ENVIRONMENTAL SITE ASSESSMENTS
OHIO COMMUNITY DEVELOPMENT CONFERENCE
JENNIFER MILLER NOVEMBER 7, 2012
ENVIRONMENTAL SITE ASSESSMENTS
“The assessment or evaluation of a property to identify
potential environmental contamination and assess potential
liability for any contamination present at a property.”
- U.S. EPA All Appropriate Inquiry guidelines
ENVIRONMENTAL SITE ASSESSMENTS
Why do we do environmental site assessment?
> CERCLA (Superfund) and All Appropriate Inquiry
> General liability: protecting occupants of and visitors to the
completed project protects the owner as well
> Economic benefit: finding and addressing environmental
concerns results in a more marketable property
ENVIRONMENTAL SITE ASSESSMENTS
How to use your ESA report and consultant
PHASE I ESAIDENTIFYING ENVIRONMENTAL CONCERNS
PHASE I ESA
How do we do phase I ESAs?
> All Appropriate Inquiry: 40 CFR 312
> ASTM E 1527-05 – Standard Practice for Environmental Site
Assessments: Phase I Environmental Site Assessment Process
(currently under revision)
> OEPA Voluntary Action Program: OAC 3745-300-06
PHASE I ESA
Recognized Environmental Condition:
> The presence or likely presence of any hazardous substances or
petroleum products on a property under conditions that indicate
an existing release, a past release, or a material threat of a
release of any hazardous substances or petroleum products into
structures on the property or into the ground, ground water, or
surface water of the property.
PHASE I ESA
Recognized Environmental Condition:
> The term includes hazardous substances or petroleum products
even under conditions in compliance with laws.
PHASE I ESA
Recognized Environmental Condition:
> The term is not intended to include de minimis conditions that
generally do not present a threat to human health or the
environment and that generally would not be the subject of an
enforcement action if brought to the attention of appropriate
governmental agencies. Conditions determined to be de minimis
are not recognized environmental conditions.
PHASE I ESA
What do we do?
> Site history
> Government databases
> Site inspection
> Interviews
> Report
PHASE I ESA: SITE HISTORY
Determine history of use to 1940 or earliest developed use,
whichever is earlier
> By definition, “developed use” includes agricultural use
> Five year intervals; larger intervals are allowed if use is obviously
unchanged (but use caution)
> Allowance for “data failure”
PHASE I ESA: SITE HISTORY
Aerial photographs (from engineer/planning, NRCS, ODOT)
PHASE I ESA: SITE HISTORY
Historical USGS topographic maps (online)
PHASE I ESA: SITE HISTORY
City/suburban/rural directories (local library history rooms)
PHASE I ESA: SITE HISTORY
Sanborn maps (local historical societies, OPLIN)
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