The Phase II Investigation is used to determine if the potential REC (recognized environmental condition) is actually an environmental risk that may require resolution such as closure through a regulatory program.
Remember that the Phase I ESA is a first look at a property’s environmental liability, potential contamination, and any risk factors in the soil, groundwater, or air (vapor intrusion) that might affect the property’s value. The Phase I ESA does not, however, require any sampling to confirm the presence of any environmental concerns. Sampling can be included but is not a required task in the scope per EPA’s All Appropriate Inquiry.
If a potential environmental concern is identified in the Phase I ESA, it is noted as a “recognized environmental condition” or REC and the consultant will recommend further file evaluation and/or sampling. The file review typically includes state and/or EPA files, especially if the Site was previously cleaned up and closed through a regulatory program. However, in most cases, the REC will require sampling of environmental media such as soil, groundwater, and/or air (sub-slab or indoor), which is referred to as a Phase II Site Investigation.
As an example, a strip center has an on-site cleaners that may have used the dry cleaning solvent tetrachloroethene or “perc”. The Phase I ESA will identify the cleaners as a REC and the Phase II Investigation will be performed to confirm if any perc and its related compounds are present in the soil, groundwater, or air at concentrations above regulatory levels.
The scope and resulting cost of the Phase II varies based on the nature of the potential RECs, what media (soil, groundwater, or air) needs to be sampled, number of samples and timing (standard or rush analysis), contaminants identified, and complexity of the Site. Additional sampling and analysis may be required at a later time, if the Site goes into a regulatory program. The initial sampling is generally used to determine if the potential RECs have impacted the property or facility. This iterative approach prevents spending too much in the initial phases of the assessment. In most cases, contaminated properties are placed into a state remediation program to get their concurrence and a final “closure” letter. It’s our experience with numerous Texas sites that this approach has been the most cost effective.
Whitehead E. S. staff has conducted many Phase II Site Investigations of real estate properties and industrial facilities in Texas. Whitehead E. S. has the expertise you need to evaluate potential contaminants of concern (COCs) and develop a “game plan” with potential costs for cleanup and regulatory closure. Our goal is to be your “Deal Maker” and Solution to Pollution!
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