Environmental site assessments, or ESAs, are specific types of reports to let prospective or current real estate property holders know whether a site may contain contamination. These reports have been in use since the early 1970s, with demand increasing following the 1980 passage of CERCLA, the Comprehensive Environmental Response, Compensation, and Liability Act.
In this post, gain an overview of the assessment process and learn specifically what is involved in a Phase 1 site assessment and Phase 2 site assessment.
What is CERCLA?
CERCLA was passed to determine who is ultimately liable for cleaning up contaminated properties and provide federal government assistance to responsible parties as may be needed to achieve remediation.
In some cases, when the responsible party cannot be located, the site is classified as an “orphan” site and the U.S. Environmental Protection Agency (EPA) itself steps in to take charge of cleanup efforts.
CERCLA has since been nicknamed “Superfund” for the federal government’s role in supporting funding and oversight for contaminated properties, or “brownfields,” undergoing remediation.
What is a Phase 1 Assessment?
The American Society for Testing and Materials (ASTM) is the agency responsible for determining what actions are performed during each phase. In Phase 1, the goal is predominantly one of information gathering.
Typically, these assessments are only performed for commercial or industrial properties, or properties that have been used in either way in the past.
Here are the main types of information gathered during a Phase 1 assessment:
- Review of public and government property history records.
- Review of property history for surrounding commercial or industrial properties.
- Interviews with current or past owners.
- Interviews with local residents and neighbors.
- Interviews with local government representatives.
- Interviews with occupants of the property (past or present).
A Phase 1 assessment does not always include actual physical sampling of soil, water, and materials collected from the site being assessed, but it can include this facet if warranted.
The main goal of a Phase 1 assessment is to determine if there is a reasonable likelihood that the site may contain contamination. If this is found to be the case, the next step is generally to order a Phase 2 assessment.
What is a Phase 2 Assessment?
A Phase 2 assessment is ordered when the Phase 1 assessment has delivered information indicating contamination may be present on the property. The focus of a Phase 2 assessment is wholly on gathering data on what types of potential contaminants may exist on the site.
To achieve this goal, a variety of laboratory tests may be performed, including (but not limited to) the following types of tests:
- Soil samples.
- Water samples.
- Soil borings.
- Installation of groundwater monitoring wells on the site and on neighboring properties as may be applicable.
- Samples from any abandoned drums left on the site.
- Samples of any dry wells, catch basins, or floor drains left on the site.
- Sampling of transformers and/or capacitors that may remain on the site.
- Geophysical tests to look for buried drums or wells.
- Underground storage tank (UST) testing.
The laboratory test results will indicate if contamination is indeed present in any of the materials found at the site or on neighboring sites. The results will also indicate the type of contaminants found. Based on these initial laboratory test results, additional tests may then be ordered as needed.
Types of Contaminants Commonly Discovered During Assessments
There are a variety of contaminants that may be present at any site that is now or has been in the past used for commercial or industrial purposes.
Some of the major contaminants often discovered during laboratory testing include (but are not limited to) these:
- Lead or lead-based paint.
- Mold.
- Mercury.
- Radon.
- Asbestos.
- Volatile Organic Compounds (VOCs) and semi-VOCs.
- Hydrogen sulfide.
- Petroleum hydrocarbons.
- Heavy metals.
- Pesticides.
- Solvents.
- Oil.
- Fertilizer.
- Concrete wash water.
- Remedial soil additives.
Each of these and other potential contaminants are termed “chemicals of concern.” Since contaminants can work their way into the air, surface waterways, soil, and underground water table over time, often the remediation effort must cover a wider area than just the contaminated site itself.
A variety of remediation techniques are currently used to address different types of contaminants found in different aspects of the site (such as water, soil, etc.) Most techniques are classified as either “ex-situ,” or excavation for remediation, and “in-situ,” or remediation in place (without excavation). Both techniques are used extensively today and often will be used together at the same site.
Thanks to Phase 1 and 2 assessments, there are nearly half a million sites in the nation currently receiving remediation treatments for eventual productive re-use.