Managing a Development Site’s Environmental Risks: Five Questions to Ask

shutterstock 192288539By Andy Bajorat

If you are building on a site with a history of different uses, construction poses risks beyond the standard OSHA concerns requiring hard hats and steel-toed boots.  Before breaking ground, you’ll want to consider the following:

Does a Phase I Environmental Site Assessment exist for your site? 

Phase I ESAs identify the full history of development and operations at your site. There may be historical impacts at your site (like a leaking underground tank) that you don’t even know about.

Does the dirt you’re moving pose a direct risk to construction workers?

If contamination has been identified in soil where you are constructing or developing property, levels may exceed the OSHA-or State exposure levels for short-term exposures or eight-hour work days. Workers may need special protective clothes or equipment to protect them from exposure. Air monitoring during work hours may also be required to limit exposure risk.

Does the dirt you’re moving need to be disposed in a special manner?

Contaminated soils may require disposal as a hazardous waste, depending on concentrations of contaminants identified. Or soils may be considered for use as clean fill, if appropriate samples and documentation can be provided. This should all be considered in advance so that trucks aren’t turned away at a landfill or take up precious space on the job site while waiting for approvals from disposal facilities.

Do on-site conditions affect your construction permits?

Soil and groundwater contaminants may affect the conditions of your stormwater control permits, air / dust control permits and/or groundwater/well permits, because what’s in the soil or groundwater at your site will be leaving your site and entering the surrounding community. Before you discharge impacted groundwater from the bottom of your construction pit to the neighborhood duck pond, you need to know what impacts, intentional or otherwise, it may have.

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Does your site contain potential regulated wetlands? 

Wetlands can be difficult to properly identify without a detailed inspection, as many areas do not contain obvious indications of wetland habitat. However, unpermitted activities such as excavation, filling, or dewatering that occur in regulated wetlands could result in significant construction delays and government fines.

The recommended best practice to avoid development pitfalls is to discuss potential environmental issues with engineers and consultants familiar with the site’s history. Gather readily available information well before the construction phase and organize a follow-up discussion with an environmental consultant who can assist owners, architect/engineers, and developers to proactively manage necessary tasks in conjunction with traditional construction services.

Andy Bajorat, CHMM, has worked in the environmental industry for more than 20 years. He currently serves as chief operating officer and Principal at BBJ Group, an environmental consultancy firm. He leads BBJ's retail sector focusing on environmental due diligence as well as the industrial sector's EHS management and compliance practice. His expertise includes Superfund site remediation, expert witness related toxic tort cases, neighborhood revitalization and lead modeling for Brownfield redevelopment sites.

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