Environmental Site Assessment Guidelines - Ohio Department of ...

oth the regulatory database review and the regulatory records review should be conducted as
part of the Phase I ESA, otherwise the regulatory database review is not to be repeated in the
Phase I ESA (see ESA Screening, GIS Database Search, Page 15 – 16). For a list of OEPA
and BUSTR contacts see Appendix F.
7.1.4.4 Interviews
The parcel owner and/or tenant must be interviewed regarding any commercial and industrial
operations involving hazardous materials and petroleum products on the parcel. It is preferred
that the interview be conducted during the site reconnaissance. For commercial or industrial
properties being studied, key employees (managers, supervisors, foremen, etc.) should be
interviewed, since they are likely to be able to provide information about past and/or present onsite
hazardous material practices. Interviews are required with neighbors or former employees
who may also provide valuable information. In addition, interviews with local officials from the
fire department, health department and/or other emergency response agencies should be
conducted at this level to acquire information regarding spills or releases of hazardous
substances in the project study area. We recognize that some interviews and inquiries about
availability of files are effectively conducted by telephone. All persons interviewed should be
identified by their name, title, and length of association with the parcel. With the introduction of
USEPA’s “All Appropriate Inquiry Rule,” interviews with past and present owners, operators, or
occupants must be conducted.
It should be recognized that property owners typically do not have their property up for sale.
The owner of a property may not be motivated to conclude the land transaction and obtaining
an interview as required under AAI may be difficult. If the property owner and/or tenant cannot
be contacted within a reasonable period of time or declines to be interviewed, the report should
document the attempts to contact them. On rare occasions, the property owner will contact
ODOT to deny any and all access to the property and/or any information concerning their
property. In these situations, ODOT will inform the consultant not to contact or enter the site.
This situation should also be documented as part of the Phase I ESA.
7.1.4.5 Site Reconnaissance
This consists of a detailed visual inspection of the site for evidence of contamination or potential
contamination by hazardous substances. It is suggested that the property owners be notified
prior to entering the property to conduct the site reconnaissance. Typically, the appropriate
ODOT District provides this notification (see Appendix G). The notification letter may include
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