To support current national park service (NPS) and department of the interior (DOI) goals to reduce comprehensive environmental response compensation and liability act (cercla) liability at park…

To support current national park service (NPS) and department of the interior (DOI) goals to reduce comprehensive environmental response compensation and liability act (cercla) liability at park facilities, phase i environmental site assessments (esas) must be conducted to determine whether or not any hazardous waste sites or contamination exists prior to land purchases and transactions. To facilitate this process we seek assistance in conducting phase i esas consistent with requirements set forth under 40 CFR 312 (the all appropriate inquiry (AAI) standard), or requirements in the american society for testing and materials (astm)1527-05. The phase i ESA will include an analysis of current and historical conditions at the park with respect to site contaminants and potential for cercla liability. The goal of the site assessment is to identify potential liabilities under cercla before land transactions take place so that costs can be incorporated into land transactions and so that individual park facilities do not end up bearing the brunt of the cost of cercla clean-up. Phase i esas must be conducted by an environmental professional (EP) as described under the AAI standard. Phase i esas beginning november 1, 2006, will be conducted using new requirements under the AAI standard and will identify recognized environmental conditions (recs) and historical recs on park owned and operated properties by incorporating the following steps: declaring that the ESA is conducted by an EP; interviewing both current and past owners, operators, occupants, neighbors and key site manager of occupied or abandoned properties; reviewing historical structures from the time structures were first on the property (or when the property was used for agricultural, commercial, industrial, residential or governmental purposes); reviewing records to include scope of environmental clean-up liens recorded under federal, state, tribal, or local law; inspecting expanded data and information pertaining to federal, state, tribal, and local records relating to the property; visually and physically inspecting the subject property and adjoining properties including all structures, roads or paths; observing and documenting all potential contaminants of concern including cercla hazardous substances, pollutants or contaminants, petroleum products, other controlled substances (e.g., drug enforcement agency (DEA) substances); identifying data gaps and commenting on significance of data gaps by EP; reporting information in accordance with the AAI standard; reporting all recognized environmental conditions (recs) or potential recs; and potential DE minimis conditions, such as small quantities of household hazardous waste, may represent a significant government liability and should be estimated and reported. A rough order of magnitude, estimate of the proper disposal cost for such materials should be reported. Previous methods for conducting phase i esas may be utilized as long as the new requirements of AAI are met. This means that all phase i esas must incorporate new provisions as described under AAI.