ASTM recently submitted their draft of E1527-05 to the EPA, which will be released simultaneously with the AAI regulation. As a result there will be changes to the current due diligence practice, whether one adopts AAI or the ASTM standard.
REQUIREMENT |
AAI |
ASTM |
Environmental Professional (EP)
|
• Licensed
Professional Engineer;
Or
• Licensed Professional Geologist; Or
• State, tribe or US territory registration; and
• 3 yrs. full-time experience
Or
• Baccalaureate degree (or higher) in relevant discipline; and
• 5 yrs. relevant experience
Or
• Baccalaureate degree (or higher) in any discipline; and
• 10 yrs. full-time experience
Note:
• EP is required to manage the assessment; not required to perform the
assessment.
|
• Individual
possessing sufficient training and experience to perform ASTM Phase I
activities;
and
• Individual with the ability to develop opinions and conclusions regarding
recognized environmental conditions
|
Interview Requirements
|
• Interview
with current owner; and
• Interview with one or more of the following persons:
– Current and past facility manager
– Past owners, occupants or operators
– Employees of current and past occupants
– Owners or occupants of neighboring/nearby properties (when subject property
is abandoned)
|
• Interview
with key site manager and occupants |
Searching Clean-up Liens
|
• Search
environmental cleanup liens |
• No
requirement. |
Reviewing Lists
|
• Reviewing
lists of registries or publicly available lists (within ½ mile
of subject property):
– Engineering Controls
– Institutional Controls
|
• No
requirement. |
Purchase Price
|
• Evaluating
the purchase price to the property value (no contamination) |
• No
requirement. |
| Additional Investigations |
• EP
required to consider degree of obviousness of presence of releases for
making
recommendations.
This requirement may increase the number of additional/follow on studies.
|
• Recognized
environmental conditions (REC) requirement or historic Rocs.
• No requirement to assess the degree of obviousness.
|
