Step 2: Site Investigation
It is essential that an appropriately detailed study of the site be performed to identify the cause, nature, and extent of contamination and the possible threats to the environment or to any people living or working nearby. The site investigation phase may include the analysis of samples of soil and soil gas, groundwater, surface water, and sediment. The migration pathways of contaminants also are examined during this phase, and a baseline risk assessment may be needed to calculate risk to human health and the environment.
Questions to Ask
- Are there Federal, State, Local, and Tribal regulatory requirements for a site investigation?
- What agency would be responsible for managing oversight of this phase?
- What happens if the appropriate agency has not developed standards or guidelines that are suitable for the proposed redevelopment?
- What technologies are available to facilitate site investigation?
- Can the need for cleanup be assessed fully and accurately from the information gathered during the site assessment or from a previous site investigation?
- What environmental conditions does the community consider unacceptable?
- What issues has the community raised that may affect the site investigation?
- What are the potential exposure pathways?
- Who or what could be affected by the contamination or the efforts to clean up the contamination?
- What happens if significant contamination is found?
- What happens if contamination poses a "significant threat" to local residents?
- What happens if the contamination is originating from an adjacent or other off-site source?
- What happens if background sampling indicates that contamination is originating from a naturally occurring source?
- Are the infrastructure systems (roads, buildings, sewers, and other facilities) contaminated?
- Could they be affected by efforts to clean up contamination?
Steps to Take:
- Identify the environmental conditions at the site.
- Conduct sampling and analysis to determine the nature, extent, source, and significance of the contamination that may be present at the site.
- Conduct sampling and analysis to fully assess the physical and geophysical conditions and characteristics of the site.
- Interpret the results of the analysis to characterize site conditions.
- Determine whether and how (if applicable) the infrastructure systems (including existing structures) are affected by contamination
Assess the risk the site may pose to human health and the environment. Consider the following exposure pathways:
- For soil and dust, direct contact, ingestion, or inhalation.
- For water and air, ingestion and inhalation.
- Determine the proper mix of technologies (such as field measurement technologies that characterize the physical and chemical aspects of the site and fixed laboratory sampling methods) that can facilitate site investigations and meet the required level of data quality objectives (DQO). DQOs are qualitative and quantitative statements specified to ensure that data of known and appropriate quality are obtained. The DQO process is a series of planning steps, typically conducted during site assessment and investigation, that is designed to ensure that the type, quantity, and quality of environmental data used in decision making are appropriate. The DQO process involves a logical, step-by-step procedure for determining which of the complex issues affecting a site are the most relevant to planning a site investigation before any data are collected.
- Examine unacceptable environmental conditions in terms of initial costs for site improvement and long-term costs for annual operation and maintenance - include potential cleanup options and constraints that may affect redevelopment requirements, such as project schedules, costs, and potential for achieving the desired reuse
- Begin consideration of sources of funding for site investigation and cleanup activities
- Consider the use of site-specific risk assessment to determine cleanup levels or guidelines when standards or guidelines have not been developed
- Continue to work with appropriate regulatory agencies to ensure that regulatory requirements are being properly addressed:
- Identify and consult with the appropriate State, Local, and Tribal agencies to include them as early as possible in the decision-making process.
- Contact the EPA regional Brownfields coordinator to identify and determine the availability of EPA support programs
- Educate members of the community about the site investigation process and actively involve them in decision making; consider risk communication techniques to facilitate those activities.
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