RE: Tobacco Processing

[Guest guest]

A few comments:

1. Revisit the Phase I ESA and the history.

2. look for:

Pesticides

Herbicides

Fungicides

(if old facility could have used arsenic-based materials)

Fertilizers and additives (Selenium for instance)

Petroleum - look for fuel tanks

Tobacco tends to pull heavy metals out of the soil, and there will be traces of

these around - probably no big deal

If it really was processing for cigarettes or dip, then other additives may

have been used in the processing

Dare I say nicotine, a potent vasco-constrictor for which chewing tobacco is

reportedly ca. 5-10 greater in concentration than a cigarette.

3. After this

Do a bulk micro-vac dust and wipe samples.

Composite samples where necessary to save money.

Need SF to give a valid number as a check.

4. The concern for " contaminants " , I'll call them chemicals or agents of

concern, can be real. Under CERCLA, the law may permit claims of surface

contamination of improvements upon the property (buildings, structures,

articles) that would present a health hazard. An example would be lead dust

from a battery manufacturer, PCBs from oils or in paints. This is not a well

defined area but was considered and set aside by most of the ASTM ESA II group

that worked on the ASTM ESA II standard [ASTM E1903 Standard Guide for

Environmental Site Assessments: Phase II Environmental Site Assessment] by ASTM

during the formulating of the ASTM ESA II Standard [i helped with this but

disagreed with leaving it out]. There was a small piece in the Legal Annex of

the drafts concerning this - the legal annex regarding this was never published

with the ESA II method and usually are not. I have dealt with surface

contamination by: As, Ba, Cd, Cr, Hg, Strontium, Pb, PAHs, PCBs, Phthalates,

Chloropyrifos, Chlordane, flammable (yes-flammable) paint residue, etc. It can

be real or over-rated but without testing - you'll never know. Oh, figuring out

an acceptable limit is another ballgame altogether.

Tony

...........................................................................

" Tony " Havics, CHMM, CIH, PE

pH2, LLC

PO Box 34140

Indianapolis, IN 46234

cell

90% of Risk Management is knowing where to place the decimal point...any

consultant can give you the other 10%â„ 

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