Phase I and Phase II Environmental Site Assessment — Brownfield Redevelopment in Bastrop, Louisiana

Phase I Environmental Site Assessment Identified a UST as a Recognized Environmental Condition

As part of the City of Bastrop’s EPA Brownfields Assessment Grant, PPM Consultants conducted a Phase I Environmental Site Assessment at the former Aaron’s Grocery #2 property in Bastrop, Louisiana. The Phase I ESA was performed under ASTM E1527 All Appropriate Inquiries standards and identified an underground storage tank (UST) system on the property as an onsite Recognized Environmental Condition (REC). Based on that finding, the City retained PPM to perform a Phase II Environmental Site Assessment to evaluate whether historical site uses had impacted soil or groundwater.

Phase II Environmental Site Assessment with UST Closure and Removal

PPM submitted a Property Eligibility Determination (PED) to EPA, which was approved, and then prepared a Sampling and Analysis Plan (SAP) for the Phase II ESA. With SAP approval in hand, PPM performed the UST closure at the site on September 8–9, 2020. The UST had to be closed and removed to access the underlying soil for sampling. UST closure, removal, and disposal were all funded under the EPA Brownfields Assessment Grant.

Soil Sampling, Laboratory Analysis, and RECAP Comparison

During UST closure, PPM collected four soil samples and submitted them for laboratory analysis of benzene, toluene, ethylbenzene, and xylenes (BTEX), Methyl Tert-Butyl Ether (MTBE), Total Petroleum Hydrocarbons – Gasoline Range Organics (TPH-G), TPH, and lead. All constituents were below laboratory detection limits except lead, which was reported below the LDEQ Risk Evaluation/Corrective Action Program (RECAP) Screening Standards. Because no analyte exceeded RECAP screening criteria, no additional environmental assessment activities were required.

LDEQ No Further Action (NFA) Determination

PPM submitted a UST closure report to LDEQ and EPA documenting the Phase II ESA findings. LDEQ reviewed the report and issued a NFA determination for the site, clearing it for redevelopment. An LDEQ NFA letter is the regulatory milestone Louisiana property owners, lenders, and buyers typically require before moving brownfield properties back into productive use.

Brownfield Redevelopment Outcome

After receiving the LDEQ NFA, the site was redeveloped by a commercial investor as Westside Secure Storage, a self-storage facility. The redevelopment created local jobs, added the property back to Morehouse Parish’s tax base, and delivered a needed service to the Bastrop community, which are all stated goals of the EPA Brownfields Program.

Project Highlights

• Phase I Environmental Site Assessment identified a former UST system as an onsite REC.
• Phase II Environmental Site Assessment included UST closure and collection of closure samples.
• Contaminants of concern: petroleum products.
• REC was mitigated; LDEQ issued a No Further Action determination.
• Project funded by the EPA Brownfields Assessment Grant.
• Site redeveloped as an operating self-storage facility.

Frequently Asked Questions About Phase I and Phase II ESAs in Louisiana

What is a Phase I Environmental Site Assessment (ESA)? A Phase I ESA is a non-intrusive investigation performed under ASTM E1527 and EPA’s All Appropriate Inquiries (AAI) rule to identify Recognized Environmental Conditions (RECs) on a commercial property. It typically includes a site walkthrough, historical records review, regulatory database search, and interviews. No sampling is performed in a Phase I ESA.

When is a Phase II Environmental Site Assessment (ESA) needed? A Phase II ESA is recommended when a Phase I ESA identifies a Recognized Environmental Condition (REC) that requires confirmation through soil, groundwater, soil vapor, or building material sampling. A REC is a red flag that suggests contamination may be present or may have been present on a property and can include things like an old UST, soil staining or chemical odor, a property history as a dry cleaner or fuel station, or neighboring contaminated sites that could have migrated. The goal of a Phase II ESA is to determine whether contamination is actually present and, if so, at what concentrations relative to state screening standards.

What is a UST closure? UST closure is the regulated process of permanently removing or closing in place an underground storage tank. In Louisiana, UST closure must follow LDEQ requirements and typically involves tank removal, closure sampling of underlying soil, laboratory analysis, and submittal of a UST Closure Report to LDEQ.

What is an LDEQ NFA determination? An Louisiana Department of Environmental Quality (LDEQ) No Further Action (NFA) is a regulatory determination that no additional investigation or remediation is required at a site. It is issued after LDEQ reviews closure or assessment reports and confirms that site conditions meet RECAP Screening Standards. An LDEQ NFA letter is commonly required by lenders and buyers to close commercial real estate transactions on former industrial or fuel-related properties.

Who is eligible for an EPA Brownfields Assessment Grant? EPA Brownfields Assessment Grants are awarded to eligible entities such as local governments, regional planning agencies, and tribal nations to inventory, characterize, and assess brownfield properties, and plan for their cleanup and reuse. Grant funds can pay for Phase I ESAs, Phase II ESAs (and related UST closure/removal), cleanup planning, community involvement activities and other eligible redevelopment planning. PPM Consultants assists Louisiana municipalities with grant applications, grant management, and technical assessment and planning work required by the EPA workplan.

What Louisiana environmental services does PPM Consultants provide? From offices in Baton Rouge and Monroe, PPM Consultants provides Louisiana environmental services including Phase I and Phase II Environmental Site Assessments, UST closure and tank management, soil and groundwater assessment and remediation, LDEQ RECAP compliance, vapor intrusion assessments, brownfield grant management, air and water permitting, and emergency response oversight.