Phase I Environmental Site Assessment Checklist

A Phase I Environmental Site Assessment (ESA) is a vital step in understanding the environmental condition of a property. Conducted according to ASTM E1527-21 standards, this process is designed to identify potential environmental risks and liabilities. Whether you’re a property buyer, developer, lender, or consultant, having a clear checklist can streamline the process and ensure no critical steps are missed. Here’s a comprehensive Phase I ESA checklist to guide you through the key tasks and considerations.

1. Define the Scope of Work

Before starting a Phase I ESA, it’s essential to clearly define the scope of work. This includes:

• Understanding Client Objectives:
  • Determine why the assessment is being conducted (e.g., property transaction, redevelopment, refinancing).
• Establishing Property Details:
  • Document property location, size, zoning, and intended use.
• Identifying Applicable Standards:
  • Confirm that the assessment will comply with ASTM E1527-21 standards and any relevant local, state, or federal requirements.

2. Records Review

Conducting a thorough records review is critical for uncovering historical and current environmental risks. Key tasks include:

• Historical Records:
  • Obtain and analyze historical aerial photographs, Sanborn fire insurance maps, city directories, and topographic maps to identify past land uses.
• Environmental Databases:
  • Search federal, state, and local environmental databases for records of:
    • Underground storage tanks (USTs)
    • Hazardous waste generators
    • Superfund sites
    • Leaking underground storage tanks (LUSTs)
    • Landfills
• Property Records:
  • Review deeds, leases, and prior environmental reports for the property.
• Zoning and Land Use Records:
  • Check local zoning ordinances and land-use plans to identify any restrictions or concerns.

3. Site Reconnaissance

A site visit is a crucial part of the Phase I ESA, providing firsthand observations of the property’s environmental condition. During the visit, focus on:

• Visual Inspection:
  • Look for signs of contamination, such as:
    • Stained soil or pavement
    • Discolored vegetation
    • Storage tanks or drums
    • Abandoned equipment or buildings
• Photographic Documentation:
  • Take clear photographs of potential environmental concerns, site features, and surrounding properties.
• Property Boundaries:
  • Confirm property boundaries and note adjacent land uses that may pose risks, such as industrial facilities or gas stations.
• Drainage and Hydrology:
  • Observe drainage patterns, surface water conditions, and proximity to wetlands or water bodies.

4. Stakeholder Interviews

Interviews provide valuable context and insights that may not be evident from records or site inspections. Key stakeholders to consult include:

• Property Owners and Occupants:
  • Gather information about current and past property uses, maintenance practices, and any known environmental issues.
• Local Government Officials:
  • Contact zoning, fire, and health departments for additional records or knowledge about the property’s history.
• Neighbors:
  • When appropriate, speak with adjacent property owners to identify potential cross-boundary concerns.

5. Identification of Recognized Environmental Conditions (RECs)

The primary goal of the Phase I ESA is to identify Recognized Environmental Conditions (RECs), which are indicators of potential contamination. Ensure the report addresses:

• Current RECs:
  • Conditions that suggest the presence of hazardous substances or petroleum products.
• Historical RECs (HRECs):
  • Conditions that were previously identified and resolved to meet regulatory standards.
• Controlled RECs (CRECs):
  • Conditions that have been managed but still require ongoing monitoring or restrictions.

6. Report Preparation

The final report is the most important deliverable of a Phase I ESA. It should include:

• Executive Summary:
  • A concise overview of findings and recommendations.
• Site Description:
  • Details about the property’s location, size, zoning, and use.
• Records Review Results:
  • A summary of historical and environmental database findings.
• Site Visit Observations:
  • Detailed descriptions of on-site observations and photographic documentation.
• Stakeholder Interviews:
  • Summaries of key insights from interviews.
• Conclusions and Recommendations:
  • Identification of RECs and any recommended next steps, such as a Phase II ESA.

7. Quality Control and Review

Before finalizing the report, conduct a thorough quality review to ensure accuracy and completeness:

• Cross-Check Findings:
  • Verify that records, site visit observations, and interviews align.
• Regulatory Compliance:
  • Confirm adherence to ASTM E1527-21 standards.
• Client Feedback:
  • Share draft findings with the client to address any questions or additional concerns.

8. Next Steps After a Phase I ESA

Depending on the findings, the next steps may include:

• No Further Action:
  • If no RECs are identified, the property can proceed with development or transaction without additional environmental investigation.
• Phase II ESA:
  • If RECs are identified, conduct a Phase II ESA to confirm and quantify contamination through sampling and laboratory analysis.
• Mitigation Planning:
  • Develop remediation plans if contamination is confirmed.

Conclusion

A Phase I Environmental Site Assessment is a critical tool for identifying and managing environmental risks. By following this checklist, you can ensure a thorough and compliant assessment that protects stakeholders and supports informed decision-making. Whether you’re conducting a Phase I ESA for a property transaction or development project, a systematic approach will help you achieve reliable and actionable results.