MEMORANDUM
TO:
EPA
Docket
SFUND­
2004­
0001
FROM:
Sven­
Erik
Kaiser
DATE:
April
29,
2005
RE:
Meeting
with
ASTM
E­
50
Subcommittee
on
Standard
E1527
On
April
19,
2005,
Sven­
Erik
Kaiser
of
EPA's
Office
of
Brownfields
Cleanup
and
Redevelopment
and
Jennifer
Anderson
of
EPA's
Office
of
General
Counsel
attended
a
meeting
of
the
ASTM
E­
50
Subcommittee
responsible
for
revising
the
ASTM
E1527
Phase
I
Environmental
Site
Assessment
Standard.
During
the
discussions
about
the
ASTM
E1527
standard,
subcommittee
members
raised
issues
about
the
EPA
Proposed
All
Appropriate
Inquiries
Rule.
EPA
listened
to
the
comments
but
did
not
respond
directly
to
the
commenters
with
regard
to
the
issues
raised
during
the
meeting.
I
am
submitting
the
ASTM
subcommittee
member
comments,
based
on
my
notes,
for
inclusion
in
the
EPA
docket
for
the
All
Appropriate
Inquiries
Rulemaking.

Members
of
the
ASTM
subcommittee
responsible
for
the
development
of
the
E1527
Phase
I
Environmental
Site
Assessment
Standard
made
the
following
comments
at
the
April
19,
2005
meeting.

1.
ASTM
members
supported
EPA's
recommendation
that
visual
inspections
be
conducted
by
an
environmental
professional
and
suggested
that
EPA
should
consider
requiring
that
the
environmental
professional
conduct
the
visual
inspection.

2.
A
commenter
was
concerned
that
the
search
distance
for
sites
classified
in
CERCLIS
as
"
No
Further
Remedial
Action
Planned"
was
too
broad
and
should
be
limited
to
the
subject
property.

3.
A
commenter
urged
EPA
to
reconsider
the
need
to
review
health
records
because
the
commenter
felt
that
such
records
were
difficult
to
obtain.

4.
Several
commenters
stated
that
environmental
liens
were
difficult
to
find
and
urged
EPA
to
alter
the
rule
language
on
environmental
liens
unless
there
were
more
sufficient
government
data
bases.

5.
Commenters
requested
clarification
on
the
treatment
of
state
certification
programs
for
environmental
professionals,
particularly
regarding
a
State
of
California
certification.
