkin-Kelly Directory Co., 1944), 221 pp.; The Greater New Haven Directory Including West Haven, East Haven, North Haven, Hamden (New Haven, Conn.: Price & Lee Co., 1937), 1,022 pp.; Heidingfeld's General Directory of New Brunswick [New Jersey] Including Highland Park (New York, N.Y.: R.L. Polk & Co., Inc., 1917), 788 pp.

^10.�Rockland County, New York, Town of Tuxedo, Orange County, and Neighboring Places Telephone Directory (n.p.: New York Telephone Co., Summer 1927), 176 pp.; Telephone Directory, Norristown and Vicinity (Philadelphia, Penn.: Bell Telephone of Pennsylvania, Fall 1932), 232 pp.; Telephone Directory, Trenton District (Newark, N.J.: New Jersey Bell Telephone Co., Sept. 1937), 110 pp.

^11.�Plant-Production Directory (Chicago, Ill.: Conover-Mast, Spring 1943), 852 pp.; Donnelley's Industrial Directory of the Eastern District (New York, N.Y.: Reuben H. Donnelley Corp., 1930), 412 pp.; Pennsylvania State Manufacturers & Industrial Classified Telephone Directory and Buyers Guide (Philadelphia, Penn.: Bell Directory Publishers, 1939), 70 pp.

^12.�Philadelphia Real Estate Directory and Service, 1926–1927 (Philadelphia, Penn.: Philadelphia Real Estate Directory Inc.), 1704 pp.

^13.�The Chester Compass, vol. 3 (Chester, Penn.: Chester Shipbuilding Co. Ltd., 1919), 32 pp.; Taylor-Wharton Team Work, vol. 3 (Easton, Penn.: Taylor-Wharton Iron & Steel Co., 1920), 24 pp.; York Ship News, vol. 3 (Camden, N.J.: New York Shipbuilding Corp., 1921), 24 pp.; The Disston Crucible, vol. 10 (Philadelphia, Penn.: Henry Disston & Sons, Inc., 1921), 14 pp.

^14.�Tool Steel Simplified (Reading, Penn.: Carpenter Steel Co., 1937), 316 pp.

^15.� "Report of the Chief of Real Estate Service," War Department Annual Reports, (Washington, DC: War Department, 1919, Vol. I, Part 4, 1920), 4447–4658; U.S. Shipping Board Emergency Fleet Corporation, Hearing Before the Committee on Commerce, United States Senate, Sixty-fifth Congress, Third Session, [Pursuant to S. Res. 170, Directing the Committee on Commerce to Investigate All Matters Connected with the Building of Merchant Vessels under the Direction of the United States Shipping Board Emergency Fleet Corporation and Report Its Findings to the Senate, Together with Its Recommendations] Thereon (Washington, DC: GPO, 1919).

^16.�Cramp's Shipyard 1830–1902 (Philadelphia, Penn.: William Cramp & Sons Ship & Engine Building Co., 1902), 180 pp.; Sun Ship (Chester, Penn.: Sun Shipbuilding and Dry Dock Co., 1946), 95 pp.; 50 Years: New York Shipbuilding Corporation (Camden, N.J.: New York Shipbuilding Corp., 1949), 79 pp.