If you plan to purchase or invest in commercial real estate, an environmental site assessment (ESA) must be conducted. These types of assessments are considered part of the “due diligence” process and help protect your investment. ESAs can also help you determine a fair value for land (site) before you buy it.
It’s likely that you have heard about a Phase 1 ESA. You may even be aware of Phase 2 ESAs. But did you know that there are also Phase 3 environmental site assessments? If you’re unfamiliar with the third phase of ESAs, this guide is for you.
Things to Know About a Phase 3 Environmental Site Assessment
A Phase 3 environmental assessment is the most advanced type of ESA and is required when contaminants are detected in subsurface (soil, groundwater or soil vapor) during Phase 2 ESAs. During a Phase 3 ESA, assessors may perform the following actions:- Installing groundwater monitoring wells
- Identify the extent of contamination by collecting soil and groundwater samples
- Determine the volume of impacted soil and groundwater
- Developing a remedial action plan or work plan
- Installation of additional groundwater monitoring wells
- Quarterly groundwater monitoring
- Excavation and disposal of contaminated soils
What’s the Difference Between Phase 1, 2, and 3 ESAs?
At first glance, all these phases can get somewhat confusing. However, the differences between the three types of ESAs are relatively straightforward. In short, Phase 1 ESAs are the least invasive. Phase 2 ESAs are slightly more so. Phase 3 ESAs are the most in-depth type of assessment. – Phase 1 ESAs check for warning signs of potential contamination. These signs are known as recognized environmental conditions (RECs). Examples include a dry cleaner facility on site or presence of underground storage tanks on site. If the Phase 1 ESA reveals RECs, a Phase 2 ESA is needed. – During a Phase 2 ESA, the assessor will take a closer look at any RECs. They will collect soil and groundwater samples, which are sent to a lab for analysis. If lab results reveal the presence of contaminants, a Phase 3 ESA is warranted. – Phase 3 ESAsdetermine the severity of contamination and outline a remedial action plan or work plan for remediation. As you can see, ESAs are performed on a progressive basis. If Phase 1 reveals no presence of RECs, a Phase 2 is not necessary. If a Phase 2 ESA determines that RECs contain no actual contaminants, you will not need a Phase 3 ESA. Phase 3 ESAs are only necessary if concerns were discovered during Phase 1 and Phase 2 ESAs. Phase 3 ESAs are designed to make properties safe for use. If contaminations are discovered, and no Phase 3 ESA is performed, the owner will incur significant liability.What Happens After a Phase 3 ESA?
Ideally, the goal is to reduce contaminant levels to zero. However, government regulations define different minimum thresholds for each type of contaminant. Some contaminants can be present and as long as they fall below these thresholds, the site can be considered to receive closure from the state agency. If the remediation efforts did not lower contaminants below the set thresholds, further assessment would be necessary. This process is repeated until the land (site) is made safe for use.Learn More About Phase 3 ESAs
Want to learn more about Phase 3 environmental site assessments and similar topics? If so, then we invite you to sign up for the RSB Environmental e-newsletter. We cover issues such as ESAs, property condition assessments, and much more. Sign up today by sending us an email at info@rsbenv.com. You’ll start receiving great content on environmental topics directly to your inbox!Frequently Asked Questions
What is a Phase 3 Environmental Site Assessment (ESA)?
A Phase 3 ESA is a comprehensive evaluation conducted when significant contamination is detected in Phase 2 ESA testing. It involves further sampling, analysis, and the development of a remediation plan to address contaminants in soil, groundwater, or soil vapor.
When is a Phase 3 ESA required?
A Phase 3 ESA is necessary if contaminants are confirmed in the subsurface during a Phase 2 ESA. This phase focuses on determining the extent of contamination and outlining the steps needed to remediate the site, making it safe for future use.
What is the difference between Phase 1, Phase 2, and Phase 3 ESAs?
- Phase 1 ESA identifies potential environmental concerns (RECs) through record reviews and site inspections.
- Phase 2 ESA investigates these RECs by collecting and analyzing soil and groundwater samples.
- Phase 3 ESA is the final step, assessing the contamination’s severity and creating a remediation plan if contamination is detected in Phase 2.
How long does it take to complete a Phase 3 ESA?
- The timeline varies depending on the contamination level and necessary remediation measures. Simple cases may take weeks, while more complex remediation efforts can extend for several months.
What happens if contaminants are still above safe levels after a Phase 3 ESA?
If remediation does not reduce contaminants below regulatory thresholds, additional assessments and remediation efforts are required until the site meets safety standards. This iterative process continues until the property is safe for its intended use.
