Statement of Qualifications for Indoor Air Quality Services
In the last few years complaints of indoor air quality issues, including mold growth, in both residential and commercial buildings have drastically risen. However, the lack of indoor air quality regulations or standards has created confusion about how much mold is ‘normal’ and what levels are safe. Environmental Management Group (EMG) staff has been investigating mold-related issues since 1997 and based upon on our experiences, we have developed a phased approach to evaluating and remediating mold-contaminated buildings to reasonable and appropriate levels. We have successfully used our approach at hundreds of properties nationwide for insurance companies, financial institutions, attorneys, developers, contractors, homeowners, and building owners.
Investigation and Protocol Development
The first step in assessing the source and extent of microbial contamination is to conduct a thorough investigation at the building. Investigations can be as simple as observing readily accessible areas, or as complex as utilizing state-of-the-art video-capture boroscopes to access wall cavities, heating, ventilating and air conditioning (HVAC) ducts, and/or subfloor areas. EMG personnel are trained, certified and experienced in conducting all levels of microbial investigation from small residences to large, multi-story, commercial buildings.
In addition, EMG can prepare a management/remediation protocol or work plan that can be implemented to mitigate any level of contamination. Our work plans are thorough, step-by-step guides to remediating the property. EMG work plans include both a detailed scope of work and cleanup criteria to be attained, which are appropriate to the building use. Specialty, certified remediation contractors can use our work plans to easily prepare their cost estimates for remediation. However, not all projects require a work plan. Many of our clients are able to manage the mold contamination or water damage present in their buildings without extensive remediation or treatment. For these clients, EMG prepares protocols or management plans specific to the site and in terms understandable to facility personnel. If necessary, EMG also provides flexible and ‘hands-on’ training for facility personnel on the implementation of the management plan.
We have provided a few brief descriptions of some of our projects where EMG has conducted microbial investigations and developed a protocol for managing or mitigating the contamination.
Confidential Client, Community Recreation Center, St. George, UT
-January 2003
When visible microbial contamination was noted on the interior surfaces of an indoor pool building, EMG was contracted by the developer to evaluate if the amount present was safe for residents and to determine if removal was feasible (if necessary). EMG conducted an extensive evaluation of the building, including attic spaces, to assess the cause of the elevated microbial activity. Based on the findings from the assessment, EMG provided the owner with a Mold Management Plan to assist in maintaining the mold levels below a safe threshold. Part of the mold management plan was to implement a periodic treatment process, which reduced the background levels of mold, enabling the facility to manage the mold reoccurrence in the high-humidity environment, without the need for remediation, demolition, or renovation.
Confidential Client, Hospital, Delano, CA
-March 2002
During renovation activities, areas within the hospital were found to contain visible mold. As such, EMG was contracted to conduct a complete mold evaluation within the hospital, including operating and emergency rooms. This investigation was completed in a manner that had no disruption to the operation of the hospital, or to its patients.
Based upon the results of the assessment, EMG worked with the facility staff of the hospital to develop a Mold Management Plan, which provided guidelines and recommended procedural changes of the hospital operations to reduce the bioburden within the entire facility, as low as reasonably achievable.
Nationwide Insurance, Private Residence, New Albany, OH
-Jan 2001
Due to a flood in the finished lower level of this executive-level private residence, EMG was contracted to investigate the nature and extent of potential mold contamination, and to assess the related damage to the structure and contents.
Based upon the results of the investigation, EMG provided a site-specific Microbial Remediation Work Plan, detailing the areas to be contained and remediated and the appropriate methods to accomplish the recommended clearance criteria. In addition, EMG included a cost matrix for the affected contents, depicting the ‘cost-to-clean’ versus ‘cost-to-replace’ comparison.
Remediation and Treatment
When our client cannot mitigate the extent of water intrusion and resulting microbial growth on his own, EMG implements the second phase of microbial services - remediation and treatment services. Remediation typically includes establishing appropriate environmental containments, removal of contents, methodical demolition of overly contaminated building materials, and subsequent physical removal of the mold by sanding, High Efficiency Particulate Air (HEPA) filter vacuuming and/or hand wiping with an appropriate biocide. EMG has a network of specialty, certified, remediation contractors that can provide these services. If requested by the client, EMG is able to provide the remediation services in-house, as well.
Our staff has conducted microbial remediation and treatment at hundreds of properties nationwide. Summaries of some of our projects are provided below.
Confidential Client, Hotel, Jackson, MS
-November 2003
EMG provided microbial remediation and treatment of a seven-story hotel in Jackson, MS. Failure of the Exterior Finish Insulating System (EFIS) caused water to intrude into one wing of the building. The water intrusion caused extensive mold contamination on five of the seven floors. Others originally initiated remediation of the mold, however during remedial activities it became apparent that the activities were not being properly implemented. Therefore, the building owner sought out EMG to assess the status of the remediation, support negotiations in settling the insurance claim, coordinate remediation completion, and to provide microbial treatment services. EMG provided the services requested by the client and completed the project to ensure that facility operations safely continued without interruption.
Confidential Client, Nursing Home, Houston, TX
-October 2003
During construction of the nursing home, a storm event flooded one wing of the single story facility. Inappropriate mitigation of the water intrusion led to the development of visible mold on the finished interior surfaces. However, the mold did not manifest itself until after the facility was opened and occupied.
At the request of the building owner, EMG provided a very discreet microbial investigation to assess the level and extent of the contamination. Based on the results of the investigation, EMG coordinated the remediation of mold by an approved specialty contractor. Following remediation EMG provided post-remediation clearance sampling and reporting.
EMG was able to complete this complex project within the timeframe specified by the client (< 1 week) and without disruption of facility operations or displacement of facility residents.
Bank One, Steeple Chase Condominiums, Walton, KY
-Oct 2003
Subsequently, a leak occurred in the vacant building, flooding all areas of each floor. The water sat in the building for approximately four months before discovery of the ensuing water damage and mold contamination. The damage from mold and water was so extensive that drywall ceilings had fallen to the floor, many wooden framing members on the bottom level had become brittle, doors had swollen shut, and visible mold was present on almost every surface. Prior to EMG’s involvement, the county building department condemned the building.
EMG was contracted by the bank to facilitate the preliminary investigation and microbial remediation cost estimates. EMG also coordinated the remediation and treatment activities, which were completed within the two-month schedule and on budget. The project aggressively passed the post-remediation inspection requirement stated in the work plan. Once the post-remediation inspection has passed, EMG and the remediation contractor arranged for an immediate inspection of the property by the county building department. Based on that inspection the county cleared the building for re-construction. In conclusion, EMG both provided the bank with a clean and safe building and strived to ensure that the appropriate building permits could be sought, unhindered, by any future buyers.
SC Anderson Inc., Middle School, Carpenteria, CA
-December 2001
While the historic school building was undergoing extensive renovation, a severe rain event blew the temporary roofing off and flooded the entire structure. The flood elevated the interior humidity within the building to a level that accelerated the growth of mold on many surfaces.
EMG worked to minimize the school schedule and monetary impacts of the flood while coordinating drying of the building and assessing the extent of the microbial contamination. Upon completion of drying the structure and performing the microbial assessment, EMG developed a detailed, site-specific microbial remediation work plan. The work plan was used by the specialty remediation contractor to remove the mold to a post-remediation criteria level confirmed by EMG. EMG managed the project such that this work was accomplished within the general contractor already tight construction schedule, therefore minimizing the time impact that the flood had on the overall project.
Other Microbial Services
In addition to our traditional indoor air quality services, EMG provides Expert Witness/Litigation Support, Emergency Response, Training, and Property Purchase/Liability Transfer. Descriptions of some of our recent projects entailing these services are provided below.
Expert Witness/Litigation Support
Based on our experience in providing quality microbial investigation and remediation services, EMG personnel have served as expert witnesses for several of our clients. As a result of our reputation, EMG has been sought out by litigation attorneys to assist in evaluating the mold-associated risks for their clients. Some of our expert witness and litigation support projects are described below.
Confidential Client, Exclusive Resort, CA
-July 2003
Design and construction failures at the building exterior resulted in severe water intrusion into each building in this multi-building, newly constructed resort.
Throughout the insurance investigation and arbitration proceedings, EMG continues to provide technical expertise on behalf of the resort owner. EMG’s services include performing an in-depth microbial assessment of the contaminant levels present throughout the complex. Our activities have been conducted in strict coordination with structural engineers and building envelope specialists in order to draw concrete, scientific conclusion as to the source and extent of the microbial contamination.
Confidential Client, Apartment Complex, Chandler, AZ
-Feb 2003
EMG provided litigation support to a party in a suite for harm from an undisclosed exposure to excessive mold levels. This included review of expert reports, coordination of facts, and over 10 hours of testimony. Due in large part to EMG’s testimony, the jury found in favor of our client.
Confidential Client, Commercial Building, Phoenix, AZ
-Jan 2001
EMG provided litigation support to a party in a suit for bad faith, non-payment, and subrogation of an insurance claim subsequent to a 2.5 Million dollar mold remediation project. This included review of expert reports, coordination of facts, and direct testimony.
Emergency Response
When a large water intrusion occurs, it is imperative that the affected areas be immediately and properly dried. Many of our clients have experienced the resulting mold growth that occurs if water intrusions are not appropriately mitigated. EMG has provided emergency response services to many of our clients. Our experienced team can coordinate large-scale drying, contents removal, and interior demolition within hours of arriving onsite.
Confidential Client, Forensic Crime Lab, Bakersfield, CA
-Feb 2002
While laboratory personnel were at lunch a fire broke out in a trashcan of a fourth floor laboratory causing the sprinkler system to initiate and thereby partially flooding three floors of the building. EMG responded to the site within two hours of the fire and coordinated the mobilization of trailer mounted commercial desiccant drying equipment (which was running within 12 hours), shutting down of the appropriate areas of the HVAC system, movement of affected personnel, and protection of contents, computers, and paperwork. Due to the quick response, the affect of the water and resultant mold growth, soot, and smoke was greatly minimized saving over a million dollars in potential damage and more than two months of productive work from the displaced workers.
Training
EMG has been sought out by various professional associations, private and non-profit corporations, educational institutions, and levels of government to provide training and education courses on indoor air quality, mold, and microbial investigation/remediation. EMG has participated in training services to over fifty clients throughout the United States. Some of the more recent training courses are included below.
American Society of Professional Education, Training, CA NV MO OH
-Summer 2003
EMG teamed with several law firms to provide mold awareness and management training at nine locations throughout the US. This training provided an overview of the biology of mold, hands-on problem identification/mitigation/resolution, and techniques to prevent litigation.
New Home Builders Conference, Training, Las Vegas, NV
-September 2003
For the fourth consecutive year, EMG participated as a speaker to over 300 people, at the conference for new-home builders and developers.
Southern Utah Home Builders Association, Training, St. George, UT
-October 2003
EMG, for the second year, was requested to provide mold and indoor air quality training to developers and builders. This training focused on molds affects on the construction industry.
City of Tempe, Training, Tempe, AZ
-February 2001
EMG developed a Mold Management Training Program, which provided city facility management personnel the information necessary for in-situ mold minimization, management, and removal.
Internet Business-to-Business Project Management
EMG offers the flexibility of managing projects using a secure direct-user interface from the EMG web page (www.environmentalmanagementgroup.com). By logging onto client-specific areas using a user identification and password, clients can view summary account information, project reports, site photographs, analytical data, and other project deliverables. In addition, clients are able to update company profile information and to instantaneously request EMG services, anywhere in the country.
Statement of Qualifications for Environmental Services
Introduction
Environmental Management Group (EMG) provides a wide variety of environmental services. Our certified environmental professionals have over 30 years of experience. Some of those environmental services included the following:
Phase I & II Environmental Property Assessments
Asbestos Inspections, Sampling & Management
Groundwater Studies
Soil Sampling & Assessment
Surface Water Quality Sampling & Assessment
Environmental Sampling (soil, water, waste)
Governmental Regulatory Environmental Affairs
Environmental Compliance Oversight
In today's regulatory and legal climate, the nature and scope of potential environmental liability associated with hazardous substances and waste has become a major concern. In the mid 1980s, the United States Congress expanded Superfund regulations by enacting the Superfund Amendment and Reauthorization Act (SARA). The SARA regulations establish strict liability for property operators, owners, both current and former, if contamination is found.
The commercial real estate market has attracted developers, investors and financial lenders to Arizona. With recent changes in federal, state and municipal environmental laws, new areas of liability have emerged in the transaction of properties contaminated with hazardous substances and waste. Given the substantial costs sometimes associated with rehabilitation of contaminated properties, it is prudent to determine the general risk of such regulated materials existing on the site prior to acquisition.
Liability for the cleanup of contaminated sites currently extends to four classes of entities:
Any existing owner or operator of a hazardous facility;
Any entity who previously owned or operated a facility at the time of disposal of the hazardous substance any hazardous substance generator including those who arrange to have toxic materials taken to a facility for disposal or treatment, and
Any entity that physically transports hazardous substances to a facility for disposal or treatment.
The SARA amendment does not relieve lenders from liability under CERCLA. The broad unavailability of environmental liability insurance may necessitate consultation with an experienced environmental risk assessment firm. Environmental concerns should be completely understood to provide facts upon which to base management decisions regarding the level of risk facing lenders, owners or purchasers.
Phase I Environmental Property Assessments
EMG conducts Phase I Environmental Property Assessment investigations in accordance with the current industry standard, American Society of Testing and Materials Practice E-1527. This standard provides a definition for "recognized
environmental conditions" as follows:
"The presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater or surface water of the property. The term includes hazardous substances or petroleum products even under conditions in compliance with laws. The term is not intended to include de minimis conditions that generally do not present a material risk of harm to public 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."
The following activities are generally conducted as a part of a Phase I Environmental Property Assessment investigation by EMG:
Property Inventory
Research of regulatory agency records at federal, state, county and local levels. Current and historical review of the subject property and adjoining area land use. Aerial photograph review. Regional and site specific geological and hydrogeological data evaluation.
Site Inspection
Visual classification of hazardous chemicals or wastes observed on the site. If hazardous chemicals or wastes are identified, suitability of chemical storage compliance is evaluated. Interview of individuals associated with the property for information regarding current and historical site use.
Prepare Assessment Report
A report of findings and recommendations is prepared for each property. An opinion is rendered as to the likelihood of "recognized environmental conditions" being present on each property.
Phase I Environmental Property Assessments are now routinely conducted as a part of property transfers by many institutions in order to document the site conditions at the time of sale. Additionally, long term environmental monitoring programs can be initiated to minimize the environmental liability stemming from discharges which may occur on or adjacent to the property.
Phase II Environmental Property Assessments
Phase II Environmental Property Assessments are conducted based on evidence of "recognized environmental conditions" on the subject property. Phase II investigations can include soil testing, groundwater testing, and site rehabilitation activities. In cases where periodic monitoring is requested by the client, staff will oversee the installation of a soil and/or groundwater monitoring system. The system allows for sample extraction at any time, providing flexibility to conduct expanded chemical testing for regulatory compliance monitoring.
Asbestos Management & Consulting
EMG provides professional consulting for asbestos management throughout Arizona, Utah and Nevada. Our certified asbestos Building Inspectors and Management Planners meet all Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA) and Asbestos Hazardous Emergency Response Act (AHERA) training requirements, including annual refresher requirements. EMG trained scientists can conduct asbestos building surveys to identify potential asbestos containing materials, sample for asbestos, provide asbestos abatement specifications, and prepare management plans.
Groundwater and Soil Sampling & Assessment
Other environmental services activities include soil and groundwater testing services, contamination assessments, remedial actions, and other services conducted at the request of the client to comply with requirements set forth by a Federal, State, or local regulatory agency.
In cases where positive identification of contamination is made at a site, EMG can address the situation through oversight and coordination of contamination assessment and remediation programs.
Representative Project Experience
The experienced staff of EMG provides environmental services to lenders, developers, operators and investors. EMG has conducted numerous assessments on a variety of properties. Our broad environmental experience includes the following projects:
Numerous environmental property assessments in Arizona, Florida and Texas. The assessments include a wide range of property – large acreages, commercial buildings, residential developments, vacant property, agricultural land, and redevelopment areas.
Numerous industrial and petroleum storage tank comprehensive site assessments including soil boring sampling, soil impact definition, soil remediation and supervision, groundwater sampling, groundwater monitoring well location selection, monitoring well installation supervision, sample collection, groundwater quality evaluation, contaminant plume delineation, risk based site assessments, corrective action plan development, and coordination with the appropriate regulatory agency.
Fueling facility compliance manual development for a school district.
Storm water sample collection and quality, waste load evaluation, and reporting for two oil refineries.
Storm water sampling protocol development, implementation and procedural training for two oil refineries.
Texas Natural Resource Conservation Commission (TNRCC) wastewater treatment plant permitting - renewal and amendments - for 200,000 and 80,000 barrels per day oil refineries.
TNRCC sewage sludge disposal permitting and annual report preparation for 700+ acre disposal site.
TNRCC water right permitting for golf course irrigation and recreation site.
Pulp and paper mill solid waste disposal facility siting and permitting. Land acquisition, facility planning, and permitting for 100-acre solid waste disposal facility located in sensitive coastal zone. Work included permitting, construction, and monitoring for initial two-year startup period for facility.
Bulk terminal property environmental assessment. Environmental assessment in conjunction with purchase of former bulk terminal. Work included soil and groundwater initial investigation for potential contamination from historic activities and sampling, assessment, and disposal of remaining products in 17 bulk tanks.
Dedicated land application site permitting, development, and operation. Land acquisition, environmental site assessment, and planning for the development of a 2,000-acre silviculture site for the beneficial use of 13,000 tons, annually, of domestic and industrial sludge. Work included project planning, development, permitting, operational procedures, environmental compliance monitoring and reporting for sludge disposal activities, and site management activities for facility.
Field studies for a five-year water quality based effluent limit determination project. Co-manager for extensive field monitoring as part of a Level II water quality based effluent limit evaluation of a 35-million gallons per day discharge to a coastal bay and estuary (shell fishing waters and state aquatic preserve). Field studies included: freshwater flow studies; bay current studies; drogue current studies; effluent dye studies; benthic biology studies; physical and chemical sediment quality studies; sediment oxygen demand studies; receiving water transparency studies; intensive water quality monitoring; and water level recorder network installation. Co-authored 25,000-page report summarizing data for submittal to regulatory agency as part of a wastewater treatment plant permit application.
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