Are Electric Transformers A Recognized Environmental Condition?

Electric transformers are found at almost every larger commercial, institutional and industrial facility. Sometimes this equipment is owned by the facility owner and sometimes by the power company. For some facilities, it is not always clearly understood who owns and is responsible for transformers.

Can Electric Transformers Leak Oil?

Yes, electric transformers can leak oil, but only if they actually contain oil.

How Can I Tell If Electric Transformer Contains Oil?

For newer transformers, the quantity of oil in the unit is usually found on the label. For older equipment, this information may not be on the label, or the label may have been removed or is illegible. In this case, a visual inspection of the equipment by a knowledgeable person can usually determine if it contains oil or not.     Not sure?   Send Caltha a photo and we may be able to determine this - send to info@calthacompany.com

Who Is Responsible To Clean Up Leaks From Transformers?

This will depend on State laws. In general, the Owner of the equipment is responsible. However, for a property owner whose property has been impacted by a leaking transformer, the issue could affect the value of the property and they may voluntarily elect to clean up leaks.

What Are The Environmental Risks For Electric Transformers?

A risk for oil spills exists for any oil-filled transformer. Older transformers commonly contained PCB oils. Use of PCB oils has been phased out and newer equipment is often labeled "No PBC"; however older electric transformers could still contain PCBs which makes clean up more involved.

Leaks can occur over long periods and accumulate slowly. The other risk is an emergency spill caused by a fire or the transformer being damaged by vehicles, etc. These risks are minimized by ensuring equipment is included in pollution prevention plans and spill plans (such as SWPPP, SPCC Plan or other spill plans) and is regularly inspected and maintained. Whether or not an individual transformer is a Recognized Environmental Condition will be determined by the Environmental Professional after considering these factors.

Typical Leaking Electric Transformer

How Long Does It Take To Do A Phase I?

This is one of the most common questions we receive.

How Long Does It Take To Do A Phase 1?

Answer: 10 business days for the vast majority of Phase 1 Environmental Site Assessments. There are a few situations where additional time may be required:

• Property owner does not allow timely access to the property for an on-site inspection,
• There are old issues on a property, such as leaking tanks, and the owner can not provide reports or other documentation to determine residual risks for the property. In this case a physical review of agency files may be required.

Fortunately, these types of situations are not encountered frequently and most Phase I assessments are completed within 2 weeks.

What Does A Phase 2 Environmental Assessment Do?

What Is A Phase II Environmental Site Assessment?

A Phase 2 Environmental Site Assessment follows a Phase 1 Environmental Site Assessment and investigates the Recognized Environmental Conditions, or REC, identified in the Phase 1 report. A Phase 2 investigation (sometimes referred to as a Limited Site Investigation or LSI) is intended to confirm the presence or absence of actual chemical or petroleum releases from each of the REC listed in the Phase 1 report. If no RECs were found during the Phase 1 ESA, then a Phase 2 investigation would not be needed.

 In most cases, the Phase 2 Environmental Site Investigation will collect soil, groundwater or soil vapor samples near the locations of the RECs. Samples are then sent to a laboratory for chemical analysis. The Phase 2 is considered a "limited" site investigation because the scope to limited to investigating the presence or absence of actual chemical or petroleum releases from each of the REC listed in the Phase 1 report.

Abandoned Underground Tanks Marked 

During Phase 2 Site Investigation

 If no indications of chemical or petroleum releases are found, then the site investigation ends. If the results show that some releases have occurred, State and Federal laws may require reporting to the appropriate agencies. In this case further investigation may be required to determine the magnitude and extent of the contamination and to determine if site remediation is needed. The subsequent investigations are sometimes referred to as Phase 3 Environmental Site Assessments and are not typically included during Phase 2 investigations.

What is A Recognized Environmental Condition? What Is A REC?

What is A Recognized Environmental Condition?

A Phase I Environmental Site Assessment conducted to meet ASTM E 1527:2013 is intended to identify Recognized Environmental Conditions, or REC, associated with a property. Simply, a REC is a condition in which a spill, leak or other type of release to the environment or inside a structure has occurred, has potentially occurred or has a reasonable threat of occurrence in the future. It could be a condition that is visible at the site, such as staining around a fueling areas, or conditions no longer present, such as historical maps indicating a gas station was once present on the property.

Bulged Chemical Drums Abandoned On Property

 ASTM E 1527:2013 defines a Recognized Environmental Condition as: "the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment. The term does not include de minimis conditions that a condition that generally does not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies."

Active Industrial Waste Burn Pit Identified 

During Phase 1 Environmental Inspection

 Under the current ASTM standard, three categories of RECs are established:

• Current Recognized Environmental Conditions
• Historical Recognized Environmental Conditions, and
• Controlled Recognized Environmental Conditions

Ottumwa, Iowa Phase I Environmental Site Assessment

Caltha LLP Project Summary

Project: Phase 1 Environmental Site Assessment 
Client: Property Developer
Location(s): Ottumwa, Iowa

Key Elements: ASTM Phase 1 Environmental Site Assessment, Tier I Vapor Encroachment Screening Assessment, ASTM E2600-10

Overview:

Caltha conducted an Phase 1 Environmental Site Assessment meeting the requirements of E 1527:13 and "All Appropriate Inquiry". The property was a multifamily residential development located near Ottumwa, IA. The assessment included reviews of historical maps, aerial photographs, owner and site manager interviews and a review of regulatory databases. The on-site inspection identified no Recognized Environmental Conditions (REC) including the potential for soil vapor intrusion risks.

Click here to review other example Caltha environmental site assessment projects. Click here to review other Caltha projects in Iowa and IDNR regulatory updates.

Minneapolis-St Paul Area Metals Factory Phase 1 Environmental Assessment

Caltha LLP Project Summary

Project: Phase 1 Environmental Site Assessment 

Client: Developer 

Location(s): Saint Paul, Minnesota

Key Elements: ASTM Phase 1 Environmental Site Assessment, Tier I Vapor Encroachment Screening Assessment, ASTM E2600-10

Overview:

Caltha conducted an Phase 1 Environmental Site Assessment meeting the requirements of E 1527:15 and "All Appropriate Inquiry". The site was the location for a historical metal products factory dating at least since 1925 and was later converted to a plastics factory. The assessment included reviews of historical maps which documented site development over a 90 year period and the locations of key industrial equipment and processes, and storage locations for fuels. The on-site inspection identified other Recognized Environmental Conditions (REC) related to waste disposal systems and underground hydraulic systems. Current and historic issues were also identified as potential soil vapor intrusion risks.

Improper Waste Storage Observed 

During Phase 1 Environmental Investigation

Click here to review other example Caltha environmental site assessment projects. Click here to review other Caltha projects in Minnesota and MPCA regulatory updates.

Minnesota Based Environmental Consultant For Site Cleanup and Investigations

Minnesota-based Environmental Consulting Firm

Caltha LLP, a Minnesota headquartered environmental assessment company, investigates the sources of contamination and remediates them. The Minnesota Pollution Control Agency and Minnesota Department of Health has recognized soil contaminates to be an environmental issue with potential health impacts. Soil pollutants such as lead, cadmium, polycyclic aromatic hydrocarbons, arsenic, asbestos, and petroleum-related products can be found in urban and rural sites across Minnesota. As a result, parties that buy or sell commercial or industrial property in Minnesota are urged to complete an environmental site assessment as part of their due diligence and mitigate potential liability.

If past spills or leaks are found, remediation services may be required. Caltha LLP is a trusted environmental consulting and engineering firm serving Minnesota with Phase I and Phase II site assessments and remediation services. Led by a member of our experienced staff, your environmental site assessment and remediation will be streamlined and completed thoroughly, thoughtfully, and to minimize current and future costs.

We perform Phase I and Phase II environmental site assessments and remediation work across Minnesota, including:

Minneapolis	St. Paul	Rochester	Duluth	Bloomington
Brooklyn Park	Plymouth	Woodbury	Eagan	Maple Grove
Coon Rapids	Blaine	Eden Prairie	Burnsville	Lakeville
St. Cloud	Apple Valley	Minnetonka	Edina	St. Louis Park
Moorhead	Mankato	Maplewood	Shakopee	Cottage Grove

Oil Contaminated Soil Left On Property 

Observed During Phase 1 ESA

Minnesota Environmental Firm Performs Vapor Intrusion Assessments

A vapor intrusion screening and soil vapor sampling has become a crucial component of Phase I and Phase II environmental site assessments. Volatile organic compounds migrate through soil and groundwater and can potentially form harmful gases which can migrate into buildings, similar to radon gas. Soil vapor mitigation eliminates a key environmental liability and when needed is an component of our site remediation services.

Leaking Tank And Fuel Pump 

At Rural Minnesota Property

Minnesota-based Consultant With MPCA, MDH, MDA and Local Agency Knowledge

Caltha LLP maintains close ties with the key State and local agencies that oversee waste management and contaminated site cleanup. In Minnesota, most environmental laws and regulations fall under the authority of the Minnesota Pollution Control Agency. The MPCA provides businesses with a wide variety of programs and resources to comply with environmental regulations. The Minnesota Department of Health also plays an important role in reviewing and setting health-based cleanup goals used by MPCA. Many projects to investigate and cleanup contaminated sites are managed through two MPCA programs, the Voluntary Investigation & Cleanup (VIC) and Petroleum Brownfields Program (PBP)

 The Minnesota Department of Agriculture (MDA) also has voluntary programs which effectively help farms and agrichemical businesses follow best practices to protect the environment. The MDA has a similar voluntary program to assess in the investigation and cleanup of agricultural chemical spills and leaks.

  Click here to request further information or to get a quote for services.

Compliance audit and Environmental Assessment in Minnesota, Arizona, California

Caltha LLP Project Summary

Project: Pre-Acquisition Due Diligence Assessment
Client: International Food Manufacturer
Location(s): California, Arizona, Minnesota

Key Elements: Phase 1 ESA; Compliance audit

Overview: This project was performed for a Minnesota-based international food manufacturer and was coordinated through a Minneapolis-based law firm. The scope of the assessment was to perform environmental due diligence for multiple facilities located in California and Arizona they intended to acquire, and comprised of a Phase 1 Environmental Site Assessment, performed in accordance with ASTM 1527-13, and a compliance audit to assess the current compliance of existing equipment and operations with applicable State and Federal regulations. Numerous compliance issues and Recognized Environmental Conditions were identified. Caltha staff provided technical support to estimate the potential costs associated with corrective actions required. Caltha also provide technical support to coordinating law firm in developing contract documents and purchase agreements that address environmental issues identified during the assessments.

Click here for more Caltha project examples related to remediation, including site assessments, response action plans and site remediation.
Click on the State to review more project examples for facilities located in in that State and State regulatory updates: AZ, CA, MN .

Phase 1 Environmental and Compliance Audit At Racine, Milwaukee Sites

Caltha LLP Project Summary

Project: Environmental Due Diligence, Phase 1 ESA and Compliance Assessment For Operations Near Racine, Wisconsin
Client: Real Estate Holding Company
Location(s): Wisconsin

Key Elements: Pre-acquisition Due Diligence, Phase I Environmental Assessment, Permit Review

Overview: Caltha was retained by this Real Estate Holding Company to conduct environmental due diligence of three properties located near Racine and Milwaukee, Wisconsin which they intended to acquire and continue to operate. Caltha staff conducted a Phase 1 ESA in accordance with ASTM standard practice E 1527-13. The ESA was augmented with a review of business risks associated with the acquisition and operation of these three existing businesses. Although no Recognized Environmental Conditions were identified, several business risks were revealed, including lack of spill prevention and control measures required under Federal rules, and lack of a State air emission permit for certain VOC emitting sources. Caltha recommended that both deficiencies be addressed prior to closing.

 Click here for more Caltha project examples related to due diligence audits and compliance audits. Click here to review more project examples for facilities located in Wisconsin and Wisconsin regulatory updates.

New Requirements For SBA Environmental Assessment In 2018

On October 13, 2017, the Small Business Administration (SBA) released a revision to its Standard Operating Procedure (SOP) 50 10 5(J), Lender and Development Company Loan Programs. This revision made several amendments to the SBA environmental policies which became effective on January 1, 2018.

Some of the key changes are:
Appendix 2 – Definitions – SBA has updated the following definitions:

• Environmental Questionnaire,
• Phase I Environmental Site Assessment (Phase I ESA),
• Records Search with Risk Assessment,
• Reliance Letter, and
• SBA Environmental Indemnification Agreement.

Appendix 3 – Reliance Letter - SBA has revised the language in the Reliance Letter to conform to the updates to the environmental policies made in Subparts B and C.

Appendix 4 – NAICS Codes of Environmentally Sensitive Industries
1. Updated the following NAICS codes: 316 – Leather & Allied Product Manufacturing, 326 – Plastics & Rubber Products Manufacturing, 332 – Fabricated Metal Product Manufacturing, 8122 – Death Care Services, and 56171 – Exterminating & Pest Control.

2. Added the following NAICS Codes: 484 - Trucking (if service bays, truck washing, or fuel tanks present and 713990 Other Recreational Industries (indoor and outdoor shooting ranges only).

Appendix 5 – Requirements Pertaining to Gas Station Loans – SBA updated this appendix for clarity.

Soil - Groundwater Site Investigation of Minnesota Commercial Real Estate

Caltha LLP Project Summary

Project: Phase 2 Site Investigation Prior To Commercial Site Redevelopment
Client: National Retailer 
Location(s): Minneapolis - Saint Paul Area, Minnesota

Key Elements: Phase 2 Site investigation, Groundwater sampling, Soil sampling

Overview: Caltha LLP conducted a Phase 2 Limited Site Investigation for this commercial property located in the suburban Minneapolis - Saint Paul Area. A Phase 1 assessment had determined a higher risk for groundwater impacts on the property due to known groundwater contamination at a nearby property. This commercial property located in the Twin Cities Metro Area was previously developed and the prospective purchaser intended to renovate existing buildings and to construct several new buildings on this mixed use site. The results of the investigation determined that low levels of solvents were present in groundwater on the site. The presence of the impacted groundwater was addressed during redevelopment of the site.

Click here for more information on Caltha's Environmental Assessment Services for commercial and industrial property transfer.