During the next few months The American Society of Testing Materials (ASTM) will release the fifth update to the Phase I Environmental Site Assessment standard (E 1527) that will include significant changes clarifying and expanding the Phase I process. The most noteworthy changes that will affect Environmental Professionals (EP) and end users of Phase I reports are summarized below.
Recognized Environmental Conditions
Recognized environmental conditions (RECs) have been at the core of ASTM E 1527 since its inaugural adoption in 1993. The 2013 update revises the definitions of RECs and Historic RECs (HRECs) and adds Controlled RECs (CRECs) to the standard.
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RECs (presence or likely presence) - The definition of RECs has remained unchanged since 1993 and the 2013 update streamlines the definition to better mimic the USEPA’s All Appropriate Inquiry (AAI) rule to eliminate ambiguities.
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Historic RECs – The definition of HRECs has been revised to better characterize past releases of hazardous substances or petroleum that has been adequately addressed through remediation or other risk based measures to meet unrestricted use criteria.
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Controlled RECs – A CREC is associated with past releases of hazardous substances or petroleum that have been addressed according to prevailing regulations and allowed to remain in place through the implementation of use restrictions and / or engineering controls.
Vapor Migration
In another significant change, the 2013 Phase I standard now explicitly recognizes subsurface vapor migration pathways. Consequently, EPs will now be required to evaluate vapor migration the same as impacted groundwater migration.
Agency File Review
The proposed standard includes agency file reviews. Specifically, the update instructs EPs to conduct agency file reviews for the target or adjoining properties that are identified in the environmental database search.
Status
The US EPA is currently reviewing the proposed update and is expected to issue a ruling that it is compliant with the AAI rule during the Summer of 2013 at which time ASTM will replace the current E 1527-05 standard with the updated E 1527-13 standard.
Roux Associates, Inc. is uniquely positioned to assist you with your environmental due diligence and Phase I projects, as a number of our Principals are active members of ASTM committees and we have performed Phase 1 assessments at high profile projects across the country.
Roux Associates, Inc. is a professional services firm providing a broad range of consulting and project management services to solve complex environmental issues associated with air, water and land. We have been providing these services to an impressive list of Fortune 500 and public sector clients nationwide for over 30 years through six offices, which are located in California, Illinois, Massachusetts, New Jersey and New York.
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