New Compliance Standard: ASTM 1527-13 (Standard Practice for Environmental Site Assessments)
The new ASTM standard for performing Phase I Environmental Site Assessments (ESA) was formally issued in November. The new standard is called ASTM 1527-21 and though it still needs to be referenced by EPA into CERCLA, APTIM will begin complying with 1527-21 going forward.
The main revisions to the environmental site assessments standard were intended to improve report consistency and quality. APTIM reports already included most of the revisions and thus users should not expect to see major changes in our reports.
Below is a summary of the most relevant updates to standard ASTM 1527-13
The definition of a Recognized Environmental Condition (REC) was reworded to focus on likely presence and likely release. The definition of likely was expanded to “that which is neither certain nor proved but can be expected or believed by a reasonable observer.” The definitions of Controlled RECs and Historical RECs were clarified to state that past releases must have affected the Subject Property. ASTM also added a new tool called the REC Appendix, which contains flowcharts and diagrams of the REC definition and examples of scenarios.
Physical Setting Review
If any physical source information, such as depth to groundwater, can be obtained from agency file reviews, that information must be included in the physical setting section of the report.
Historical Research. There must be clearer emphasis on property identification, understanding that property use, size and address may have changed over the years. Instead of generic terms for property usage like “commercial” or “industrial,” the standard now requires the actual specific usage to be stated in the report. The revised standard also requires the review of the following standard resources: historical aerial photographs, historical topographic maps, city directories and fire insurance maps. If these sources were not reviewed, the report must state why.
Adjoining Property Research
Research on past uses of adjoining properties is now required. The same four (4) standard sources required for the Subject Property are also required for adjoining properties.
Not many changes for this section other than the report must indicate if specific features, activities, uses and conditions were or were not present and if present, must describe.
Significant Data Gap
The definition has been revised to state that a data gap is significant if it affects the ability of the environmental professional to identify a REC.
Reports – Overall
The property being studied should consistently be called “subject property.” The report should include more discussion about how significant data gaps affect the report opinions and report conclusions must include a statement about significant data gaps. Reports must now formally include photographs and a site map.
These have been added to the list non-scope considerations of the report. Once emerging contaminants are defined to be a hazardous substance under CERCLA, they will be required to be evaluated with the scope of the standard.
If you have any questions about the revised ASTM 1527-21 standard, please contact your APTIM representative.
By: Michael Jennings, APTIM
APTIM. Expect the Extraordinary.
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