ASTM finalized E1527-13, the latest Phase I Environmental Site Assessment standard on November 6, 2013. EPA subsequently approved E1527-13 as being compliant with All Appropriate Inquiry (AAI) regulations on December 30, 2013.
Here’s the top 3 things you need to know about these updated regulations:
ASTM updated the definition of a REC (Recognized Environmental Condition) to specifically include vapor as a potential concern. Previously, it was left to the Environmental Professional’s discretion or their client to determine if vapor should be considered when performing a Phase I. Environmental Professionals (EPs) must now consider solid, liquid and vapor releases of hazardous substances or petroleum products.
Bottom Line: You may see more RECs now that include vapor issues.
ASTM added the term CREC (Controlled Recognized Environmental Condition) to better define sites which have past releases that have been properly addressed but still have a required control (eg: commercial/industrial land use restriction, engineered barrier, etc).
Bottom Line: If you see a CREC, don’t panic. A CREC is a “good REC.” Gabriel can advise you and your client about any site-specific requirements regarding the continuing obligations.
ASTM states that agency file reviews should be conducted if the subject property or adjoining property is identified in any of the standard environmental records sources. Previously, some EPs would review these government records during their Phase I assessments but many would not. Now, these reviews must be included unless records are not reasonably ascertainable.
Bottom Line: Other firms might increase their prices to include this additional work. Gabriel has always done file reviews for these types of sites, so you will not see an increase in our prices to add in the file review.