Published: Jan 2007
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In Part One of this manual, we concentrated on performing Phase I Environmental Site Assessments (ESAs) in accordance with ASTM E 1527 . Part Two of this manual focuses on some of the key aspects associated with performing the Phase II Environmental Site Assessments (Phase II ESAs) in accordance with ASTM E 1903 . As of the writing of this manual the ASTM task group was in the process of negotiating the necessary revisions that were needed to make the Standard consistent with the changes that took place in the Phase I Standard. Two main approaches to revising the Phase II Standard were under consideration. The 1997 version of the Phase II Standard allows great flexibility enabling the user and the environmental professional to design the process to meet the needs of the user. Some task group members suggested changes to make the Phase II Standard more prescriptive. This approach would simplify some of the decision-making process but could adversely impact the level of professional judgment, and thus potentially detract from the value and diverse applicability of the Phase II process. It is likely that the Phase II standard will be revised to describe the scientific methods and practices appropriate for various types of investigation that typically occur after a Phase I but before regulatory involvement. Most states have specific requirements for site assessment once contamination is identified and reported. The Phase II standard may address those situations when assessment activity is necessary but there is insufficient information to require involvement of a regulatory agency. Such activities can be related to business decisions (is the contamination present or not, big problem or little problem, does it leave the site) or LLP defenses (identify continuing obligations, reasonable steps, or confirm a REC). The scientific method described in the current Phase II standard is not likely ot undergo significant change, however the actual document could be substantially revised. The EPs should monitor the development of the Standards, and whenever applicable modify their procedures when strict conformance to the latest version of the Standards is desired or mandated.
Paper ID: MNL11254M