Numerous ASTM Standards Complement the Phase I ESA Standard

In a recent blog post my colleague Michael Wolf penned an article about the upcoming changes to the ASTM E1527 Standard, Phase I Environmental Site Assessment Process. With that being reported, we wanted to take the opportunity to expand on the presence of the ASTM standards and discuss some of the complimentary standards that exist within the ASTM library. As a voting member on the D18 Soil and Rock Committee and the E50 Environmental Assessment, Risk Management and Corrective Action Committee, I have the fortunate and unique perspective of how the ASTM standards are formulated. Each standard is meticulously prepared by committee under the direction of a committee chairperson and then peer reviewed by voting members of that committee. As such, the standards are developed with a vast amount of experience and expertise in the chosen area. With that kind of expertise behind each standard, the standards can be used as an industry guideline for projects that may not be under any type of regulatory scrutiny.

There are numerous standards that are complimentary to the E1527 Standard. Of course the E1528 is the first to come to mind, which is the standard for Transaction Screens. These screens are meant to be used when a Phase I ESA may not be necessary due to a particular user’s risk tolerance needs, or the size and historic use of a subject property. Not very well known, but still quite apropos for land acquisition, is a sister document to the E1527 Standard, E2247 Phase I Environmental Site Assessment Process for Forest Land and Rural Property. This standard is applicable for properties that are 120 acres or greater of forestland or rural property, or with a developed use of only managed forestland and/or agriculture with respect to the range of contaminants within the scope of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and petroleum products. Many users will desire a property physical evaluation along with a Phase I ESA. ASTM has developed standard E2018 Standard Guide for Property Condition Assessments to prescribe this type of evaluation. A Task Group has started the process of updating or possibly keeping “as is” the PCA Standard Guide.

The new E1527 standard, due for release later this year, will include language to clarify the evaluation of vapor encroachment conditions as part of an ESA. The USEPA and many states are developing, or have already developed, regulatory standards for vapor intrusion and vapor encroachment issues. ASTM has likewise developed a standard, E2600 Standard Guide for Vapor Encroachment Screening on Property Involved in Real Estate Transactions. As a follow-up to a Phase I ESA, E1903 was developed to standardize the Phase II Environmental Site Assessment. As a further follow up to the Phase I ESA standard, ASTM has developed a standard for future owner obligations in order to maintain the CERCLA liability protection given by the All Appropriate Inquiry legislation. This standard is E2790 Standard Guide for Continuing Obligations. Another area that is growing in concern, particularly in the southeast U.S., is the presence of mold within building envelopes. ASTM has standardized the inspection process through E2418 Standard Guide for Readily Observable Mold and Conditions Conducive to Mold in Commercial Buildings.

Beyond the complimentary standards to the E1527 Phase I ESA, there are many ASTM standards for detailed tasks within one or another standard. Some of this myriad of task-specific standards include D5092 Groundwater Monitoring Well Construction, D5521 Development of Groundwater Monitoring Wells, D7758 Passive Soil Gas Sampling, D7648 Active Soil Gas Survey, D1586 Standard Penetration Test (SPT), and D2488 Identification of Soils, to name a few.

Although many people are aware of the ASTM standard for Phase I Environmental Site Assessments, not all are aware of the many other standards that the ASTM organization and industry professionals have developed to compliment the Phase I standard. These complimentary standards have paved the way to some form of industry standardization, to fill the void left by the absence of or vagueness of federal, state and local regulations. It is imperative for the environmental consultant to know and understand these standards in order to better serve the client.