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ASTM Phase I vs. MCP Phase I

March 28th, 2014 by Stephanie Hanson


Guest Blogger – Stephanie  Hanson

I’m sometimes asked the difference between a Phase I completed under the MCP and a Phase I Environmental Site Assessment that follows the American Society for Testing and Materials (ASTM) Standards, also referred to as an ASTM Phase I. Both are completely different and used for totally different purposes.

In general terms, an MCP Phase I is completed for contaminated disposal sites after notification of a release has been made to MassDEP. An ASTM Phase I is most often used for property transactions where the buyer (and sometimes seller) wants to complete due diligence.

A Phase I Report and Investigation per 310 CMR 40 (the MCP) is completed for contaminated disposal sites. It summarizes the limited investigation and assessment activities taken at the site to determine the appropriate response actions to reduce or remove contamination under future comprehensive response actions. It also supports Tier Classification of the site, a process under the MCP that determines the level of MassDEP oversight needed based on the degree of contamination. It typically includes general site information, site history, nature and extent of contamination, migration pathways and exposure potential, and an evaluation for immediate response actions.

An ASTM Phase I performed in accordance with ASTM E1527-13 is generally intended to qualify a buyer for the innocent landowner defense to CERCLA (Comprehensive Environmental Response, Compensation and Liability Act) liability. An ASTM Phase I applies practices that constitute ‘all appropriate inquiry into the previous ownership and uses of the property consistent with good commercial or customary practice’. The goal is to identify the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products.

For more information about CEI’s ASTM Phase I services please contact Stephanie Hanson at 800.725.2550 or shanson@ceiengineers.com.

Visit us at www.ceiengineers.com

Posted in the categories Compliance, Hazardous Waste Remediation, MCP.