Entry by JoeDerhake
When doing Phase I Environmental Site Assessments, sometime the facts are on the border between a recognized environmental condition and an environmental issue. This blog is my latest in a series of borderline decisions.
Here is the scenario: the Phase I ESA finds a classic REC on site. Let’s say we have 15 years of dry cleaners on-site in the 1970s and 1980s—clearly a REC. However, in this instance the site was redeveloped with a high-rise office building with a 3 level subterranean garage in 1988. The construction project necessitates excavating 40 feet from lot-line to lot-line. Assume groundwater is at 80 feet below ground surface.
The environmental professional may point out that the solvent could have penetrated all of the way to groundwater, but the excavation of 40 feet of soil clearly is a significant mitigating event.
Would you as an environmental professional still consider this situation a recognized environmental condition? Would you recommend Phase II Environmental Testing?
Providing our clients with good environmental risk management opinions is a very important part of our job. Please let me know what you think?
Phase I Environmental Site Assessment, Phase I ESA, Environmental Risk Management, Phase II Environmental Testing