Key Conclusion: The main goal and purpose of a Phase 1 assessment is to determine the need for a Phase 2 subsurface investigation.
A Phase 1 ESA is an evaluation of environmental conditions based on available agency and other printed and published documents. There are some situations, based on current, previous or nearby uses that the conclusions of an ESA may recommend a Phase 2 project. In Phase 1 ASTM standard terminology these are referred to as recognized environmental conditions (REC).
REC may include 1) a current condition such as the presence of an underground storage tank (UST) or sump used for chemicals, 2) the current or historical documented spillage, leakage or dumping of hazardous substances, 3) a former UST or other underground oil or chemical storage device that was removed but there is not sufficient subsurface sampling data, 4) an adjacent or up-gradient site is already a known leak case
An adequate Phase 1 MUST identify specific problems in specific locations involving specific chemicals (i.e. why, where and what?). It is not possible to abolish all risk regarding subsurface environmental conditions. It is never possible to test all areas on a Property for all chemicals. The best a Phase 2 can accomplish is to minimize the risk of a specifically identified problem. It is not acceptable to recommend Phase 2 sampling and then miss the target area. Yet this is an example of a recommendation that is presented in poorly prepared ESA reports.
Imprecise statements in an ESA report such as “based on historical uses of the Property, there may have been releases of petroleum products and solvents to the subsurface” are essentially meaningless. That is because it does not identify why, where and what implies that any chemical contaminant could be present in any location on the Property. If a Phase 2 investigation is performed based on that recommendation, there will be questions about why, where and what?