During the course of a Phase I Environmental Site Assessment, Gabriel reviews aerial photographs showing the site and surrounding area. Depending on its location, aerial photographs can be available as far back as ~1930, with updates every 5-15 years.
These aerial photos can help us determine when the property was first developed, as well as any changes in the property use, building size, and surrounding area development. Key items that can be seen on aerial photographs include:
- Historical gas station
- Aboveground storage tanks
- Past use as farmland
- Building additions
- Illegal dumping
- Presence of wetlands
- Drum storage
- Location of roads or railroad tracks/spurs
Gabriel was conducting a Phase I at a suburban location in the Chicagoland area. While reviewing the aerial photos, we found that the site was undeveloped in 1949; by 1970 had been developed into a gas station; and by 1990 had been redeveloped into its current use as a strip mall. This 1970 aerial photo was the key historical documentation which showed there may be petroleum products still present at this site, especially since no other documentation existed of UST removal or soil sampling.
1949 Aerial Photo – shows vacant land
1970 Aerial Photo – shows site developed as a gas station
1990 Aerial Photo – shows site redeveloped as a strip mall
If you have questions about how Gabriel uses aerial photos in our Phase I research, contact Natalie Neuman, Group Leader Assessment Services, at 773-486-2123 or nneuman[at]gabenv.com.
During the course of a Phase I Environmental Site Assessment, Gabriel reviews government records from a variety of federal, state, local, and tribal agencies. We will review all pertinent records available, including, but not limited to: underground storage tanks (USTs); hazardous materials stored, used or disposed; environmental violations; building permits; occupancy permits; fire inspection records; construction permits; demolition permits; and closure projects.
These records help us determine if hazardous substances or petroleum products are currently or were previously located on the site.
Recently, Gabriel was conducting a Phase I ESA at an auto repair facility in Chicago. The current owner/occupant did not have any knowledge of USTs on the property.
However, during a search of Illinois Office of the State Fire Marshal (OSFM) and Chicago Department of Public Health (CDPH) records, it was discovered that three tanks were installed at the property between 1972 and 1979, prior to the current owner purchasing the property. The previous owner had operated the property as a gas station in addition to the repair shop, so a diesel tank, gasoline tank and used oil tank had been installed.
None of these tanks had any record of removal, which means there is a strong likelihood that the tanks are still on site and possibly leaking due to their age and material.
If you have questions about how Gabriel uses government records reviews in our Phase I research, contact Natalie Neuman, Group Leader Assessment Services, at 773-486-2123 or nneuman[at]gabenv.com.
EPA is finishing their review process prior to issuing the Final Rule amending the All Appropriate Inquiry (AAI) regulations to remove reference to ASTM E1527-05 and replace with E1527-13. This ASTM Phase I Environmental Site Assessment standard was updated in November 2013 and confirmed by EPA to be compliant with the AAI rule in December 2013.
EPA received five comments to their proposed rule in July 2014, four of which were positive and one of which was negative. EPA will address the negative comment in the Final Rule’s preamble and explain its reasoning for why it disagrees with the comment.
EPA will also clarify in its preamble that any Phase I’s completed to the ASTM E1527-05 standard between November 1, 2005 and the effective date of the Final Rule will still be considered as compliant with the AAI regulations.
EPA has stated that it intends to make the effective date one year after the Final Rule is published, which is expected to occur in late September/early October. They decided that an earlier effective date may be burdensome to some entities who are still transitioning to the new ASTM standard. Any Phase I’s completed for federal Brownfields grants, however, must be completed to the E1527-13 standard effective immediately, upon the date the Final Rule is published.
For more information on the proposed Rule and to access the comments submitted, visit the EPA’s Proposed Rule for Standards and Regulations of All Appropriate Inquiries webpage.
If you have any questions about the ASTM standard or Phase I’s in general, contact Natalie Neuman, Group Leader of Assessment Services, at nneuman[at]gabenv.com.
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 I 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.