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Thursday, April 14, 2011

The Environmental Site Assessment as an Archeological Study

Guest article by John Carter

An environmental site assessment (ESA) is a report mandated by law designed to establish the well being of any piece of property that in practice usually applies to commercial and/or industrial properties. An ESA is divided into three parts called phases that are numbered I, II and III. A Phase I report is used to determine whether or not the possibility of a release of hazardous material has in fact occurred on a property by determining its prior history. A Phase II report determines if in fact that a release has occurred on a property by taking samples from the property and subjecting them to a battery of lab tests. If in fact the results of this analysis returns indicating that there are indeed hazardous materials that are found on the property above the threshold levels mandated by law the property has to undergo a Phase III Investigation to determine the amount, extent and the effects on human and other life forms the contamination will cause. Photocopies are taken of each report for inclusion in appendix A. of the ESA, and a brief annotation is included in the finished assessment.

023_003 Industrial Park in Manchester
(This is an aerial photo of an industrial park in Manchester, CT showing several areas of environmental interest.  Try locating them on the photo, describe why they would be on interest, and try to determine which ones would become archeological sites in the future?)

Together the three phases of an ESA are very similar to an archeological study, but the single phase that develops the most information that pertains to a specific piece of property is Phase I. This part of an ESA starts in the reading room of the government body of the state that has charge of environmental affairs. This is a collection of environmental records that report any releases of hazardous materials that are known to have occurred on the property or that have occurred off the property, but could have compromised its environmental integrity.

The next stop is usually the state library where they keep other forms of documentation required for a site assessment like aerial photographs, insurance maps, city directories, telephone books and town histories. Even more information can be gathered from back issues of newspapers. Copies of all this documentation are included in Appendix B. of the ESA. As you gather this material you are also writing part of the ESA.

There is also a considerable amount of other information that has to be gathered from the town records of the town where the property is located among them are: Land Records dating back to 1940, or earlier if necessary. We once had to trace the land records back to 1763 because then the property in question had been the largest tannery in the state. Tanneries are one of the most environmentally damaging establishments there are; they can be a nightmare especially if they ever used the Chrome Tanning Process leaving behind a trail of Hexavalent Chromium contamination.

The local search continues with records from the Fire Marshall, the Planning and Zoning Commission, a search in the morgue of the local newspaper and finally statements that are taken from some of the locals who have had contact with the site. There is some additional material like a description of the process if any that has been manufactured or used on the site.

A Phase I ESA is written up and ends with a set of conclusions that affect the outcome of the ESA either it ends with the conclusion that no further environmental work needs be done. If there is historical evidence that the probability of a release occurring on the property is high then the nature of the release and its location is included in the conclusions, and the recommendation is that further environmental work is required so that the ESA continues with a Phase II investigation.

A Phase II ESA is designed to determine if in fact a release of hazardous materials did in fact occur on the property. Although this report is much shorter it deals strictly with the chemical analysis of air, water and soil samples from the site and sometimes “wipe samples” that are taken inside of any structures that are on the property that have been listed as suspect during the Phase I ESA. The various samples are taken at the site according to American Society of Testing Materials (ASTM) standards and transported under a Chain of Custody (CofC) to a certified analytical lab for analyses.

A similar report is drawn up to the Phase I only this time it describes the results of the analysis and reports on the allowable Environmental Protection Agency (EPA) guidelines for hazardous materials. The EPA has a table of the various contaminants of concern. If in the course of analyses any of these standards are exceeded the site is deemed contaminated, and the Environmental Analyst must proceed with a Phase III ESA.

Generally if a property fails a Phase II Investigation the owner or buyer walks away from the property allowing it to become a Superfund or RCRA property. This is the origin of many industrial properties that are designated as “Brownfields.”

A Phase III ESA is similar to a Phase II only it goes into much more detail because it not only tests for contaminants, but also tests for there extent and effects on humans and other life forms.
The similarities between an ESA are uncanny, and the ESA with some modifications could stand as a good plan for designing an archeological dig; all that is needed is to change the objectives. Rather then searching for hazardous waste releases you are hunting for artifacts of a previous age. The ASTM Standard for Phase I ESAs is ASTM 1577-05 and a guide for conducting an ESA is ASTM E1528 that explains the parameters of an ESA, or could be modified to an archeological site.

In truth, there are many similarities between an environmental establishment and an archeological site; the main difference is measured in years, and remember today’s site is tomorrows archeological dig that is performed to discover how people lived in the past. The ESA gives the analyst an insight into industrial archeology, and ultimately many of the same problems exist. Have you ever seen an ancient Superfund Site, they exist.

Author Bio

John Carter is a geologist that paid his way through college as a commercial helicopter pilot in the NY Metro area.  He has had extensive experience as a prospector, and operated an environmental consulting firm specializing in environmental site assessments and is certified by the State of Connecticut as an Environmental Analyst III.  In his early life he worked as an experimental machinist on aircraft and electronic parts before receiving his degree as a geologist.


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