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ASTM E1527-13

August 22nd, 2014

History of Fire Insurance Maps

Photo courtesy of Historical Information Gatherers

Photo courtesy of Historical Information Gatherers

For environmental consultants, fire insurance maps (FIMs) can be a goldmine of historical information that is relevant to today’s environmental conditions on a particular property.  These FIMs were created for fire insurance companies to evaluate the degree of hazard for a particular building or area.  FIMs were first created in London in the late 1700s, and the practice quickly spread to the U.S.  The most well-known FIM company, the D. A. Sanborn National Insurance Diagram Bureau (later renamed to Sanborn Map Company) was founded in 1867 with an atlas of  fire insurance maps of the Boston area.  That book can be found today in the Library of Congress.

FIMs documented information that can still be important when conducting historical research during a Phase I Environmental Site Assessment.  They are recognized by ASTM as one of the standard historical sources that may be used to determine if a Recognized Environmental Condition (REC) exists at the subject site.

Key environmental information that can be found on a FIM includes: storage tanks (including gasoline, heating oil, etc.); historical use of the property or adjoining properties; location of petroleum products; industrial processes; heating sources; chemical storage; etc.  Other useful information that may be available: if a basement is present, when a building was constructed, and general layouts.

Historical Information Gatherers (HIG) has recently released an interesting white paper about the history of fire insurance maps.  The white paper includes information about land use, structures and possible environmental issues that one can discover using FIMs, as well as how FIMs were created and updated.  It is available for a free download on HIG’s website.  HIG is in the process of digitizing more than 500,000 color FIMs available through the Library of Congress.

More information about the history of the Sanborn Map Company is available on the Library of Congress website.

 

August 6th, 2014

What the heck is a “CREC”?

When the new E1527-13 Phase I Environmental Site Assessment standard was released in late 2013, ASTM included a new term: CREC. ASTMlogo

A CREC is a Controlled Recognized Environmental Condition, a subset of the traditional REC. CREC was developed to address the controlled presence of potential hazardous substances or petroleum products, as defined by the local environmental regulatory agency.

CREC examples:

  • Site A had a Leaking Underground Storage Tank (LUST) incident which was cleaned up to the satisfaction of the IEPA, with a land use restriction (eg: could only be used for commercial-industrial use). This would be considered a CREC since there are still hazardous substances and/or petroleum products present on the property, however the property has  been deemed safe for commercial or industrial use (though not residential use).
  • Site B was a former industrial operation that went through the Site Remediation Program (SRP) cleanup process. As part of the No Further Remediation (NFR) letter, the contaminated part of the property must remain capped by an engineered barrier. This would be considered a CREC since there are still hazardous substances present on the property, however they have been controlled by the engineered barrier.

Though the CREC is considered a REC, most CRECs would not be a major concern for a buyer or their lender. This language was developed to clarify situations such as these in order to give purchasers and lenders greater peace of mind about these sites.

July 25th, 2014

EPA Closes Comment Period for AAI Rule Amendment

Effective July 17th, 2014, U.S. Environmental Protection Agency (EPA) has closed the comment period for its proposed rule amending the All Appropriate Inquiries (AAI) regulations.  This proposed change would remove reference to the older Phase Iepa_logo2 Environmental Site Assessment ASTM standard (E1527-05) and confirm that Phase I assessments should be completed to the current ASTM standard (E1527-13).  EPA believes this change would promote the use of the current standard and reduce any confusion by having two standards in the regulatory reference documents.

EPA confirms that any Phase I’s conducted between November 1, 2005 and the date of the proposed rule implementation that were conducted to the ASTM E1527-05 standard would comply with the All Appropriate Inquiries regulations.

Only five comments were submitted during the comment period, with four in favor of the rule change for clarification purposes.  The one negative comment urged the EPA to continue allowing the use of 1527-05 in order to avoid the investigation of vapor as a pathway of concern.

EPA is reviewing the comments and will issue their final rule shortly.  Implementation of this amendment is expected to occur one year after the final rule is published in the Federal Register.

For further information about this proposed change, visit the EPA’s Proposed Rule webpage.

May 28th, 2014

HUD Adopts E1527-13 for all Phase I Requirements

The U.S. Department of Housing and Urban Development (HUD) has updated its guidance documents for the Office of Housing and Federal Housing Administration (FHA) to require the latest ASTM standard (E1527-13) effective May 16, 2014.  This change affects several guidance documents throughout Office of Housing/FHA, including, but not limited to, the Multifamily Accelerated Processing (MAP) Guide, the Condominium Project Approval and Processing Guide, Handbook 4600.1 REV-1, Section 232 Mortgage Insurance for Residential Care Facilities, and Handbook  4615.1, Mortgage Insurance for Hospitals.

HUD specifically details the addition of the term CREC (Controlled Recognized Environmental Condition) and inclusion of vapor to the migration pathway as important reasons to require ASTM E1527-13.

“The new CREC definition will result in some environmental conditions being listed as CRECs if they have been remediated to restricted levels, as opposed to an unrestricted or de minimis level, and will be a great tool for Office of Housing/FHA staff to assess whether the site is appropriate for residential use,” stated Carol Galante, Assistant Secretary for Housing – Federal Housing Commissioner.

If you have any questions about the new Phase I standard, contact Natalie Neuman (nneuman[at]gabenv.com or 773-486-2123).

April 11th, 2014

3 Things To Know About the New Phase I Standard

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:

VAPOR

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.

CREC

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.

FILE REVIEWS

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.