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Clearwater Group

Expertise in Environmental, Resource, and Sustainability Consulting

Frequently Asked Questions (FAQ)



Challenge: Uncertainty as to Technical Progress of Complex Environmental or Engineering Projects

Solution:  Second Opinion Analysis

Details:  Sometimes it is difficult to determine whether a project is moving toward the established goals and objectives, and meeting milestones in a cost-effective way.  Some environmental projects last for many years, and the high cost of data collection, the uncertainties of regulatory direction, the lack of clear objectives, and the limitation of funding creates anxiety abut the progress toward the goal of project completion and case closure.  Clearwater Group offers a second opinion and peer review services to evaluate the technical objectives.  Examples of second opinion reviews might include the path to case closure of an environmental project, or an examination of engineering plans for storm water control to verify regulatory compliance.  The firm uses spreadsheets to evaluate what is known and what is still unknown about the site or project conditions, where important and critical data gaps exist and what are the impediments of successful project completion. 

Clearwater Group has provided technical review and second opinion on numerous projects and reports.  The Clearwater Group Principals have served in a peer review capacity for several organizations.  James Jacobs served from 2006 to 2011 on the Fulbright Peer Review Committee, screening potential Fulbright scholars in environmental sciences.  From 2005 to 2010, he served on the National Screening Committee for the American Institute of Professional Geologists for candidates applying for the Certified Professional Geologist designation.  Since 2005, he has been on the Advisory Board for the Association for Environmental Health and Sciences.  The duties include the review of abstracts submitted for presentations for the annual San Diego, California Soils, Sediments, and Water conference and reviewing student presentations.  In October 2011, Jacobs was selected by the CalEPA to perform a peer review for the University of California related to Cr(VI) (also called hexavalent chromium).  The document requiring technical review was the 2007 Pacific Gas and Electric (PG&E) Hinkley, California Chromium Background Study Report which was the site of the Erin Brockovich movie.  As a publicly elected official, since 2002, Jacobs has served on the Tamalpais Community Services District as well as on the Sewerage Agency of Southern Marin.  Jacobs provides technical review of contracted science and engineering projects for the agencies as part of the discussions with the board of directors.  Olivia Jacobs has provided technical review and second opinion analysis on a variety of environmental projects for public water resource reports, as well as for current or adjacent property owners whose land has been impacted by petroleum hydrocarbons or chlorinated solvents.  


Clearwater performs forensic studies to evaluate environmental, engineering, and construction incidents or events.   Most normal environmental and engineering projects start with a task and proceed with accomplishing the goals.  In a forensic study, the incident (a spill, an accident, a catastrophic event) is the starting point, and the project looks to put the event in context, supported with consultant reports, laboratory data, and other normally obtained environmental information.  Traditional mitigation environmental and engineering projects are frequently focused on future actions and events, such as prevention of spills and leaks, proper health and safety training, and attaining specific technical objectives and goals.  

Forensic studies are different from traditional environmental and engineering projects in that the focus is on evaluating the past in a methodical manner.  Starting with the set of consultant reports and files, timelines and narratives are developed in a forensic study using depositions, regulatory files, interview transcripts, historic Phase I Environmental Site Assessments, newspaper articles, historic aerial photographs, historic maps, consultant and contractor invoices, past health and safety plans, daily field tickets, and other information.  

The firm has worked for insurance companies and attorneys in collecting new foresnic evidence to explain complex subsurface conditions or events.  Environmental molecular diagnostics are used to analyze biological and chemical characteristics of groundwater, surface water, soil, sediments, mineral ores, petroleum hydrocarbons and other compounds.  These advanced techniques incorporate dozens of emerging analytical methods including Polymerase Chain Reaction (PCR), compound specific isotope chemistry analysis, enzyme activity probes, microbial analysis and identification and other techniques to provide supporting forensic evidence for complex environmental and engineering cases.  Passive vapor organic compound sorber surveys and historic aerial photographs can also be used to piece together the likely events of an accident, spill, or chemical release. ​


For cost allocation questions for environmental and specific types of engineering cases, the main issues Clearwater can address are whether the past services or those services to be provided in the future reflect customary, reasonable and necessary tasks for the required scope of work.   Based on experience, training, education, Clearwater Group  has evaluated complex cost recovery cases as licensed professionals and general engineering and building contractors to examine invoices, daily field tickets, workplans, rate sheets, final reports, photographs and other documentary evidence.  Below are the type of questions that might be considered for cost allocation projects:  

  •  Is the scope of work appropriate, reasonable and necessary for the goals of the project?  

  •  Were similar methods customarily accepted by regulatory agencies and used by other professionals in the area?  

  • In complex environmental cleanup cases with multiple parties, did the parties contribute equally over time to the contamination and were the contaminants of equal or different toxicity or level of recalcitrance in soil or groundwater (and consequently different cost to remove)?
  • Were the same contaminants released and processes performed on a property over time (such as a producing oil field), or were there several distinct contaminants from specific processes over time (such as an industrial region with multiple manufacturers)?
  • Were the cleanup costs appropriately divided among responsible parties?
  • Were all the consulting and contracting companies performing the work properly licensed?  
  • Were the all the workers, operators, competent persons, and field supervisors properly trained?
  • Are all reports correct and were they submitted on time to the regulatory agency to maintain compliance?  
  • Were there possible conflicts of interests in the services provided, and were those noted and disclosed?
  • Were the costs and level of effort appropriate for the scope of work, and how do they compare with standard reference tables from Means, Dodge or other available information?
  • What is the relationship between the property owner, the licensed professionals (consultants) and contractors?  
  • Were contractors and subcontractors appropriately trained for safety and hazmat work, which include medical surveillance, 40-hour OSHA safety training and annual refreshers?
  • Were all daily field tasks fully documented in writing and with photographs and logs?  
  • Do time sheets match billing tickets and invoices?
  • Was overtime pay paid properly according to state law?  
  • Do subcontractors have appropriate health and safety paperwork? 
  • Does the timeline of field and office tasks match the invoices? 
  • Were the tasks performed in a professional manner?
  • How close were the as-builts to the actual plans?
  • ​Was the level of care appropriate for the location and professional standards?
  • Were the change orders justified? 



1) Cost Allocation of Environmental Remediation and Mitigation Measures 2-Day Class

One of the issues with litigation settlement of remediation claims is the equitable cost allocation of past and future costs for cleanup. Other topics to be discussed include environmental valuation, assessment and determination of financial responsibility using forensic evidence and other methods when standard chemical release documentation is not available.  The basis of this workshop is the upcoming book, Cost Allocation for Environmental Projects; in press, James Jacobs.

2)  Environmental Aspects of Oil Spills and Gas Leaks 2-Day Class

The workshop is based on the McGraw-Hill book, Oil Spills and Gas Leaks, by Testa and Jacobs, 2014.

3)  Recycling Oil Field Wastes, Bioremediation of Oil Field Soils and Sludges, and Soil Recycling using Cold Mix Asphalt Processing, and Innovative Water Treatments - 2 Day Class

The class is based on the McGraw-Hill book, Oil Spills and Gas Leaks, by Testa and Jacobs, 2014 and selected soil recycling chapters of the Wiley book, Acid Mine Drainage, Rock Drainage, and Acid Sulfate Soils Jacobs, Lehr and Testa, 2014.  This class could occur in the field, if we have a demonstration area and appropriate vendors to perform some of the processes.  

4)  Environmental Aspects of Hydraulic Fracturing Operations and Oil and Gas Production - 2 Day Class

based on the upcoming book, Fracking: Environmental Protection and Development of Unconventional Oil and Gas Resources (in press), Jacobs and Testa.  This class discusses the need for objective documentation and data collection from both land owners, community leaders, and regulators as well as operators, consultants, and attorneys.  The class describes the precautionary principle as it applies to hydraulic fracture stimulation, and ways to protect the environment and mitigate hazardous conditions.

5)  Mitigation of Acid Mine Drainage During Mining and Land Development - 2 Day Class

The class describes restoration of abandoned mine sites, as well as planning for current or future mining areas.  The class is based on the Wiley book, Acid Mine Drainage, Rock Drainage, and Acid Sulfate Soils, ed. Jacobs, Lehr and Testa, 2014.  

6)  Environmental Management System (EMS) for the Oil and Gas Industry.  5 Day Class 

The class focuses on the software tools, techniques and management systems of environmental management in the oil and gas industry, especially related to drilling and production activities and wastes.  Workshop sessions will feature policy development, conducting environmental reviews, addressing environmental issues including waste management, energy efficiency, pollution control and emergency planning, and environmental monitoring.

​7)  Assessing VOC Migration Pathways, Testing New Vapor Intrusion Site Conceptual Models & Practical VOC Sampling Methods – 2 Day Class

This pragmatic workshop will provide the basis for developing more realistic field testing and site conceptual models for releases into the subsurface of industrial chlorinated solvents like PCE, TCE, and 1,4-Dioxane, as well as fuel hydrocarbons.  The class will discuss exposure pathway analysis and risk assessment.   The class will be particularly relevant to regulatory personnel, environmental consultants, responsible parties, attorneys and wastewater collection and plant operators.  Participants will learn how to design field sampling programs to test exposure pathways to develop accurate site conceptual models.  Exposure mitigation measures will be taught from designing and planning to implementation and monitoring.

8)  Qualified Stormwater Developer / Qualified Stormwater Practitioner (QSD/QSP): 1 Day Class

This class, required by the California State Water Resources Control Board and implemented through Trainers of Record (ToR) certified by the California Stormwater Quality Association (CASQA), provides the information needed to develop stormwater erosion control plans for construction sites, including those sites with rebuilding after fires and floods.  The class focuses on performing on-site erosion control activities and to pass the QSD/QSP exams.  The class provides practical field examples by a QSD/QSP ToR.

9)  Qualified Stormwater Industrial Practitioner (QISP): 1 Day Class

This class, required by the California State Water Resources Control Board and implemented through Trainers of Record (ToR) certified by the California Stormwater Quality Association (CASQA), provides the information needed to develop stormwater plans for industrial properties.  The class is focused on participants to perform on-site erosion control activities at industrial sites, and to pass the QISP exam.  The class provides practical field examples by a QISP ToR.


Clearwater Group Principal Geologist, James A. Jacobs, designed and taught 7 to 20 day duration classes:

In 2003, Jacobs was awarded a Fulbright Senior Specialist grant to teach workshops on water resources management and environmental science at the University of the West Indies (UWI). 

In 2004, he was awarded a second Fulbright Senior Specialist grant to teach the 20-day Environmental Engineering (EM643), a graduate class at UWI, Mona Campus, Jamaica; (80 hours of classroom instruction).

In 2008, Jacobs won a third Fulbright Senior Specialist grant to teach Risked-Based Environmental Decision Making for Afeka College of Engineering in Tel Aviv, Israel.  (40 hours of classroom instruction, taught with Chin Man Mok, Ravi Arulanantham and Ami Adini).

In 2011, Jacobs designed and taught Sustainable Remediation Methods for Soils and Water (X-451); University of California, Berkeley Extension program for Spring 2011 and Fall 2011; Berkeley, California, USA (15 hours of classroom instruction per semester).

In 2011, Jacobs co-taught a Risked-Based Environmental Decision Making, Technical University of Munich, Munich, Germany; (total 40 hours of classroom instruction, taught with Chin Man Mok and Ravi Arulanantham).

In 2012, Jacobs won a fourth Fulbright Senior Specialist grant and taught Risk-Based Subsurface Environmental Management and Sustainable Remediation and other environmental workshops and graduate classes focused on sustainable environmental practices, recycling, and practical remediation efforts as part of the Fulbright grant program at SRTM University in Nanded, India; (42 hours of classroom instruction, taught with Chin Man Mok and Stephen Baker). 


SRTMU: Risk-Based Subsurface Environmental Management and Sustainable Remediation; School of Earth Sciences, Department of Environmental Science, Swami Ramanand Teerth Marathwada University, Nanded, India. Lecture hours: 42; participants: 45 students; Year: 2012; Co-teachers: Chin Man Mok and Stephen Baker; Lecturers.  Projects.

Government Institute of Science, Department of Geology, Government Institute of Science, Aurangabad, India. GIS:Analysis and Sustainable Remediation of Environmental Resources; Lecture hours: 16; participants: 30 students; Year: 2012; Co-teachers: Stephen Baker; Lectures.

TUM: Risk-Based Subsurface Environmental Management, Engineering Department, Technical University of Munich, Munich, Germany. Lecture hours: 30; participants: 18 students; Year: December, 2011; Co-teachers: Chin Man Mok, and Ravi Arulanantham; Exams and Projects.

UCBE: X-451: University of California, Berkeley Extension, Berkeley Campus, California: 7 session graduate class titled Sustainable Remediation of Soil and Groundwater. Lecture hours: 32; participants: 8 students; Year: Fall 2011; Exams and Projects.

UCBE: X-451: University of California, Berkeley Extension, San Francisco Campus, California: 7 session graduate class titled Sustainable Remediation of Soil and Groundwater. Lecture hours: 32; participants: 12 students; Year: Spring 2011; Exams and Projects.

UWI – EM643: University of the West Indies, Mona Campus, Jamaica, Geology Department:
4-week daily graduate class titled Environmental Engineering: Sampling, Assessment and Remediation. The course was a required class for a master's degree in Contaminant Hydrogeology, Environmental Science and Risk Management. Lecture hours: 80; participants: 13 students; Year: March, 2004; Exams and Projects.


ACE: Remediation of Contaminated Soils and Groundwater: The California Experience. Engineering Department, Afeka College of Engineering in Tel Aviv, Israel. Lecture hours: 40; participants: 28 students; Year: 2008; Co-teachers: Ravi Arulanantham, Chin Man Mok, and Ami Adini.

UWI: Risked-Based Corrective Action, Risk Assessment, and In-Situ Remediation
and Natural Attenuation Processes; Petroleum Corporation of Jamaica and UWI Geology Department, University of the West Indies, Mona Campus (near Kingston, Jamaica). Lecture hours: 24; participants: 35 students; Year: March 2004; Co-teachers: Ravi Arulanantham and Roger Brewer.

UWI: Environmental Sampling and Remediation Workshop; Geology Department, University of the West Indies, Mona Campus (near Kingston, Jamaica). Lecture hours: 8; participants: 15 students; Year: February 2003.


Jacobs has taught other environmental workshops at national meetings, including the following:

"Two Phase Extraction Methods, Application for Groundwater and Soil Remediation."  A four hour Workshop presentation given by Mehmet Pehlivan, James Jacobs and others:

  • American Institute of Professional Geologists, 2009 National Meeting, Grand Junction, Colorado

  • Association for Environmental Health and Sciences, 2008, National Meeting, San Diego, California

  • Association for Environmental Health and Sciences, 20010, National Meeting, San Diego, California
  • Battelle Chlorinated Solvent Conference, 2008, Monterey, California

"RBCA Grows Up: Introduction to Environmental Hazard Evaluation and Advanced Approaches for Site Investigations."  A four hour Workshop presentation given by Roger Brewer, James Jacobs and others:

  • Association for Environmental Health and Sciences, 2009, National Meeting, San Diego, California 

In 2006, Jacobs organized a one-day seminar in San Francisco related to climate change issues and opportunities, sponsored by Lorman Education titled "Effects of Climate Change on Development, Infrastructure, Water Resource Management, and Business Opportunities in California."  Participants included James Jacobs, P.G., Stephen Baker, P.G., Peter Mesard, P.E., P.G., Jeff Nelson, P.E., Charles McGlashan, and Kent Alm, Esq.

2010, “In-Well Stripping/Recirculation and Two-Phase Extraction Methods, Application and Enhancement for Groundwater and Soil Remediation” A four hour Short Course presentation, 20th International Conference on Soils, Sediments, Water, and Energy and AEHS Foundation Annual Meeting 2010, San Diego, California, March 15-18, 2010; Co-teachers: Mehmet Pehlivan and Philip G. Mihopoulos,

2009, “Risked Based Corrective Action (RBCA) Grows Up: Introduction to Environmental Hazard Evaluation and Advanced Approaches for Site Investigations.” A four hour Short Course presentation, Association for Environmental Health and Sciences, 2009, National Meeting, San Diego, California, Co-teachers: Roger Brewer, and Jason Brodersen.

2009, “Two-Phase Extraction Methods, Application for Groundwater and Soil Remediation” A four hour Short Course presentation, American Institute of Professional Geologists, 2009 National Meeting, Grand Junction, Colorado; Co-teachers: Mehmet Pehlivan.

2008, “Two-Phase Extraction Methods, Application for Groundwater and Soil Remediation” A four hour Short Course presentation, The 6th International Conference, Remediation of Chlorinated and Recalcitrant Compound, Monterey, California, May 19-22, 2008. Organized by Battelle, Columbus, Ohio; Co-teachers: Mehmet Pehlivan.


Clearwater Group helps to mentor students and  young professionals.

Since 2010, Jacobs has been the American Institute of Professional Geologists (AIPG) Sponsor of the University of California at Davis (UCD) AIPG Student Section.  Jacobs has lectured about topics related to being a professional geologist, interviewing for jobs, writing resumes, and career development.

​Other lectures and student interactions are reflected in the gallery of photos from India to Germany to Davis, California.

In 2016, Jacobs has been the American Institute of Professional Geologists (AIPG) Sponsor of the Sonoma State University AIPG Student Section in Rohnert Park, California.



This article originally appeared in Groundwater Resources Association’s Hydrovisions in 2002 and in the American Institute of Professional Geologists’ The Professional Geologist in 2002. Although everyone has a resume, new hires and seasoned geologists from other geology fields (petroleum and mining) are always calling and emailing me to find out about how to break into the environmental job market. I get several calls or emails every week. What follows is one opinion on how to break into the environmental job market without any experience. Persistence counts for everything. 

The environmental industry is still vibrant based on the number of calls received from new graduates wanting career opportunities. Environmental issues, including water availability and treatment are an important national challenge. These issues will only grow in importance as the population grows and clean water resources diminish. There are many books on preparing resumes. Using an Internet search engine such as Google, type in key words “environmental jobs”, “geology career”, and hundreds of web sites will be available. The question is how to make your resume stand out, get a successful interview and the job offer? 

The Catch-22 problem exists where many companies won’t hire new workers without some experience. But how does a newly graduated environmental professional or the seasoned geologist with several years of experience in another field of geology get that first environmental job without experience? Here are a few ideas that might help: 

Resumes - The resume is a sales brochure indicating your level of written communication skill. Keep it brief; 1 to 3 pages. Use many bullets and do include dates of previous jobs, colleges or activities. Spelling and grammar are important, especially on resumes. Resumes should highlight your proven activities such as problem solving, leadership, team building, reliability and organizational ability. Computer and Internet skills are always a plus. Technical training can given to any good employee, however, companies cannot train new hires in reliability or honesty. For more information, there are dozens of books on resume preparation in the local library or bookstore. 

Internships while in School - For college and university students, try to get that environmental internship while at school to make contacts and get some experience. Even if there is no money involved, the contacts could be well worth the effort. 

Join Associations - For students and seasoned geologists alike, there are many good professional and technical associations one can join. The local and national  meetings of the American Institute of Professional Geologists provide excellent networking opportunities. The AIPG national meetings are excellent gatherings of high-level geologists. For students, some associations may have a reduced student membership rate. These meetings offer great contacts, friendships, as well as the chance to hear a good professional or technical talk. For those wanting a job in a new area, these meetings are the best place to meet the professionals who practice in a particular technical area or location. Sometimes even the food is good. Many times, the students are given free passes to participate in these meetings. The AIPG website ( has information on local AIPG sections and on the profession. For California, check out the California Council of Geoscience Organizations ( for a listing of prominent geology societies and job listings. For other states, job hunters can call members in their state AIPG Section to get names and contacts for other local or state geology societies. 

Get there first - I get resumes from environmental professionals throughout the nation and abroad asking for a job. If you want a position in a certain location, it would be good to set up an interview when you are in the area, if you don't already live here. Some larger firms are willing to pay for interview expenses and travel costs, but small firms may want to see some commitment to the environmental field and local area before shelling out hundreds of dollars in interview expenses. 

Read Up – Many local libraries have trade and technical journals from the environmental field. Groundwater, Environmental Pollution, Water Well Journal, Pollution Engineering, and dozens of others contain important information about the environmental field. Type these names into the 

Take the Training – Employers are required to pay for the training costs and wages during training. Combine the wages and the training costs, an employer could spend a few thousand dollars on a new untested employee. Many large environmental companies are willing to take the risk. However, in a crowded job market, to make a new hire more attractive to any environmental employer, pro-active job seekers could spend their own money and take the OSHA 40 Hour Hazardous Materials training. Make sure the class is widely recognized as accredited before spending any money. Call the local EPA and OSHA office and get their recommendations on accredited classes. Call some prospective employers and find out which vendors they recommend. Some employers may require all employees to take their 40-hour class. 

Why should a job seeker take the class on his or her nickel? First, it shows commitment to the environmental field, but more importantly, it will allow the job seeker a better understanding of the environmental industry, the safety concepts, the terms and the equipment. It allows an employer to hire a prospective employee and with some in-house training, get the new hire billable within a shorter time. The training, required by CFR 1910.120 is given by many vendors and is sometimes offered as a for credit class at some colleges and universities. In fact, some vendors provide the training over the web. The costs range is from $100 for training provided by equipment operators unions, community colleges, or city education extension programs to $400 to $800 for private firms. The internet classes are about $400 to $500. Does a job seeker need to have the 40-hour OSHA hazardous materials training class prior to the interviews? No, but having two similar job candidates, who would you hire? 

Having the training will allow a general familiarity with the environmental field. The interviews will be much better, as the potential hire will be able to speak the language of the environmental professional. For the environmental company, the risk of hiring any new employee is huge – what if the employee doesn’t work out and quits within 3 months. The OSHA Hazardous Materials training means large costs for the company: the cost of the training, the salary of the worker during the training and the delay in being able to use a new hire in the field until the training is completed. Having the training means the new employee can be billable in the field right away, making the company very happy. 

Bring in a Clean Driver’s Record - Get a driver's license for the state as soon as possible. Bring a copy of your driver's record with you during the interview to show a clean driver's record during the interview. Keep your driver’s record clean. There is a steep insurance surcharge for new employees having numerous accidents or tickets for driving under the influence of drugs or alcohol. 

Medical exams – Certainly, new hires don’t need to have medical exams before an interview. However, a new hire having an occupational medical exam before the interview is ready to work. A graduating student might be able to get an occupational exam at the college or university health clinic at a nominal cost. A seasoned geologist  changing fields might use his health insurance for an annual occupational medical exam, usually covered by insurance. Without the exam certificate, the new company may have to wait up to 30 to 60 days to obtain an appointment for an occupational medical exam. The medical certificate should state that he or she is healthy, can wear a respirator and can work in the field. Again, most companies will provide their own medical exam, but if someone comes in with the forms already filled out, it shows a willingness to be prepared and get to work. Again, with two similar applicants, whom would you hire? 

Supporting Paperwork – Bring personal reference lists, letters of recommendation and transcripts from all colleges and universities with you to the interview. For new hires, professors are a good choice, as well as summer job or internship supervisors. Having the paperwork available and ready in the interview shows preparation and understanding of the hiring process. 

Practice – Go to as many interviews as possible. This is true for the new graduate as well as the seasoned geologist who has not been to interviews for many years. Practice the questions and answers before the interview. Show up neatly dressed and groomed, with copies of the above items. Good verbal skills are a requisite for most environmental jobs. 

Interviews – Whether you are fresh out of school or a seasoned geologist with 30 years of experience in the oil business, honesty, ambition, communication skills and people skills can be more important in an interview than technical skills. Good attitude is everything in the interview and is contagious. 

Summary – Getting a job in any field without experience is always difficult. Being prepared for an interview will help new hires and seasoned geologists with their job search, regardless the environmental company they ultimately join. Although there are no guarantees that having all of these items will get you a job, interviewers may be impressed and appreciate your skills, dedication and commitment to give you an opportunity. Best wishes on your job search and check out the local and national AIPG meetings and events! If you have any questions, please email me at

About the author: Jim Jacobs, CPG#7760, is Chief Hydrogeologist for Clearwater Group.  His specialty is in-situ remediation of metals, hydrocarbons and solvents. He has over 35 years of experience. He is past president of the CCGO, a director for the Groundwater Resources Association of California (GRA) and active with AIPG and other organizations. 


Phase I Environmental Assessments are performed for a variety of reasons: 

 Due diligence for all appropriate inquiries for a real estate property transfer; 

 Use by a building owner to verify conditions at the beginning of a lease term; 

 Use by a tenant at the end of a lease term to verify environmental compliance and site conditions; 

 Evaluation of corporate environmental liabilities for stock valuations; 

 Confirm environmental impact migration from adjacent or nearby sites; and 

 Third-party review of environmental operations and business practices. 

Clearwater has been performing expedited Phase I Environmental Assessments since 1990 to identify recognized environmental conditions on real property. Most reports meet the ASTM International E1527-13 standard published November 6, 2013 for due diligence.  Sometimes limitations in budget or available time preclude all of the tasks listed on the ASTM standard. 

Who needs a Phase I Environmental Assessment? 

 Buyers of real property; 

 Seller of real property who don't want sale delays or last minute surprises; 

 Public companies to verify environmental liabilities; 

 Banks, lenders, and credit unions. 

Clearwater works with other lenders, including major banks, credit unions and due diligence for loans from the Small Business Administration, or meeting requirements of Fannie Mae, and Freddie Mac. 

SCOPE OF WORK A Typical Phase I Environmental Site Assessment Report Scope includes: 

Site Visit

 Inspection of the Site;  Catalog the Presence of Hazardous Materials; 

 Catalog the Presence of Petroleum Fuel, Lubricant and Other Products; 

 Visually identify likely PCBs, asbestos, lead paint, formaldehyde, etc.; and 

 Perform vicinity inspection. 

Historical Research 

 Historical Aerial Photographs; 

 Polk Reverse Street Directories; 

 Building Permits; 

 Planning Records and Zoning; 

 Topographical Maps; 

 Sanborn Fire Insurance Maps; 

 Department of Oil and Gas Maps; 

 Landfill, Service Station, Dry Cleaner, Factory identification; 

 Mining Maps and Mineral Leases; and 

 Title Information, as available. 

Geology and Hydrogeology 

 Soil Type; 

 Topography and Elevation; 

 Geological Setting; and 

 Groundwater Depth.

Regulatory Status 

 Fire Department Files; 

 County or City Hazardous Materials Business Plan; 

 Environmental Violations and Compliance; and 

 State and Federal Database Review. 

Interviews with Knowledgeable Persons 

 Interview of Tenants and Owners; and 

 Interview State and Local Regulators. 

Document Review 

 Review Reports and Files Provided by Others. 

Report Preparation 

 Prepare report stamped by Professional Geologist (PG) with Recognized Environmental Conditions (RECs) Recognized Environmental Conditions 

If a Phase I Environmental Site Assessment identifies recognized environmental conditions and potential sources of contamination of the site by hazardous materials, a Phase II Subsurface Investigation may be conducted. 

The Phase II Subsurface Investigation includes sampling and laboratory analysis to confirm the presence of hazardous materials. 

Some of the tests that may be performed include: 

 Surficial soil and water samples 

 Subsurface Investigation, sometimes called a Phase II Environmental Assessment with subsurface soil borings; 

 Groundwater monitoring well installation, sampling, and analysis; 

 Container inventory and drum sampling ; 

 Sampling of floor drains and catch basins; 

 Electrical Transformer and capacitor sampling for Polychlorinated Biphenyls (PCBs); 

 Geophysical testing with ground penetrating radar (GPR) or magnetic/induction tools to locate buried tanks and drums; and 

 Verifying the presence of underground storage tanks. 

Other Services 

Sometimes a Phase I Environmental Assessment is not needed. Frequently a Phase I Environmental Assessment has been performed, so an update is needed. Another service is a site inspection as a stand-alone service to see if a Phase I Environmental Assessment is appropriate. 

Desk Study Review

A desk study review is a professional evaluation of the environmental database search files, the historic aerial photographs and documents provided by the owner. 

 Site Inspection Project 

 Desk Study Review 

Optional Sampling Services 

Sometimes optional services are requested, which include asbestos, lead paint, and PCB sampling and indoor air quality sampling related to possible toxic building materials such as formaldehyde or vapor intrusion. 



Clearwater Group (Lic. 799370) and in-house FAST-TEK Engineering Support Services (Lic. 624461) have worked on thousands of properties, performing subsurface investigation and drilling services since 1990. Soil or groundwater samples are collected using Clearwater Group's Geoprobe® 5400 Direct Penetration Technology (DPT) rig. The rig can also be used to perform active high-resolution soil gas surveys or accurate soil conductivity logging for rapid lithologic assessment. Clearwater Group also performs drilling and sampling in specialized environments: lagoons, bays, tundra, and wetlands. Clearwater uses passive soil vapors surveys as a screening tool to identify the presence and approximate concentration of volatile and semivolatile organic compounds found in the subsurface.  Low flow groundwater sampling methods lower waste disposal costs.  


PROJECT: Phase II Subsurface Investigation - Clearwater Group performed a Phase II Subsurface Investigation to determine the location of the source of PCE, TCE, motor oil, and diesel detected in one of three monitor wells on-site. A regulatory approved workplan and health and safety plan were developed. Twenty 1.5 inch diameter borings were drilled by Clearwater Group using continuous core drilling to a maximum depth of 11 feet below ground surface. This method of drilling allowed for a detailed characterization of the subsurface conditions. 

Location: Rohnert Park, California
Client: Artesian Environmental

RESULTS: The Clearwater Group drilling method saved the client an estimated $8,640 in disposal fees.

PROJECT: Phase II Environmental Subsurface Investigation - As part of a corporate divestment, a Phase II Environmental Assessment was performed by Clearwater Group at an office building in Mountain View, California. Subsurface drilling using the continuous coring tool was performed. Clearwater Group drilled four boreholes to a maximum depth of 19 feet below ground surface. Soil and groundwater samples were collected and analyzed for solvents and gasoline. Cost control was performed by computer accounting and a weekly job summary.

Location: Mountain View, California
Client: Consultant

RESULTS: Clearwater Group saved the client approximately $7,655 over the cost of conventional well installations and soil disposal.

PROJECT: Subsurface Investigation in Gas Field - Clearwater Group represented the land owner to perform a visual survey and subsurface investigation of shallow soil conditions in a gas field. Fifteen well sites and two tank farms were inspected. Twenty soil borings were drilled by Clearwater Group to evaluate subsurface conditions. Water samples were collected in two well cellars. Contaminants included crude oil, motor oil and lubricants. The visual survey and laboratory analyses were used to develop a soil remediation plan and a more effective operations and maintenance program. 

Location: Sacramento Area, California
Client: Gas Property Owner 

RESULTS: Clearwater Group's written report was used for settlement purposes in favor of the client, saving the client hundreds of thousands of dollars.

PROJECT: Subsurface Characterization and Well Installation - Clearwater Group was retained by a client to oversee the drilling of ten soil borings, converting seven borings into groundwater monitoring wells. Clearwater Group delineated the vertical and lateral extent of gasoline, diesel, and metals contamination on the subject property, a former bulk storage facility. Cross sections, well logs and iso-concentration maps were used to define the contamination on the site. Significant regulatory and client contact was performed on this site. 

Location: San Diego
Client: Consulting Firm 

RESULTS: The placement of the wells allowed for accurate assessment of the vertical and lateral extent of hydrocarbon contamination in the subsurface, saving the client tens of thousands of dollars in additional subsurface investigations.


PROJECT: Groundwater Monitor Well Installation - Clearwater Group performed a Phase II Subsurface Investigation by drilling seven soil borings on-site. Three of the wells were subsequently converted into groundwater monitoring wells for the detection of free phase liquid hydrocarbons and dissolved constituents in groundwater.

Location: Stockton, California
Client: Consultant

RESULTS: The placement of the wells allowed for accurate assessment of the subsurface conditions, saving the client tens of thousands of dollars in additional subsurface investigations.

PROJECT: Subsurface Investigation and Monitor Well Installation - Clearwater Group was retained by a bank to perform a subsurface investigation using direct penetration technology (DPT) drilling using Clearwater Group's Geoprobe equipment. Clearwater Group drilled three soil borings as the initial phase of the subsurface investigation. Based on the direct penetration technology boring results. Clearwater Group installed three groundwater monitoring wells that were placed in appropriate locations: two were downgradient and one was placed in the upgradient location. All three wells were placed in zero-contamination areas. The wells were developed, surveyed and sampled. The site was closed.

Location: Berkeley, California
Client: Artesian Environmental

RESULTS: After one year of quarterly monitoring, site closure was obtained.

PROJECT: Subsurface Investigation for Lease Transfer - As part of negotiation for a new lease, a consultant retained Clearwater Group to perform a subsurface investigation. The previous tenant had operated a vehicle and equipment rental and repair business on the property. After completing a Phase I Environmental Assessment, Clearwater Group performed a subsurface investigation to document subsurface conditions. Clearwater Group collected four groundwater samples and twelve soil samples using direct penetration technology (DPT) drilling. Based on the chemical analyses, it appeared that an offsite source of gasoline had impacted the groundwater beneath the property. Minor concentrations of oil and grease were detected in the soils. The results helped to establish pre-lease conditions for the owner and new tenant, minimizing potential conflict in the future. The responsible party was notified as to the extent of the gasoline contamination.

Location: Santa Rosa, California
Client: Equipment Company 

RESULTS: The subsurface investigation was completed and the lease transfer was accomplished.


Project: Subsurface Investigation at Resins Plant - Clearwater Group was hired to perform angle drilling and limited access drilling services for a consultant in a resins plant in northern California. Clearwater Group's 40 hour-OSHA safety trained, two person crew drilled in level C protection into soils containing phenols. Clearwater Group drilled several borings and cored concrete. Soil samples were collected in 4 foot long, 1.25 inch diameter stainless steel samplers with inner sleeves. All holes were grouted with neat cement. No cuttings were generated. 

Location: Northern California
Client: Consultant

RESULTS: Soil cuttings were not generated and the client saved $1,900 in soil disposal fees.

Project: Soil Vapor Survey at Airport - Clearwater Group was hired to perform a soil vapor survey along 1,000 foot pipeline containing aviation fuel at the San Francisco International Airport. The survey included twenty-five points. Data from the vapor survey was reported to the client using iso-concentration maps. A detailed report with the field procedures was prepared for the client. All vapor holes were grouted with neat cement. No cuttings were generated.

Location: San Francisco, California
Client: Consultant 

RESULTS: The soil vapor survey was completed in the field in half the time and under budget.

PROJECT: Soil Sampling in Lagoon - Clearwater Group designed a limited access, continuous core drilling program in an abandoned landfill. The landfill was located in an environmentally sensitive area located in the Golden Gate National Recreation Area. Clearwater Group drilled 77 soil borings in an inaccessible area in the lagoon to delineate the vertical and lateral extent of metals and hydrocarbon contaminated soils. Several soil borings were drilled below low tide. Clearwater Group interacted with the Coastal Commission and the San Francisco Bay Office of the RWQCB.

Location: Bolinas Lagoon, California
Client: Stimpel-Wiebelhaus Associates

RESULTS: Clearwater Group obtained high quality soil samples for the client

PROJECT: Limited Access Soil Sampling at Gasoline Station - Clearwater Group performed soil sampling near gasoline pumps at a gasoline service station. In one day, four soil borings were drilled by Clearwater Group under a canopy using a 1.5 inch diameter stainless steel continuous coring sampler to evaluate subsurface conditions. The soil samples were collected in transparent, non-reactive, hard-shell transparent plastic soil liners. The borings were drilled to a maximum of 19 feet below ground surface. Grab groundwater samples were also collected. Clearwater Group negotiated the project with the San Joaquin County Environmental Health Department.

Location: Manteca, California
Client: Confidential 

RESULTS: Continuous core drilling provided superior geologic data which would not have been available using standard drilling techniques. Since soil cuttings were not generated, the client saved an estimated $2,000 in soil disposal fees.


PROJECT: Subsurface Investigation and Drilling - Clearwater Group conducted a Phase II Subsurface Investigation to determine the location of the source of solvents detected in one of three monitor wells on-site. A regulatory approved workplan and health and safety plan were developed. Twenty 1.5 inch diameter borings were drilled by Clearwater Group using continuous core drilling to a maximum depth of 11 feet below ground surface. Clearwater Group negotiated with the North Coast Regional Office of the RWQCB.

Location: Rohnert Park, California
Client: Fortune 500 Firm 

RESULTS: Continuous core drilling allowed for a detailed characterization of the soil conditions.

PROJECT: Sampling: 400 Soil Samples - Clearwater Group designed a soil drilling and sampling program on a 5,000 cubic foot soil pile at a Caltrans yard. Clearwater Group drilled 100 soil borings to a maximum of 21 feet below ground surface. Clearwater Group drilled more than 1,800 feet, obtaining 400 discrete soil samples in five days.

Location: Vallejo, California
Client: Consulting Company 

RESULTS: Clearwater Group obtained soil samples for the client under difficult drilling conditions.

PROJECT: Continuous Soil Sampling in Wetlands - Clearwater Group designed a limited access, continuous core drilling program in a wetlands. Clearwater Group continuously cored 5 soil borings to a maximum of 18 feet below ground surface. Clearwater Group drilled through peat and Bay Mud to evaluate the presence of metal contaminated soils.

Location: Point Pinole, California
Client: Consulting Company 

RESULTS: Clearwater Group obtained soil samples for the client under difficult drilling conditions.

PROJECT: Limited Access Well Installation - Clearwater Group was retained to install two 2-inch diameter monitoring wells beneath a ten foot building overhang at a car stereo installation store. The borings were drilled with a Mobile Minuteman Drill Rig to a maximum of 23 feet below ground surface. After drilling was completed, the borings were converted into 2-inch diameter monitoring wells. Site closure was granted by San Mateo County Environmental Health Department in 1995.

Location: Burlingame, California
Client: Investor 

RESULTS: The drilling was completed on time and on budget and site closure was granted.

PROJECT: Soil Vapor Survey - Clearwater Group was retained to perform a soil vapor survey at a Hamilton Air Force Base, which was slated for closure. Approximately 40 holes were drilled to about 10 feet below ground surface. Clearwater Group drilled through up to 16 inches of concrete through airport runways. Soil vapor samples were collected using SUMMA canisters.

Location: Novato, California
Client: URS/Woodward-Clyde Consultants

RESULTS: The job was completed on time in a professional manner.


PROJECT: Water Sampling of 23 Monitor Wells at National Laboratory - Clearwater Group was retained to purge and sample 23 monitoring wells at a National Laboratory. Monitor well depths ranged from 50 to 150 feet below ground surface. Previous sampling protocol was not to current RWQCB standards. Clearwater Group implemented EPA - RWQCB approved sampling protocol and submitted documentation of field procedures as well as laboratory data.

Location: Livermore, California
Client: Laboratory 

RESULTS: The project was performed on-time and on-budget. Clearwater Group recommended various changes in the sampling equipment in place to improve sampling quality.

PROJECT: Water Sampling of 7 Monitor Wells - At a site of a former gasoline underground storage tank and bulk facility, Clearwater Groupwas retained to install, develop, purge and sample seven groundwater monitoring wells. Monitor well depths averaged 35 feet below ground surface. Documentation of well sampling was included in the written report.

Location: San Diego, California
Client: Petroleum Company 

RESULTS: Groundwater sampling results have led the client to bring in additional upgradient potentially responsible parties for financial liabilities.

PROJECT: Water Sampling of 10 Monitor Wells - Clearwater Group was retained to perform monitor well purging and sampling of ten monitoring wells at a fleet maintenance facility in the San Francisco Bay Area. Monitor well depths averaged 25 feet below ground surface. Documentation of monitoring well sampling data was included in the certified report. The contaminants included diesel and gasoline.

Location: Burlingame, California
Client: Rental Car Company 

RESULTS: Reduced monitoring requirements were negotiated with the regulator, lowering costs. High quality sampling and reporting allowed the client to assess clean-up options.

PROJECT: Site Closure and Sampling of 3 Monitor Wells - Two underground storage tanks were removed from the property in 1991 by Clearwater. Clearwater Group was retained in 1992 to perform monitor well purging and sampling of three 25 foot deep monitoring wells at a warehouse in Oakland, California. Documentation of monitoring well sampling was included in the written report. The contaminants included diesel and gasoline.

Location: Oakland, California
Client: Major Bank

RESULTS: Site closure was granted April, 1994 after the wells were sampled for one year.

PROJECT: Water Sampling of 39 Monitor Wells: EPA Site - Clearwater Group performed quarterly data collection and sampling for 39 monitor wells at the EPA ARCSWEST Frontier Fertilizer Project. The contaminants included a variety of pesticides.

Location: Davis, California
Client: Bechtel Environmental, Inc. 

RESULTS: The firm's responsive service with rigorous schedules helped with project success


SEWER AIR TESTING - Evaluating Alternate Exposure Pathways of VOC Vapors into Indoor Air from Legacy Sewer-Plumbing Systems

Legacy Sewer and Plumbing Systems: Many urban sewer systems in North America are more than 100 years old and are well past their design life.  The legacy sewer mains and associated laterals and components frequently subside, fail, and develop cracks or separations over time.  These are evidenced as breaches in the concrete, clay or transite pipes or corrosion in cast iron pipes.  Tree and plant roots commonly damage sewer pipe integrity.  

Sewer system pipes are a potential alternate exposure pathway for toxic sewer gases and volatile organic compounds (VOCs) like benzene in gasoline, and tetrachloroethylene (PCE), a common dry cleaning solvent, to migrate into indoor air. A common US EPA (2002) vapor intrusion model (Figure 1) needs to be re-evaluated and updated to include this important exposure pathway, especially in buildings located upgradient and outside of mapped groundwater contaminant plumes containing VOCs.  The US EPA (2002) and other regulatory agencies use various vapor intrusion prediction models to make risk-based environmental decisions, including the commonly used model by Johnson and Ettinger (1991).  VOC-impacted groundwater can infiltrate into cracked and leaking sewer trunk lines.  The VOC volatilizes into sewer air and migrates through the sewer system into the indoor air in houses which have inadequate vapor seals (Figure 2).  There are hundreds of thousands of shallow groundwater plumes containing VOC in urban areas in North America. There are also countless urban sewer systems which leak significantly during strong rain events.  The research is focused on studying the migration of VOCs into indoor air through legacy sewer-plumbing systems and ineffective vapor seals and are planning to document the extent to which VOC vapors migrate within sewer pipes located upgradient and outside of delineated VOC groundwater plume areas.  Figure 1 (left): A common VOC vapor model (modified after others, original from US EPA, 2002).  Figure 2 (right):  An example of an alternate exposure pathway model showing sewer gases and VOCs entering indoor air through ineffective plumbing vapor seals. Note: VOCs are released to the indoor air and through the vent line on roof.   VOC data ( Riis et al., 2010; and Pennell et al., 2013) support this alternate VOC exposure pathway into indoor air.  Conditions in the houses reflect exposure pathways. (See Figure 2, right): A:  Intact vapor seals and not over VOC plume  (exposure pathway not completed); B:  Leaky vapor seals and not over VOC plume  (exposure pathway completed); C:  Intact vapor seals and working SSD over VOC plume (exposure pathway not completed); and D:  Leaking vapor seals and working SSDs over VOC plume (exposure pathway completed)

Breached Sewer Lines

When breached sewer collection pipes intersect contaminated soil and groundwater containing VOCs, for example, the potential for VOC-containing water and VOC-containing vapor to infiltrate into breached sewer pipes is high.  While VOC-containing fluids are conveyed downgradient in the sewer pipes toward the wastewater treatment plant, the VOCs in groundwater, pipe debris/solids and soil vapor naturally volatilizes and migrates in the sewer pipes.  VOCs in vapor form (sewer air) migrates without specific regard to gravity.  

Sewer air, which migrates throughout the system, frequently contains sewer gases such as methane, ammonia, hydrogen sulfide, and low levels of carbon dioxide and any other volatile compounds.  Some sewer gases, such as hydrogen sulfide or ammonia, are odoriferous and are recognizable. Depending on concentrations, commonly detected VOCs such as PCE, trichloroethene (TCE), benzene, and other chemicals as well as sewer gases mentioned above, can migrate by diffusion or other methods throughout the main sewer lines, the attached sewer laterals and plumbing pipes in each structure on the wastewater system.   

VOCs and Indoor Air Quality

Indoor air quality degradation caused by vapor intrusion of VOCs into structures has been a health concern of the US EPA and other agencies for three decades. Sewers and plumbing systems have not been generally included as potential vapor conduits in the standard site conceptual models for indoor air quality developed by US EPA (2002) and others.  


Two recent PCE-specific vapor intrusion studies documented significant indoor air contributions of PCE from the plumbing-sewer systems located within PCE groundwater plume areas; the PCE groundwater plumes studied were in Skuldelev, Denmark (Riis et al., 2010) and in Boston, Massachusetts (Pennell et al., 2013).  In both studies, PCE vapors were found in indoor air and were tracked back to sewer-plumbing systems which intersected a delineated PCE groundwater plume.  In both cases, the concentrations of PCE detected inside the buildings were orders of magnitude higher than the levels generally considered safe for long-term indoor air exposure.  

In the Denmark study (Riis et al., 2010), PCE was reported in indoor air near the drain under a kitchen sink as high as 810 µg/m3.  In the Boston study, concentrations of PCE in isolated bathroom air was 2.1 µg/m3.  When the sewer connection for the toilet in the bathroom was open to indoor air, the inside air had a PCE concentration of 62 µg/m3 to 190 µg/m3.  

Regulatory Levels

For the Massachusetts Department of Environmental Protection (MassDEP), the threshold value for PCE is 1.4 μg/m3. The two studies described above (Riis et al., 2010 and Pennell et al., 2013), although not in California, represent residential exposures.  Using the California Department of Toxic Substances Control (DTSC, 2014) Human and Ecological Risk (HERO) recommended values for PCE concentrations for residential air screening levels calculated using the Regional Screening Level (RSLs) calculator are 0.41μg/m3 for cancer and 37μg/m3 for non-cancer risk.  San Francisco Bay Regional Water Quality Control Board (RWQCB, 2013) Environmental Screening Levels (ESLs) for PCE in indoor air (residential) is 0.41 μg/m3.  Clearly, the indoor air concentrations in both studies indicate the PCE concentrations in indoor air are at levels worthy of concern and additional study and a need for mitigation.

Regardless of the regulatory level used for environmental guidance or action levels, the hazard communication about the potential for vapor exposure of toxic compounds to unsuspecting building occupants is needed.  The levels of PCE detected in indoor air (Riis et al., 2010 and Pennell et al., 2013) are small compared to the immediately dangerous to life and health (IDLH) for an instantaneous exposure of PCE.  However, the concern is regarding low level of exposure of possibly multiple volatile compounds over decades to building occupants who are unaware they are being exposed, especially because they may be located far away from the release of the volatile compounds.

Research Significance

Many urban PCE plumes intersect breached sewer systems. Due to the potential for migration of toxic vapors within the breached sewer-plumbing system, this study sets out to evaluate the pattern of PCE migration into upgradient buildings connected by the sewer-plumbing systems but which are clearly outside of the known impacted soil or groundwater plume area.  The significance of the research is that unsuspecting, upgradient occupants in buildings which have vapor seal leaks and which are connected to failed sewer trunk lines which have infiltration of PCE-impacted groundwater may have long-term exposure to toxic vapors.  A second significance is that the scientific and regulatory community has not generally included this exposure pathway in regulatory decision making. The vapor exposure potential for residents or workers outside of the impacted soil and groundwater plume is not part of the standard indoor air exposure model. 

Research Objectives

The following research tasks should be considered in evaluating the role of VOCs in sewer air and the potential for indoor air quality degradation:

1) Working with the local sewer agency, to document the presence of PCE outside the groundwater plume area and to verify the exposure vulnerability of upgradient occupants. The study will start with screening and sampling iteratively in sewer manholes and cleanouts for sewer gases and PCE in a system which intercepts a known groundwater PCE plume. The next phase will follow up in buildings sharing a compromised sewer trunk line within and upgradient of a documented PCE release.  

2) Once detected in outside manholes and cleanouts, indoor air will be sampled within accessible buildings in basements or crawl spaces, at each floor, and near vapor seals such as in bathrooms and kitchens. The project will include the inspection and documentation of plumbing fixtures and the condition of vapor seals in buildings where PCE detections are observed.  Methodology: Perform vapor screening using hand-held digital vapor meters (photoionization detectors [PIDs] calibrated for PCE), and confirm PID detections with discrete air samples using SUMMA canisters analyzed by gas chromatography methods (6L; 24 hrs, EPA Method SIM TO-15);

3) Develop sewer system inspection documentation protocols for sewer agencies;

4) Based on field observations, develop consistent, simple, low-cost and effective building inspection protocols for vapor seal evaluations in buildings where sewer gases or PCE are detected. Improve sewer gas and PCE sampling protocols and methods for low-cost and simple vapor intrusion evaluations of the sewer-plumbing system.  Determine radius of influence for indoor air exposures from initial source of air contaminants for the study area based on field data and observations;

5) Develop simple process and low-cost mitigation measures in buildings for vapor seal repair or replacement; and 

6) Develop a ranking method for sewer replacement and vapor mitigation measures. Prepare a guidance document to share the findings with sewer and regulatory agencies, building owners and environmental professionals.


California Department of Toxic Substances Control (DTSC). 2010. Human Health Risk (HERO), Office of Human and Ecological Risk Overview; Retrieved January 20, 2014; 

Gorder, K. and Dettenmaier, E.  2011.  Portable GC/MS Methods to Evaluate Sources of cVOC Contamination in Indoor Air.  Groundwater Monitoring & Remediation, National Groundwater Association, Fall, Vol. 31, Issue 4, p. 113-119.  

Jacobs, J.A., Jacobs, O.P., and K.G. Pennell. 2014. Geologists and Site Conceptual Models: VOCs and Sewer Gas in Indoor Air Resulting from Migration from Breached Sewer Conveyance Systems, American Institute of Professional Geologists National Meeting, Abstracts, p. 73-74.

Jacobs, J.A., Jacobs, O.P., and K.G. Pennell. 2015. One Alternate Exposure Pathway of VOC Vapors from Contaminated Subsurface Environments into Indoor Air - Legacy Sewer-Plumbing Systems, Groundwater Resources Association of California, Spring 2015, p. 20-24.

Johnson, P. C, and R. A. Ettinger. 1991. Heuristic model for predicting the intrusion rate of contaminant vapors in buildings. Environ. Sci. Technol. 25: 1445-1452.

Johnson, P. C. 2014. Vapor Intrusion: Lessons-Learned from Four Years of Intensive Monitoring of a House Over a Dilute Chlorinated Solvent Plume, GRACast Web Seminar Series on Vapor Intrusion, Part 2, Groundwater Resources Association of California, Sacramento, California, June 25.       

​Massachusetts Department of Environmental Protection (MassDEP). 2011. Interim final vapor intrusion guidance, WSC#11-435. Boston, Massachusetts: MassDEP.

Pennell, K.G., Scammell, M.K., McClean, M.D., Arnes, J., Weldon, B., Friguglietti, L., Suuberg, E.M., Shen, R., Indeglia, P.A., and W.J. Heiger-Bernays. 2013. Sewer Gas: An Indoor Air Source of PCE to Consider During Vapor Intrusion Investigations, Groundwater Monitoring & Remediation; Volume 33, Issue 3, Summer 2013, p. 119–126.

Riis, C.E., A.G. Christensen, M.H. Hansen, and H. Husum. 2010. Vapor Intrusion through sewer systems: Migration pathways of chlorinated solvents from groundwater to indoor air. Presented at the Seventh Battelle International Conference on Remediation of Chlorinated and Recalcitrant Compounds, Monterey. sgs-attachment-1.pdf (accessed August 1, 2014). 

San Francisco Bay Regional Water Quality Control Board (RWQCB). 2013. 2013 Tier 1 ESLs, Summary Table F, December, 19 p.

Sewerage Agency of Southern Marin (SASM), 2010, Sewage Spill Reduction Action Plan; Annual Report on Flow Monitoring, Prepared by RMC, October, Mill Valley, CA, 31 p.

United States Department of the Army. 2001. Plumbing, Pipe Fitting, and Sewerage, Field Manual FM 3-34.471 (FM 5-420), Headquarters, Washington, D.C., August 31, 276 p. 

United States Environmental Protection Agency (US EPA). 2011. Background indoor air concentrations of volatile organic compounds in north American residences (1990–2005): A compilation of statistics for assessing vapor intrusion. EPA 530-R-10-001. Washington, DC: Office of Solid Waste and Emergency Response (OSWER). United States Environmental Protection Agency (US EPA). 2002. OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (Subsurface Vapor Intrusion Guidance), November 2002. 

Other Suggested Readings Regarding Soil Vapor or Indoor Air

Agency for Toxic Substances and Disease Registry (ATSDR). 2004. Health Consultation. Mountain View Sewer Gas Investigation, Scottsdale, Maricopa Country, Arizona, 16 p.

American Society for Testing and Materials (ASTM) International. 2003. "Standard Practice for Installing Radon Mitigation Systems in Existing Low-rise Residential Buildings" (ASTM E-2121-03, February 10, 2003).

Brown, S.K., M.R. Sim, M.J. Abramson, and C.N. Gray. 1994. Concentrations of volatile organic compounds in indoor air — A review. Indoor Air 4:123–124. 

Bylin, C. 2009. New Measurement Data has Implications for Quantifying Natural Gas Losses from Cast Iron Distribution Mains: Pipeline and Gas Journal, September, 2009.Federal Register. 2011. Public comment on the development of final guidance for evaluating the vapor intrusion to indoor air pathway from contaminated groundwater and soils (subsurface vapor intrusion guidance). 

California Department of Toxic Substances Control (DTSC). 2014. Human Health Risk Assessment (HHRA) Note, Office of Human and Ecological Risk (HERO), Table 3, Page 1, Alternate air screening levels currently recommended in lieu of the Spring 2013 RSLs, July 14, 27 p.

Federal Register 76, no. 52: 14660-14661. 

Hartman, B., and J. Jacobs. 2000. Soil Vapor Principles, Standard Encyclopedia of Environmental Science and Technology, J. Lehr, ed., McGraw Hill, New York, NY; p. 11.87 -11.95. 

Hartman, B., and J. Jacobs. 2000. Applications and Interpretation of Soil Vapor Data to Volatile Organic Compound Contamination, Standard Encyclopedia of Environmental Science and Technology, J. Lehr, ed., McGraw Hill, New York, NY; p. 11.96 – 11.112. 

Hawkins, J. 2008. Vapor Intrusion in Texas: Evaluating the indoor air pathway. Presentation to the Society of Texas Environmental Professionals, Texas. (accessed January 13, 2013). 

Hodgson, A.T., and H. Levin. 2003. Volatile organic compounds in indoor air: A review of concentrations measured in North America since 1990. Report LBNL-51715. Berkeley, California: Lawrence Berkeley National Laboratory. 

Holcomb, L.C., and B.S. Seabrook. 1995. Indoor concentrations of volatile organic compounds: Implications for comfort, health, and regulation. Indoor Environment 4:7–26. 

Interstate Technology and Regulatory Council (ITRC). 2007. Vapor intrusion pathway: A practical guideline. VI-1. Washington, DC: ITRC. 

Kladder, D. L, Burkhart, J.F., Jelinek, S.R. 1993. "Protecting Your Home from Radon: A Step-by-step Manual for Radon Reduction."Massachusetts Department of Environmental Protection (MassDEP). 2011. Interim final vapor intrusion guidance, WSC#11-435. Boston, Massachusetts: MassDEP. 

Massachusetts Department of Environmental Protection (MassDEP). 2008. Residential typical indoor air concentrations. Technical Update. Boston, Massachusetts: MassDEP. 

McAlary, T., and P.C. Johnson. 2009. Editorial: GWMR focus issue on vapor intrusion. Ground Water Monitoring and Remediation 29 1: 40-41.

New York State Department of Environmental Conservation. 2002.  "Draft DER-10 Technical Guidance for Site Investigation and Remediation." Division of Environmental Remediation. December 2002.

New York State Department of Health (NYDOH). 2006. Final guidance for evaluating soil vapor intrusion in the state of New York, October, Troy, NY, 82 p.

Office of Hazard Evaluation and Emergency Response (HEER). 2014. State of Hawaii Office Technical Guidance Manual (TGM), Section 7 Soil Vapor and Indoor Air Sampling Guidance, Soil Vapor and Indoor Air Sample Analysis; Interim Final; p. 118-132.; Retrieved June 4, 2014;

Shah, J.J., and H.B. Singh. 1988. Distribution of volatile organic chemicals in outdoor and indoor air. Environmental Science & Technology 22, no. 12:1381–1388. 

Stolwijk, J.A.J. 1990. Assessment of population exposure and carcinogenic risk posed by volatile organic chemicals in indoor air. Risk Analysis 10, no. 1:4 9–57. 

United States Environmental Protection Agency (US EPA). 2012. US EPA’s Vapor Intrusion Database: Evaluation and characterization of attenuation factors for chlorinated volatile organic compounds and residential buildings. EPA 530-R-10-001. Washington, DC: Office of Solid Waste and Emergency Response (OSWER). 

United States Environmental Protection Agency (US EPA). 2011. Background indoor air concentrations of volatile organic compounds in North American residences (1990–2005): A compilation of statistics for assessing vapor intrusion. EPA 530-R-10-001. Washington, DC: Office of Solid Waste and Emergency Response (OSWER). 

United States Environmental Protection Agency (US EPA). 2010. Review of the draft 2002 subsurface vapor intrusion guidance. Washington, DC: Office of Solid Waste and Emergency Response (OSWER). 

United States Environmental Protection Agency (US EPA). 2008a. Draft US EPA’s vapor intrusion database: Preliminary evaluation of attenuation factors. Washington, DC: USEPA. 

United States Environmental Protection Agency (US EPA). 2008b. Brownfields Technology Primer: Vapor Intrusion Considerations for Redevelopment; EPA-542-R-08-001, March, 44 p.

United States Environmental Protection Agency (US EPA). 2003. Toxicological review of hydrogen sulfide (CAS No. 7783-06-4). EPA/635/R-03/005. Washington, DC: USEPA. 

United States Environmental Protection Agency (US EPA). 2003. "Consumer's Guide to Radon Reduction" (EPA 402-K-03-002; revised February 2003).

United States Environmental Protection Agency (US EPA). 2002. Draft guidance for evaluating the vapor intrusion to indoor air pathway from groundwater and soils, EPA 530-D-02-004. Washington, DC: USEPA.

United States Environmental Protection Agency. 2001. "Building Radon Out: A Step-by-Step Guide on How to Build Radon-Resistant Homes" (EPA 402-K-01-002, April 2001).

United States Environmental Protection Agency. 1999a. "Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air, Second Edition.  Compendium Method TO-15; Determination of Volatile Organic Compounds (VOCs) in Air Collected in Specially-Prepared Canisters and Analyzed by Gas Chromatography/Mass Spectrometry (GC/MS), Center for Environmental Research, Office of Research and Development, Cincinnati, OH, January, 52 p.

United States Environmental Protection Agency. 1999b. "Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air, Second Edition.  Compendium Method TO-13; Determination of Polycyclic Aromatic Hydrocarbons (PAHs) in Ambient Air using Gas Chromatography/Mass Spectrometry (GC/MS), Center for Environmental Research, Office of Research and Development, Cincinnati, OH, January, 84 p.

United States Environmental Protection Agency (USEPA). 1998. A comparison of indoor and outdoor concentrations of hazardous air pollutants. Inside IAQ EPA/600/N-98/002 Spring/Summer. Washington, DC: USEPA. 

Vroblesky, D.A., M.D. Petkewich, M.A. Lowery, J.E. Landmeyer. 2011. Sewers as a source and sink of chlorinated-solvent groundwater contamination, Marine Corps Recruit Depot, Parris Island, South Carolina. Ground Water Monitoring and Remediation, 31, no. 4: 63–69. 

More Information

Additional information can be obtained by contacting Olivia Jacobs (cell: 510-590-1099 or email or James A. Jacobs (cell: 510-590-1098 or email to


Clearwater Group performs appraisals for oil and gas royalty interests, production operations, acreage and resources, for valuation and estate planning purposes. In addition to the production declines and production rates, the issue of environmental liability and well destruction are important to assess prior to the production purchase.  Below is a general scope of work that might be performed during an oil and gas field evaluation:

Develop a site history;

Develop a full inventory of all production, as well as royalty payments to others, based on the seller’s information and County or State records, as available.  

Determine production decline curves based on operator records and field production averages;

Determine the general condition of the facilities and property by a site inspection;

Develop cost ranges for environmental liabilities, such as oil leakage near production equipment or pipelines, if present;

Determine cost ranges for well abandonment, if needed; and

Determine value of production based on 3 different valuation methods and prepare a report with the findings.

The Auger Group, Inc. dba Clearwater Group performs oil and gas lease appraisal, cost allocation studies, due diligence, and other evaluations. The firm was incorporated in California in 1990 with offices in Point Richmond, California and San Rafael, California.


Clearwater Group has evaluated mine properties for resource potential, tax value for estate purposes, as well as for environmental issues.  The firm has performed valuations of property with gold and silver resources as well as coal properties.  The company has worked on mitigation measures to minimize acid mine drainage potential of sulfur-rich deposits.

Principal Geologist James A. Jacobs co-authored Acid Mine Drainage, Rock Drainage, and Acid Sulfate Soils (2014, Wiley).

The author is shown at the Richmond Portal of Iron Mountain Mine, a U.S. EPA Superfund Site with a documented -3.6 pH. Photos below show Iron Mountain Mine, with passive mitigation measures to treat acid mine drainage in the eastern U.S.


The identification of the six elements of acidic drainage can be done by easily by professionals and interested persons with a modest budget of a few hundred dollars for laboratory tests.  Most of the elements noted below can be identified by performing a site inspection.

1) Disturbance of pyrite-rich rocks; (identify pyrite with a hand lens and geology maps);

2) Aerobic conditions with oxygen in air and dissolved oxygen in water; (identify with a DO meter and a site inspection);

3) Microbial colonies which use pyrite as terminal electron acceptor for cellular respiration; (identify with a microbiological lab test);

4) Acidphile bacteria produce sulfuric acid (H2SO4) which lowers pH of drainage; (identify pH with a pH meter or pH paper and inspecting for visual evidence such as corrosion);

5) Acids dissolve toxic metals (Al, As, Cd, Mg, Mn, Pb, Zn, etc.) (identify metals with laboratory tests such as EPA Method 6020); and

6) Ecological and economic damage: such as fish kills, dead vegetation, habitat destruction, erosion, etc. (identify with a site inspection and reviewing regulatory reports and other documents and aerial photos).

​Water treatment at Iron Mountain Mine relies on lime treatment as well as stormwater diversion.

Passive constructed wetlands have been used for acid mine drainage treatment.

Cold mix asphalt (CMA) can also be used to incorporate mining wastes into a recycled product. 


Rate Studies  
Agencies need authoritative rate studies and cost control policies to remain financially healthy.  Our principals focus on long-term goal setting and strategic planning as part of the process of comprehensive rate planning, examining annual costs of providing services to customers, and the costs of operations and maintenance, the long-term capital costs and interest, and other factors such as pensions, medical benefits, etc.  to develop a comprehensive  rate evaluation.  Developing an agency-specific rate study or cost control program starts with a discussion of the agency's goals and objectives for the study. 

Types of services which benefit from professional rate studies:

  • Water
  • Wastewater
  • Stormwater
  • Electric
  • Refuse
  • Recycling
  • Flood Control
  • Irrigation
  • Natural Gas
  • Park & Recreation
  • Other

We are a small firm to provide personal and responsive service.  The principals have over 60 years of combined experience and bring in other experts to supplement the team.  Developing an agency-specific rate study or cost control program starts with a discussion of the agency's goals and objectives for the study. 

Since 1990, we have been performing cost allocation evaluations and contract review.  Since 2003, the principals have reviewed dozens of rate evaluations for changes in sewer collection fees, refuse fees, recycling fees, and wastewater treatment rates as board members of a community services district and a local wastewater treatment agency.  We perform comprehensive and defensible rate studies and cost allocation evaluations.

Asset Life
In planning out capital improvement plans, the asset life-cycle should outlast the funding cycle.  We work with engineers and contractors to determine existing asset condition.  We also work with attorneys, and others to prepare defensible rates. 

Community Advisors
We've been around for over 26 years and have provided  value to our customers in cost allocations and economic analysis.  Our team is small, but responsive. Our professional consulting practice relates to comprehensive rate studies and cost control solutions.  Our analysis compares our customer's costs with fees of similarly sized agencies, their budgets, and their costs.  We work with process engineers, bond experts, attorneys and accountants familiar with the special requirements of public agencies.

Community Meetings and Meeting Facilitation:   
Public Meetings and Goal Setting
Strategic Planning Workshops
Environmental Seminars 
Worker and Resident Training           

Agency Environmental Compliance
Stormwater Pollution Prevention Plans (SWPPP)
Dust Control Plans
Noise and Vibration Plans
Erosion Control Plans
Health and Safety Training
NPDES Permits
Evaluating Impacts from Hydraulic Fracturing Operations 

Rate studies evaluate the differences in rates among service providers in nearby areas, and the analyses generally require collection of rate structures, revenues, budgets, schedule of capital improvement projects, service-area demographic characteristics, long-term liabilities and other related information.  

Proposition 218  
A discussion of rates in California could not occur without Proposition 218, the “Right to Vote on Taxes Act”, which was approved by California voters in November 1996.  The proposition is codified as Articles XIIIC and XIIID of the California Constitution. 

Proposition 218 establishes requirements for imposing or increasing property related taxes, assessments, fees and charges. For many years, there was no legal consensus on whether water and sewer rates met the definition of “property related fees”. In July 2006, the California Supreme Court essentially confirmed that Proposition 218 applies to water rates. There are still many unanswered questions regarding Proposition 218, and we work with expert attorneys to evaluate the defensiblity of agency-specific rates.



​The Maher Program, per the City of San Francisco Health Code (SF HC) Article 22A, applies to sites seeking a Department of Building Inspection Permits and planning to move at least 50 cubic yards of soil in areas of Bay fill, areas of current or historical industrial use, areas within 150 feet of an elevated freeway and areas within 100 feet of sites with current or past underground storage tanks (including but not limited to current and former gas stations and dry cleaners).

For more information, see the SFDPH website:



1)  Application and fee to San Francisco Department of Public Health (SFDPH);

2)  Site history as described in the Phase I Environmental Site Assessment (Phase I ESA) defines the Recognized Environmental Conditions (RECs) to be addressed in the Subsurface Investigation;

3)  Work Plan for Subsurface Investigation includes a subsurface evaluation, typically using soil, groundwater and soil vapor samples.  The Work Plan must be submitted to SFDPH for approval then implementation.  the Subsurface Investigation Report is submitted after the findings from the Subsurface Investigation are known; 

4)  The Site Mitigation Plan (SMP) addresses any RECs and current or future environmental issues on the property.  The SMP must be approved by SFDPH and then implemented in the field; and  

5)  The Final Certified Project Report is prepared and submitted to SFDPH documenting SMP implementation. 


The Maher Ordinance was created in 1996 and requires that properties located along certain portions of San Francisco known to be underlain by artificial bay-margin fill be evaluated for the potential presence of soil or groundwater contamination prior to issuance of a grading or building permit on projects disturbing at least 50 cubic yards of soil.  Compliance generally requires a site history review, development of a work plan for soil and groundwater testing, and submittal of a Site Mitigation Plan with recommendations for managing exposure to any hazardous materials disturbed during construction


The City of San Francisco adopted major updates to Article 22A of the San Francisco Public Health Code (Maher Ordinance) in August 2013. These changes expand the types and number of properties potentially subject to SFDPH review and oversight related to the characterization and mitigation of hazardous materials in soil, soil vapor, and groundwater.  A map of areas subject to potential Maher Ordinance rules has been developed.  In addition, regardless of the location, the SFDPH requires a review for any property that meets one of the following criteria:

1)  A property which potentially contains hazardous or contaminated soil or groundwater;

2)  A property which was historically zoned for industrial use;

3)  A property which has ever contained an underground storage tank (UST);

4)  A property which is located within 100 feet of a current or former UST; and 

5)  A property which is located within 150 feet of a freeway.


Stormwater Pollution Prevention Plans, Dust Control Plans, Hazard Communication Plans, Erosion Control Plans, Haz Mat Storage Plans, Injury Illness Prevention Plans, OSHA Health and Safety Plans, and other engineering and safety documents could be required as part of a redevelopment project.  A proposed redevelopment site may be subject to other environmental regulations in addition to the Maher Ordinance.  These regulations include the following:

1)  The San Francisco Health Code, Article 22B, Demolition and Construction Dust Control;

2)  The California Air Resources Board Asbestos Airborne Toxic Control Measure for Construction and Grading;

3)  The State Water Resources Control Board Waste Discharge Requirements or Order 2012-0006-DWQ Construction General Permit for Stormwater Discharges; and

4)  The San Francisco Department of Public Works Order No. 158170 for Industrial Waste Discharges into the City’s Sewer System.