Environmental assessments and audits are completed at industrial and commercial sites for a variety of reasons. Real estate property transactions (e.g., purchase, sale, refinancing) are typically the driver for Phase I Environmental Site Assessments (ESAs). Suspected releases often dictate a need or desire to conduct a Phase II ESA to confirm whether or not the release impacted the environment. Many companies incorporate third party Environmental Compliance Audits (ECUs) conducted by experienced environmental consulting professionals into their overall compliance programs to supplement their day-to-day compliance activities and/or to satisfy corporate Environmental Management System (e.g., ISO 14001) requirements.
A Phase I Environmental Site Assessment (ESA) is an investigation completed to research the current and historical uses of a property as part of a commercial real estate transaction to identify potential liabilities for the buyer, seller, owner, or lender related to potential environmental concerns. The intent of the assessment is to evaluate if current or historical property uses could have impacted the soil or groundwater and pose a threat to the environment and/or human health. Phase I ESAs are typically completed in accordance with the specific ASTM E 1527-13 Standard Practice for Environmental Site assessments, adhering to a comprehensive report outline, rigorously addressing all items identified in this Standard.
A Phase II ESA is performed if there is a known potential for environmental concerns to be present. For example, if a Phase I ESA identifies areas of concern, a Phase II may be performed to determine whether or not contamination is present. A Phase II evaluation typically involves intrusive investigation (e.g., drill, Geoprobe®, hand auger) to collect samples of soil, groundwater, surface water, and/or suspected hazardous materials for laboratory analysis for potential pollutants of concern. Data from the sampling effort is compiled and evaluated relative to regulatory, health, and/or ecological risk standards/thresholds, and the Phase II report documents the investigation methods, results, findings, and recommendations.
An Environmental Compliance Audit (ECA) is conducted by a qualified environmental compliance specialist at an operating industrial facility to evaluate existing operations, standard operating procedures, records, and reporting to assess compliance with applicable environmental regulatory requirements. The ECA is typically initiated with a review
of existing environmental permits, plans, compliance reporting/recordkeeping, and communications with agencies that can be provided prior to conducting the site visit to identify applicable requirements from federal, state, and/or
local environmental regulations to focus the site visit and evaluation to those program elements specifically applicable to the facility. The onsite portion of the audit then involves further review of available regulatory documentation, visual inspection of operations, and interviews with facility personnel. Following the facility inspections and information gathering, the compliance specialist often conducts a close-out meeting with facility environmental and/or management personnel to review and discuss preliminary findings. An ECU report then typically documents the inspection, findings, and recommendations. Findings are often broken out into those that could be a violation and others that are recommended best practices or areas for improvement.
Environmental Assessments/Audits need not always fit one of the standard categories, nor include all elements of a certain type of study. These investigations can be tailored to cover specific needs and program elements. For example, a facility environmental manager may have a good handle on most environmental programs at his/her facility, such as hazardous waste, wastewater, stormwater, and spill prevention, but have concerns that there may be air quality issues that he/she is unaware of. An air quality regulatory review audit can then be tailored to only look at and evaluate compliance with the facility air permit and identify applicable air quality regulatory requirements that may have been missed in the existing program from federal/state regulations.
The EI Group, Inc. (EI) has been providing a wide variety of environmental due diligence and compliance audit services for over 30 years for lenders, developers, borrowers, investors, and industrial facilities. EI has performed these services in all 50 states and abroad.
To schedule an environmental site assessment or with questions regarding environmental issues, contact Mark Cramer, PE at (919) 459-5229 or mcramer@ei1.com.