Site assessment is the first and critical step of environmental site management. This crucial phase of any given project sets the stage for the life cycle of the project, no matter the complexity. Often owners and practitioners find themselves in a position of reacting to conditions identified through the early stages of site assessment, resulting in misaligned actions to the stated vision or goals for the site. Taking a more deliberate and proactive approach to environmental site management, including risk assessment and background studies creates a much better outcome for the site and the many key stakeholders impacted by environmentally impaired assets. A proactive risk approach delivers the greatest value for the resources committed to the environmental life cycle.
One example we see across North America and globally is metals in soil and groundwater. The long history of industrialization, urbanization and economic growth has led to the widespread presence of metals in the environment. Background constituents in the environment create a common challenge for site owners and key stakeholders. To be proactive with constituents in soil and groundwater testing, investing upfront in determining what levels of metal are background or human-caused increases a better outcome.
This can be achieved within the project’s remedial investigation (RI) stage. The RI stage determines what levels of metals such as arsenic, lead and cadmium in the soil and groundwater can be considered “background,” part of the environment. It will also determine if metals are anthropogenic in nature and are likely the result of previous human activity, often unrelated to current day activities. In such a scenario, site owners might counter that if the concentration of metals present in the site’s soil and groundwater is low enough to avoid triggering regulatory concerns, there is no need to spend money upfront to distinguish between background and human-caused metal impacts. Instead, countering to extrapolate from the back end of the environmental review process – the natural or background levels on site.
The question becomes more challenging when the natural levels of metals in the soil may be higher than the risk-based screening values used to determine whether their presence at a site poses a threat to human health and/or the environment. In the instance of elevated naturally occurring metal concentrations, it might be seen as unreasonable for regulators to require remediation to the point of non-detect or even compliance with the risk-based screening level.
Our experience with many property owners determines otherwise, with greater outcomes associated with upfront investments in soil and groundwater contaminants.
Driving better outcomes through a proactive, risk-based approach
There are several reasons to take steps early in the RI process to distinguish background levels of metals from those that are site-specific.
When less removal is the better solution
If you have established site-specific soil background levels early, you may be able to choose less intrusive and quicker alternatives to mitigate risks while also setting proper expectations and managing costs of the extent of remedial actions to be taken.
Consider a site with naturally high levels of metal levels. If an upfront background metals study hasn’t been performed, there’s no awareness of anything other than the understanding that levels are high. You may think it’s necessary to take costly and intrusive action, such as digging soil down to a certain level over large parts of the property.
Or, you may believe it is necessary to treat the groundwater contamination on site. This has the potential to migrate off your property line, potentially causing concern for your neighbors through drilling extraction wells on the property to filter out the metals.
In the case of dig-and-dump, or pump-and-treat, the question remains: what to do with the excavated soils or water produced from remedial activities?
Following this approach by determining background metal levels early, you yield the best outcome for all stakeholders and guide them to the best possible outcome in potential remedial action.
When balanced approaches create stakeholder value
Tackling the challenge of legacy environmental conditions requires an approach that recognizes the unique drivers for a complex group of stakeholders. Municipal leaders, environmental NGOs and neighboring property owners have a right to be concerned that the development of your property is performed in a way that minimizes risk. It’s better for relations with these stakeholders if this is clearly conveyed well before construction starts. And environmental assessment is an important part of this approach. It is also imperative to assure risks to human health and the surrounding environment due to site-related activities are being addressed.
There is a possibility the media may cause unwarranted concern around soil contamination issues related to the property. As a result, local government and state regulators may feel pressured to step in and require more expensive measures be taken. Environmental assessments and investigations have greater credibility when the field work is done with transparency, with the results made available to all stakeholders. This is most effective when the background study is performed early assuring stakeholders their interests are being safeguarded. And if needed, remedial actions focused on risks associated with a release or site.
The result is fewer chances for outside factors to cause disruption to a project’s timelines and budget, enabling a smooth process. Acting early and with integral transparency can protect your property in the most cost-effective manner. Having our experts get involved early allows for faster development of your property.
