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ASTM D 6008 Document Information:
Title
Standard Practice for Conducting Environmental Baseline Surveys
ASTM International
Publication Date:
Oct 10, 1996
Scope:
Purpose - The purpose of this practice is to define good commercial
and customary practice in the
United States for conducting an environmental baseline survey (EBS) in
order to determine certain
elements of the environmental condition of federal real property,
including excess and surplus
property at closing and realigning military installations. This effort
is conducted to fulfill
certain requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of
1980 (CERCLA) section 120(h), as amended by the Community
Environmental Response Facilitation Act
of 1992 (CERFA). As such, this practice is intended to help a user to
gather and analyze data and
information in order to classify property into seven environmental
condition of property area types
(in accordance with the Standard Classification of Environmental
Condition of Property Area Types).
Once documented, the EBS is used to support Findings of Suitability to
Transfer (FOSTs), Findings
of Suitability to Lease (FOSLs), or uncontaminated property
determinations, or a combination
thereof, pursuant to the requirements of CERFA. Users of this practice
should note that it does not
address (except where explicitly noted) requirements for appropriate
and timely regulatory
consultation or concurrence, or both, during the conduct of the EBS or
during the identification
and use of the standard environmental condition of property area
types.
Environmental Baseline Survey - In accordance with the Department of
Defense (DoD) policy, an EBS
will be prepared or evaluated for its usefulness (and updated if
necessary) for any property to be
transferred by deed or leased. The EBS will be based on existing
environmental information related
to storage, release, treatment, or disposal of hazardous substances or
petroleum products on the
property to determine or discover the obviousness of the presence or
likely presence of a release
or threatened release of any hazardous substance or petroleum product.
In certain cases, additional
data, including sampling, if appropriate under the circumstances, may
be needed in the EBS to
support the FOST or FOSL. A previously conducted EBS may be updated as
necessary and used for
making a FOST or FOSL. An EBS also may help to satisfy other
environmental requirements (for
example, to satisfy the requirements of CERFA or to facilitate the
preparation of environmental
condition reports). In addition, the EBS provides a useful reference
document and assists in
compliance with hazard abatement policies related to asbestos and
leadbased paint. The EBS process
consists of discrete steps. This practice principally addresses
EBS-related information gathering
and analysis.
CERCLA Section 120(h) Requirements - This practice is intended to
assist with the identification of
installation areas subject to the notification and covenant
requirements of CERCLA § 120(h)
relating to the deed transfer of contaminated Federal real property
(42 USC 9601 et seq.).
CERFA Requirements - This practice can be used to provide information
that can be used to partially
fulfill the identification requirements of CERFA [Pub. L. 102-426, 106
Stat. 2174], which amended
CERCLA. Property classified as area Type 1, in accordance with
Classification D 5746 is eligible
for reporting as "uncontaminated" under the provisions of CERFA.
Additionally, certain property
classified as area Type 2, where evidence indicates that storage
occurred for less than one year,
may also be identified as uncontaminated. At installations listed on
the National Priorities List,
Environmental Protection Agency (EPA) concurrence must be obtained for
the property to be
considered "uncontaminated" and therefore transferable under CERCLA
§ 120(h)(4). The EPA has
stated that there may be instances in which it would be appropriate to
concur with the DoD
Component that certain property can be identified as uncontaminated
under CERCLA § 120(h)(4)
although some limited quantity of hazardous substances or petroleum
products have been stored,
released, or disposed of on the property. If the information available
indicates that the storage,
release, or disposal was associated with activities that would not be
expected to pose a threat to
human health or the environment (for example, housing areas,
petroleum-stained pavement areas, and
areas having undergone routine application of pesticides), such
property should be eligible for
expeditious reuse.
Petroleum Products - Petroleum products and their derivatives are
included within the scope of this
practice. Areas on which petroleum products or their derivatives were
stored for one year or more,
known to have been released or disposed of [CERCLA§ 120(h)(4)]
are not eligible to be reported
as "uncontaminated property" under CERFA.
Other Federal, State, and Local Environmental Laws - This practice
does not address requirements of
any federal, state, or local laws other than the applicable provisions
of CERCLA identified in
1.1.2 and 1.1.3. Users are cautioned that federal, state, and local
laws may impose additional EBS
or other environmental assessment obligations that are beyond the
scope of this practice. Users
should also be aware that there are likely to be other legal
obligations with regard to hazardous
substances or petroleum products discovered on property that are not
addressed in this practice and
that may pose risks of civil or criminal sanctions, or both, for
noncompliance.
Other Federal, State, and Local Real Property and Natural and Cultural
Resources Laws - This
practice does not address requirements of any federal, state or local
real property or natural and
cultural resources laws. Users are cautioned that numerous federal,
state, and local laws may
impose additional environmental and other legal requirements that must
be satisfied prior to deed
transfer of property that are beyond the scope of this practice.
Objectives - Objectives guiding the development of this practice are
(1) to synthesize and put in
writing a standard practice for conducting a high quality EBS, (2) to
facilitate the development of
high quality, standardized environmental condition of property maps to
be included in an EBS that
can be used to support FOSTs, FOSLs, and other applicable
environmental condition reports, (3) to
facilitate the use of the standard classification of environmental
condition of property area
types, and (4) to facilitate the development of a standard guide for
preparing and updating EBS
reports.
Limitations - Users of this practice should note that, while many of
the elements of an EBS are
performed in a manner consistent with other "due diligence" functions,
an EBS is not prepared to
satisfy a purchaser of real property's duty to conduct an "appropriate
inquiry" in order to
establish an "innocent landowner defense" to CERCLA § 107
liability. Any such use of any EBS
by any party is outside the control of the United States Department of
Defense and its components
and beyond the scope of any EBS. No warranties or representations are
made by the United States
Department of Defense, its components, its officers, employees, or
contractors that any EBS Report
satisfies any such requirement for any party.
Organization of This Practice - This practice has 15 sections. Section
1 is the scope. Section 2
identifies referenced documents. Section 3, Terminology, includes
definitions of terms not unique
to this practice, descriptions of terms unique to this practice, and
acronyms and abbreviations.
Section 4 is the significance and use of this practice. Section 5
describes user's
responsibilities. Sections 6-13 are the main body of the data
gathering analysis steps of the EBS
process. Section 14 briefly describes the EBS Step 3 classification of
environmental condition of
property area types. Section 15 contains a list of keywords.
This standard does not purport to address all of the safety concerns,
if any, associated with its
use. It is the responsibility of the user of this standard to
establish appropriate safety and
health practices and determine the applicability of regulatory
limitations prior to use.
Keywords:
- environment
- environmental assessment
- environmental baseline
- environmental condition
- environmental condition of property
- restoration
- site assessment
- site characterization
- site remediation
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