Environmental Investigations
Phase I Environmental Site Investigation (ESI)
§ Initial environmental investigation of a Subject Property. This investigation includes, but is not limited to, a visual site inspection, historical data searches of governmental records, and interviews.
§ The objective for a Phase I is to determine any recognized environmental conditions at the Subject Property including, but not limited to: the presence or releases of hazardous substances, asbestos, lead based paint, historical uses of the Subject Property, and contaminated adjoining properties.
Phase II Subsurface Soil Investigation (SSI)
§ If the phase I ESI recognizes any environmental concerns at a site that may affect the soil, a phase II SSI may be warranted. This investigation includes the advancement of soil borings and/or installation of monitoring wells. Samples from these borings/wells are submitted to a laboratory for analysis of specific target indicator compounds. This analysis is dependant on historical or current processes, underground storage tanks or other environmental concerns at the site.
§ If the water/soil samples that are analyzed have contain concentrations of contaminants of concern above a certain level (IEPA Tier I comparison charts), then it is usually recommended that the site be entered into the voluntary site remediation program with IEPA in order to obtain a No Further Remediation Letter.
Site Remediation Program (SRP)
§ The point to this program is to define the extent of contaminants at the site, and to remediate them, so that they no longer pose a threat to human health or the environment. The “No Further Remediation” letter is the end result of this program.
§ Enrollment into this program will call for additional investigations of the subsurface soil to determine the extent and quantity of the contamination.
§ The first investigation to be carried out is a comprehensive site investigation. This will define the extent of all contaminants of concern at the site.
§ Once the comprehensive site investigation is carried out, a comprehsive site investigation report is written up to report the findings.
§ Based on the findings a remedial objectives report is written up which attempts to model any contaminants of concern at the site. To define if they are going to migrate onto adjacent sites or into surface water or drinking water.
§ Once the remedial objectives report is finalized a remedial action plan is drawn up in order to lay our the plan for remediation. This report makes recommendations on whether soil may be left in the ground and capped with concrete, or whether soil needs to be removed from the site to a landfill or actively remediated through an insitu process, of which there are many methods available.
§ Active remediation will be carried out only if concentrations in the soil or groundwater are above certain IEPA acceptable concentrations. (Normally when you can actually see the contaminants with the naked eye. Otherwise, remediation entails capping with concrete, three feet of clean soil, or using an institutional control such as a city wide groundwater ordinance prohibiting groundwater to be used as a potable source.
§ Once these investigations, remediation and reports are finalized a final remedial action completion report is submitted to the IEPA for review. This report concludes and summarizes findings, and stipulates what will be attached to any deed in order for a site to obtain the “No Further Remediation” letter.
§ Each report is reviewed by the IEPA and additional investigations and changes to plans may be made along the way. Once entering the program from start to finish if can take 9-12 months to obtain the “No Further Remediation” letter. Most of this time is spent with reports sitting at the IEPA for review.
1 comment:
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