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Phase I Environmental Site Assessment Spotlight: File Review

January 27th, 2016

One of the major changes to the Phase I Environmental Site Assessment ASTM standard during the recent revision (E1527-13) is the enhanced requirement to conduct file reviews of government records. This requirement can uncover environmental concerns documented by old building permits, wrecking permits, tank permits, and fire records.

Because this file review can add extra time – and expenses – to a Phase I, not all consultants include this research as part of their standard assessment.  Skipping this part of the due diligence process may result in missing important information, as illustrated by the case study below.

Sometimes municipalities have digitized these older records and can make them available via PDFs.  Other times, we are required to review records in person either on paper files or on microfiche.

Key records we’re looking for include:

  • Fuel or heating oil tank installation/removal
  • Previous uses of the building (eg: rug cleaner; tool & die shop)
  • Fire inspection records regarding storage and usage of hazardous materials
  • Violations caused by environmental concerns (eg: hazardous waste disposal or storage)
  • Permits to upgrade HVAC system which may indicate past use of heating oil

Case Study

Gabriel was conducting a Phase I in a Chicago suburb. This municipality made some of its old permit records available via PDF,

building permit - fuel tank2

“Fuel Tank” highlighted in red on this building permit application from 1957

including old building permits.  On the building permit to the right, we discovered “Fuel Tank” listed on this original application from 1957.  No indication of size or location was provided.

Gabriel then conducted an in-person review of the remaining records the village stored only on microfiche.  On many Fire Department inspection records from 1959-1970s, the heating system is identified as oil-forced air.  There is no documentation found for when the building switched to the current natural gas fueled unit heaters.

Due to the file review of these government records, Gabriel concluded that fuel oil had been used as the heating source at the site for many years, and that an underground fuel oil tank may still exist on site.

No USTs were registered at the site and no visual indications of a UST were found during the site inspection.  Therefore, without this file review, this Recognized Environmental Condition (REC) may have been missed.

If you have questions about how Gabriel uses file reviews in our Phase I research, contact Natalie Neuman, Group Leader Assessment Services, at 773-486-2123 or nneuman[at]gabenv.com.

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