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September/October 2010

E50 Standards Protect People and the Environment

Standards for Environmental Site Assessment, Risk Management and Corrective Action

To help navigate the complex demands of today’s regulatory environment with regard to storage tanks, commercial real estate and more, ASTM Committee E50 continues to provide guidance to industry.

Every day we gather guidance from directions on a roadmap, steps in a how-to book or the expertise of an instructor or colleague. For those engaged in commercial real estate transactions impacted by U.S. federal legislation, guidance comes through standards from ASTM International Committee E50 on Environmental Assessment, Risk Management and Corrective Action.

This year, Committee E50 marks 20 years of providing guidance on environmental assessment applications: more than 1,000 members currently maintain 34 standards related to commercial real estate and forestland, tanks and surface mines. (See sidebar, "A Timeline of Selected E50 Standards"). And the committee’s work continues as it grapples with climate change and the challenges of writing standards connected to that issue and others.

Storage Tanks and a New Committee

Like many ideas, it began with pen and a paper napkin. In this case, after a day of standards development meetings, a gathering of ASTM members determined that an activity on petroleum storage tanks would more appropriately be its own technical committee. That’s how William Gulledge recalls the concept for the committee, which grew into a separate group in 1990 from Committee D34 on Waste Disposal. Gulledge, senior director, Chemical Products and Technology, American Chemistry Council, Arlington, Va., is still involved in several E50 groups; he says, “E50 came from D34, but since the activities of E50 were not related to waste disposal, the new committee idea arose.”

The committee’s ongoing standards activities related to petroleum storage tanks have produced such standards as E1990, Guide for Performing Evaluations of Underground Storage Tank Systems for Operational Conformance with 40 CFR, Part 280 Regulations, an educational tool for tank owners, operators and other users that provides an overview of general requirements for these systems.

Subcommittee E50.01 on Storage Tanks is currently working on WK11080, Guide for Environmentally Sound Management of Underground Storage Tank Systems Storing Hazardous Substances or Petroleum, which addresses the principal considerations for preventing problems, and Subcommittee E50.04 on Corrective Action is working on WK15256, Guide for Investigation of Petroleum Underground Storage Tank Equipment Problems and Releases, which will establish protocols and documentation for industry, regulators and consultants to identify compliance options and reduce pollution using a tiered approach.

Risk-Based Corrective Action

More than a half million storage tanks for petroleum or other hazardous chemicals exist in the United States, according to the U.S. Environmental Protection Agency, which regulates the prevention, detection and cleanup of tanks that leak.

In the mid-1990s, E50 saw that it could provide guidance through a streamlined decision process to select corrective actions for petroleum release sites. “The challenge is to determine what poses a risk — and what does not,” wrote Dennis Rounds, an E50 officer, in the January 2005 SN. Rounds, executive director of the Office of Risk Management and the Petroleum Release Compensation Fund in Pierre, S.D., adds that risk-based corrective action was developed with training in mind so that the guide could be implemented successfully by state environmental regulatory programs. That has happened with RBCA, which is a part of programs in most states.

Starting with E1739, Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites, which focuses on one source — the petroleum tank — where RBCA can come into play, the E50 group has also produced additional RBCA standards, one for chemicals other than petroleum (E2081) and one for ecological receptors (E2205), as well as related standards.

E1527, A Flagship Standard

Early on in the committee’s existence, E50 members took on another challenge: to provide interest groups — bank and insurance companies that make commercial loans, purchasers, consultants who produce environmental assessment reports, environmental lawyers and government — with a common process that would satisfy EPA requirements for how to conduct “all appropriate inquiries” under the scope of the Comprehensive Environmental Response, Compensation and Liability Act.

That standard is E1527, Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, and ASTM International first published the flagship E50 standard in 1993. Before E1527, reports to meet the EPA requirements could be as brief as a single sheet checklist or as long as hundreds of pages of information, according to John Worlund, Converse Consultants, Bellingham, Wash., and an ASTM International member since 1988. There was a need for guidance, and Committee E50 stepped up to fill that need.

Little did Worlund think, back in 1993, that he would still be teaching ASTM technical and professional training courses on environmental site assessment in 2010. Worlund knew the value of the course, and the standard on which it is based, but he wondered how long the need would continue. He adds that additional professionals have entered the field or have new responsibilities for such work, so he continues to teach the course. It’s 15 years later and the course, based on E1527, still headlines ASTM International TPT listings.

ASTM holds TPT courses based on E1527 and on companion standards E1528, Practice for Limited Environmental Due Diligence: Transaction Screen Process, and E1903, Guide for Environmental Site Assessments: Phase II Environmental Site Assessment Process, among others. E1528 delineates a checklist environmental process for “clean” pieces of real estate (those never used for industrial purposes). E1903 covers parcels where potential problems have been identified, then dealt with, and is often used, Worlund says, to help define the problem in a business sense in order to determine risk and whether to proceed with a purchase.

“If you were getting ready to buy a piece of commercial real estate, you didn’t want to buy one that was contaminated because you could be held responsible for the cleanup,” Worlund says.

“This standard [E1527] has made a huge contribution to the commercial real estate market place,” Gulledge says. E1527 covers how to conduct an inquiry designed to identify recognized environmental conditions in connection with a property such as a gas station or dry cleaner, and it is cited in the EPA All Appropriate Inquiries law. As Julie Kilgore, Wasatch Environmental Inc., Salt Lake City, Utah, and chairman of Committee E50, wrote in the June 2006 SN, “Those early efforts [in the early 1990s] resulted in an ASTM standard practice that [has] stood the test of time and held up to the severe scrutiny of an equally passionate and committed EPA negotiating team.”

Climate Change

Committee E50 continues to recognize the need for guidance with its current work on what climate change means for a corporation’s bottom line. The committee is considering standards regarding the business side of climate change.

“Financial disclosures attributed to environmental liabilities (climate change included) are required of public companies” by the U.S. Securities and Exchange Commission, Gulledge says. “Climate change is a new area for these disclosures, and ASTM is providing guidance for these disclosures.”

ASTM published the first standard from E50’s climate change task group, a part of Subcommittee E50.05 on Environmental Risk Management, in March of this year. The standard, E2718, Guide for Financial Disclosures Attributed to Climate Change, delineates a process to identify potential financial risks and opportunities associated with climate change, quantify the financial impact of those risks and decide the appropriate disclosure content.

Other work items now under way are intended to assist companies as they take further steps. These drafts consist of:

  • WK21096, Guide for Disclosures Related to Climate Change Exposures/Risks;
  • WK21808, Guide for Basic Assessment and Management of Greenhouse Gases;
  • WK21810, Guide for Integration of Climate Change Risk Management into Sustainability and Greening Programs;
  • WK21811, Guide for Using Renewable Energy Projects on Brownfields in Climate Risk Management Strategies; and
  • WK21812, Guide for Adaption Mitigation for Climate Change Risk.

Ongoing Guidance

Committee E50 continues to look at environmental assessment and risk management and how it can provide standards needed by industry. “We’re trying to provide common language or boundary conditions,” says Worlund.

That now means draft standards in new areas for the committee, including building energy performance and what constitutes green remediation.

A nearly 300-member task group is developing draft standard WK24707, Practice for Building Energy Performance Assessment and Disclosure for a Building Involved in a Real Estate Transaction, so that all parties understand how the energy use information has been collected and reported. And WK23495, Guide for Green and Sustainable Site Assessment and Cleanup, is an effort to help the regulated community meet environmental requirements in greener, more sustainable ways that balance the social, environmental and economic aspects of a cleanup operation.

Where environmental assessment and risk management are matters of concern, E50 is probably there too, to provide guidance.