This document describes various types and names of “Environmental Site Assessments” (ESAs), and the uses for which they are often intended. Many different interpretations of terms and assessment types are used in industry. Chapman Engineering offers the following as factual information, when a “standard” applies in the industry, and as professional opinion in other cases.

Phase I ESA

This ESA provides a property buyer or financing entity with significant background information about property land use history, title chain study (if necessary), observable environmental conditions, and potential for influence from other properties. The American Society for Testing and Materials (ASTM) has produced a well-known and commonly used outline for a Phase I (ASTM E 1527-97, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process):

1. EXECUTIVE SUMMARY

2. INTRODUCTION
2.1 Purpose
2.2 Special Terms and Conditions
2.3 Limitations and Exceptions of Assessment
2.4 Limiting Conditions and Methodology Used

3. SITE DESCRIPTION
3.1 Location and Description
3.2 Site and Vicinity Characteristics
3.3 Descriptions of Structures, Roads and Other Site Improvements
3.4 Information Provided by User Regarding Environmental Liens, or Specialized Knowledge or Experience
3.5 Current Uses of the Site
3.6 Past Uses of the Site
3.7 Current and Past Uses of Adjacent Properties
3.8 Site Plan

4. RECORDS REVIEW
4.1 Standard Environmental Record Sources, Federal and State
4.2 Physical Setting Sources
4.2.1 Topography
4.2.2 Soil/Geology
4.2.3 Surface Water Hydrology
4.2.4 Subsurface Hydrology
4.3 Historical Use Information

5. INFORMATION FROM SITE RECONNAISSANCE AND INTERVIEWS
5.1 Hazardous Substances in Connection with Identified Uses
5.2 Hazardous Substance Containers and Unidentified Substance Containers
5.3 Storage Tanks
5.4 Transformers or Indications of PCBs
5.5 Discharge Incidents or Solid Waste Disposal/Open Dumping
5.6 Interviews
5.7 Potential Contaminant Receptors
5.8 Review of UST Monitoring Records for Previous Monitoring (subject to current owner providing access to records)

6. FINDINGS AND CONCLUSIONS

7. QUALIFICATIONS OF REPORTING PERSONNEL


Phase II ESA

The Phase II ESA incorporates actual sampling (whether above-ground or underground, and for air, soil, water, building materials or other media) to identify whether and to what degree a site suffers from contamination. It may be proposed to include all aspects of a Phase I, or it may be proposed as work separate from the Phase I step. Sampling may be for such contaminants as asbestos, lead in paint or other materials, PCBs, hydrocarbons, pesticides and herbicides, or other more exotic compounds. ASTM has recently issued a standard practice for Phase II performance, which is gaining acknowledgment and support over time.

Phase III ESA

The Phase III ESA usually involves actual remediation (cleanup) of contamination identified on a property. Most often this is done with full disclosure to regulatory agencies, and cleanup objectives are tied to target levels set by regulators. Additional contaminant sampling and reporting of all activities is typical. In Texas, and since 2000, the Texas Risk Reduction Program rules have governed much assessment and cleanup activity, using risk-based corrective action (RCBA) principles. This involves the identification of target "chemicals of concern" (COC's), setting "protective concentration levels" (PCL's) for each COC, then performing cleanup based on the risks identified.

Transaction Screen

A transaction screen, as defined in an ASTM “Standard Practice” E 1526-93, is a less intensive overview of a property than a Phase I ESA. It is usually performed for a buyer or financing institution. This screen most often consists of a property walk-through, and possibly interviews with people familiar with the properties current use.


Minimum Site Assessment (MSA)

The MSA was an assessment on property affected by petroleum storage tanks (PST), performed in Texas using a guideline established by the Texas Petroleum Marketers and Convenience Store Association (TPCA). This guideline was created in fall 1995 in response to a Texas Commission on Environmental Quality (TCEQ) regulation requiring site assessment to find whether PST locations in Texas needed access to the TCEQ Reimbursement Fund. TCEQ required a minimum assessment in order to preserve the original deductible amount a responsible party would pay on a Leaking Petroleum Storage Tank (LPST) case for which the State of Texas would reimburse costs.

The MSA required that all potential source areas (current and former tankholds, line trenches and dispenser islands) be sampled to see whether petroleum contamination exists above TCEQ action levels. If so, the site was then listed as an LPST case and required more rigorous assessment. This form of assessment passed out of existence at the end of 1998, at the same time that TCEQ stopped accepting new LPST case discoveries for reimbursement eligibility.

Risk-Based Assessment (RBA) and Risk-Based Corrective Action (RBCA)

Between 1992 and 1995, Texas and many other states recognized that cleaning up contaminated sites, whether for petroleum or more exotic contamination, was prohibitively expensive (or technically improbable) if every site had to be cleaned to background levels. US EPA, ASTM and many state agencies cooperated to create a risk-based assessment model, in which a site is studied to see if contamination actually poses a current or potential threat to human, animal or ecological health. RBCA (“Rebecca”) was formalized for petroleum storage tank locations under the ASTM Standard E 1739, “Risk-Based Corrective Action Applied at Petroleum Release Sites.”

Plan A Risk-Based Assessment

Virtually all TCEQ programs are now incorporating RBCA and RBA. In LPST work, TCEQ directs that the first assessment performed on an LPST site be the Plan A Risk-Based Assessment. This assessment defines a contamination plume in soil, and possibly in ground water, vertically and laterally. A site’s LPST case may close after a Plan A assessment, if all contaminant levels fall below very conservative target concentrations set by TCEQ. As a secondary review, if contaminant levels are above targets, the site may still close if certain “exit criteria” TCEQ has created allow such closure.

Plan B Risk Assessment

This risk assessment was common in Texas under the LPST program from 1996 through the 2001-2002 time period. It has been used sparingly since then, and risk assessment is more commonly tied to Texas Risk Reduction Program (TRRP) rule requirements and guidance in Texas at this writing.

If contaminant levels were higher than target levels, and exit criteria defined by TCEQ did not allow site closure, TCEQ usually directed performance of a Plan B assessment. Plan B took into account more site-specific information that can allow a site to close if, for instance, shallow soils have hydrocarbon vapors but there is a permanent concrete drive over the contaminated soils. A Plan B developed levels of contamination that were safe to be left in place, because of site factors that decreased the measured risk to receptors, whether people, animals or plants. Plan B assessments have been replaced by the new Texas Risk Reduction Rule Program (TRRP), which takes the same general "risk assessment" methodology and applies it in more comprehensive fashion..

Texas Risk Reduction Program, 30 TAC Chapter 350

In 1998, TCEQ released new draft “Risk Reduction Program” Rules. These rules are meant to take all TCEQ-managed assessment/cleanup programs into a common “risk reduction” approach to assessment and remediation. This resulted in creation by rule of 30 TAC Chapter 350, the TRRP rules. Cal Chapman was and industry representative to the (then) TNRCC/Industry working group, which over about nine months wroked on what became the rule language adopted. The TRRP Rule was adopted in September 1999, and became effective January 1, 2000.

Once the rule went into effect, TNRCC and industry representatives formed a number of guidance task groups, who created more than 30 detailed gudance documents. These documents helped to define the practices and details inferred or intended by the TRRP rules. Mr. Chapman co-chaired TRRP-13 for three years.

Even now, some guidance documents have not been finalized. However, Texas has built the strongest "working model" of risk-based corrective action (RBCA) in the United States, in this company's opinion. In many instances, using the TRRP rules and guidance result in more comprehensive assessment, and better definition of both the contamination plumes and the risks associated with contamination. The end result is that less money is spent on actual cleanup. Often, the total costs associated with the contamination release, its assessment and cleanup are lower than what would happen under the old "decontaminate to background" approach. This often led to digging and hauling a problem, only to relocate it elsewhere..

Other Assessments

Assessments may start as Phase I’s or II’s, and can lead to discovery of hazardous substances. When contaminants such as dry cleaning fluids (chlorinated solvents), PCB-containing oils, heavy metals, or other hazardous substances are found on a property, further assessments are performed under ”Resource Conservation and Recovery Act” (RCRA) or Superfund regulations. These are now commonly overseen by TCEQ, but may involve US EPA as well. Chapman Engnieering has assessed and remedaited former dry cleaners, animal dipping vats on ranches, LPST facilities, landfills, and a host of other properties.

TCEQ established a Voluntary Cleanup Program (VCP) in fall 1996 for site owners who want to voluntarily initiate site assessment and cleanup. This allows a property owner to possibly avoid compliance violations and fines, and restore compromised property with possible financial help from the State of Texas. As part of this program, some property owners are eligible for an “Innocent Owner/Operator Program/Certification (IOP).”

US EPA and many states have generated what is called the “Brownfields” program. This allows property owners or prospective purchasers to rehabilitate old industrial locations, many of which are completely abandoned. Using RBCA approaches, the properties are cleaned up to acceptable risk levels, then re-developed into similar industrial or commercial uses as what had been historically performed. This commonly involves CERCLIS (Superfund) sites listed by US EPA.


For questions or estimates regarding environmental site assessments, please contact Chapman Engineering at 800/375-7747.

Copyright 1998, EFSI
Copyright 2000-2008, Chapman Engineering