The current ASTM Phase I practice (E1527-05) was established in 2005. Eight years from the release of E1527-05, environmental professionals are updating and developing established practices.Revisions include modifications for current thinking of environmental concerns and differentiating closed out versus potentially ongoing concerns.Below is a summary of the changes:
- Definitions: RECs, HRECs, CRECs – The Recognized Environmental Condition (REC) definition has been changed to clarify its meaning. A release occurring within a building structure is no longer identified as an REC. The Historical Recognized Environmental Condition (HREC) was developed to address all types of previous releases or environmental conditions within a site (sites with residual contamination or cleaned up completely). However, it was not clear to users that an HREC could potentially mean that institutional controls were developed for the site and need to be continually maintained. The addition of a Controlled REC (CREC) was created to clarify the sites that have residual contamination and provide the proper information for users.
- Vapor Intrusion (Guidance Document E2600) – Vapor intrusion has been an implied part of Phase I ESAs for some time but has not been strongly encouraged except for gas stations & dry cleaners.Vapor intrusion is not a disregarded source of contamination. New to E1527-13 is the ASTM E2600 “guidance” document. This document is not required in an ASTM Phase I under the new regulations; however, the creation of this document strengthens the language to more explicitly consider vapor as a contaminant pathway.
- Regulatory Reviews / File Reviews – ASTM Phase I under the current regulations, includes a limited amount of regulatory research of specific spills or releases pertaining to adjacent & abutting sites. The revised version of this section in the regulation places a stronger emphasis on the applicability of regulatory reviews. While the necessary data base review is substantial in most cases, additional research for specific finds of adjacent & abutting properties may be needed to complete the report.
- Title and Judicial Records (User Information) – A change in language in the revisions reiterates the importance of identifying the presence of an Activity Use and Limitation (AUL) or environmental lien on the subject property. The onus is on the User to provide full information to the Environmental Professional. The search of judicial records is a change in process to ensure all relevant & pertinent information is included.
For further information on how updates to the Phase I ASTM may affect property acquisition and underwriting, contact Mr. Stephen Dowaliby at firstname.lastname@example.org or at (978) 688-7804 x119.