Our coverage is Nationwide for Phase I and Phase II

What is a Phase I Environmental Site Assessment (ESA)?

A Phase I ESA is a preliminary evaluation of a property’s environmental condition, designed to identify potential or existing environmental contamination liabilities. It is typically conducted during real estate transactions, such as property purchases, refinancing, or development, to help buyers, sellers, lenders, and other stakeholders assess risks and ensure compliance with regulations like the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, also known as Superfund). The process does not involve physical sampling, testing, or invasive procedures; instead, it relies on research, observations, and interviews to flag “Recognized Environmental Conditions” (RECs)—the presence or likely presence of hazardous substances or petroleum products due to a release or material threat of release.

The Phase I ESA follows the ASTM International Standard E1527-21 (“Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process”), which is consistent with the U.S. Environmental Protection Agency’s (EPA) All Appropriate Inquiries (AAI) rule under 40 CFR Part 312. Compliance with this standard can qualify property owners for liability protections under CERCLA, such as innocent landowner defenses. The assessment must be performed by a qualified “environmental professional” (EP) with specific credentials, such as relevant education, experience, and licensure.

Purpose of a Phase I ESA

  • Risk Identification: To uncover potential environmental issues early, preventing buyers from inheriting costly cleanup responsibilities.
  • Regulatory Compliance: Meets EPA’s AAI requirements for CERCLA liability protections and supports due diligence in transactions.
  • Informed Decision-Making: Helps stakeholders evaluate property value, negotiate terms, secure financing, and plan for any further investigations (e.g., Phase II ESA with sampling).
  • Financial Protection: Identifies issues that could affect insurance, loans, or resale value.

Key Steps in the Phase I ESA Process

The process is structured and non-invasive, typically taking 2-4 weeks to complete. Here’s a breakdown of the main components, based on ASTM E1527-21 and EPA guidelines:

  1. Records Review:
    • Examine historical and regulatory records to trace the property’s past uses and potential contamination sources.
    • Sources include: Aerial photographs, fire insurance maps (e.g., Sanborn maps), city directories, topographic maps, building permits, property tax files, zoning/land use records, and environmental databases (e.g., federal, state, tribal, and local records on hazardous waste sites, spills, or underground storage tanks).
    • For adjoining properties, review obvious uses and assess their potential impact on the subject property; justify any omissions in the report.
    • Also includes a search for environmental liens and Activity and Use Limitations (AULs) in land title records, dating back to at least 1980 (or explain why not).
  2. Site Reconnaissance (Visual Inspection):
    • Conduct an on-site walkthrough of the property and visual observations of adjoining properties (from public vantage points if access is denied).
    • Look for signs of environmental concerns, such as stained soil, distressed vegetation, abandoned drums or tanks, odors, chemical storage, or evidence of spills/releases.
    • Note current operations, structures, and any obvious hazards.
  3. Interviews:
    • Speak with current and past property owners, operators, occupants, and site managers about historical uses, incidents, or concerns.
    • For abandoned properties, interview neighboring owners or occupants.
    • Consult local government officials (e.g., fire departments, health agencies) for additional records or insights.
    • Assess the purchaser’s specialized knowledge, the property’s purchase price relative to fair market value (if uncontaminated), and any commonly known information.
  4. Report Preparation and Evaluation:
    • Compile findings into a detailed report, including: Summary of research, observations, interviews; identification of RECs, Historical RECs (HRECs—past issues resolved), or Controlled RECs (CRECs—ongoing but managed conditions); photographs, maps, and appendices.
    • The EP must sign a declaration certifying the assessment.
    • Note any data gaps (e.g., inaccessible records) and their impact on conclusions.
    • The report is viable for 180 days from the transaction date; for up to one year, specific components (e.g., interviews, inspections) must be updated.

Important Definitions from ASTM E1527-21

  • Recognized Environmental Condition (REC): The presence, likely presence, or material threat of hazardous substances or petroleum products at the property, excluding minor (de minimis) conditions that don’t pose a threat.
  • Historical REC (HREC): A past REC that has been addressed to regulatory satisfaction and no longer poses a threat.
  • Controlled REC (CREC): A REC managed through controls (e.g., deed restrictions) to prevent exposure or release.
  • Non-scope items include emerging contaminants like PFAS (per- and polyfluoroalkyl substances), unless classified as hazardous under CERCLA or required by state laws.

Updates in ASTM E1527-21 (from E1527-13)

  • Refined REC definitions and added a logic diagram for classifying REC/HREC/CREC.
  • Mandated title searches from 1980 and justification for skipped historical reviews.
  • Required dating of key components in reports and clarified update rules for report viability.
  • Emphasized adjoining property reviews and emerging contaminants as non-scope.

Benefits of Conducting a Phase I ESA

  • Liability Protection: Qualifies for CERCLA defenses, shielding owners from cleanup costs.
  • Cost Savings: Identifies issues early, allowing for negotiation or avoidance of problematic properties.
  • Marketability: Enhances property appeal by demonstrating due diligence and transparency.
  • Peace of Mind: Provides a clear picture of environmental risks, facilitating smoother transactions.

If RECs are identified, a Phase II ESA (involving sampling and analysis) may be recommended. Costs for a Phase I typically range from $2,000 to $5,000, depending on property size and complexity. For the most current guidance, consult an environmental professional or review the full ASTM standard.

Phase II ESA Services Nationwide: Confirm Subsurface Conditions with Defensible Data

GeoTILL delivers Phase II Environmental Site Assessments (Phase II ESAs) across the U.S. using targeted soil, groundwater, and vapor sampling with laboratory analysis—so you can quantify risk, protect your schedule, and make confident real estate and construction decisions.

When a project requires more than screening, a Phase II Environmental Site Assessment (Phase II ESA) provides the intrusive, sampling-based evidence needed to answer the questions that drive cost and liability:
Is there contamination? Where is it? How much is present? What does it mean for financing, design, construction, and long-term risk?

Our Phase II approach is built around smart scoping and efficient field execution—targeted sampling locations, appropriate analytical programs, and clear reporting that supports
lenders, developers, and property owners. Whether the objective is to confirm clean conditions, support negotiations, or prepare for a practical response strategy, we tailor the scope to your constraints while maintaining rigorous QA/QC, chain-of-custody practices, and defensible documentation.

Need a Phase II ESA proposal? We can quickly align on objectives, access, utility clearance needs, sampling methods, laboratory turnaround, and reporting timelines to keep your transaction or project moving.

Quick Comparison: Phase I vs. Phase II vs. Response / Remediation

Item Phase I ESA Phase II ESA Response / Remediation
Primary purpose Identify risk indicators and determine whether additional investigation is warranted. Confirm and quantify impacts through subsurface sampling and laboratory analysis. Address confirmed impacts through removal, treatment, controls, and/or regulatory coordination.
Intrusiveness Non-intrusive; records-based screening. Intrusive field investigation (soil, groundwater, and/or vapor sampling). Active construction or engineering response, often with verification sampling.
Typical triggers Due diligence, acquisition, lending, refinancing, or redevelopment screening. Known or suspected releases, staining/odors, tank history, industrial or solvent use, impacted fill, migration concerns, or disposal risk. Confirmed impacts requiring delineation, cleanup, risk management, or closure support.
Field activities Typically no subsurface sampling. Borings/test pits, soil sampling, potential groundwater sampling (wells as needed), and/or soil vapor screening. Removal actions, treatment, controls, oversight, confirmation/delineation sampling, and O&M as applicable.
Best fit for Teams needing screening-level due diligence and risk triage. Teams needing defensible data for decisions, negotiations, design, or compliance planning. Owners/developers needing practical solutions aligned with project continuity.

What Is a Phase II Environmental Site Assessment?

A Phase II Environmental Site Assessment (Phase II ESA) is a targeted subsurface investigation performed to confirm or rule out environmental impacts that may be suspected based on site history, observed conditions, or prior due diligence findings.
Unlike screening-only approaches, a Phase II is intrusive and typically includes soil, groundwater, and/or soil vapor sampling followed by laboratory testing to quantify potential impacts.

For lenders, developers, and property owners, a Phase II ESA converts uncertainty into measurable facts—helping answer the risk-and-cost questions that directly affect acquisition terms, redevelopment feasibility, schedule reliability, and long-term liability.

Why a Phase II ESA Matters

A Phase II ESA is commonly used to:

  • Confirm or refute suspected environmental impacts with analytical data.
  • Define the type, depth, and lateral extent of impacts (where contamination is and how far it extends).
  • Support lender and investor decisions with defensible results.
  • Reduce costly surprises during construction by identifying subsurface issues early (including excavation handling and disposal risk).
  • Establish a technical basis for response planning when impacts are confirmed.

When a Phase II ESA Is Commonly Recommended

A Phase II ESA is typically initiated when conditions suggest a potential release of petroleum or hazardous substances, or when redevelopment/excavation plans create uncertainty around subsurface conditions. Common triggers include:

  • Current or historical gas stations, fueling areas, or vehicle maintenance shops.
  • Known or suspected underground storage tanks (USTs) or aboveground tanks.
  • Historic industrial use (manufacturing, machining, plating, printing, metalworking, etc.).
  • Dry cleaners or other solvent-related operations.
  • Known spills, staining, strong odors, distressed vegetation, or impacted fill materials.
  • Adjacent properties with uses that may have migrated impacts (industrial sites, rail corridors, and similar corridors).
  • Brownfield or redevelopment sites where subsurface conditions are uncertain.
  • Sites where construction will require deep excavation and the team needs to manage soil disposal risk.

What a Phase II ESA Typically Evaluates

Soil Sampling and Testing

Soil sampling is commonly used to evaluate:

  • Petroleum hydrocarbons associated with fueling and maintenance activities.
  • Metals, SVOCs, and other constituents associated with industrial operations.
  • Concerns related to historic fill (ash, cinders, demolition debris, or unknown imported materials).

Groundwater Sampling and Testing

Groundwater sampling may be required when:

  • Impacts could migrate off-site or toward utilities and basements.
  • The site history indicates petroleum or chemical handling where groundwater could be intercepted.
  • Redevelopment plans include deeper excavations that may intercept groundwater.

Groundwater work often includes (as appropriate to the site objectives):

  • Monitoring well installation (when needed for groundwater sampling and/or water-level evaluation).
  • Measurement of groundwater depth and, when appropriate, evaluation of flow direction.
  • Laboratory analysis aligned with suspected contaminants and project decision needs.

Soil Vapor / Vapor Intrusion Screening

Soil vapor testing may be considered when:

  • Volatile compounds are suspected (e.g., chlorinated solvents, gasoline-range petroleum constituents).
  • Buildings are present or planned where vapor intrusion could be a risk pathway.
  • Regulatory or lender requirements call for vapor evaluation.

How a Phase II ESA Is Planned

A strong Phase II ESA is driven by a focused investigation plan—not a one-size-fits-all sampling approach. We develop a site-specific scope that aligns with project objectives, schedule constraints, and anticipated risk.

Key planning elements commonly include:

  • Target areas based on historical operations and likely release points.
  • Sampling depth rationale (near-surface vs. deeper zones; utility corridors; proposed excavation subgrades).
  • Selection of sampling methods appropriate to site access, depth requirements, and anticipated materials.
  • Analytical selection tailored to the suspected conditions and decision context.

Typical Field Methods Used in Phase II ESAs

Phase II ESAs can be completed using a range of field techniques. The method is selected based on access, depth requirements, anticipated materials, and site constraints.

  • Direct-push sampling (rapid soil sampling; useful for many shallow-to-intermediate investigations).
  • Hollow-stem auger borings (useful where deeper sampling or well installation is needed).
  • Rock coring / advanced drilling (where bedrock is present or shallow).
  • Monitoring well installation (as needed for groundwater sampling and water-level evaluation).
  • Test pits (useful for evaluating fill, debris, and near-surface conditions where access permits).
  • Soil gas probe installation (when vapor screening is part of the scope).

Laboratory Analysis and Data Quality

Laboratory testing is a core component of Phase II work. The analytical suite is selected to match suspected conditions and the project's risk profile (transaction, redevelopment, refinancing, or planning).

A defensible Phase II ESA program emphasizes:

  • Proper sample handling, preservation, and holding-time management.
  • Documentation of sample locations, depths, and field conditions.
  • Chain-of-custody and traceable sample identifiers.
  • Field quality control where appropriate (duplicates, blanks, etc.).
  • Review of laboratory deliverables for completeness and usability.

The goal is not just producing results—it is producing results that can withstand lender scrutiny and support real project decisions.

How Phase II ESA Findings Are Interpreted

A Phase II deliverable should answer practical questions such as:

  • Are impacts present or absent?
  • If present, are they localized or widespread?
  • Are impacts shallow (construction handling/disposal issue) or deeper (potential long-term liability)?
  • Is groundwater affected or likely to be affected?
  • Does the data suggest active migration, or stable/limited conditions?
  • What are the likely implications for schedule, cost, and constructability?

What Happens After a Phase II ESA?

Not every Phase II result leads to remediation. Many investigations confirm that suspected issues are not present, or that impacts are limited and manageable.
If impacts are confirmed, next steps may include:

  • Focused follow-up sampling to define extent (delineation).
  • Risk pathway evaluation (including vapor considerations where applicable).
  • Development of a practical response strategy aligned with construction plans.
  • Coordination with the project team to minimize schedule disruption.
  • Planning for targeted removal, disposal profiling, or other response actions.

Phase II ESA Timeline and Cost Drivers

Timeline

Timelines vary based on access, scope complexity, drilling needs, and laboratory turnaround.
A typical schedule includes scope finalization, field sampling, laboratory analysis/validation, interpretation, and reporting.
For time-sensitive schedules, Phase II scopes can be structured to prioritize critical path decisions while maintaining defensibility.

Cost Drivers

Common cost drivers include:

  • Number of sampling locations and required depths.
  • Whether groundwater wells are needed.
  • Analytical suite selection (petroleum-focused vs. broader industrial parameters).
  • Site access constraints and drilling method requirements.
  • Laboratory turnaround time.
  • Whether vapor investigation is included.

Phase II ESA FAQs

How is a Phase II ESA different from Phase I?

A Phase II ESA includes intrusive sampling and laboratory testing to confirm whether contamination is present and to quantify impacts with measurable data.

Does a Phase II ESA always require groundwater wells?

Not always. Some Phase II scopes focus on soil only, especially when concerns are shallow or when confirming impacts before installing wells is the most efficient approach.

How many samples are needed for a Phase II ESA?

There is no universal number. Sample counts depend on suspected source areas, site size, geology, and the specific decisions the client needs to make. The most effective scopes are targeted and defensible.

Can Phase II findings affect construction?

Yes. Shallow impacts can affect excavation handling, worker safety planning, and soil disposal requirements. Identifying these issues early can prevent delays later.

Can GeoTILL perform Phase II ESAs nationwide?

Yes. GeoTILL supports Phase II ESA projects across the United States, coordinating investigation planning, fieldwork, laboratory testing, and reporting to meet transaction and development timelines.


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