The American Society for Testing and Materials (ASTM) has completed their revisions for an update to the most widely-used standard for Phase I Environmental Site Assessments (ESAs). The new standard, ASTM E-1527 13, was released on November 6th, 2013.
UPDATE: The new standard is expected to complete its EPA approval process by late 2013 or early 2014. ASTM released the new standard on November 6th, 2013, however Weber, Hayes and Associates will not be implementing the new standard until the review is complete.
Weber, Hayes and Associates has reviewed the significant revisions being proposed and is prepared to provide thorough, high quality Phase I ESAs in full compliance with the new standard. Currently, Weber, Hayes and Associates already includes several of the items that will be added with the updated standard with our Phase I ESA package, including local and state agency file reviews and a screen for vapor encroachment conditions.
The proposed revisions seek to simplify and clarify language and definitions at the heart of the standard, particularly around what qualifies as a Recognized Environmental Condition (REC), what qualifies as a Historical Recognized Environmental Condition (HREC) and it introduces a new term, the Controlled Recognized Environmental Condition (CREC). Generally speaking, these changes seek to provide greater clarity in identifying whether an environmental condition currently represents an immediate risk to a property, or that the identified risks have been addressed under regulatory oversight and do not constitute a significant risk at present.
Other updated areas to be found in ASTM E-1527 13 include:
- Language discussing how to evaluate for Vapor Encroachment Conditions (VECs), and provides a more refined definition of the term “migration”. In addition, indoor air quality was previously considered outside of the scope of a Phase I ESA, but considering the addition of the VEC review, indoor air quality can now be assessed in relation to vapor intrusion/migration effects from petroleum and other volatile chemical plumes at or in the Site vicinity.
- A requirement for the environmental professional conducting the assessment to complete local and state agency regulatory file reviews if the target Site or adjoining properties appears in regulatory databases identifying these properties as having a record of a petroleum product or hazardous material release, as being a generator of hazardous waste or other regulatory signifiers.
For those interested in more information, please see a good summary of the proposed changes and the history of the Phase I ESA standard in its relation to the EPA’s All Appropriate Inquiries at Environmental Data Resources’ website.
Effective January 1, 2013, all businesses required to submit Hazardous Materials Management Plans (HMMPs) and other hazardous materials related documentation to Certified Unified Program Agencies (CUPA), must now submit their annual reporting through the new web-based California Environmental Reporting System (CERS).
Weber, Hayes and Associates has undergone training for this program and can assist clients in preparing and submitting their required documentation.
The Safe Drinking Water State Revolving Fund (SDWSRF) accepts applications through the Universal PreApplication Process each year for a short window of time. This year, applications are being accepted from May 3 through July 8, 2013. Note: The 2013 deadline has now passed. Next year’s window will likely open and close over a similar time frame.
Weber, Hayes and Associates has successfully assisted schools and other public institutions in their application process to the SDWSRF. This is a great means to remedy longstanding water quality issues for party’s strapped for the necessary resources.
This funding mechanism provides a pathway to remedy deficiencies with public water systems, whether they be associated with health risks, compliance issues with the Safe Drinking Water Act, or outdated water systems for communities unable to raise the necessary funds to replace. While this is a prioritized funding system, there is a large amount of funding available. In addition, the relative ease of applying to the SDWSRF can make a little effort up-front highly worthwhile by protecting a community’s drinking water quality for future generations.
For more information on the SDWSRF, please see the California Department of Public Health’s website.
For a cost-effectiveness analysis tool for funding sources, please see the EPA’s Financing Alternatives Comparison Tool (FACT).
The State Water Resources Control Board (SWRCB) recently adopted the Low-Threat Underground Storage Tank Case Closure Policy (Low-Threat Closure Policy), effective August 17, 2012. The Low-Threat Closure Policy specifies that in the absence of unique attributes of a case or site-specific conditions that demonstrably increase the risk associated with residual petroleum constituents, cases that meet the eight (8) general and three (3) media-specific criteria described in the policy, are defined as being a low threat to human health, safety or the environment and are appropriate for closure pursuant to Health and Safety Code section 25296.10.
Weber, Hayes and Associates has been reviewing Leaking Underground Storage Tank (LUST) cases for eligibility for low threat case closure since the policy’s adoption last year. We have now closed multiple sites under this new policy and are happy to discuss its implications for your LUST site.
Low-Threat Closure Policy Watchdog Effort
Weber, Hayes and Associates was proud to support efforts to evaluate the potential impacts of the recently adopted Low-Threat UST Closure Policy. See http://ustlowriskpolicy.org/ for comments on the policy, background information and perspectives on the future of contamination cleanup in California.