Doing Phase 1 Environmental Site Assessments in California can be a little different than in other states. Of course each state is different, but California has several factors that make environmental assessments pretty unique here.
Registered Environmental Professional
California is one of the only states that register environmental professionals. ASTM E1527-05 requires that an environmental professional perform the Phase 1 Environmental Site Assessment; therefore, a quality sensitive client will ask if their California environmental consultant is a Registered Environmental Assessor (REA).
California Regulatory Programs
Another reason Phase 1 Environmental Site Assessments in California are different is due to the many and diverse regulatory programs in California that can impact the Phase 1 ESA. These regulatory programs are often pertinent to records requests and file reviews done during the Phase 1 Environmental Report – the environmental professional has to know where to look or they could be missing important information about the property. Some of these programs relate more to subsurface investigations and site cleanup, but they are also relevant to the Phase 1 ESA world. The environmental professional needs to understand the regulatory framework for what would be considered a recognized environmental condition and what might not be – for ex., if a site is contaminated, is contamination above pertinent regulatory levels in California or not?
It is important to use a firm familiar with these programs:
1) Regional Water Quality Control Boards: In most states the regulations are statewide rules with maybe some variations for cities and counties. In California, the State Water Board grants a lot of power and autonomy to the Regional Water Quality Control Boards. The regional water boards are organized generally by watershed and may split counties. Water boards may have very different regulations. For example, the San Francisco Bay Regional Water Quality Control Board developed Environmental Screening Levels (ESLs) for soil and groundwater contamination, whereas the Los Angeles Regional Water Quality Control Board uses different screening levels including Soil Screening Levels, CHHSLs for soil-gas (see below), and Maximum Contaminant Levels (MCLs) for groundwater.
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