On Wednesday, April 18, an ASTM E50 task group consisting of environmental consultants, lenders, attorneys, EPA and other interested parties met in Phoenix, AZ to discuss revisions to the ASTM E1527-05 Phase I Environmental Site Assessment Standard. The last time the standard was updated was in 2005, when EPA released the details of its All Appropriate Inquires Rule, which cites the current standard as “at least as stringent” as EPA’s rule. According to ASTM bylaws, standards must be updated and reissued every eight years to avoid sun-setting and becoming invalid. A task group formed in 2010 and has since issued two revised versions to sub-committee voting.
In the most recent draft of the standard, the task group has proposed several changes to the standard, most intended to be clarifications rather than changes to industry practices. These proposed revisions include:
- Clarification about when an Agency File Reviews should be conducted as part of a Phase I ESA. The task group’s goal is to create greater consistency without adding undue burden on professionals
- Introduction of a new term, Controlled Recognized Environmental Condition, which would cover past contamination to soil and groundwater that has previously been remediated. A CREC would be distinct from a Historical Recognized Environmental Condition (REC) and a REC.
- Reference to the ASTM E2600-10 Vapor Encroachment Screening Standard and explanation that vapor plumes should be treated as any other source of contamination would be treated within the Phase I ESA.
The task group’s meeting on Wednesday included discussions on each of these topics, focusing on the negative votes and comments that were returned in the latest ballots. The group will adjust the draft accordingly over the next several weeks and is likely to send a new draft to main committee ballot this fall. Industry should expect a newly minted E1527 Standard sometime in 2013, pending EPA approval and update to the AAI rule
For more information on proposed clarifications, read EDR Insight’s recent Technical Brief on Agency File Reviews and check commonground for the latest updates on E1527 revision