All Appropriate Inquiries Rule:
Reporting Requirements Checklist for Assessment
Grant Recipients
WHAT is "ALL APPROPRIATE INQUIRIES"?
"All appropriate inquiries," or AAI, is a process of evaluating a property's environmental conditions and
assessing the likelihood of any contamination. Every Phase I assessment conducted with EPA
Brownfields Assessment Grant funds must be conducted in compliance with the All Appropriate Inquiries
Final Rule at 40 CFR Part 312. The All Appropriate Inquiries Final Rule provides that the ASTM El527-
05 standard is consistent with the requirements of the final rule and may be used to comply with the
provisions of the rule. In addition, all appropriate inquiries must be conducted in compliance with the
Final Rule or the ASTM standard to obtain certain protections from liability under the federal
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, aka Superfund).
WHAT ARE THE DOCUMENTATION REQUIREMENTS FOR ALL APPROPRIATE INQUIRIES?
The final rule requires that the results of an AAI investigation be documented in a written report. The
specific reporting requirements for all appropriate inquiries are provided in 40 CFR §312.21 (Results of
Inquiry by an Environmental Professional) and §312.31 of the final rule and in §12 of ASTM E1527-05.
All AAI final reports must, at a minimum include the following:
1. An opinion as to whether the inquiry identified conditions indicative of releases or threatened releases
of hazardous substances, and as applicable, pollutants and contaminants, petroleum or petroleum
products, or controlled substances, on, at, in, or to the subject property.
2. An identification of "significant" data gaps (as defined in §312.10 of AAI final rule and §12.7 of
ASTM El 527-05), if any, in the information collected for the inquiry. Significant data gaps include
missing or unattainable information that affects the ability of the environmental professional to
identify conditions indicative of releases or threatened releases of hazardous substances, and as
applicable, pollutants and contaminants, petroleum or petroleum products, or controlled substances,
on, at, in, or to the subject property. The documentation of significant data gaps must include
information regarding the significance of these data gaps.
3. Qualifications and signature of the environmental professional(s). The environmental professional
must place the following statements in the document and sign the document:
• ' '[I, We] declare that, to the best of [my, our] professional knowledge and belief, [I, we] meet the definition of
Environmental Professional as defined in §312.10 of this part.''
• ' '[I, We] have the specific qualifications based on education, training, and experience to assess a property of the
nature, history, and setting of the subject property. [I, We] have developed and performed the all appropriate
inquiries in conformance with the standards and practices set forth in 40 CFR Part 312. "
Note: Please use either "I" or "We."
4. In compliance with §312.31(b) of the AAI final rule and §12.6.1 of ASTM E1527-05, the
environmental professional must include in the final report an opinion regarding additional
appropriate investigation, if the environmental professional has such an opinion.
For each Phase I Environmental Site Assessment, or AAI, conducted using EPA Brownfields Grant monies,
the grantee must complete, sign, date, and submit the following check list with any AAI reports submitted to
EPA.
Also see U.S. EPA's website at www.epa.gov/brownfields for additional information.
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Checklist for Phase I Site Assessments Conducted using EPA Brownfields
Assessment Grant Funds
Contact Information
Grantee Name:
Grant Number:
ACRES Property ID:
Program Manager Name:
(Point of Contact)
Contact Phone Number:
Name / Address of Property Assessed:
Checklist
Please indicate that each of the following All Appropriate Inquiries documentation requirements were
met for the Phase I assessment conducted at the above listed property:
O An opinion as to whether the inquiry has identified conditions indicative of releases or threatened
releases of hazardous substances, and as applicable, pollutants and contaminants, petroleum or
petroleum products, or controlled substances, on, at, in, or to the subject property.
O An identification of "significant" data gaps (as defined in §312.10 of AAI final rule and §12.7 of
ASTM El 527-05), if any, in the information collected for the inquiry, as well as comments
regarding the significance of these data gaps. Significant data gaps including missing and
unattainable information that affects the ability of the environmental professional to identify
conditions indicative of releases or threatened releases of hazardous substances, and as
applicable, pollutants and contaminants, petroleum or petroleum products, or controlled
substances, on, at, in, or to the subject property.
O Qualifications and signature of the environmental professional(s). The environmental
professional must place the following statements in the document and sign the document:
O ' '[I, We] declare that, to the best of [my, our] professional knowledge and belief, [I, we] meet the definition
of Environmental Professional as defined in §312.10 of this part.''
O ' '[I, We] have the specific qualifications based on education, training, and experience to assess a property of
the nature, history, and setting of the subject property. [I, We] have developed and performed the all
appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312.''
Note: Please use either "I" or "We."
D In compliance with §312.31(b) of the AAI final rule and §12.6.1 of ASTM E1527-05, the
environmental professional must include in the final report an opinion regarding additional
appropriate investigation, if the environmental professional has such an opinion.
Signature of Grantee Program Manager Date
Brownfields Fact Sheet Solid Waste EPA 560-R-11-030
AAI: Reporting Requirements and and Emergency June 2011
Grantee Checklist Response (5105) www.epa.gov/brownfiehls
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