Installment 4 of our Phase I ESA Educational Series
4.1 Identifying Areas of Potential Environmental Concern (APECs)
Once the Records Review, Site Reconnaissance, and Interviews are complete, the next crucial step in a Phase I Environmental Site Assessment (ESA) is to interpret all gathered information and pinpoint any Areas of Potential Environmental Concern (APECs). An APEC typically arises from:
- Historical or Current Commercial or Industrial Uses: For example, properties with past operations like dry-cleaning, automotive repair, or chemical storage.
- Evidence of Possible Contamination: Such as visibly stained soils, undocumented fill, or waste disposal sites.
- Regulatory Flags: Past enforcement actions or permits that suggest potential environmental liabilities.
Relevance to BC CSR
- If an APEC aligns with activities or substances regulated under the BC Contaminated Sites Regulation (CSR), additional investigations might be needed to confirm whether the site meets the threshold of a “contaminated site.”
- Properties identified as having potential contamination may be subject to a Phase II ESA (Detailed Site Investigation), or in BC terms, a Stage 2 Preliminary Site Investigation (PSI), to comply with CSR requirements.
4.2 Interpreting Findings
Properly synthesizing the data from multiple sources is key. Assessors must correlate the Records Review details with onsite observations and interview insights to determine whether any recognized environmental conditions are present.
Common Factors Considered
- Site-Specific Historical Use: How previous activities could have impacted soil or groundwater.
- Proximity to Other Potentially Contaminating Operations: Neighboring gas stations, factories, landfills or other commercial and industrial uses.
- Regulatory Database Information: Records from municipal, provincial, or federal agencies (including potential references to the CSR).
If these factors suggest an elevated risk of contamination, the assessor will highlight them as APECs in the final report.
4.3 Report Preparation
A well-structured Phase I ESA report clearly documents all findings and conclusions. Typically, the report includes:
- Executive Summary
- A concise overview of the site, the activities performed, and the key results or concerns identified.
- Scope & Methodology
- Details of the Records Review, Site Reconnaissance, and Interviews undertaken.
- Findings & Risk Assessment
- Description of any APECs, supported by photos, site plans, and/or historical data.
- Conclusions & Recommendations
- Whether additional investigation (Phase II ESA, Detailed Site Investigation, or Stage 2 PSI in BC) is advised.
- Guidance on potential remedial actions or further regulatory steps under the BC CSR.
- Limitations
- Clarifies the boundaries of the assessment such as data gaps, scope or restricted site access.
Ensuring CSR Alignment
For properties in British Columbia, it’s often prudent to highlight how findings relate toBC CSR, especially if the recommended next steps involve compliance measures or formal notification to provincial authorities.
4.4 Key Takeaways & Call to Action
- Risk Identification is a Multi-Step Process: Integrating historical records, onsite inspections, and interviews helps build a complete picture of environmental risk.
- Thorough Reporting is Essential: A comprehensive, well-organized Phase I ESA report stands up to scrutiny—legal, financial, and regulatory.
- BC CSR Considerations: If your findings indicate potential contamination, you may need further action under the BC CSR, including a Phase II ESA or Stage 2 PSI.
Stay tuned for our next installment, where we’ll explore Common Misconceptions of Phase I ESAs. If you have concerns about potential environmental liabilities on your property, contact our team. We’ll help you interpret Phase I ESA results and navigate compliance with the CSR.
References
BC Contaminated Sites Regulation (CSR) – Environmental Management Act
BC Laws – Contaminated Sites Regulation (BC Reg. 375/96)
CSA Z768-01 – Phase I Environmental Site Assessment
CSA Environmental Site Assessment Standards
ASTM International: Standard Practice for Phase I Environmental Site Assessments (E1527)
ASTM E1527
US EPA: Brownfields and Land Revitalization
Overview of Brownfields Site Assessment