Using ASTM D6008 Standard Practice for Determining the Environmental Condition of Federal Property to Comply with the Requirements of CERCLA §120(h)
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About the Course
This course will discuss how to properly and effectively gather, review, and analyze records and aerial imagery to confirm the use, storage, or release of hazardous substances and petroleum at real property being sold, leased, or transferred by a federal landholding agency to another entity. Additionally we will cover how to conduct site visits and interviews to confirm the information distilled from the records review and analysis, how to synthesize the results of these steps to determine the environmental condition of property type, and provide the required notification to a lessee or subsequent landholding agency regarding the status of any response actions and any land use restrictions imposed upon the property due to past releases.
By the end of this course you will be able to:
- Identify the records and aerial imagery of the landholding agency and adjoining properties to be gathered, reviewed, and analyzed
- Describe what to look for during site visits to the subject property and adjoining properties, and why
- Identify who to interview at the federal landholding agency, the adjoining properties, and regulatory agencies and the types of questions to ask during the interviews
- Describe the process to determine the environmental condition of property type
- Prepare a written report that conforms with the requirements of CERCLA §120(h) and the General Services Administration’s Real Property Management Regulations codified in 41 CFR 102-75.
- Gather information related to orphaned wells on the property for management in accordance with the Orphaned Well Site Plugging, Remediation, and Restoration program (Orphaned Well Program) that was established by Section 40601 of the Infrastructure Investment and Jobs Act (IIJA).
Who Should Attend
This course is intended for Federal landholding agencies, including, but not limited to: the Department of Defense, Bureau of Land Management, Bureau of Reclamation, U.S. Fish and Wildlife Service, U.S. Forest Service, National Park Service, Department of Transportation, Department of Homeland Security, NASA, Federal Aviation Agency, Federal Highway Administration, Environmental Protection Agency, General Services Administration and environmental contractors working for each of these agencies.
ASTM Standards Referenced
This course references the following ASTM Standards and Other Publications:
- E1527 Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process
- E2247 Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property
- D5746 Classification of Environmental Condition of Property Area Types for Defense Base Closure and Realignment Facilities
- Department of Defense Manual 4715.20, Defense Environmental Restoration Program (DERP) Management, August 2018
- Department of Defense 4165.66M Base Redevelopment and Realignment Manual, August 2018
- Department of Defense Instruction 4715.18, Emerging Chemicals (ECs) of Environmental Concern, September 4, 2019
- Department of the Air Force Instruction 32-7020, Environmental Restoration Program, December 2020
- Office of the Undersecretary of Defense. Policy Memorandum for Clarifications and Upcoming Changes to Department of Defense Instruction 4715.18 in Response to Department of Defense Office of Inspector General Findings, April 2022