J II m •- 'a 1 &EPA j All Appropriate Inquiries: Reporting Requirements Checklist for Assessment Grant Recipients What are "All Appropriate Inquiries"? All appropriate inquiries (AAI) is the process of evaluating a property's environmental conditions and assessing the potential liability for any contamination. Every Phase I environmental site assessment conducted with U.S. Environmental Protection Agency (EPA) Brownfields Program assessment grant funds must be conducted in compliance with the AAI final rule in the Code of Federal Regulations (CFR), 40 CFR Part 312. The AAI final rule provides that the ASTM International Standards ASTM E1527-21 "Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process" and E2247-16 "Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property" are consistent with the requirements of the AAI final rule and can be used to satisfy the statutory requirements for conducting AAI. AAI may be conducted in compliance with either of these standards to obtain protection from potential liability under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as an innocent landowner, contiguous property owner or bona fide prospective purchaser. What are the documentation requirements for AAI? The final rule requires that the results of an AAI investigation be documented in a written report. The specific reporting requirements for AAI are provided in 40 CFR Section 312.21, Results of inquiry by an environmental professional; Section 312.31 of the final rule; and ASTM E1527-21 and E2247-16. All AAI final reports must, at a minimum, include: 1. An opinion on whether the AAI identified conditions indicating a release or threatened release of hazardous substances, pollutants and contaminants, petroleum or petroleum products, or controlled substances on, at, in or to a property. 2. Identification of any significant data gaps (as defined in Section 312.10 of AAI final rule and Sections 3.2.78 and 12.6.2 of ASTM E1527-21 and Section 12.7 of E2247-16) in the information collected for the AAI. Significant data gaps include missing or unattainable information that affects the ability of the environmental professional to identify conditions indicating a release or threatened release of hazardous substances, pollutants and contaminants, petroleum or petroleum products, or controlled substances on, at, in or to a property. Documentation of data gaps must include information explaining the significance of those gaps. 3. The qualifications and signatures of the environmental professionals that conducted or supervised the AAI. The environmental professionals must include both of the following statements in the document (use either "I" or "We") 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." ------- 4. In compliance with Section 312.31(b) of the AAI final must include an opinion regarding additional appropriate investigation if they have such an opinion. rule and Section 12.14 of ASTM E1527-21 and E2247-16, the environmental professionals For each Phase I environmental site assessment or AAI conducted using EPA Brownfields grant funds, the grantee must complete, sign, date and submit the checklist below with any AAI reports submitted to EPA. For more information on AAI requirements, visit www.epa.gov/brownfields/brownfields-all- appropriate-inquiries. Checklist for Phase I Site Assessments Brownfields Assessment Grant Funds Conducted Using EPA CONTACT INFORMATION Program manager name (point of contact): Grantee name: Grant number: Contact phonei ACRES property ID: Name and address of assessed property: CHECKLIST Please indicate that each all appropriate inquiries (AAI) documentation requirement has been met for the Phase I assessment conducted for this property: ~ An opinion has been included on whether the AAI identified conditions indicating a release or threatened release of hazardous substances, pollutants and contaminants, petroleum or petroleum products, or controlled substances on, at, in or to this property. ~ Any significant data gaps (as defined in Section 312.10 of AAI final rule and Section 12.7 of ASTM E1527-21 and E2247-16) in the information collected for the AAI have been identified, and comments explaining the significance of those gaps have been included. Significant data gaps include missing or unattainable information that affects the ability to identify conditions indicating a release or threatened release of hazardous substances, pollutants and contaminants, petroleum or petroleum products, or controlled substances on, at, in or to this property. ~ The qualifications and signatures of the environmental professionals who conducted or supervised the AAI are included. The following statements have been included in the document (use either "I" or "We"), and the environmental professionals have signed 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." ~ In compliance with Section 312.31(b) of the AAI final rule and Section 12.61 of ASTM E1527-21 and E2247-16,the environmental professionals have provided an opinion regarding additional appropriate investigation if they have such an opinion. Grantee program manager signature: Date: For more information, visit the EPA Brownfields website at www.epa.gov/ brownfields. EPA 560-F23-004 ------- |