Further Investigation Phase I/II & Site Remediation

Size: px

Start display at page:

Download "Further Investigation Phase I/II & Site Remediation"

Sara Flowers
6 years ago
Views:

1 Further Investigation Phase I/II & Site Remediation Office of Environment and Energy April Presentation Objectives Introduction to further investigations Evaluating professional reports Online resources 2 1

2 Further Investigations Phase I ESA Phase II ESA Other studies as needed Clean-up as needed 3 Phase I ESA ASTM E , Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process Known as the Phase I or Phase I ESA Developed to address business risk 4 2

3 Who is ASTM International? Nonprofit organization for professionals worldwide Sets industry standards Publishes over 12,000 standards on a variety of industrial processes, design & measurement techniques 5 EPA Standard All Appropriate Inquiries Rule 40 CFR 312 CERCLA - landowner strictly liable AAI - procedure for providing landowner protection ASTM E satisfies AAI procedure 6 3

4 HUD Residential Risk Standard 24 CFR 58.2(i)(2) Phase I Purpose Section - include a statement that, in addition to satisfying AAI, the Phase I is being carried out to address 58.5(i)(2). 7 Phase I ESA Prepare in accordance with ASTM E1527, latest standard ASTM E1527 Appendix X4 sets out organization of report and content 8 4

5 Phase I ESA - validity Valid for 180 days 180 days 1 year requires updating in accordance with the standard. > 1 year new Phase I 9 Phase I Timing - validity At user discretion an older Phase I may be adequate depending on knowledge of whether conditions at or around site have changed 10 5

6 Phase I ESA Non intrusive investigation Identifies Recognized Environmental Conditions (RECs) Historical RECs (HRECs) Controlled RECs (CRECs) not remediated to unrestricted residential use standard. Vapor Migration 11 Phase I Non-Scope considerations Past agricultural use pesti- or herbi-cide use Lead Asbestos Radon May be included at user request 12 6

7 Phase I user evaluation Make sure the EP has access to the entire site Provide EP with information Ask for a draft of the report Read the whole report Does it follow the standard Look for data gaps Are vapor conditions analyzed 13 Phase I user evaluation Read the Findings and Conclusions Recommendations should be included Further investigation recommendations (for RECs/non-scope findings of concern) Activity/Use Limitation summary (for CRECs) 14 7

8 User determines next steps Ultimately it is user s (RE s) determination whether further investigation needed 15 Identifying Options for Further Investigation 16 8

9 Phase II ASTM E Site-specific sampling technique designed by EP for the specific type of contamination suspected and unique site setting 17 Possible outcomes from Phase II Data shows the concern does not require any further investigation, remediation or other measures Data refines conceptual site model in a way that identifies need for further testing (Phase III) 18 9

10 Possible outcomes from Phase II Data indicates possible contamination Consider rejecting site, or Involve appropriate oversight agency and contractors to design and approve remediation/control approach 19 Vapor Migration 20 10

11 21 Vapor Migration E1527 Phase I assesses releases of hazardous substances into the environment / property /structures Not limited to specific media (soil, water), so includes vapor 22 11

12 Vapor Migration E Vapor Encroachment Screening E recommended area of consideration (AOC) = 1/3 mile Based on type of contaminant EP may reduce/expand BUT, residential development requires most cautious approach to vapor migration 23 Vapor Migration Tier 1, Tier 2 Conclusion of Tier 1 - VEC likely exists/cannot be ruled out Move to E2600 Tier 2 screening or Reject site ASTM E Tier 1 protocol, Section 8 Tier 2 protocol, Section

13 Testing for vapor Several possible types of testing groundwater, soil gas, indoor air quality (existing buildings) Oversight not always clear first contact health department, EPA, and/or state guidance 25 Useful Resources EPA Vapor Page: n/ EPA brownfields redevelopment & vapor guidance: C%20Vapor%20Intrusion%20Consider ations%20for%20redevelopment%20 EPA%20542-R pdf 26 13

14 LSTF Oversight 27 Remediation Standard Closing the Loop Due to: o Sensitivity of residential development o Potential for EJ in affordable housing o Stringent 58.5(i)(2) requirements ( free of ) 28 14

15 Remediation Standard Closing the Loop Whenever: Contamination potential on a site confirmed through Phase II testing (or previously known) Always complete necessary steps to obtain: No Further Action Required (NFAR) letter from local, state, tribal or federal oversight agency 29 Federal Self-Implementing Cleanup Program for PCB remediation Follow 40 CFR (a) EPA Brownfields website Superfund Program

16 State websites California mapper ov/ California Vapor Intrusion up/vapor_intrusion.cfm 31 State websites Arizona Arizona Department of Environmental Quality (ADEQ) Nevada - Nevada Division of Environmental Protection's (NDEP) Hawaii Hawaii Department of Health (DOH)

17 Questions, Comments, Concerns Thank You for Participating 33 17

VAPOR ENCROACHMENT VAPOR INTRUSION; TRANSACTIONAL ASSESSMENT OF THE POSSIBLE VAPOR INTRUSION PATHWAY

VAPOR ENCROACHMENT VAPOR INTRUSION; TRANSACTIONAL ASSESSMENT OF THE POSSIBLE VAPOR INTRUSION PATHWAY By Russell Griebel, P.G., C.P.G. United Consulting Presentation Talking Points How We Got Here Vapor