ENVIRONMENTAL LAW Scenario

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You are the manager of a small business that wants to start a new business cleaning electrical circuit boards under a Department of Defense contract. The boards are to be cleaned with MEK. The MEK is sprayed on the boards and then wiped off with lint and static free cotton wipes. The wipes are disposed after use. You will need to process a large number of boards to be competitive. You will use approximately 200 gallons of MEK each day and you will need to have about a ten day supply on-site. You will use a high-tech spray system so most of the MEK will be gathered on the wipes with a recovery of about 80%. The remainder will be vented to the atmosphere to protect your workers. Waste wipes will require disposal. This will require expansion of our facility on one of two properties. The local City government owns both but has leased the property to businesses. Both businesses went bankrupt and the owners fled to South America. The City would like to transfer the land to a private enterprise and recover some of their costs. The first site covers about 100 acres and lies in a low area which the City considers a useless bog. They will sell the property for about $500 and acre. The bog covers about 20 acres but your engineers feel that they can fill the area to provide a satisfactory foundation for a new building. The site also has a small dump. The engineers state that the dump really isn’t much of a problem. There are about 10-15 five-gallon cans that are empty. The engineers made a quick survey of the area and kicked the cans to determine that they were empty. The labels on the cans are old but on two of the cans they could read “Silvex”. This must be some type of paint or other product so it isn’t really a problem, after all the cans are empty. There are also some broken concrete blocks and bricks in the dump. There are a few tires in the dump but one worker has already asked for them. He plans on making tree swings for his kids on his lakeside property. There is an old power pole that once serviced an old service station. The station fell down several years ago. There is a considerable amount of fire resistant exterior tile lying about the area. Below the power pole, a transformer is sitting on the ground. There is a leak in it with an oil stain approximately 5 feet in diameter. The engineers noted that there were several pipes sticking out of the ground. These can easily be pulled out using the bulldozer that will be used to push the old station and transformer into the dump for fill.