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Environmental Site Assessments: In Search of Better Conclusions

Written by Bill Leedham, P. Geo., CESA, Down 2 Earth Environmental Services Inc.

Environmental consultants sometimes struggle with reporting their Phase One Environmental Site Assessment (ESA) findings and conclusions, especially for properties with limited available data, or where the identified environmental issues are deemed to be of low to moderate concern.

Environmental consultants are often in search of ‘Better Conclusions’. When I refer to “better conclusions”, I am talking about rational and defensible conclusions that are presented clearly and designed to meet the report objectives (as defined by regulation and client needs) and not simply stating that “no concerns were identified and no further action is needed” (which most clients would prefer).

As environmental consultants, we understand each site and report is unique and the conclusions are dependent on the available data, as interpreted by a qualified professional. The suggestions offered are by no means comprehensive or all inclusive, but are meant to generate some thoughtful discussion when writing and reviewing Phase One ESA reports.

Follow the Regulation(s)

Depending on the locale and client requirements, you could be following one of several ESA guidelines. Make sure you have conducted your ESA in accordance with the applicable and/or client-requested format, and that the content and wording of your conclusions follows the suggested or mandatory requirements. For example, CSA Z-768-01 requires ESA Conclusions to state either no evidence, or evidence of actual and/or potential contamination has been revealed.

Ontario Regulation 153/04, as amended for filing a Record of Site Condition requires, among other things, that the assessor’s conclusions specifically state whether the RSC can be filed on the basis of the Phase One alone; and whether a Phase Two ESA is required to file the RSC. Failure to include the mandatory statements with the specified wording can result in denial of the RSC application.

If the report is to be compliant with ASTM E1527-13, the conclusions must summarize all recognized environmental conditions; provide one of the ASTM-prescribed concluding statements; and include statements certifying that an Environmental Professional (EP) has conducted All Appropriate Inquires (AAI). The assessor should always be familiar with the most current ESA standards, and ensure that that the format they utilize is applicable to the Site and meets all regulatory and stakeholder objectives.

Know Your Client…. And Other Stakeholders

Phase One ESAs are conducted for a variety of reasons including transactional due diligence, mortgage financing, regulatory requirements or private/internal planning needs. The types and objectives of clients can also vary from Site owners to property buyers, sellers, or managers. Often other third parties such as banks, municipalities, government agencies or environmental regulators can have a significant impact on the content and acceptability of the report conclusions.

As an assessor you need to know in advance all the involved stakeholders, especially those that will require and expect reliance on your report in their decision making process. Different clients can tolerate varying degrees of environmental risk.

For example, a client that has owned and operated an industrial facility since first developed use, and has no plans to sell, redevelop or obtain bank financing may be comfortable with the simple identification of potential environmental concerns and decide not to undertake any further confirmatory investigations.

However, a bank financing a purchase of the same industrial property may have a lower risk tolerance, and will likely require a better understanding of the environmental issues, including Phase One ESA conclusions that clearly state whether or not a Phase Two ESA is recommended by the assessor.

To produce a valid report that assists the stakeholders in their decision making, the assessor must also know all stakeholder objectives, and understand their respective risk tolerance and required level of comfort.


About the Author

Bill Leedham is the Head Instructor and Course Developer for the Associated Environmental Site Assessors of Canada (www.aesac.ca); and the founder and President of Down 2 Earth Environmental Services Inc. You can contact Bill at [email protected].

Avoiding Common Phase Two ESA Errors – Part 2

By: Bill Leedham, P.Geo, QP, CESA.

Last month I discussed some common mistakes I have encountered in reviewing Phase Two Environmental Site Assessment reports, specifically in the initial planning stage, now it’s time to turn our attention to recognizing and reducing errors during the Phase Two ESA field work.

Sometimes, deficiencies that occur in the planning stages of a Phase Two ESA transfer into errors in field procedures.  This can be caused by poor communication between the project manager and field staff (i.e. the PM neglects to inform field personnel of specific project requirements, and/or field staff forget to include important sampling media or potential contaminants of concern).  Full, two-way communication is vital to successful completion of any Phase Two ESA. It’s not enough for senior staff to just assume that less experienced team members understand all the complexities of the sampling plan; nor is it acceptable for a project manager to fail to provide adequate guidance and answers to questions from the field.  I have always thought it was important for junior staff to ‘know what they don’t know’ and encouraged them to ask questions at any time.  When project managers are ‘too busy’ to answer questions and simply tell their staff to ‘figure it out themselves’ everyone loses.

Photo Credit: All Phase Environmental

Despite good intentions and full communication, deficiencies can still occur.  Some are the result of inexperience compounded by poor judgement; some are due to budget limitations or staffing shortfalls; and some are caused through poor sampling protocols.  Some of the more common field sampling errors can include: failure to sample all relevant media at a Site (e.g. no sediment or surface water sampling is undertaken despite the presence of a potentially impacted water body); failure to consider all potential contaminants of concern (e.g. sampling only for petroleum hydrocarbons at a fuel storage site and not volatile parameters like BTEX); failure to sample in locations where contaminants are most likely to occur or be detected (e.g. sampling only surficial or near surface soils, and not at the invert of a buried fuel tank or oil interceptor, or failure to sample groundwater in a potable groundwater situation); and lack of field or lab filtering of groundwater samples for metals analysis (failure to remove sediment prior to sample preservation can skew the results for metals analysis).

Inadequate sampling and decontamination procedures can also bias lab results, leading to inaccurate or faulty conclusions.  When samples are disturbed (such as grab samples of soil collected directly from a drill augur that has travelled through an impacted zone) or collected improperly (e.g. compositing soil samples for analysis of volatile components); the test results can be biased and may not be representative of actual site conditions.  Similarly, failure to properly clean drilling and sampling equipment can result in apparent impacts that are actually the result of cross contamination between sampling points. Consider using dedicated or disposable sampling equipment to reduce this potential. A suitable quality control program should also be implemented, including sufficient duplicate samples, trip blanks, etc. for QA/QC purposes, and inclusion of equipment rinsate blanks to confirm adequate decontamination.

These are only a few of the more common field sampling errors I have come across. In an upcoming article I will discuss other practical methods to reduce errors in Phase Two data interpretation and reporting.

About the Author

Bill Leedham is the Head Instructor and Course Developer for the Associated Environmental Site Assessors of Canada (AESAC); and the founder and President of Down 2 Earth Environmental Services Inc. You can contact Bill at [email protected]

 

This article first appeared in AESAC newsletter.

Avoiding Common Phase Two ESA Errors – Part 1

By: Bill Leedham, P.Geo, QP, CESA.

Previously I have written about common errors I have encountered in reviewing Phase One Environmental Site Assessment reports, now it’s time to focus on some of the commonplace mistakes I have seen in planning and conducting Phase Two ESAs.

A properly scoped Phase Two needs to be based on accurate site data, which should entail completing a thorough Phase One ESA to identify actual and potential environmental concerns. An incomplete or deficient Phase One ESA (or absence of any prior site assessment) can lead to un-investigated areas, unidentified contaminants, missed contamination, and costly oversights when it comes to completion of the Phase Two work. With the high costs of drilling, sampling and lab analyses – and the even higher costs of remediation; it is vital that the consultant knows where to look and what to look for, in any intrusive site investigation; which requires a diligent and comprehensive Phase One ESA to get it right.

Photo by Azad K. (Geo Forward Inc.)

A Phase Two ESA can be required for a variety of reasons; including transactional due diligence, litigation, remedial planning, and obtaining regulatory approvals. The consultant must know and understand all client and stakeholder objectives, as well as the local regulatory requirements.  Conducting a CSA-compliant Phase Two ESA when the Client is expecting ASTM protocols and the regulator requires a different legislation-specific format to support regulatory approval will lead to problems, delays, possible costs over-runs – and a very dissatisfied client.  Two-way communication and full understanding of the project before, during and after the Phase Two plays an important role in successful and timely project completion.

Once the project requirements are defined, a Sampling Plan must be developed to meet these requirements.  Too often, mistakes are made when the number and location of sampling points is underestimated, or improperly selected. The consultant must consider all the potentially impacted media to be sampled. This could include not just soil; but often groundwater, sediment, and surface water; and sometimes soil vapour, indoor air quality, and building materials.  Consideration of the frequency and extent of sampling is necessary to investigate all relevant media and to fully characterize the environmental condition of the Site.  Utilizing a Conceptual Site Model to consider the contaminant sources, migration pathways and potential receptors unique to the Phase Two property is a useful and too often under-used method of developing a suitable Sampling Plan.

Site specific conditions, access, logistics, safety and (unavoidable) budgetary considerations also play a huge part in properly scoping and conducting any successful Phase Two ESA, but these are all wide ranging topics to cover another day.  Next month I will discuss other methods to recognize and avoid common errors in field sampling.

 

About the Author

Bill is the Head Instructor and Course Developer for the Associated Environmental Site Assessors of Canada (AESAC); and the founder and President of Down 2 Earth Environmental Services Inc. You can contact Bill at [email protected]

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