Environmental Site Assessment Guidelines - Ohio Department of ...
Environmental Site Assessment Guidelines - Ohio Department of ... Environmental Site Assessment Guidelines - Ohio Department of ...
these procedures. This includes locally administered projects, as per the Manual of Procedures, Locally Administered Transportation Projects. Due diligence issues address the potential liability of acquiring a portion or all of a property, while due care issues pertain to the proper management of any hazardous or regulated waste generated during the construction of a project. While conducting literature search reviews, care should be taken not to overlook potential environmental concerns during this early level of research. A release during construction of a project could cause a negative impact on public health causing ODOT potential liability, delay of the project’s completion, and increased project cost. To ensure the appropriate level of inquiry is undertaken, consultants performing ESAs for ODOT must be pre-qualified with the Office of Contracts. In addition, the consultants should be familiar with regulatory agency policies, rules, and regulations concerning all appropriate legislation including, but not limited to, SARA, CERCLA, RCRA, HSWA, and applicable state environmental regulations. ODOT’s ESA process comprises several levels of investigation that include historical/environmental research, visual assessments, and sampling and testing. Subsequently, documentation of ESA activities is generally presented in the form of an ESA Screening, Phase I ESA, or a Phase II ESA. However, there can be some projects that may require other ESA studies (i.e. No ROW ESA Screening, Phase II ESA Work Plan, additional Phase II ESA, etc.) depending on the nature and complexity of the project. The Red Flag Summary for environmental site assessment issues is conducted for projects under ODOT's PDP. The Red Flag Summary consists of a search of environmental databases maintained by the USEPA and the OEPA, as well as from local and state agencies such as the health department and BUSTR (Bureau of Underground Storage Tank Regulations), and ground truthing this information. The goal of the Red Flag Summary is to identify and locate properties with known or suspected environmental contamination which could control or influence project corridor locations. The identification of these types of properties also will assist in the development of a realistic project schedule if they cannot be avoided. The ESA Screening is used to identify suspect parcels very early in project development. All properties within the project or corridor are screened at this level. The purpose of the ESA Screening is to provide a method for ODOT to investigate projects and to identify suspect parcels requiring Phase I ESA investigation without obtaining large amounts of parcel specific information. The properties/parcels identified in the ESA Screening as potential environmental concerns are advanced for further investigation. 3
The Phase I ESA is a more detailed investigation based on the accumulation and review of parcelspecific information. This includes investigation of the historic ownership of a property, current and former land uses, physical characteristics of the surrounding area and a photographic log to document the present conditions. In addition to historic and present land uses of a parcel, the Phase I ESA identifies potential sources of contamination and other environmental concerns associated with parcels requiring further investigation. Based on the findings of the Phase I ESA, the proposed ROW (right-of-way) and proposed construction activities, Phase II ESA sampling and testing recommendations may be warranted. If the Phase I ESA indicates that there is a reasonable likelihood that contamination is present on a specific parcel, then a Phase II ESA consisting of a sampling and testing program is implemented. The Phase II ESA includes field sampling and laboratory analyses to verify the presence or absence of contaminants. This process ordinarily would provide adequate information to aid in the further development of the project. If avoidance of a parcel is not possible, then the issues of due care associated with the property must be studied within the context of the project. We hope that this manual will be useful to everyone conducting ESAs during the development of transportation projects and how the information is collected and used. We have tried to provide clarification and insights into conducting environmental site assessment investigations for ODOT from the previous versions of this manual and incorporate USEPA's AAI to ensure that all the necessary data are collected to make the best informed decision for ODOT's projects. 4
- Page 1 and 2: ENVIRONMENTAL SITE ASSESSMENT GUIDE
- Page 3 and 4: 7. PHASE I ENVIRONMENTAL SITE ASSES
- Page 5 and 6: APPENDIX A Project Development Proc
- Page 7: Approval of NEPA documents is under
- Page 11 and 12: Red Flag Summary No ROW ESA Screeni
- Page 13 and 14: The goal of this IOC is to alert th
- Page 15 and 16: 4. RED FLAG SUMMARY A Red Flag Summ
- Page 17 and 18: 5.1.2 Introduction An introduction
- Page 19 and 20: following regulatory databases: NPL
- Page 21 and 22: evidence of a release since the uti
- Page 23 and 24: 5.4 Reporting Requirements for ODOT
- Page 25 and 26: 6.1 Elements of the No ROW ESA Scre
- Page 27 and 28: 6.1.4 Regulatory Database Review A
- Page 29 and 30: 6.1.7 Site Inspection A site inspec
- Page 31 and 32: 6.3 Reporting Requirements for Cons
- Page 33 and 34: 7. PHASE I ENVIRONMENTAL SITE ASSES
- Page 35 and 36: A. Aerial Photographs B. Aerial pho
- Page 37 and 38: D. E. F. Property Tax Files These f
- Page 39 and 40: investigations for other environmen
- Page 41 and 42: 7.1.4.6 Proposed Right-of-Way and C
- Page 43 and 44: 7.2 Reporting Requirements The titl
- Page 45 and 46: 8. PHASE II ENVIRONMENTAL SITE ASSE
- Page 47 and 48: with the highest field reading shou
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- Page 51 and 52: 9.1.3 Background Information This s
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The Phase I ESA is a more detailed investigation based on the accumulation and review <strong>of</strong> parcelspecific<br />
information. This includes investigation <strong>of</strong> the historic ownership <strong>of</strong> a property, current and<br />
former land uses, physical characteristics <strong>of</strong> the surrounding area and a photographic log to document<br />
the present conditions. In addition to historic and present land uses <strong>of</strong> a parcel, the Phase I ESA<br />
identifies potential sources <strong>of</strong> contamination and other environmental concerns associated with<br />
parcels requiring further investigation. Based on the findings <strong>of</strong> the Phase I ESA, the proposed ROW<br />
(right-<strong>of</strong>-way) and proposed construction activities, Phase II ESA sampling and testing<br />
recommendations may be warranted.<br />
If the Phase I ESA indicates that there is a reasonable likelihood that contamination is present on a<br />
specific parcel, then a Phase II ESA consisting <strong>of</strong> a sampling and testing program is implemented.<br />
The Phase II ESA includes field sampling and laboratory analyses to verify the presence or absence <strong>of</strong><br />
contaminants. This process ordinarily would provide adequate information to aid in the further<br />
development <strong>of</strong> the project. If avoidance <strong>of</strong> a parcel is not possible, then the issues <strong>of</strong> due care<br />
associated with the property must be studied within the context <strong>of</strong> the project.<br />
We hope that this manual will be useful to everyone conducting ESAs during the development <strong>of</strong><br />
transportation projects and how the information is collected and used. We have tried to provide<br />
clarification and insights into conducting environmental site assessment investigations for ODOT from<br />
the previous versions <strong>of</strong> this manual and incorporate USEPA's AAI to ensure that all the necessary<br />
data are collected to make the best informed decision for ODOT's projects.<br />
4