Will ASTM Environmental Site Assessment Changes Affect Your Business?

The recent changes to the ASTM E1527-13 standard may affect turnaround time and costs of Phase I environmental site assessments (ESA), PM Environmental says.

The ASTM updates consist of simplifications, clarifications and increased detail or guidance on provisions that were already in E1527-05. They are intended to allow environmental professionals (EPs) to better discuss and categorize concerns found during the completion of Phase I ESAs.

Modification 1: Regulatory File Reviews

Previously, EPs performing Phase I ESAs were not required to perform regulatory file reviews. The new standard states the EP “should” review pertinent regulatory files or justify the reason why the regulatory file was not reviewed.

How does this affect you?

Known scope of work: This may simplify comparing the price and delivery time of a Phase I ESA. For some companies, including PM, file reviews are standard procedure. Others, however, can leave this step out to provide a lower cost bid. Make sure to compare “apples to apples” bids.

Increased costs: Reviewing regulatory files often increases the cost of a Phase I ESA. This is why some companies that do not do it as part of their standard scope of services appear to have lower prices.

More thorough information: Reviewing regulatory files often results in more thorough information, allowing the EP to make conclusions and eliminate Recognized Environmental Conditions (RECs).

Longer turnaround time: In many instances, reviewing regulatory files may extend the delivery time for a Phase l ESA. This is due to reviewing the files at regulatory agencies, which takes additional time. The standard industry turnaround time is three to four weeks. Consultants who do not include regulatory file reviews as part of their standard scope of service may offer a shorter lead-time.

Modification 2: Vapor Intrusion

The impact of vapor intrusion is now a consideration when performing Phase I ESAs. Along with soil and groundwater, an EP must consider the contamination in the soil vapor phase. E1527-13 includes vapor in the definition of “migration” and also clarifies that vapor intrusion/migration does not fall under the category of an Indoor Air Quality concern (which is out of the ASTM E1527 scope of work).

How does this affect you?

Phase II ESAs will often include vapor sampling. The EPA and state environmental regulatory agencies have been developing vapor intrusion guidance for the last few years. The change to E1527-13 will result in vapor concerns being evaluated as a relevant contaminant pathway in Phase II ESAs. If vapor impacts are present, costs will increase to monitor and/or mitigate (i.e. engineering controls) to meet due care/continuing obligations.