The following SCA protocol has been developed for Environmental Due Diligence of schools considered for lease renewals:
I. Conduct Environmental Due Diligence
A. Phase I Environmental Site Assessment (ESA) includes the following:
- Visual inspection of property and surrounding area
- Interview of landlord and occupants
- Review of commercially available regulatory databases and historical land use maps
- Review of public documents and records indicating past uses of the property
If a Phase I ESA was already performed by SCA, a Site Inspection (SI) will be conducted. This includes a visual inspection of the property and surrounding area and interview of the landlord and occupants. A regulatory database review may also be conducted, as appropriate.
B. Based on the findings of the Phase I ESA/SI, SCA will perform Indoor Air Quality Testing (IAQ) of selected Volatile Organic Compounds using EPA Methodology TO-15. If warranted, a soil vapor intrusion survey will be conducted, which may include sub-slab soil vapor sampling and/or additional Indoor Air Quality (IAQ) testing.
II. Handling of Environmental Site Assessment Data
A. Upon verification of the laboratory data from the IAQ testing that indicate the concentration of a chemical substance exceeds the applicable New York State Department of Health (DOH) Air Guideline Value (AGV), and is suggestive of soil vapor intrusion, SCA will:
- Immediately contact the New York City Department of Health and Mental Hygiene (DOHMH) for consultation and guidance and may also contact the New York State Department of Health (NYSDOH).
- Immediately inform the school principal(s), the Director of DOE Environmental Health and Safety, the district superintendent, the District Community Education Council President, School Parent Association, local elected officials, and other concerned parties (e.g. UFT and other unions representing school staff) of:
Environmental conditions and test results, and
Plan for further investigation and potential sampling, if necessary.
- Assist the school principal(s) in scheduling a meeting with the school community as soon as practicable following receipt of confirmed test results.
- Immediately conduct confirmatory IAQ sampling if any initial test results exceed an AGV.
III. Remediation Recommendations
A. If at any point during the investigation, the SCA determines that mitigation measures involving significant construction-related activities are required to render the school suitable for continued use, SCA will announce its intent to relocate the school on a temporary or permanent basis and will immediately begin to explore alternative locations. Relocation may be necessitated by, among other reasons, the installation of a sub-slab depressurization system for intercepting subsurface vapors beneath the building. Notification of interested parties will proceed in the same manner as described in paragraph II above.
B. If SCA determines that mitigation measures can be accomplished without disrupting school activities, SCA will complete its investigation and develop a course of action.