You Completed an Environmental Site Assessment – Now What?

Contributed by Jared S. Saterfiel, Principal/District Manager, PPM Consultants

As an environmental consultant, I have seen the importance of environmental site assessments (ESAs) first-hand. ESAs are an integral part of any real estate transaction, development, or construction project. These assessments provide crucial information about potential environmental liabilities associated with a specific site, allowing property owners, developers, and other stakeholders to make informed decisions.

What is an Environmental Site Assessments (ESA)?

Environmental Site Assessments are systematic investigations conducted to identify potential or existing environmental contamination liabilities. They are typically divided into three phases: Phase I, Phase II, and Remedial Investigations and Planning. These assessments are not just due diligence; they are an essential risk management tool to protect human health, safeguard the environment, and ensure compliance with regulatory requirements.

Whether you are purchasing a piece of land, redeveloping a site, or constructing a new facility, an ESA provides a clear picture of the site’s environmental status. By identifying potential contamination or other environmental concerns, stakeholders can proactively address these issues and avoid costly surprises down the road.

Phase I Environmental Site Assessment

The first step in the ESA process is a Phase I Environmental Site Assessment. This phase is non-intrusive and involves a detailed review of available information about the site. Key components of a Phase I ESA include:

1. Site History Review: This involves examining historical records, aerial photographs, and maps to determine how the property was used in the past. For example, if the property was once used as a gas station, dry cleaner, or industrial facility, these are red flags for potential contamination.
2. Regulatory Records Review: Environmental databases and local, state, and federal regulatory records are reviewed to identify any previous environmental violations or incidents associated with the site or neighboring properties.
3. Site Inspection: The site is visually inspected to identify any observable signs of contamination, such as stained soil, chemical storage, or unusual odors.
4. Interviews: Current and past property owners, tenants, and site managers are interviewed to gather information about historical site activities.

The primary goal of Phase I is to identify Recognized Environmental Conditions (RECs), which are indications of potential environmental contamination. If no RECs are found, the ESA process may stop here. However, if RECs are identified, further investigation is required.

Phase II Environmental Site Assessment

If the Phase I ESA identifies potential environmental concerns, a Phase II Environmental Site Assessment is conducted. This phase involves collecting physical samples and analyzing them to determine whether contamination is present and, if so, to what extent. Key activities in Phase II include:

1. Soil Sampling: Samples are taken from various locations and depths to test for contaminants such as petroleum hydrocarbons, heavy metals, pesticides, or volatile organic compounds (VOCs).
2. Groundwater Testing: Groundwater samples are collected and analyzed to identify contaminants that may have leached from the soil.
3. Air Monitoring: In some cases, air samples are collected to assess indoor air quality or vapor intrusion risks, particularly in buildings located above contaminated soil or groundwater.

For example, a typical Phase II ESA might be required for a former dry-cleaning facility where perchloroethylene (PCE) was historically used. PCE is a common contaminant that poses risks to both human health and the environment. Sampling in such cases would confirm whether PCE is present in the soil or groundwater and determine the necessary next steps.

Remedial Investigation and Planning

If contamination is confirmed during Phase II, the next step is a Remedial Investigation. This phase aims to:

1. Define the Extent of Contamination: This involves mapping the horizontal and vertical spread of contaminants in soil, groundwater, or air.
2. Determine Causes: Understanding the source of contamination is crucial for effective remediation.
3. Evaluate Risks: The investigation assesses the risks to human health and the environment, considering factors such as exposure pathways and contaminant toxicity.

Based on the findings of the Remedial Investigation, a Remediation Plan is developed. This plan outlines the most effective strategies to mitigate contamination, such as:

• Soil Excavation and Disposal: Contaminated soil is removed and disposed of at a licensed facility.
• Groundwater Treatment: This can involve pump-and-treat systems, in-situ chemical oxidation, or other technologies.
• Vapor Mitigation: Vapor barriers or ventilation systems may be installed to protect buildings from harmful gas intrusion.

The remediation process is closely monitored to ensure its effectiveness. Once completed, the site is re-evaluated, and a closure report is prepared to document the entire process.

The Value of ESAs

Environmental Site Assessments offer several critical benefits, making them indispensable for real estate and development projects.

1. Risk Mitigation: Identifying and addressing environmental liabilities early helps prevent unexpected costs, project delays, and potential legal disputes. For example, if a site is contaminated, buyers can negotiate cleanup costs with the seller before closing the deal.
2. Regulatory Compliance: ESAs ensure compliance with environmental laws and regulations at the local, state, and federal levels. Non-compliance can lead to hefty fines, penalties, and reputational damage.
3. Human Health and Environmental Protection: Contaminated sites pose risks to nearby communities and ecosystems. ESAs help identify and address these risks, promoting sustainability and safety.
4. Enhancing Property Value: A clean environmental bill of health can increase property value and make it more attractive to buyers, investors, and developers.
5. Demonstrating Responsibility: Conducting an ESA signals a commitment to environmental stewardship, which is increasingly important to consumers, investors, and other stakeholders.

Real-Life Application

Consider a developer planning to purchase an industrial site for a new housing project. A Phase I ESA reveals that the site was historically used as a manufacturing facility that stored hazardous chemicals. Phase II sampling confirms the presence of heavy metals and VOCs in the soil and groundwater.

Thanks to the ESA, the developer is now aware of these issues and can work with environmental professionals to remediate the site before construction begins. This proactive approach not only protects future residents but also enhances the project’s marketability and ensures compliance with regulatory standards.

The Role of Environmental Professionals

Conducting an ESA requires specialized knowledge and expertise. Environmental professionals play a vital role in ensuring the accuracy and reliability of the assessment process. They are trained to:

• Interpret historical and regulatory data.
• Design and execute sampling plans.
• Analyze and communicate complex environmental findings.
• Develop cost-effective remediation strategies including ensuring all measures of liability protection through various regulatory programs are considered early in the process.
• Pursuit of any public grant monies that may be available for assessment or clean up of the property

As an environmental consultant, I strongly recommend conducting an ESA for any real estate transaction, development, or construction project. This due diligence process is not just a legal or financial safeguard—it is an investment in public health, environmental protection, and sustainable development.

Partner with PPM Consultants for Your ESA Needs

If you are considering a real estate transaction, development, or construction project, contact us at PPM Consultants to discuss how we can assist with your ESA needs. Our experienced team of environmental professionals offers comprehensive ESA services tailored to your specific project requirements. From Phase I assessments to full-scale remediation planning and execution, we are here to ensure your project meets all environmental regulations and is safe for all involved.

Taking the time to conduct an ESA upfront can save you significant time, money, and stress in the long run. Trust PPM Consultants to provide the expertise and support you need to navigate the environmental challenges of your next project with confidence.

If you want to discuss the ESA process for your pending project, please feel free to reach out to me at jared.saterfiel@ppmco.com.