The revised ASTM “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process” has been published in final form in November 2013. Caltha LLP is now conducting all Phase 1 ESAs using the revised standard.
Two of the key requirements that are significantly different compared to previous versions of this standard are:
- Requirement for physical review of agency file. If relevant information which may be useful in the assessment is only accessible in agency files, then a file review needs to be conducted.
- The standard now specifies three different categories for Recognized Environmental Conditions:
- ASTM E 1527-13 defines recognized environmental conditions the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment.
- A historical recognized environmental condition is a past release of any hazardous substances or petroleum products that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted use criteria established by a regulatory authority, without subjecting the property to any required controls.
- A controlled recognized environmental condition is a recognized environmental condition resulting from a past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory authority with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls.