As a real estate developer or landowner, you will likely have to perform a Phase I Environmental Site Assessment (ESA) when developing a piece of property. A professional engineer or professional geologist must perform the ESA, and it must be completed in accordance with the ASTM E1527-13 standard.
The ASTM E1527-13 is updated every 8 years with a new version. The new edition of the standard will be ASTM E1527-21 and it is largely the same with updates mainly to make it more user friendly. It is set to be released this fall, but it could be the end of 2022 before the EPA recognizes the new standard as consistent with the requirements for All Appropriate Inquiries (AAI).
At McFadden Engineering, we are aware of these changes, and we are in communication with government regulators to ensure that all Phase I ESA’s that we perform are completed correctly and efficiently.
The EPA has given guidance to continue the use of the E1527-13 standard, even once the new standard is released, until the EPA officially accepts the new standard as AAI. However, the new standard can be referenced in the report, but the report needs to be completed in accordance with the E1527-13 standard.
The new E1527-21 standard is going to address different areas that cause confusion, such as shelf-life clarity. It will have a discussion on the meaning of “likely” in a report and how it can be used. Also, it is going to address data gaps and how they affect the conclusions that are made in the report.
A hot topic recently has been PFAS and the effects it has on the environment. It is not yet regulated under CERCLA, which means it does not have to be considered in the Phase I ESA. However, the new standard will have an “Emerging Contaminants” section which will provide some guidance on how to deal with the possibility of PFAS being regulated in the future.
McFadden Engineering has a wealth of experience covering a broad range of civil and environmental services. Our specialties include environmental permitting for municipal, commercial, and industrial dischargers, environmental permitting and compliance management for industrial manufacturing facilities, site assessments and remediation, master planning for utilities, water quality projects, and wastewater process design.
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