Environmental Site Assessments – Phase 1
HOW IS A PHASE 1 ENVIRONMENTAL SITE ASSESSMENT (ESA) PERFORMED?
A Phase 1 ESA follows the American Society of Testing and Materials (ASTM) guidelines known as ASTM-E-1527-05 Stand for Phase One Environmental Site Assessments (ESA).
Only a full Phase 1 ESA will satisfy the liability protection under CERCLA for “recognized environmental conditions”- the presence or likely presence of hazardous substances and petroleum products on a property under conditions that indicate an existing release, a past release or a material threat of a release into ground, groundwater or surface water.
THE PROCESS
Records Review
- Title Review – What was the property used for in the past? Are there any uses that might raise a red flag?
- Determine the surrounding land use – An important part of the assessment as the contamination risk can increase significantly if the adjacent properties have documented or potential contamination.
- Historical aerial photograph review – A report will almost always include historical aerial photographs to review a time-line for development of the property as well as adjacent properties.
- Agency and record discovery – Agencies such as fire departments, local health departments, petroleum tank management associations and water departments may be contacted in order to gather current and historical information concerning the property and surrounding area.
Site Investigation
- A visual inspection of the property and any buildings.
- The confines of the building(s) are inspected and property boundary measurements observed. The focus of a Phase 1 inspection is environmental and does not include the structure of any of the systems of the building.
- Photographs are taken of the property.
- No physical testing or sampling is conducted during a Phase 1 ESA.
Interviews
- Interviews will be conducted with anyone who may have information that would help with the report. For example, past and present property managers, tenants and owners.
- If there is a concern regarding surrounding properties, interviews may be conducted with people who have been or who are involved with that property.
Report
- Documentation – Findings, opinions and conclusions must be supported by documentation to facilitate the assessment.
- Scope of Services – The report will describe all services performed in detail to allow for another party to reconstruct the work completed during the investigation.
- Findings – The Findings section identifies known or suspected recognized environmental conditions.
- Opinion – Includes the environmental professional’s opinions of the impact on the property of conditions identified in the Findings section.
- Additional Investigations – The environmental professional should include an opinion if any additional investigations are necessary to further clarify any findings that may indicate there are environmental concerns.
- Data Gaps – Should there be any significant data gaps that affect the ability to evaluate the property, these need to be identified and commented on.
- Conclusions – Provides a summary of all recognized environmental conditions associated with the property.
The comprehensive Phase 1 ESA Report will identify all known or suspected hazardous material or petroleum product releases with recommendations for sampling and analysis (referred to as a Phase 2) and/or remediation/clean-up (Phase 3).