SOIL MANAGEMENT
ESA alone typically takes three to four weeks to complete. However, a Phase I ESA is not necessarily required, nor do you need to wait to have one completed before considering how soil might impact your project.
During a Phase I, or when scoping a project without one, former uses of the property – and those nearby – that may have resulted in contamination to the project site are identi- fied. Some potential sources of contamination include:
Spills/releases of hazardous substances Underground storage tanks Abandoned pipelines Bulk petroleum storage Railroad tracks Agricultural use Chemical/pesticide mixing or transfer stations Illegal dumping Industrial use
Deteriorating lead-containing paint on building exte- riors
Properly applied pesticides beneath building founda- tions
Through training and experience, qualified professionals use knowledge of contaminant sources, geologic setting, and historical practices (i.e., common practices during a specific time in the site region) to assess the likelihood of potential impacts to the property. The types of contaminants expected, their persistence and characteristics, potential pathways, and future land use are also considered when determining if there are RECs that might affect the property and additional investigation is warranted.
Some property uses are a dead giveaway that sampling should be conducted prior to construction. Examples include gas stations, auto repair shops, dry cleaners, firing ranges, and sugar mills.
Other uses that may result in contaminated soil are much more subtle. Redeveloping a former gym built in 1991 into student housing? Not a problem. But if that gym was built in 1970, sampling for organochlorine pesticides, arsenic, and petroleum products beneath the building slab if it is to be demolished is prudent. Why? Because from the mid-1940s to the late 1980s, it was common practice in Hawaii to apply chlordane (an organochlorine pesticide) and related termiti- cides beneath building slabs to manage pests. The pesticides were often mixed with arsenic and, occasionally, the mixture was suspended in diesel or similar petroleum-based carriers for sprayed-on application. While the proper application of pesticides isn’t considered a REC provided the slab remains intact, it becomes both an environmental and worker protec- tion issue during redevelopment if the slab is disturbed (e.g., cut to retrofit utilities or demolished entirely).
Even when one is “pretty sure” there are no impacts to the site, sampling may be warranted if there will be excess soils generated during construction that will not be reused on-site. Typically, the landfill or recycling facility will require proof
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that soil meets their acceptance requirements. Furthermore, offsite re-use of soils can be very risky without thorough documentation that the soils do not contain contaminants at concentrations greater than the applicable environmental action levels. Without such documentation, regulatory viola- tions/citations, potential lawsuits, and punitive damages are very real concerns.
Already Have Sampling Data?
Existing data should be reviewed by a qualified environ- mental professional to ensure the investigative methods and conclusions were sound. Even if the existing data met previ- ously required contaminant criteria, that may not be the case today. Regulatory standards, industry best practices, and environmental action levels change over time, with a general tendency to become stricter as additional knowledge is gained. Soil sampling conducted in 1990 typically cannot be relied on in 2022; the regulatory landscape has changed. Furthermore, disposal facilities typically only accept analytical results for samples collected within the past year.
There’s a lot to understand when it comes to soil manage- ment. Having a knowledgeable consultant to help navigate those waters can save a lot of time and money, especially when brought onboard early.
What is Your End Game?
Prior to initiating an extensive investigation, it is critical to determine the project objectives (Figure 1). Is a “no further action” designation from the regulatory agency required so the property doesn’t carry any environmental encumbrances? Is the plan to manage contamination in place, if encountered, or to excavate soils that contain contaminants at concentrations greater than the most conservative action levels? There are benefits and drawbacks to both approaches, and a good con- sultant can help guide the decision process. Alternatively, the project objective may be limited to worker protection during trenching activities, in which case an entirely different tactic would be warranted.
The sampling and analysis approach should be developed to meet the stated project objectives, budget, and timeline while still satisfying regulatory and disposal/recycling require- ments. A Sampling and Analysis Plan (SAP) is often prepared to formally define the project objectives and the investigation intended to address those objectives. For some undertakings, obtaining advanced regulatory approval can prove very benefi- cial, although doing so typically adds to the early part of the schedule. It all takes time, and often more than expected. If the required environmental sampling is not performed early in the planning and design phases, the project budget may be impacted by higher costs due to expedited analytical costs and increased contractor and consultant fees.
What is the Phase II Process?
Once the SAP is approved by all parties, the Phase II ESA – where the actual sampling takes place – can be initiated.
During the Phase II, samples of soil, groundwater, soil vapor, surface water, and/or sediment are collected as specified in the project scope or SAP. Before sampling occurs, the site must be adequately prepared to avoid delays in field activi- ties due to restricted access. This may involve removing any
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