The American Society for Testing and Materials (ASTM) recently published a revision to the EPA certified standard for Phase I Environmental Site Assessments (ESAs). The new standard, ASTM E-1527 13, was released on November 6th, 2013 and approved by the US EPA in January 2014.
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 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.