Key Takeaways
- Accompany the EP during the Phase I site visit, provide context, and ask for preliminary impressions on-site.
- Phase II uses direct-push soil sampling, monitoring wells for groundwater, and vapor probes for soil gas.
- Results are compared to federal MCLs and state-specific screening levels to determine regulatory compliance.
- Focus on spatial extent, vertical extent, migration potential, and estimated remediation cost for investment decisions.
This lesson walks through the practical execution of Phase I and Phase II environmental assessments: what to expect during the site visit, how samples are collected and analyzed, and how to interpret laboratory results against regulatory standards.
The Phase I Site Visit
The EP will spend 2-4 hours on-site (longer for larger properties). They will systematically walk the interior and exterior, looking for: evidence of chemical storage or use (drums, containers, staining), underground storage tanks (fill pipes, vent pipes, dispensers), floor drains that may discharge to soil, transformers or electrical equipment that may contain PCBs, evidence of past industrial or commercial operations, and current environmental compliance (hazardous waste storage, SPCC plans). Accompany the EP during the site visit to provide context and ensure they have access to all areas. Point out any areas of concern you identified during your own walk-through. Ask the EP for preliminary impressions before they leave the site.
Phase II Sampling and Laboratory Analysis
Phase II soil sampling uses a direct-push rig (Geoprobe) to collect soil cores at depths of 2-15 feet, typically at 5-10 locations per site. Groundwater sampling requires installing temporary or permanent monitoring wells (2-4 inch diameter, 15-30 feet deep) and collecting water samples after the well has stabilized. Soil vapor sampling installs vapor probes through the building slab or at the building perimeter to collect gas samples. All samples are shipped under chain-of-custody protocols to a certified laboratory. Analysis typically takes 5-10 business days. Results are reported in parts per million (ppm) for soil, parts per billion (ppb) for groundwater, and micrograms per cubic meter for soil vapor. Each analyte result is compared to the applicable screening level to determine if contamination exceeds regulatory thresholds.
Interpreting Phase II Results
Phase II results fall into four categories. Clean: all results below screening levels—no further action. Low-Level Contamination: results above background but below screening levels—monitoring may be recommended but no remediation required. Above Screening Levels: one or more samples exceed regulatory standards—remediation is likely required, but the extent depends on the contaminant, concentration, and affected area. Significantly Elevated: concentrations many times above screening levels—significant remediation required, potentially a deal-killer. For investment decision-making, focus on: the spatial extent of contamination (how large an area is affected?), the vertical extent (how deep does it go?), the potential for migration (is it moving toward receptors like drinking water wells?), and the estimated remediation cost range. Request that the consultant provide a remediation cost estimate as part of the Phase II report.
Schedule & Milestones
Day 22: Receive Phase I report identifying the REC. Immediately authorize Phase II testing. The EP quotes $12,000 for 6 soil borings, 2 monitoring wells, and laboratory analysis.
Day 25: Drilling crew mobilizes. Six soil borings at depths of 5, 10, and 15 feet at locations selected by the EP (former hydraulic lift locations, former UST area, and background locations).
Day 26: Two monitoring wells installed and developed. Groundwater samples collected after 24-hour equilibration.
Day 27: All samples shipped to lab under chain of custody. Request rush analysis (additional $1,500) to meet DD deadline.
Day 32: Lab results received. Three soil samples show total petroleum hydrocarbons (TPH) at 800-2,200 ppm (screening level: 1,000 ppm). One groundwater sample shows benzene at 8 ppb (MCL: 5 ppb).
Day 33: EP delivers Phase II report: contamination is localized (former UST area), moderate severity, remediation estimate $45,000-$85,000 for soil excavation and monitored natural attenuation of groundwater over 3-5 years.
Key Takeaways
- ✓Accompany the EP during the Phase I site visit, provide context, and ask for preliminary impressions on-site.
- ✓Phase II uses direct-push soil sampling, monitoring wells for groundwater, and vapor probes for soil gas.
- ✓Results are compared to federal MCLs and state-specific screening levels to determine regulatory compliance.
- ✓Focus on spatial extent, vertical extent, migration potential, and estimated remediation cost for investment decisions.
Sources
Common Mistakes to Avoid
Assuming a Phase I with no RECs means the property has zero environmental risk
Consequence: Phase I has inherent limitations—it does not include sampling and relies on available records which may be incomplete
Correction: Understand Phase I limitations and consider site-specific factors (adjacent industrial uses, fill material, historical gaps) when evaluating residual risk
Proceeding with acquisition before Phase II results are available when RECs were identified
Consequence: Closing before understanding contamination scope exposes the buyer to unlimited cleanup liability
Correction: Never waive the DD contingency or close before Phase II results confirm the contamination status when RECs have been identified
Test Your Knowledge
1.What does a Phase I site reconnaissance involve?
2.What triggers the escalation from Phase I to Phase II?
3.What does Phase II soil and groundwater sampling determine?