Riverside (Corona) California Phase I Environmental Site Assessments

Additional State Information

When selecting an environmental consulting firm to perform your Phase I Environmental Site Assessment in California, you should either choose a California firm or at least a non-California firm that is intimately familiar with CA regulations. Here are five reasons why:

1. 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 I Environmental Site Assessment; therefore, a quality-sensitive client will ask if their CA environmental consultant is a Registered Environmental Assessor (REA).
2. 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.
3. CHHSLs: 
   The California Environmental Protection Agency (EPA) published the California Human Health Screening Levels (CHHSLs) in 2005. The CHHSLs provide the user with a chemical-specific look-up table for what levels of soil gas or indoor air concentrations represent a threat to human health. CHHSLs are not intended to be regulatory numbers but are often treated as such. CHHSLs are also famously conservative. You need an environmental consultant doing your Phase I ESA that knows how to interpret soil gas and indoor air data in relation to CHHSLs and this requires a lot of California experience.
4. CUPAs: 
   Certified Unified Program Agencies (CUPAs) have a lot of power in California. CUPA are city or county agencies that have been more or less deputized to handle certain regulatory functions. An example of a CUPA is the City of Los Angeles Fire Department, which oversees releases from underground storage tanks (USTs), termed leaking USTs or LUSTs. To do proper regulatory due diligence during a Phase I Environmental Site Assessment your environmental professional must understand the California CUPAs.
5. CEQA: 
   The California Environmental Quality Act (CEQA) is California’s equivalent of the National Environmental Protection Act (NEPA). A Phase I Environmental Site Assessment sometimes has to deal with CEQA/NEPA issues like wetlands, endangered species, and/or historical resources as additional scope items.

The above issues are really statewide issue. Some of California’s largest cities and counties have unique regulations too, and you can really get some complex jurisdictional issues.