Schools SSp2: Environmental Site Assessment

Laura, I would go with what they ask for on the LEED Online form—GBCI can't argue with that. It's a V4 form so they've had plenty of time to edit it.

John,

LEED 2009 for Schools New Construction and Major Renovations mandates compliance with the prerequisite SSp2: Environmental Site Assessment and would therefore require conducting a Phase I Environmental Site Assessment.

Just on the face value of the information you’ve provided, I doubt LEED would accept the existing ESA. Six years is way too long for any ESA to remain valid, given the facts a Phase I requires a visual inspection of the property, including walking over the entire site, a comprehensive photographic log and interviews with the owner/manager/user of all adjacent properties. Additionally, it’s difficult to get lending institutions to accept a Phase I that is over 12 months old. You would be well advised to have an environmental expert "refresh" the existing 2005 report.

You need a narrative thoroughly explaining the type of contamination and the plans for remediation. It does not need to be completed. That's the way it was interpreted under NC v2.2 and I don't see anything in the 2009 RG or LOL form to indicate a change.

Elizabeth,

Although 2009 LEED for Schools prefers SSp2 be addressed at the “Design Review” phase, it doesn’t have to. The Design Review language specifically states “…enables project teams to assess the likelihood of achievement for some or all design-phase credits and/or prerequisites, prior to substantial project completion”. Also, the rating system permits a “Combined Review”, which means all documentation is submitted AFTER construction. If you haven’t yet submitted, just upload documentation from your environmental consultant describing the contamination, the remedial action planned and a schedule for the cleanup. If you have already submitted the “Design Review”, just cover it in the “Construction Review” phase. On occasion the location of the contamination identified is remote from the construction area and remediation is done simultaneously with the construction. In the end, LEED wants to know that the intent and requirement of credits/prerequisites have been met.

Thank you Michelle and Larry. We are just beginning the construction process, and are about to submit our design submittal. Your advice is most appreciated.

SPP2 says that If a site is contaminated, it must be remediated to meet local, state, or federal EPA region residential (unrestricted) standards, whichever is most stringent.

Do they really mean remediated or are engineering controls (such as barriers to dermal contact with soil) acceptable, if the local enforcing agency (state DEQ/DEP) finds them acceptable? This is an important distinction as the cost difference can be very significant (dig and haul to a landfill vs. encapsulation and O&M). The engineered barrier is in the final analysis the best solution, especially when in situ remediation is not practical.
Much thanks ...

Donald,

Engineering controls, such as encapsulating asbestos of laying asphalt over contaminated soils is acceptable. The intent in these instances is to remove the source from direct human contact.

Thanks for your quick response, Larry. I thought that had to be the case as the alternative seemed unreasonble.

I see the same thing you see on LEED Online.

I would either a) send a feedback question via LEED Online, or b) upload it into one of the other slots, like the alt compliance path slot, and include a note in the alt compliance path narrative area about why you did that, or c) don't worry about it -- if they don't ask for it, assume they don't want it. Or d) some combination of a through c.

They definitely want it uploaded. I uploaded it in the Phase I section (it is the closest to the intended compliance route) and will follow up with a question. Once I get an answer, I'll let you know.

Martin,

Although SSp2 lists ASTMVoluntary standards development organization which creates source technical standards for materials, products, systems, and services Phase I and Phase II ESA in the requirements, CIRs have generally given allowances for alternatives as long as they meet the intent of the credit. For instance, a CIR issued on 07/10/2006 ruled, in part: “The geotechnical assessment as performed essentially meets the objectives of a Phase II Environmental Site Assessment…”. Given the fact that California’s environmental regulations are some of the most stringent in the nation, I could not foresee LEED mounting any challenge to this. LEED respects California standards as witnessed by their deferring to California’s testing procedures for VOCs1. Volatile organic compounds (VOCs) are carbon compounds that participate in atmospheric photochemical reactions (excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides and carbonates, and ammonium carbonate). The compounds vaporize (become a gas) at normal room temperatures. 2. A molecule containing one or more carbon atoms that tends to evaporate (volatilize) into the air at typical ambi­ent conditions. Some legal definitions of VOCs are restricted to those that react with sunlight to generate smog. Some VOCs are carcinogens, suspected carcinogens, or known irritants at typical levels. on School projects. The website linked below refers to a 2009 DTSC proposed analysis at a school site under consideration. As described in the article, I would suspect that LEED would readily accept this.

http://www.ci.hercules.ca.us/index.aspx?page=23&recordid=173

I hope someone else might have more insight, but I don't know the details of the ASTMVoluntary standards development organization which creates source technical standards for materials, products, systems, and services standard, nor did a LEED consultant I checked with. In the U.S. we don't normally need to be familiar with the details of it.

You might check this Phase I ESA blog site, which has some more in-depth knowledge.