Phase II Environmental Site Assessments or Investigations (PH II ESA)
The main purpose of conducting a PH II ESA is to determine
whether known or possible contamination might be encountered during
construction. The information from a PH II ESA may be useful in
developing cost-effective preventive action plans or specifications
to handle any contamination found. A PH II ESA may also help to
determine closure requirements of regulated facilities or contaminated
areas. A PH II ESA should include the following activities:
- Develop a soil and/or groundwater sampling and analysis plan, such as locations of borings, depths of borings, locations of monitor wells, groundwater gradient, and hydrogeologic or hydraulic testing
- Identify and characterize the contamination through sampling and analytical testing
- Determine the horizontal and vertical extents of contamination that might be encountered prior to or during construction
- Assess worker safety and public health exposure concerns
- Determine the regulatory handling, reuse and/or disposal requirements for contaminated media
- Recommend a cost-effective preventive action plan to ensure the contamination is not aggravated.
Sampling and analysis can be very expensive. The most cost-effective
approaches will vary on a case-by-case basis. Several factors determine
when and how to conduct a cost-effective environmental site investigation.
For example, the sampling and analysis plan should limit the number
of investigations or remobilization. However, multiple or phased
investigations may be necessary for some projects or individual
sites; detailed information about a project's proposed excavation
and de-watering requirements may be needed to develop an adequate
sampling and analysis plan. One option is to perform more detailed
design activities during advanced planning to facilitate the investigation.
Another option is to postpone investigation until the project details
are known later in the project development process. It may also
be more cost-effective to combine geotechnical testing with environmental
testing.
Since a preferred alternative or alignment could change during
the environmental process, investigations should be performed after
approval of the environmental documentation, public involvement
or environmental clearance. To determine whether possible contamination
exists on a proposed right of way, investigations depend on property
owners providing access or right of entry. If right of entry is
refused, the investigation may be postponed until the eminent domain
process or until after acquisition.
FHWA has specific guidelines for projects requiring Environmental
Impact Statements (EIS). Prior to selection of a project alternative,
detailed design activities and additional investigations may be necessary
to evaluate the impact and obtain sufficient information for the
project decision-making process. Sufficient information is necessary
to characterize the site, identify the type and extent of contamination,
and estimate disposal, waste management or cleanup costs. It may
also be necessary to determine alternative treatment, cleanup, disposal
measures, and associated costs. Assuming that right of entry can
be obtained, the hazardous materials assessment should be completed
and documented in the Final EIS prior to circulation; however, it
is not necessary to complete all investigations prior to environmental
clearance. If a contaminated site cannot or will not be cleaned up
prior to acquisition and it is decided to proceed with the project,
then a more detailed site investigation can be performed after clearance.
More detailed site investigations may be needed to determine waste
characteristics, hydrogeologic conditions and/or extent of contamination.
For all projects, hazardous materials assessment should be
completed prior to finalizing the Plans, Specification and Estimates
(PS&E). If the analytical testing does not reveal contamination,
then there is added support that contingencies or special provisions
are not required in the PS&E.