Overview
of
Additions
and
Modifications
to
ASTM
1527­
2000
Standard
from
the
1997
ASTM
Standard
Background
Document
for:

Clarification
to
Interim
Standards
and
Practices
for
All
Appropriate
Inquiry
Under
CERCLA
and
Notice
of
Future
Rulemaking
Action
U.
S.
Environmental
Protection
Agency
Office
of
Brownfields
Cleanup
and
Redevelopment
October
2002
­1
Overview
of
Additions
and
Modifications
to
ASTM
1527­
2000
Standard
from
ASTM
Standard
1527­
97
The
following
provides
an
overview
of
modifications
made
to
ASTM's
1527­
97
standard
entitled
"Standard
Practice
for
Environmental
Site
Assessments:
Phase
I
Environmental
Site
Assessment
Process"
in
updating
the
standard
to
new
standard
ASTM
1527­
2000.

1.
Section
1.
Scope
Overview:
States
the
purpose
of
the
standard
as:
"to
define
a
good
commercial
and
customary
practice
in
the
United
States
of
America
for
conducting
an
environmental
site
assessment...
."
This
section
also
establishes
that
the
goal
of
an
environmental
site
assessment
is
to
identify
recognized
environmental
conditions,
identifies
related
practices
for
conducting
site
assessments,
states
that
the
practice
does
not
address
any
local,
state,
or
federal
laws
other
than
the
innocent
landowner
defense
under
the
Comprehensive
Environmental
Response,
Compensation
and
Liability
Act
(CERCLA),
states
the
objectives
of
the
standard
and
defines
what
is
beyond
the
scop
of
the
standard.

Modifications:

a.
Language
is
added
to
the
purpose
statement
stating
that
"An
evaluation
of
business
environmental
risk
associated
with
a
parcel
of
commercial
real
estate
may
necessitate
investigation
beyond
that
identified
in
this
practice."

b.
At
the
end
of
section
1.
1.
1.
"Recognized
Environmental
Conditions"
the
following
statement
is
added:
"Conditions
determined
to
be
de
minimis
are
not
recognized
environmental
conditions.

c.
At
the
end
of
section
1.
3
"considerations
Beyond
Scope,"
the
following
sentence
is
added:
"The
appropriateness
of
including
an
investigation
of
any
such
conditions
in
the
environmental
professional's
scope
of
services
should
be
evaluated
based
upon,
among
other
factors,
the
nature
of
the
property
and
the
reasons
for
performing
the
assessment
(for
example
a
more
comprehensive
evaluation
of
business
environmental
risk)
and
should
be
agreed
upon
between
the
user
and
environmental
professional
as
additional
services
beyond
the
scope
of
this
practice
prior
to
initiation
of
the
environmental
site
assessment
process."

d.
At
the
end
of
section
1.
4
"Organization
of
This
Practice,"
the
following
is
added:
"Appendix
X3
includes
guidance
to
assist
users
in
the
preparation
for
and
selection
of
an
environmental
professional
to
conduct
a
Phase
I
Environmental
Site
Assessment."
­2
e.
A
new
section
1.
6
is
added:
"1.
6
This
practice
offers
a
set
of
instructions
for
performing
one
or
more
specific
operations
and
should
be
supplemented
by
education,
experience
and
professional
judgment.
Not
all
aspects
of
this
practice
may
be
applicable
in
all
circumstances.
This
ASTM
standard
practice
does
not
necessarily
represent
the
standard
of
care
by
which
the
adequacy
of
a
given
professional
service
must
be
judged,
nor
should
this
document
be
applied
without
consideration
of
a
project's
unique
aspects.
The
word
"standard"
in
the
title
means
only
that
the
document
has
been
approved
through
the
ASTM
consensus
process.

2.
Section
2.
Referenced
Documents
No
modifications
to
this
section.

3.
Section
3.
Terminology
Overview:
This
section
provides
definitions,
descriptions
of
terms
and
a
list
of
acronyms.

Modifications:

a.
A
new
definition
of
"Activity
and
Use
Limitations"
is
added.

b.
The
definitions
of
"asbestos"
and
"asbestos­
containing
materials"
are
deleted.

c.
The
definition
of
"CORRACTS
list"
is
changed.

d.
A
definition
of
"engineering
controls"
is
added.

e.
A
definition
of
"institutional
control"
is
added.

f.
A
definition
of
"business
environmental
risk"
is
added.

g.
A
definition
of
"historical
recognized
environmental
condition"
is
added.

h.
A
definition
of
"material
threat"
is
added.

i.
A
sentence
was
added
to
the
definition
of
"recognized
environmental
condition"
stating:
"Conditions
determined
to
be
de
minimis
are
not
recognized
environmental
conditions.

j.
The
explanation
for
the
acronym
"CORRACTS"
in
the
list
of
acronyms
was
modified.

k.
The
acronym
"NFRAP"
(No
Further
Remedial
Action
Planned)
was
added
to
the
list
of
acronyms.
­3
l.
The
acronym
"TSD"
(hazardous
waste
treatment,
storage
or
disposal
facility)
was
added
to
the
list
of
acronyms.

m.
Entries
in
the
section
were
renumbered
to
reflect
additions
and
deletions.

4.
Section
4.
Significance
and
Use
Overview:
Explains
the
intended
use
for
the
standard.

Modifications:

a.
In
section
4.
4,
the
explanation
of
"additional
services"
is
modified
to
add
a
sentence
at
the
end
stating:
"Such
additional
services
may
include
business
environmental
risk
issues
not
included
within
the
scope
of
this
practice,
examples
of
which
are
identified
in
Section
12.1.4
under
Non­
Scope
Considerations."

5.
Section
5.
User's
Responsibilities
Overview:
This
section
describes
tasks
performed
by
the
"user"
and
which
do
not
require
the
technical
expertise
of
an
environmental
professional.

Modifications:

a.
Task
5.
2
"Checking
Title
Records
for
Environmental
Liens"
is
modified
to
include
within
the
scope
of
the
task
checking
for
"activity
and
use
limitations
(including
institutional
and
engineering
controls)."

b.
A
new
Task
5.5
is
added.
This
task
reads:
5.5
Other­
The
user
shall
make
known
to
the
environmental
professional
the
reason
why
the
user
wants
to
have
the
Phase
I
Environmental
Site
Assessment
performed.
Typical
reasons
might
include,
among
others,
the
intention
to
satisfy
one
of
the
requirements
to
qualify
for
the
innocent
landowner
defense
to
CERCLA
liability,
or
the
need
to
understand
any
potential
environmental
liabilities
that
could
materially
impact
the
operation
of
the
business
associated
with
the
parcel
of
commercial
real
estate.
The
user
and
the
environmental
professional
may
need
to
modify
the
scope­
of­
services
performed
under
this
practice
for
special
circumstances,
including,
but
not
limited
to,
operating
industrial
facilities,
or
large
tracts
of
land
(large
areas
or
corridors).
If
the
user
does
not
identify
the
purpose
of
the
Phase
I
Environmental
Site
Assessment,
the
environmental
professional
shall
add
limiting
language
to
this
effect
in
the
report
and
assume
the
purpose
is
to
qualify
for
the
innocent
landowner
defense
to
CERCLA
liability.
­4
6.
Section
6.
Phase
I
Environmental
Assessment
Overview:
This
section
identifies
and
explains
the
tasks
to
be
performed
in
conducting
a
Phase
I
Environmental
Assessment.

Modifications:

No
modifications.

7.
Section
7.
Records
Review
Overview:
This
section
defines
the
scope
of
and
purpose
of
a
records
review
conducted
to
help
identify
recognized
environmental
conditions.

Modifications:

a.
Modifications
are
made
to
the
description
of
task
7.
1.
8
"Documentation
of
Sources
Checked."
The
modifications
establish
that
"supporting
documentation
shall
be
included
in
the
report
or
adequately
referenced
to
facilitate
reconstruction
of
the
assessment
by
an
environmental
professional
other
than
the
environmental
professional
who
conducted
it."

b.
The
table
in
section
7.
2.
1.
1
"Standard
Environmental
Record
Sources:
Federal
and
State"
is
modified
to
include
the
"Federal
CERCLIS
NFRAP
site
list."

c.
The
table
in
section
7.
2.
2
"Additional
Environmental
Record
Sources:
State
or
Local"
which
identifies
types
of
state
and
local
sources
of
environmental
records
to
be
checked,
is
modified
to
include:
1)
"Brownfield
Sites,"
and
2)
"Local
Land
Records
(for
activity
and
use
limitations)."

8.
Section
8.
Site
Reconnaissance
Overview:
This
section
identifies
and
explains
tasks
for
obtaining
information
indicating
the
likelihood
of
identifying
recognized
environmental
conditions
in
connection
with
the
property.

Modifications:

No
modifications.
­5
9.
Section
9.
Interviews
with
Owners
and
Occupants
Overview:
This
section
identifies
and
explains
tasks
for
obtaining
information
indicating
recognized
environmental
conditions
in
connection
with
the
property
from
property
owners
and
occupants.

Modifications:

No
modifications.

10.
Section
10.
Interviews
with
Local
Government
Officials
Overview:
This
section
identifies
and
explains
tasks
for
obtaining
information
indicating
recognized
environmental
conditions
in
connection
with
the
property
from
local
government
officials.

Modifications:

No
modifications.

11.
Section
11.
Evaluation
and
Report
Preparation
Overview:
This
section
describes
the
recommended
format
and
content
of
the
Phase
I
Environmental
Site
Assessment
report.

Modifications:

a.
Section
11.
2
"Documentation"
is
revised
to
read
as
follows:
"The
analysis,
opinions
and
conclusions
in
the
Phase
I
Environmental
Site
Assessment
report
shall
be
supported
by
documentation.
If
the
environmental
professional
has
chosen
to
exclude
certain
documentation
from
the
report,
the
environmental
professional
shall
identify
in
the
report
the
reasons
for
doing
so
(for
example,
a
confidentiality
agreement).
Supporting
documentation
shall
be
included
in
the
report
or
adequately
referenced
to
facilitate
reconstruction
of
the
assessment
by
an
environmental
professional
other
than
the
environmental
professional
who
conducted
it.
Sources
that
revealed
no
findings
shall
also
be
documented."

b.
Section
11.4
"Credentials"
of
standard
1527­
97
is
deleted.
­6
c.
A
new
section
11.4
entitled
"Scope
of
Services"
is
inserted.
This
new
section
reads
as
follows:
"The
report
shall
describe
all
services
performed
in
sufficient
detail
to
permit
another
party
to
reconstruct
the
work
performed."

d.
A
new
section
11.
5
entitled
"Findings"
is
inserted.
This
new
section
reads
as
follows:
"The
report
shall
have
a
findings
section
which
identifies
known
or
suspect
environmental
conditions
associated
with
the
property,
and
which
may
include
recognized
environmental
conditions,
historical
recognized
conditions
and
de
minimis
conditions,
among
other
environmental
conditions."
The
previous
standard
included
a
section
11.6
"Findings
and
Conclusions"
that
was
similar
to
new
section
11.
5
"Findings."

e.
The
previous
section
11.5
(of
standard
1527­
97)
entitled
"Opinion"
is
deleted
and
replaced
with
the
following
section
11.6
(also
entitled
"Opinion"):
"The
report
shall
include
the
environmental
professional's
opinion(
s)
of
the
impact
on
the
property
of
known
or
suspect
environmental
conditions
identified
in
the
findings
section.
The
logic
and
reasoning
used
by
the
environmental
professional
in
evaluating
information
collected
during
the
course
of
the
investigation
related
to
known
or
suspect
environmental
conditions
shall
be
discussed.
The
opinion
section
shall
specifically
include
the
environmental
professional's
rationale
for
concluding
that
a
known
or
suspect
environmental
condition
is
or
not
currently
a
recognized
environmental
condition.
Known
or
suspect
environmental
conditions
shall
be
listed
in
the
conclusions
section
of
the
report."
The
language
beginning
with
"The
logic
and
reasoning..."
is
new
in
the
1527­
2000
standard.

f.
The
previous
section
11.6
in
standard
1527­
97
entitled
"Findings
and
Conclusions"
is
deleted
and
replaced
with
a
new
section
11.7
entitled
"Conclusions"
that
reads
as
follows:
11.7
Conclusions­
The
report
shall
include
a
conclusions
section
that
summarizes
all
recognized
environmental
conditions
connected
with
the
property
and
the
impact
of
these
recognized
environmental
conditions
on
the
property.
The
report
shall
include
one
of
the
following
statements:
11.7.1.1
"We
have
performed
a
Phase
I
Environmental
Site
Assessment
in
conformance
with
the
scope
and
limitations
of
ASTM
Practice
E
1527
of
[insert
address
or
legal
description],
the
property.
Any
exceptions
to,
or
deletions
from,
this
practice
are
described
in
Section
[
]
of
this
report.
This
assessment
has
revealed
no
evidence
of
recognized
environmental
conditions
in
connection
with
the
property,"
or
11.7.1.2
"We
have
performed
a
Phase
I
Environmental
Site
Assessment
in
conformance
with
the
scope
and
limitations
of
ASTM
Practice
E
1527
of
[insert
address
or
legal
description],
the
property.
Any
exceptions
to,
or
deletions
from,
this
practice
are
described
in
Section
[
]
of
this
report.
This
assessment
has
revealed
no
evidence
of
recognized
environmental
conditions
in
connection
with
the
property
except
for
the
following:
(list)."

g.
Previous
section
11.7
"Deviations"
is
renumbered
to
be
new
section
11.8
entitled
"Deviations."
­7
h.
The
previous
section
11.8
"Signature"
is
renumbered
to
be
section
11.11.

i.
A
new
section
11.10
entitled
"References
is
added
and
reads
as
follows:
"The
report
shall
include
a
references
section
to
identify
published
referenced
sources
relied
upon
in
preparing
the
Phase
I
Environmental
Site
Assessment.
Each
referenced
source
shall
be
adequately
annotated
to
facilitate
retrieval
by
another
party."

j.
A
new
section
11.12
entitled
"Qualifications"
is
added
and
reads
as
follows:
"The
report
shall
include
a
qualifications
statement
of
the
environmental
professional(
s)
responsible
for
the
Phase
I
Environmental
Site
Assessment
and
preparation
of
the
report."

k.
A
new
section
11.13
entitled
"Appendices"
is
added
and
reads
as
follows:
"The
report
shall
include
an
appendix
section
containing
supporting
documentation."

12.
Section
12.
Non­
Scope
Considerations
Overview:
This
section
describes
and
lists
additional
issues
and
additional
standards
that
a
user
may
wish
to
address
or
use
that
are
not
included
within
ASTM's
1527
standard.

Modifications:

a.
Several
non­
scope
considerations
are
added
to
the
list
of
additional
issues
in
section
12.1.4.
These
addition
issues
include:
regulatory
compliance,
cultural
and
historic
risks,
industrial
hygiene,
health
and
safety,
ecological
resources,
endangered
species,
indoor
air
quality,
and
high
voltage
power
lines.

13.
Appendix
X1.
Legal
Background
to
Federal
Law
and
the
Practices
on
Environmental
Assessments
in
Commercial
Real
Estate
Transactions
Overview:
Provides
background
information
on
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
(CERCLA).

Modifications:

No
modifications.

14.
Appendix
X2.
Recommended
Table
of
Contents
and
Report
Format
­8
Overview:
The
appendix
provides
a
recommended
table
of
contents
for
the
Phase
1
report.

Modifications:

a.
The
recommended
table
of
contents
is
replaced
almost
in
its
entirety
with
a
new
recommended
table
of
contents.

15.
Appendix
X3.
Guidance
to
Assist
Users
in
the
Preparation
for
and
Selection
of
an
Environmental
Professional
to
Conduct
a
Phase
I
Environmental
Site
Assessment
Overview:
Provides
recommendations
on
information
that
should
be
collected
prior
to
selecting
an
environmental
professional
and
provides
recommendations
on
how
to
select
an
environmental
professional.

Modifications:

a.
This
appendix
is
new
to
ASTM
1527­
2000.
