Designation: D 6008 – 96

Standard Practice for

Conducting Environmental Baseline Surveys1
This standard is issued under the fixed designation D 6008; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (e) indicates an editorial change since the last revision or reapproval.

1. Scope conducted EBS may be updated as necessary and used for

1.1 Purpose—The purpose of this practice is to define good making a FOST or FOSL. An EBS also may help to satisfy
commercial and customary practice in the United States for other environmental requirements (for example, to satisfy the
conducting an environmental baseline survey (EBS) in order to requirements of CERFA or to facilitate the preparation of
determine certain elements of the environmental condition of environmental condition reports). In addition, the EBS pro-
federal real property, including excess and surplus property at vides a useful reference document and assists in compliance
closing and realigning military installations. This effort is with hazard abatement policies related to asbestos and lead-
conducted to fulfill certain requirements of the Comprehensive based paint. The EBS process consists of discrete steps. This
Environmental Response, Compensation and Liability Act of practice principally addresses EBS-related information gather-
1980 (CERCLA) section 120(h), as amended by the Commu- ing and analysis.
nity Environmental Response Facilitation Act of 1992 1.1.2 CERCLA Section 120(h) Requirements—This practice
(CERFA). As such, this practice is intended to help a user to is intended to assist with the identification of installation areas
gather and analyze data and information in order to classify subject to the notification and covenant requirements of CER-
property into seven environmental condition of property area CLA § 120(h) relating to the deed transfer of contaminated
types (in accordance with the Standard Classification of Federal real property (42 USC 9601 et seq.).
Environmental Condition of Property Area Types). Once docu- 1.1.3 CERFA Requirements—This practice can be used to
mented, the EBS is used to support Findings of Suitability to provide information that can be used to partially fulfill the
Transfer (FOSTs), Findings of Suitability to Lease (FOSLs), or identification requirements of CERFA [Pub. L. 102-426, 106
uncontaminated property determinations, or a combination Stat. 2174], which amended CERCLA. Property classified as
thereof, pursuant to the requirements of CERFA. Users of this area Type 1, in accordance with Classification D 5746 is
practice should note that it does not address (except where eligible for reporting as “uncontaminated” under the provisions
explicitly noted) requirements for appropriate and timely of CERFA. Additionally, certain property classified as area
regulatory consultation or concurrence, or both, during the Type 2, where evidence indicates that storage occurred for less
conduct of the EBS or during the identification and use of the than one year, may also be identified as uncontaminated. At
standard environmental condition of property area types. installations listed on the National Priorities List, Environmen-
1.1.1 Environmental Baseline Survey—In accordance with tal Protection Agency (EPA) concurrence must be obtained for
the Department of Defense (DoD) policy, an EBS will be the property to be considered “uncontaminated” and therefore
prepared or evaluated for its usefulness (and updated if transferable under CERCLA § 120(h)(4). The EPA has stated
necessary) for any property to be transferred by deed or leased. that there may be instances in which it would be appropriate to
The EBS will be based on existing environmental information concur with the DoD Component that certain property can be
related to storage, release, treatment, or disposal of hazardous identified as uncontaminated under CERCLA § 120(h)(4)
substances or petroleum products on the property to determine although some limited quantity of hazardous substances or
or discover the obviousness of the presence or likely presence petroleum products have been stored, released, or disposed of
of a release or threatened release of any hazardous substance or on the property. If the information available indicates that the
petroleum product. In certain cases, additional data, including storage, release, or disposal was associated with activities that
sampling, if appropriate under the circumstances, may be would not be expected to pose a threat to human health or the
needed in the EBS to support the FOST or FOSL. A previously environment (for example, housing areas, petroleum-stained
pavement areas, and areas having undergone routine applica-
tion of pesticides), such property should be eligible for
1
This practice is under the jurisdiction of ASTM Committee D-34 on Waste expeditious reuse.
Management and is the direct responsibility of Subcommittee D34.05 on Site 1.1.4 Petroleum Products—Petroleum products and their
Remediation.
Current edition approved Oct. 10, 1996. Published December 1996. Originally derivatives are included within the scope of this practice. Areas
published as PS 37. Last previous edition PS 37 – 95. on which petroleum products or their derivatives were stored

Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959, United States.

1
 D 6008 – 96
for one year or more, known to have been released or disposed priate safety and health practices and determine the applica-
of [CERCLA§ 120(h)(4)] are not eligible to be reported as bility of regulatory limitations prior to use.
“uncontaminated property” under CERFA.
1.1.5 Other Federal, State, and Local Environmental 2. Referenced Documents
Laws—This practice does not address requirements of any 2.1 ASTM Standards:
federal, state, or local laws other than the applicable provisions E 1527 Practice for Environmental Site Assessments: Phase
of CERCLA identified in 1.1.2 and 1.1.3. Users are cautioned I Environmental Site Assessment Process2
that federal, state, and local laws may impose additional EBS E 1528 Practice for Environmental Site Assessments:
or other environmental assessment obligations that are beyond Transaction Screen Process2
the scope of this practice. Users should also be aware that there D 5746 Classification of Environmental Condition of Prop-
are likely to be other legal obligations with regard to hazardous erty Area Types2
substances or petroleum products discovered on property that 2.2 Department of Defense Policies:
are not addressed in this practice and that may pose risks of DoD Policy on the Environmental Review Process to Reach
civil or criminal sanctions, or both, for noncompliance. a Finding of Suitability to Lease (FOSL), September
1.1.6 Other Federal, State, and Local Real Property and 19933
Natural and Cultural Resources Laws—This practice does not DoD Policy on the Environmental Review Process to Reach
address requirements of any federal, state or local real property a Finding of Suitability to Transfer (FOST) for Property
or natural and cultural resources laws. Users are cautioned that Where No Release or Disposal Has Occurred, June
numerous federal, state, and local laws may impose additional 19943
environmental and other legal requirements that must be DoD Policy on the Environmental Review Process to Reach
satisfied prior to deed transfer of property that are beyond the a Finding of Suitability to Transfer (FOST) for Property
scope of this practice. Where Release or Disposal Has Occurred, June 19943
1.2 Objectives—Objectives guiding the development of this DoD Policy on the Implementation of the Community
practice are (1) to synthesize and put in writing a standard Environmental Response Facilitation Act (CERFA), Sep-
practice for conducting a high quality EBS, (2) to facilitate the tember 19933
development of high quality, standardized environmental con- 2.3 Department of Defense Guidance Document:
dition of property maps to be included in an EBS that can be BRAC Cleanup Plan Guidebook, Fall 19933
used to support FOSTs, FOSLs, and other applicable environ- 2.4 Federal Standards:4
mental condition reports, (3) to facilitate the use of the standard Title 40, Code of Federal Regulations (CFR), Part 300,
classification of environmental condition of property area National Oil and Hazardous Substances Pollution Contin-
types, and ( 4) to facilitate the development of a standard guide gency Plan
for preparing and updating EBS reports. Title 40, Code of Federal Regulations (CFR), Part 302,
1.3 Limitations— Users of this practice should note that, Designation Reportable Quantities and Notification
while many of the elements of an EBS are performed in a Title 40, Code of Federal Regulations (CFR), Part 355,
manner consistent with other “due diligence” functions, an Emergency Planning and Notification
EBS is not prepared to satisfy a purchaser of real property’s
3. Terminology
duty to conduct an “appropriate inquiry” in order to establish
an “innocent landowner defense” to CERCLA § 107 liability. 3.1 This section provides definitions (of terms not unique to
Any such use of any EBS by any party is outside the control of this practice), descriptions of terms specific to this practice, and
the United States Department of Defense and its components a list of acronyms and abbreviations used herein. The terms are
and beyond the scope of any EBS. No warranties or represen- an integral part of this practice and are critical to its under-
tations are made by the United States Department of Defense, standing and use. Many of these terms are also found in
its components, its officers, employees, or contractors that any Practice E 1527.
EBS Report satisfies any such requirement for any party. 3.2 Definitions:
1.4 Organization of This Practice—This practice has 15 3.2.1 asbestos—six naturally occurring fibrous minerals
sections. Section 1 is the scope. Section 2 identifies referenced found in certain types of rock formations. Of the six, the
documents. Section 3, Terminology, includes definitions of minerals chrysotile, amosite, and crocidolite have been most
terms not unique to this practice, descriptions of terms unique commonly used in building products. When mined and pro-
to this practice, and acronyms and abbreviations. Section 4 is cessed, asbestos is typically separated into very thin fibers.
the significance and use of this practice. Section 5 describes Because asbestos is strong, incombustible, and corrosion-
user’s responsibilities. Sections 6-13 are the main body of the resistant, asbestos was used in many commercial products
data gathering analysis steps of the EBS process. Section 14 beginning early in this century and peaking in the period from
briefly describes the EBS Step 3 classification of environmen-
tal condition of property area types. Section 15 contains a list
of keywords. 2
Annual Book of ASTM Standards, Vol 11.04.
3
Available from Department of Defense, Office of Environmental Security, 3400
1.5 This standard does not purport to address all of the Defense Pentagon, Washington, DC 20301-3400.
safety concerns, if any, associated with its use. It is the 4
Available from the Superintendent of Documents, U.S. Government Printing
responsibility of the user of this standard to establish appro- Office, Washington, DC 20402.

2
 D 6008 – 96
World War II into the 1970s. When inhaled in sufficient substance under subparagraphs (A) through (F) of this para-
quantities, asbestos fibers can cause serious health problems. graph, and the term does not include natural gas, natural gas
3.2.2 asbestos-containing material (ACM)—any material or liquids, liquefied natural gas, or synthetic gas usable for fuel
product that contains more than 1 % asbestos. (or mixtures of natural gas and such synthetic gas).” Users of
3.2.3 Comprehensive Environmental Response, Compensa- this practice should note that certain states may expand this
tion, and Liability Information System (CERCLIS)—the list of definition to include other substances not meeting the above
sites compiled by EPA that EPA has investigated or is currently definition. The user or environmental professional should
investigating for potential hazardous substance contamination consider whether the state in which the installation is located
for possible inclusion on the National Priorities List. has identified such identified substances.
3.2.4 contaminated public wells—public wells used for 3.2.11 hazardous waste—any hazardous waste having the
drinking water that have been designated by a government characteristics identified under or listed pursuant to section
entity as contaminated by toxic substances (for example, 3001 of the Solid Waste Disposal Act (42 USC § 6901 et seq.)
chlorinated solvents), or as having water unsafe to drink (but not including any waste the regulation of which under the
without treatment. Solid Waste Disposal Act has been suspended by Act of
3.2.5 drum—a container (typically, but not necessarily, Congress) and so forth.
holding 55 gal [208 L] of liquid) that may have been used to 3.2.12 landfill—a place, location, tract of land, area, or
store hazardous substances or petroleum products. premises used for the disposal of solid wastes as defined by
3.2.6 dwelling—structure or portion thereof used for resi- state solid waste regulations. The term is synonymous with the
dential habitation. term solid waste disposal site and is also known as a garbage
3.2.7 environmental lien—a charge, security, or encum- dump, trash dump, or similar term.
brance upon title to a property to secure the payment of a cost, 3.2.13 local street directories—directories published by
damage, debt, obligation, or duty arising out of response private (or sometimes government) sources that show owner-
actions, cleanup, or other remediation of hazardous substances ship, occupancy, or use of sites, or combination thereof, by
or petroleum products upon a property, including (but not reference to street addresses. Often local street directories are
limited to) liens imposed pursuant to CERCLA 42 USC § available at libraries of local governments, colleges or univer-
9607(1) and similar state or local laws. sities, or historical societies.
3.2.8 ERNS list—EPA’s Emergency Response Notification 3.2.14 material safety data sheet (MSDS)—written or
System list of reported CERCLA hazardous substance releases printed material concerning a hazardous substance which is
or spills in quantities equal to or greater than the reportable prepared by chemical manufacturers, importers, and employers
quantity, as maintained by the National Response Center. for hazardous chemicals pursuant to OSHA’s Hazard Commu-
Notification requirements for such releases or spills are codi- nication Standard, 29 CFR 1910.1200.
fied in 40 CFR Parts 302 and 35515. 3.2.15 National Contingency Plan (NCP)—the National Oil
3.2.9 Federal Register (FR)—publication of the United and Hazardous substances Pollution Contingency Plan found at
States government published daily (except for Federal holidays 40 CFR § 300, which is the EPA’s regulations for how
and weekends) containing all proposed and final regulations hazardous substances are to be cleaned up pursuant to CER-
and some other activities of the Federal government. When CLA.
regulations become final, they are included in the Code of 3.2.16 National Priorities List—list compiled by EPA pur-
Federal Regulations (CFR) as well as published in the Federal suant to CERCLA 42 USC § 9605(a)(8)(B) of properties with
Register. the highest priority for cleanup pursuant to EPA’s Hazard
3.2.10 hazardous substance—a substance defined as a haz- Ranking System. See 40 CFR Part 300.
ardous substance pursuant to CERCLA 42 USC § 9601(14), as 3.2.17 occupants—those tenants, subtenants, or other per-
interpreted by EPA regulations and the courts: “(A) any sons or entities using the property or a portion of the property.
substance designated pursuant to section 1321(b)(2)(A) of Title 3.2.18 owner—generally the fee owner of record of the
33, (B) any element, compound, mixture, solution, or substance property.
designated pursuant to Section 9602 of this title, (C) any 3.2.19 petroleum exclusion—the exclusion from CERCLA
hazardous waste having the characteristics identified under or liability provided in 42 USC § 9601(14), as interpreted by the
listed pursuant to Section 3001 of the Solid Waste Disposal Act courts and EPA: “The term (hazardous substance) does not
(42 USC § 6921) (but not including any waste the regulation of include petroleum, including crude oil or any fraction thereof
which under the Solid Waste Disposal Act (42 USC§ 6921 et which is not otherwise specifically listed or designated as a
seq.) has been suspended by Act of Congress), (D) any toxic hazardous substance under subparagraphs ( A) through (F) of
pollutant listed under Section 1317(a) of Title 33, (E) any this paragraph, and the term does not include natural gas,
hazardous air pollutant listed under Section 112 of the Clean natural gas liquids, liquefied natural gas, or synthetic gas
Air Act (42 USC § 7412), and (F) any imminently hazardous usable for fuel (or mixtures of natural gas and such synthetic
chemical substance or mixture with respect to which the gas).”
Administrator (of EPA) has taken action pursuant to Section 3.2.20 petroleum products—those substances included
2606 of Title 15. The term does not include petroleum, within the meaning of the petroleum exclusion to CERCLA, 42
including crude oil or any fraction thereof which is not USC § 9601(14) as interpreted by the courts and EPA, that is:
otherwise specifically listed or designated as a hazardous “petroleum, including crude oil or any fraction thereof which is

3
 D 6008 – 96
not otherwise specifically listed or designated as a hazardous any extremely hazardous substance. Often the local fire depart-
substance under subparagraphs ( A) through (F) of this para- ment is the local emergency planning committee. Records of
graph, and the term does not include natural gas, natural gas such notifications are “records of emergency release notifica-
liquids, liquefied natural gas, or synthetic gas usable for fuel tions” (SARA § 304).
(or mixtures of natural gas and such synthetic gas).” 3.2.31 solid waste disposal site—a place, location, tract of
3.2.21 Phase I Environmental Site Assessment— the pro- land, area, or premises used for the disposal of solid wastes as
cess described in Practice E 1527. defined by state solid waste regulations. The term is synony-
3.2.22 pits, ponds, or lagoons—man-made or natural de- mous with the term landfill and is also known as a garbage
pressions in a ground surface that are likely to hold liquids or dump, trash dump, or similar term.
sludge containing hazardous substances or petroleum products. 3.2.32 solvent—a chemical compound that is capable of
The likelihood of such liquids or sludge being present is dissolving another substance and a hazardous substance, used
determined by evidence of factors associated with the pit, in a number of manufacturing/industrial processes including
pond, or lagoon, including, but not limited to, discolored water, but not limited to the manufacture of paints and coatings for
distressed vegetation, or the presence of an obvious wastewater industrial and household purposes, equipment clean-up, and
discharge. surface degreasing in metal fabricating industries.
3.2.23 property—the real property that is the subject of the 3.2.33 State registered USTs—State lists of underground
EBS described in this practice as well as the real property storage tanks required to be registered under Subtitle I, Section
adjacent to the subject property (which may be privately 9002 of RCRA.
owned). Real property includes buildings and other fixtures 3.2.34 sump—a pit, cistern, cesspool, or similar receptacle
and improvements located on the property and affixed to the where liquids drain, collect, or are stored.
land.
3.2.35 underground storage tank (UST)—any tank, includ-
3.2.24 property tax files—the files kept for property tax
ing underground piping connected to the tank that is or has
purposes by the local jurisdiction where the property is located
been used to contain hazardous substances or petroleum
and includes records of past ownership, appraisals, maps,
products and the volume of which is 10 % or more beneath the
sketches, photos, or other information that is reasonably
surface of the ground.
ascertainable and pertaining to the property.
3.2.25 RCRA generators—those persons or entities that 3.2.36 USGS 7.5 Minute Topographic Map—the map (if
generate hazardous wastes, as defined and regulated by RCRA. any) available from or produced by the United States Geologi-
cal Survey, entitled “USGS 7.5 Minute Topographic Map” and
3.2.26 RCRA generators list—list kept by EPA of those
showing the property.
persons or entities that generate hazardous wastes, as defined
and regulated by RCRA. 3.2.37 wastewater—water that ( 1) is or has been used in an
industrial or manufacturing process, (2) conveys or has con-
3.2.27 RCRA TSD facilities—those facilities on which treat-
veyed sewage, or ( 3) is directly related to manufacturing,
ment, storage, or disposal, or a combination thereof, of
processing, or raw materials storage areas at an industrial plant.
hazardous wastes takes place, as defined and regulated by
Wastewater does not include water originating on or passing
RCRA.
through or adjacent to a site, such as stormwater flows, that has
3.2.28 RCRA TSD facilities list—list kept by EPA of those
not been used in industrial or manufacturing processes, has not
facilities on which treatment, storage, or disposal, or a combi-
been combined with sewage, or is not directly related to
nation thereof, of hazardous wastes takes place, as defined and
manufacturing, processing, or raw materials storage areas at an
regulated by RCRA.
industrial plant.
3.2.29 recorded land title records—records of fee owner-
3.3 Definitions of Terms Specific to This Standard:
ship, leases, land contracts, easements, liens, and other encum-
brances on or of the property recorded in the place where land 3.3.1 adjacent properties—those properties contiguous or
title records are, by law or custom, recorded for the local partially contiguous to the boundaries of the property being
jurisdiction in which the property is located. (Commonly, such surveyed during an EBS or other activity intended to classify
records are kept by a municipal or county recorder or clerk.) the property into a standard environmental condition of prop-
Such records may be obtained from title companies or directly erty area type, or other properties relatively near the installa-
from the local government agency. Information about the title tion that could pose significant environmental concern and/or
to the property that is recorded in a U.S. district court or any have a significant impact on the results of an EBS or on the
place other than where land title records are, by law or custom, classification of installation property into standard environ-
recorded for the local jurisdiction in which the property is mental condition of property area types.
located, are not considered part of recorded land title records. 3.3.2 aerial photographs—photographs, taken from an
See 3.3.33 and 7.2.4. aerial platform, having sufficient resolution to allow identifi-
3.2.30 records of emergency release notifications (SARA§ cation of development and activities of areas encompassing the
304)—Section 304 of EPCRA or Title III of SARA requires property. Aerial photographs are commonly available from
operators of facilities to notify their local emergency planning government agencies or private collections unique to a local
committee (as defined in EPCRA) and State emergency re- area.
sponse commission (as defined in EPCRA) of any release 3.3.3 all remedial action taken—for the purposes of this
beyond the facility’s boundary of any reportable quantity of practice, all remedial action, as described in CERCLA§

4
 D 6008 – 96
120(h)(3)(B)(i), has been taken if “the construction and instal- tions. This term should not be used to describe Practices
lation of an approved remedial design has been completed, and E 1527, E 1528, or this practice, although an environmental
the remedy has been demonstrated to the administrator [of audit may include an EBS or, if prior audits or EBSs are
EPA] to be operating properly and successfully. The carrying available, may be part of an EBS.
out of long-term pumping and treating, or operation and 3.3.12 environmental baseline survey (EBS)—a survey of
maintenance, after the remedy has been demonstrated to the federal real property based on all existing environmental
administrator to be operating properly and successfully does information related to storage, release, treatment, or disposal of
not preclude the transfer of the property.” [42 USC § hazardous substances or petroleum products or derivatives on
9620(h)(3)]. Alternatively, in circumstances where a remedy the property to determine or discover the obviousness of the
has been constructed, but no ongoing treatment or operation presence or likely presence of a release or threatened release of
and maintenance is required, for example, “clean closure” or any hazardous substance or petroleum product. In certain
excavation of soil with off-site treatment, all remedial action cases, additional data, including sampling and analysis, may be
means that all action required to meet applicable state or needed in the EBS to support the classification of the property
federal regulatory standards, including, as required, state or into one of the standard environmental condition of property
federal regulatory approval, has been taken. area types. Additionally, an EBS may also satisfy the uncon-
3.3.4 applicable requirements—those cleanup standards, taminated property identification requirements of CERFA. An
standards of control, and other substantive requirements, cri- EBS will consider all sources of available information con-
teria, or limitations promulgated under federal environmental cerning environmentally significant current and past uses of the
or State environmental or facility siting laws that specifically real property, and shall, at a minimum, consist of the following:
address a hazardous substance, pollutant, contaminant, reme- 3.3.12.1 Detailed search and review of available informa-
dial action, location, or other circumstances found at a CER- tion and records in the possession of the DoD Components or
CLA site. Only those state standards that are identified by a records made available by the regulatory agencies or other
state in a timely manner and that are more stringent than involved federal agencies. The DoD Components are respon-
federal requirements may be applicable.
sible for requesting and making reasonable inquiry into the
3.3.5 approximate minimum search distance—the area for existence and availability of relevant information and records
which records must be obtained and reviewed pursuant to to include any additional study information (for example,
Section 7 subject to the limitations provided in that section. surveys for radioactive materials, asbestos, radon, lead-based
This may include areas outside the property and shall be paint, transformers containing PCB, RCRA Facility Assess-
measured from the nearest property boundary. This term is ments and Investigations, Underground Storage Tank Cleanup
used instead of radius to include irregularly shaped properties. Program) to determine the environmental condition of the
3.3.6 BRAC statutes—Title II of the Defense Authorization property;
Amendments and Base Closure and Realignment Act of 1988
3.3.12.2 Review of all reasonably obtainable federal, state,
(Pub. L. 100-526, 10 USC 2687, note.) and the Defense Base
and local government records for each adjacent facility where
Closure and Realignment Act of 1990 (Part A of Title XXIX of
there has been a release or likely release of any hazardous
Pub. L. 101-510, 10 USC 2687, note.), collectively.
substance or any petroleum product, and which is likely to
3.3.7 closing military installation—installations identified cause or contribute to a release or threatened release of any
for closure pursuant to BRAC statutes, or installations previ- hazardous substance or any petroleum product on the federal
ously closed under the authority of 10 USC 2687. real property;
3.3.8 DoD Component—collectively, the Office of the Sec-
3.3.12.3 Analysis of aerial photographs that may reflect
retary of Defense, the Military Departments, the Chairman of
prior uses of the property, which are in the possession of the
the Joint Chiefs of Staff, the Inspector General of the Depart-
federal government or are reasonably obtainable through state
ment of Defense, the Defense Agencies and the DoD Field
or local government agencies;
Activities.
3.3.9 disposal—the discharge, deposit, injection, dumping, 3.3.12.4 Interviews with current or former employees, or
spilling, leaking, or placing of any hazardous substances, or both, involved in operations on the real property;
petroleum products or their derivatives into or on any land or 3.3.12.5 Visual inspections of the real property; any build-
water so that such hazardous substances, or petroleum products ings, structures, equipment, pipe, pipeline, or other improve-
or their derivatives or any constituent thereof may enter the ments on the real property; and of properties immediately
environment or be emitted into the air or discharged into any adjacent to the real property, noting sewer lines, runoff pat-
waters including ground water. terns, evidence of environmental impacts (for example, stained
3.3.10 due diligence—the process of inquiring into the soil, stressed vegetation, dead or ill wildlife) and other obser-
environmental characteristics of a parcel of commercial real vations which indicate actual or potential release of hazardous
estate or other conditions, usually in connection with a com- substances or petroleum products;
mercial real estate transaction. The degree and kind of due 3.3.12.6 Identification of sources of contamination on the
diligence vary for different properties and differing purposes. installation and on adjacent properties which could migrate to
3.3.11 environmental audit—the investigative process to the parcel during federal government ownership;
determine if the operations of an existing facility are in 3.3.12.7 Ongoing response actions or actions that have been
compliance with applicable environmental laws and regula- taken at or adjacent to the parcel; and

5
 D 6008 – 96
3.3.12.8 A physical inspection of property adjacent to the including all activities related to this practice, and from the
real property, to the extent permitted by owners or operators of information and data gathered by such activities, having the
such property. ability to develop conclusions regarding environmental condi-
3.3.13 environmental baseline survey (EBS) report—the tion of property and recognized environmental conditions in
written record of an EBS that includes the following: connection with the property being evaluated. An individual’s
3.3.13.1 An executive summary briefly stating the areas of status as an environmental professional may be limited to the
real property (or parcels) evaluated and the conclusions of the type of EBS to be performed or to specific steps of the EBS for
EBS; which the professional is responsible. The person may be an
3.3.13.2 The property identification (for example, address, independent contractor of an employee of the Department of
assessor parcel number, legal description); Defense or its components.
3.3.13.3 Any relevant information obtained from a detailed 3.3.18 fill dirt—dirt, soil, sand, or other earth, that is
search of federal government records pertaining to the prop- obtained off-site, that is used to fill holes or depressions, create
erty, including available maps; mounds, or otherwise artificially change the grade or elevation
3.3.13.4 Any relevant information obtained from a review of real property. It does not include material that is used in
of the recorded chain of title documents regarding the real limited quantities for normal landscaping activities.
property. The review should address those prior ownerships/ 3.3.19 innocent landowner defense—that defense to CER-
uses that could reasonably have contributed to an environmen- CLA liability provided in 42 USC § 9601(35) and 42 USC §
tal concern, and, at a minimum, cover the preceding 60 years; 9607(b)(3). One of the requirements to qualify for this defense
3.3.13.5 A description of past and current activities, includ- is that the party make“ all appropriate inquiry into the previous
ing all past DoD uses to the extent such information is ownership and uses of the property consistent with good
reasonably available, on the property and on adjacent proper- commercial or customary practice.” There are additional re-
ties, quirements to qualify for this defense.
3.3.13.6 A description of hazardous substances or petroleum 3.3.20 installation restoration program (IRP)— the DoD
products management practices (to include storage, release, program, mandated by 10 USC § 2407 to assess and respond to
treatment, or disposal) at the property and at adjacent proper- releases of hazardous substances on military property under the
ties; control of the military services. Additionally, based upon
3.3.13.7 Any relevant information obtained from records policy decisions, the IRP serves as an umbrella program for
reviews and visual and physical inspections of adjacent prop- environmental response in all media, including RCRA correc-
erties; tive action, LUST corrective action, as well as CERCLA
3.3.13.8 Description of ongoing response actions or actions removals and remedial actions. Generally, where field sam-
that have been taken at or adjacent to the property; pling or intrusive environmental testing is required, the IRP
3.3.13.9 An evaluation of the environmental suitability of will serve as a vehicle for such testing. The IRP is also known
the property for an intended lease or deed transaction, if as the Defense Environmental Restoration Program.
known, including the basis for the determination of such 3.3.21 interviews—sessions with current or former employ-
suitability; and ees involved in operations on the real property, conducted to
3.3.13.10 Reference to key documents examined (for ex- ascertain if storage, release, treatment, or disposal of hazardous
ample, aerial photographs, spill incident reports, investigation substances, petroleum products or their derivatives occurred or
results). is occurring on the real property.
3.3.14 environmental condition of property area type—any 3.3.22 local government agencies—those agencies of mu-
of the seven standard environmental condition of property area nicipal or county government having jurisdiction over the
types defined in the Standard Classification of Environmental property. Municipal and county government agencies include,
Condition of Property Area Types. but are not limited to, cities, parishes, townships, and similar
3.3.15 environmental condition of property map— a map, entities. Local government agencies may also include, where
prepared on the basis of all environmental investigation infor- appropriate, state agencies with local jurisdiction which per-
mation conducted to date, that shows the environmental form functions commonly performed in other locations by
condition of a DoD installation’s real property in terms of the local government agencies.
seven standard environmental condition of property area types 3.3.23 migration—the movement of contaminant(s) away
as defined in the standard classification. from a source through permeable subsurface media (such as the
3.3.16 environmental investigation—any investigation in- movement of a ground water plume of contamination), or
tended to determine the nature and extent of environmental movement of contaminant(s) by a combination of surficial and
contamination or to determine the environmental condition of subsurface processes.
property at a BRAC installation. Environmental investigations 3.3.24 obviousness—the condition of being plain or evident.
may include, but are not limited to, environmental site assess- A condition or fact which could not be ignored or overlooked
ments, preliminary assessments, site inspections, remedial by a reasonable observer while conducting a records search or
investigations, EBSs, RCRA facility assessments, and RCRA while physically or visually observing the property in conjunc-
facility investigations. tion with an EBS.
3.3.17 environmental professional—a person possessing 3.3.25 other historical sources—any source or sources other
sufficient training and experience necessary to conduct an EBS than those designated in 7.2.1-7.2.4 that are credible to a

6
 D 6008 – 96
reasonable person and that identify past uses of the property. Phase I Site Assessment results in recognized environmental
The term includes, but is not limited to: miscellaneous maps, conditions, but not environmental condition of property area
newspaper archives, and records in the files and/or personal types.
knowledge of the property owner and/or occupants. 3.3.33 recorded chain of title documents—this term has the
3.3.26 physical setting sources—sources that provide infor- same meaning as recorded land title records.
mation about the geologic, hydrogeologic, hydrologic, or 3.3.34 records search and/or review—detailed search and
topographic characteristics of a property. review of available information and records in the possession
3.3.27 practically reviewable—information that is practi- of the DoD components and records made available by the
cally reviewable is information provided by the source in a regulatory agencies or other involved federal agencies, includ-
manner and in a form that, upon examination, yields informa- ing, but not limited to IRP studies and analyses, surveys for
tion relevant to the property without the need for extraordinary radioactive materials, asbestos, radon, lead-based paint, elec-
analysis of irrelevant data. The form of the information shall be trical devices (that is, transformers) containing PCB, RCRA
such that the user can review the records for a limited facility assessments and Investigations to determine what, if
geographic area. Records that cannot be feasibly retrieved by any, hazardous substances or petroleum products may be
reference to the location of the property or a geographic area in present on the property. For the purposes of adjacent facilities,
which the property is located are not generally practically a records search includes the review of all reasonably obtain-
reviewable. Most data bases of public records are practically able federal, state, and local government records for each
reviewable if they can be obtained from the source agency by adjacent facility where there has been a release or likely release
the county, city, zip code, or other geographic area of the of any hazardous substance or any petroleum product, and
facilities listed in the record system. Records that are sorted, which is likely to cause or contribute to a release or threatened
filed, organized, or maintained by the source agency only
release of any hazardous substance or any petroleum product
chronologically are not generally practically reviewable. This
on the federal real property.
term has the same meaning as provided in Practice E 1527.
3.3.35 release—any spilling, leaking, pumping, pouring,
3.3.28 preliminary assessment (PA)—review of existing
emitting, emptying, discharging, injecting, escaping, leaching,
information and an off-site reconnaissance, if appropriate to
determine if a release or potential release may require addi- dumping, or disposing into the environment (including the
tional investigation or action. A PA may include an on-site abandonment or discarding of barrels, containers, and other
reconnaissance, if appropriate. closed receptacles) of any hazardous chemical, extremely
hazardous substance, or CERCLA hazardous substance.
3.3.29 publicly available—information that is publicly
available means that the source of the information allows 3.3.36 relevant and appropriate requirements— those
access to the information by anyone upon request. cleanup standards, standards of control, and other substantive
3.3.30 reasonably available—information that is (1) pub- requirements, criteria, or limitations promulgated under federal
licly available, (2) obtainable from its source within reasonable environmental or State environmental or facility siting laws
time and cost constraints, and (3) practically reviewable. This that, while not “applicable” to a hazardous substance, pollut-
term has the same meaning as the term “reasonably ascertain- ant, contaminant, remedial action, location, or other circum-
able” as provided in Practice E 1527. stance at a CERCLA site, address problems or situations
3.3.31 reasonably obtainable—information that is (1) pub- sufficiently similar to those encountered at the CERCLA site
licly available, (2) obtainable from its source within reasonable that their use is well suited to the particular site. Only those
time and cost constraints, and (3) practically reviewable. This state standards that are identified in a timely manner and are
term has the same meaning as the term “reasonably ascertain- more stringent than federal requirements may be relevant and
able” as provided in Practice E 1527. Reasonably available and appropriate.
reasonably obtainable are synonyms. 3.3.37 remedial actions—those actions consistent with a
3.3.32 recognized environmental conditions—the presence permanent remedy taken instead of, or in addition to, removal
or likely presence of any hazardous substances or petroleum action in the event of a release or threatened release of a
products on any federal real property under conditions that hazardous substance into the environment, to prevent or
indicate an existing release, a past release, or a material threat minimize the release of hazardous substances so that they do
of a release of any hazardous substances or petroleum products not migrate to cause substantial danger to present or future
into the environment. The term includes hazardous substances public health or welfare or the environment.
or petroleum products even under conditions in compliance 3.3.38 removal—the cleanup or removal of released hazard-
with laws. The term is not intended to include de minimis ous substances from the environment; such actions as may be
conditions that generally do not present a material risk of harm necessary to take in the event of the threat of release of
to public health or the environment and that generally would hazardous substances into the environment; such actions as
not be the subject of an enforcement action if these conditions may be necessary to monitor, assess, and evaluate the release
were brought to the attention of appropriate governmental or the threat of release of hazardous substances; the disposal of
agencies. This term is introduced in Practice E 1527, and is removed material; or the taking of such other actions as may be
used herein only in conjunction with EBS Steps 1 and 2 (see necessary to prevent, minimize, or mitigate damage to the
6.2), as an intermediate outcome prior to the Step 3 classifi- public health or welfare or to the environment, which may
cation of environmental condition of property area types. A otherwise result from a release or threat of release.

7
 D 6008 – 96
3.3.39 required remedial actions—remedial actions deter- tures located on it and observations made by the sense of smell,
mined necessary to comply with the requirements of CERCLA particularly observations of noxious or foul odors.
§ 120(h)(3)(B)(i). 3.4 Acronyms:Acronyms and Abbreviations:
3.3.40 required response actions—removal and/or remedial 3.4.1 ARARs—applicable or relevant and appropriate re-
actions determined necessary to comply with the requirements quirements.
of CERCLA§ 120(h)(3)(B)(i). 3.4.2 ASTM—American Society for Testing and Materials.
3.3.41 significant and significance—in this practice, signifi- 3.4.3 BRAC—Base Realignment and Closure.
cant and significance connote the opposite of trivial or de 3.4.4 CERCLA—Comprehensive Environmental Response,
minimis. An event or condition is considered significant if it Compensation and Liability Act of 1980, as amended (42 USC
has the potential to present a nontrivial risk to human health 9620 et seq.).
and the environment, using the risk range established by the 3.4.5 CERCLIS—Comprehensive Environmental Response,
NCP. A probability is considered significant when an environ- Compensation and Liability Information System.
mental professional estimates the probability as nontrivial. For 3.4.6 CERFA—Community Environmental Response Fa-
example, in the hypothetical case of an underground tank that cilitation Act of 1992 (102 Pub. L. 426, 106 Stat. 2174).
was installed and removed prior to the existence of regulatory 3.4.7 CFR—Code of Federal Regulations.
requirements for tank closure, the environmental professional 3.4.8 DoD—Department of Defense.
must evaluate the possibility of release from the tank in the 3.4.9 EBS—environmental baseline survey.
absence of soil testing results. If such an evaluation, based 3.4.10 ECP—environmental condition of property.
upon observed site conditions and documented soil corrosivity 3.4.11 USEPA—United States Environmental Protection
characteristics were to conclude that the probability of release Agency.
is trivial or very close to zero, then no soil testing would be 3.4.12 EPCRA—Emergency Planning and Community
undertaken in the absence of a specific regulatory requirement Right to Know Act, 42 USC.
for such testing. On the other hand, there is a significant 3.4.13 ERNS—Emergency Response Notification System.
probability of release if such an evaluation were to determine 3.4.14 ESA—environmental site assessment.
that the probability of release were greater than the extremely 3.4.15 FOIA—U.S. Freedom of Information Act (5 USC
low probability encompassed by the concept of trivial. The 552 et seq.).
evaluation of significance, in this sense, is a matter of profes- 3.4.16 FOSL—Finding of Suitability to Lease as described
sional judgment on the part of the environmental professional in applicable DoD Policy.
and should be so documented. 3.4.17 FOST—Finding of Suitability to Transfer as de-
scribed in applicable DoD Policy.
3.3.42 site inspection (SI)—an on-site investigation to de-
3.4.18 FR—Federal Register.
termine whether there is a release or potential release and the
3.4.19 IRP—Installation Restoration Program.
nature of the associated threats. The purpose is to augment the
3.4.20 LUST—leaking underground storage tank.
data collected in the PA and to generate, if necessary, sampling
3.4.21 MSDS—material safety data sheet.
and other field data to determine if further action or investiga-
3.4.22 NCP—National Contingency Plan.
tion is appropriate.
3.4.23 PA—preliminary assessment.
3.3.43 standard classification—the Standard Classification 3.4.24 PCBs—polychlorinated biphenyls.
of Environmental Condition of Property Area Types. 3.4.25 RCRA—The Resource Conservation and Recovery
3.3.44 standard environmental condition of property area Act, as amended, 42 USC 6901 et seq.
type—one of the seven environmental condition of property 3.4.26 SARA—Superfund Amendments and Reauthoriza-
area types defined in the Standard Classification. tion Act of 1986.
3.3.45 standard practice—the activities set forth in this 3.4.27 SI—site inspection.
practice and Practices E 1527 and E 1528, where referenced. 3.4.28 TSD—treatment, storage, and disposal.
3.3.46 storage—the containment of hazardous substances, 3.4.29 USC—United States Code.
petroleum products or their derivatives, either on a temporary 3.4.30 USGS—United States Geological Survey.
basis or for a period of years, in such a manner as not to 3.4.31 UST—underground storage tank.
constitute disposal of such hazardous substances, petroleum
4. Significance and Use
products, or their derivatives.
4.1 Uses—This practice is intended for use by DoD com-
3.3.47 transaction screen process—the process described in
ponents and environmental professionals in order to facilitate
Practice E 1528.
EBS efforts. It is also intended for use by preparers and
3.3.48 transaction screen questionnaire—the questionnaire reviewers of environmental condition of property maps and
provided in Practice E 1528. EBS Reports used to support CERFA uncontaminated property
3.3.49 user—the party seeking to use this practice to per- identifications and property suitable for transfer by lease or by
form an EBS of the property. A user may include, without deed.
limitation, a DoD component (acting as owner of the property). 4.2 Clarifications on Use:
3.3.50 visual and/or physical inspection—actions taken dur- 4.2.1 Use Not Limited to CERCLA—This practice is de-
ing an EBS to include observations made by vision while signed to assist the user in developing information about the
walking through or otherwise traversing a property and struc- environmental condition of a property and as such has utility

8
 D 6008 – 96
for a wide range of persons, including those who may have no judgments made at the time and under the circumstances in
actual or potential CERCLA liability. which they were made. Subsequent EBSs should not be
4.2.2 Residential Tenants/Purchasers and Others—No im- considered valid standards to judge the appropriateness of any
plication is intended that it is currently customary practice for prior EBS based on hindsight, new information, use of devel-
residential tenants of multifamily residential buildings, tenants oping technology or analytical techniques, or other factors.
of single-family homes or other residential real estate, or 4.5 Continued Viability of Environmental Baseline
purchasers of dwellings for one’s own residential use, to Survey—An EBS meeting or exceeding this practice and
conduct an EBS in connection with these transactions. Thus, completed less than 180 days prior to the date of a subsequent
these transactions are not included in the term commercial real use is presumed to be valid for that use. An EBS not meeting
estate transactions. Thus, although such property may be or exceeding this practice or completed more than 180 days
included within the scope of an EBS, their occupants shall not previously may be used to the extent allowed by 4.6-4.6.5.
be treated as key site personnel with regard to the housing 4.6 Prior EBS Usage— This practice recognizes that EBSs
occupied for the purpose of conducting an EBS.
performed in accordance with this practice or otherwise
4.2.3 Site-Specific— This practice is site-specific in that it containing information which was reasonably accurate at the
relates to assessment of environmental conditions of federal time prepared will include information that subsequent users
real property. Consequently, this practice does not address may want to use to avoid undertaking duplicative EBS proce-
many additional issues raised in transactions such as purchases dures. Therefore, this practice describes procedures to be
of business entities; or interests therein, or of their assets, that followed to assist users in determining the appropriateness of
may well involve environmental liabilities pertaining to prop-
using information in EBSs performed previously. The system
erties previously owned or operated or other off-site environ-
of prior EBS usage is based on the following principles that
mental liabilities.
should be adhered to in addition to the specific procedures set
4.3 Related Practices—See Practices E 1527 and E 1528. forth elsewhere in this practice:
4.4 Principles—The following principles are an integral
4.6.1 Use of Prior Information—Subject to 4.6.4, users and
part of this practice and all related practices and are intended to
environmental professionals may use information in prior
be referred to in resolving any ambiguity or exercising such
EBSs provided such information was generated as a result of
discretion as is accorded the user or environmental professional
procedures that meet or exceed the requirements of this
in performing an EBS or in judging whether a user or
practice or accurately state the limitations of the information
environmental professional has conducted appropriate inquiry
or has otherwise conducted an adequate EBS. presented. When using information from an EBS which, as a
whole, fails to meet or exceed the requirements of this practice,
4.4.1 Uncertainty Not Eliminated—No EBS can wholly
the use shall be limited to those portions of the EBS which,
eliminate uncertainty regarding the potential for recognized
based upon the limitations and methodology of the EBS
environmental conditions in connection with a property. Per-
Report, the environmental professional finds to be reasonably
formance of this practice is intended to reduce uncertainty
accurate.
regarding the potential for recognized environmental condi-
tions in connection with a property to the minimum practicable 4.6.2 Prior EBS Meets or Exceeds—Subject to 4.6.4, a prior
level, but not eliminate such uncertainty altogether, as well as EBS may be used in its entirety, without regard to the specific
to recognize reasonable limits of time and cost for property procedures set forth in these practices if, in the reasonable
information (see 7.1.3.2). judgment of the user, the prior EBS meets or exceeds the
4.4.2 Not Exhaustive— Appropriate inquiry does not mean requirements of this practice and the conditions at the property
an exhaustive assessment of an uncontaminated property. likely to affect environmental condition of property area types
There is a point at which the cost of information obtained or the in connection with the property are not likely to have changed
time required to gather it outweighs the usefulness of the materially since the prior EBS was conducted. In making this
information and, in fact, may be a material detriment to the judgment, the user should consider the type of property subject
orderly completion of transactions. One of the purposes of this to the EBS and the conditions in the area surrounding the
practice is to identify a balance between the competing goals of property.
limiting the costs and time demands inherent in performing an 4.6.3 Current Investigation—Except as specifically pro-
EBS and the reduction of uncertainty about unknown condi- vided in 4.6.2, prior EBSs should not be used without current
tions resulting from additional information. investigation of conditions likely to affect the environmental
4.4.3 Level of Inquiry Is Variable—Not every property will condition of property in connection with the property that may
warrant the same level of EBS effort. Consistent with good have changed materially since the prior EBS was conducted.
practice, the appropriate level of EBS will be guided by the For an EBS to be consistent with this practice, a new visual
type of property subject to EBS and the information developed inspection, interviews, an update of the records review, and
in its conduct. other appropriate activities may have to be performed.
4.4.4 Comparison With Subsequent Inquiry—It should not 4.6.4 Actual Knowledge Exception—If the user or environ-
be concluded or assumed that an inquiry was not an appropriate mental professional(s) conducting an EBS has actual knowl-
inquiry merely because the inquiry did not identify recognized edge that the information being used from a prior EBS is not
environmental conditions in connection with a property. The accurate or if it is obvious, based on other information obtained
EBSs must be evaluated based on the reasonableness of by means of the EBS or known to the person conducting the

9
 D 6008 – 96
EBS, that the information being used is not accurate, such tioned that elements of this practice pertain to an initial EBS
information from a prior EBS may not be used. conducted by a DoD component as well as to EBS updates,
4.6.5 Contractual Issues Regarding Prior EBS Usage—The supplemental EBSs, or site-specific EBSs, or a combination
contractual and legal obligations between prior and subsequent thereof, (however termed by the DoD component). As such, it
users of EBSs or between environmental professionals who is anticipated that it will only be necessary to complete all steps
conducted prior EBSs and those who would like to use such and tasks identified in this practice for the initial EBS for the
prior EBSs are beyond the scope of this practice. property. The user or environmental professional should obtain
the input of the DoD component end user regarding the level of
5. User’s Responsibilities effort to be used during any supplemental EBS efforts.
5.1 Scope—This section is limited to the responsibilities of 6.2 Five Steps—Within the limitations described in 6.1, it is
users of this practice. Users may be either DoD component anticipated that the EBS process will commonly consist of at
staff or environmental professionals contractually engaged to least four and possibly five discrete steps. These are summa-
perform EBSs. Users of this practice should be familiar with its rized as follows:
entire contents before conducting or documenting an EBS, and 6.2.1 EBS Step 1—Gathering of data and information in
to use best professional judgment regarding its applicability to accordance with the process described in the applicable DoD
a particular situation. policy referenced in 2.2 and as further elaborated in Sections
5.1.1 DoD Component Staff—DoD component staff who 7-13 of this practice.
have both the requisite specialized knowledge and experience 6.2.2 EBS Step 2—Analysis of data and information in
and appropriate training can use this practice as a starting point accordance with the process described in Sections 7-13 of this
for conducting or updating EBSs. Although this practice has practice.
been designed to help DoD components meet certain legal and
6.2.3 EBS Step 3—Determination of the environmental
policy requirements, it should not be used as a substitute for
condition of property area type for the real property being
meeting environmental, BRAC statute, or health and safety
evaluated by the EBS, in accordance with the process de-
legal requirements that exist under various laws, regulations,
scribed in this practice and DoD policy.
and DoD and DoD component policies and guidance.
6.2.4 EBS Step 4—Preparation of an EBS Report in accor-
5.1.2 Environmental Professionals—Environmental profes-
dance with the format described in the applicable DoD policy.
sionals who have both the requisite specialized knowledge and
experience, and appropriate training can use this practice as a 6.2.5 EBS Step 5—Updating and enhancing, as necessary,
starting point for conducting or updating EBSs. Although this an EBS Report to support property transfer transactions (for
practice has been designed to help environmental professionals example, FOSLs, FOSTs, or environmental condition reports).
contractually engaged by DoD components to conduct EBSs, This process may require repeating Steps 1 through 3 to
in accordance with applicable legal and policy requirements, it incorporate additional information or data, or both, generated
should not be used as a substitute for meeting environmental, between the time an initial EBS report is issued and the time an
BRAC statute, or health and safety legal requirements that updated version is used to support a property transfer transac-
exist under various laws, regulations, and DoD and DoD tion.
component policies and guidance. Contractually engaged en- 6.3 Additional Explanation of EBS Steps 1 and 2—Steps 1
vironmental professionals should not use this practice to and 2 of the EBS process will consider all sources of available
perform tasks that are inherently governmental functions. information concerning environmentally significant current
5.2 Specialized Knowledge or Experience of the User— and past uses of the real property, and shall, at a minimum,
Users of this practice are expected to have the requisite consist of the following eight components, as described in
environmental and health and safety training necessary to overview as follows (more detailed descriptions of each
conduct the tasks identified in this practice. The DoD compo- component are found in Sections 7-13):
nents are responsible for identifying appropriate staff for 6.3.1 Records Search and Review Scope—Detailed search
conducting these functions, and are also responsible for con- and review of available information and records in the posses-
tractually ensuring that environmental professionals engaged to sion of the DoD components or records made available by the
perform EBSs have appropriate qualifications. These qualifi- regulatory agencies or other involved federal agencies. Depart-
cations should be identified in the contract or scope of work. ment of Defense (DoD) components are responsible for re-
questing and making reasonable inquiry into the existence and
6. Environmental Baseline Survey Process availability of relevant information and records to include any
6.1 Objective—In accordance with DoD policy, the purpose additional study information (for example, surveys for radio-
of the EBS is to determine or discover and to document the active materials, asbestos, radon, lead-based paint, drinking
obviousness of the presence or likely presence of a release or water quality, indoor air quality, transformers containing PCBs,
threatened release of any hazardous substance or petroleum RCRA Facility Assessments and Investigations, and Under-
product. In certain cases, additional data, including sampling ground Storage Tank Cleanup Program) to help support the
and analysis, may be needed in the EBS or EBS supplement to determination of the environmental condition of property area
support the classification of the property into one of the type.
standard environmental condition of property area types. Ad- 6.3.2 Adjacent Facility Records Search and Review Scope—
ditionally, an EBS may also satisfy the uncontaminated prop- Review of all reasonably obtainable federal, state, and local
erty identification requirements of CERFA. Users are cau- government records for each adjacent facility where there has

10
 D 6008 – 96
been a release or likely release of any hazardous substance or information reviewed that are obvious in light of other infor-
any petroleum product, and which is likely to cause or mation of which the environmental professional has actual
contribute to a release or threatened release of any hazardous knowledge.
substance or any petroleum product on the real property. 7.1.3 Reasonably Obtainable/Standard Sources—
6.3.3 Aerial Photography Analysis—Analysis of aerial pho- Availability of record information varies from information
tographs that are in the possession of the federal government or source to information source, including governmental jurisdic-
are reasonably obtainable through state or local government tions. The user or environmental professional is not obligated
agencies that may reflect prior uses of the property. to identify, obtain, or review every possible record that might
6.3.4 Interviews—Interviews with key current or former exist with respect to a property. Instead, this practice identifies
employees, or both, involved in operations on the real property. record information that shall be reviewed from standard
6.3.5 Visual Inspections—Nonintrusive visual inspections sources, and the user or environmental professional is required
of the real property; any buildings, structures, equipment, pipe, to review only record information that is reasonably ascertain-
pipeline, or other improvements on the real property; and of able from those standard sources. Record information that is
properties immediately adjacent to the real property, noting reasonably obtainable means: ( 1) information that is publicly
sewer lines, runoff patterns, evidence of environmental impacts available, (2) information that is obtainable from its source
(for example, stained soil, stressed vegetation, dead or ill within reasonable time and cost constraints, and (3) informa-
wildlife), and other observations which indicate actual or tion that is practically reviewable.
potential release of hazardous substances or petroleum prod-
7.1.3.1 Publicly Available—Information that is publicly
ucts.
available means that the source of the information allows
6.3.6 Contamination Source Identification—Identification
access to the information by anyone upon request.
of sources of contamination on the installation and on adjacent
properties which could migrate to the real property. 7.1.3.2 Reasonable Time and Cost—Information that is
6.3.7 Ongoing Response Actions—Ongoing response ac- obtainable within reasonable time and cost constraints means
tions or actions that have been taken at or adjacent to the that the information will be provided by the source within a
property will be identified and documented. reasonable amount of time of receiving a written, telephone, or
6.3.8 Physical and Visual Inspection of Adjacent in-person request at no more than a nominal cost intended to
Property—A physical inspection of property adjacent to the cover the source’s cost of retrieving and duplicating the
real property, to the extent permitted by owners or operators of information. Information that can only be reviewed by a visit to
such property. A visual inspection will be accomplished from the source is reasonably ascertainable if the visit is permitted
areas of public access if a physical inspection is not authorized by the source within a reasonable amount of time of the
by the owners or operators of such property. request.
7.1.3.3 Practically Reviewable—Information that is practi-
7. Records Search and Review cally reviewable means that the information is provided by the
7.1 Introduction— Reasonable prudence, CERFA require- source in a manner and in a form that, upon examination, yields
ments (in the case of an EBS performed to support the information relevant to the property without the need for
identification of uncontaminated property), and DoD guidance extraordinary analysis of irrelevant data. The form of the
mandate that the federal real property be evaluated in order to information shall be such that the user can review the records
support real property transactions. One component of this for a limited geographic area. Records that cannot be feasibly
evaluation is the review of all reasonably obtainable federal, retrieved by reference to the location of the property or a
state, and local government records to determine where, on the geographic area in which the property is located are not
installation, there has been storage, release or likely release of generally practically reviewable. Most databases of public
any hazardous substance or any petroleum product, and which records are practically reviewable if they can be obtained from
is likely to cause or contribute to a release or threatened release the source agency by the county, city, zip code, or other
of any hazardous substance or any petroleum product on the geographic area of the facilities listed in the record system.
real property. Records that are sorted, filed, organized, or maintained by the
7.1.1 Objective—The objective of the records review is to source agency only chronologically are not generally practi-
perform those parts of Steps 1 and 2 of the EBS process cally reviewable. For large databases with numerous facility
pertaining to obtaining and reviewing adequate and complete records (such as RCRA generators and registered USTs), the
records that will help the user or environmental professional records are not practically reviewable unless they can be
make an environmental condition of property area type deter- obtained from the source agency in the smaller geographic area
mination regarding the federal real property. of zip codes. Even when information is provided by zip code
7.1.2 Accuracy and Completeness—Accuracy and com- for some large databases, it is common for an unmanageable
pleteness of record information varies among information number of sites to be identified within a given zip code. In
sources, including governmental sources. Record information these cases, it is not necessary to review the impact of all of the
is often inaccurate or incomplete. The user or environmental sites that are likely to be listed in any given zip code because
professional is not obligated to identify mistakes or insufficien- that information would not be practically reviewable. In other
cies in information provided. However, the environmental words, when so much data is generated that it cannot be
professional reviewing the records shall make a reasonable feasibly reviewed for its impact on the property, it is not
effort to compensate for mistakes or insufficiencies in the required to be reviewed.

11
 D 6008 – 96
7.1.4 Alternatives to Standard Sources—Alternative sources sources may be obtained in the discretion of the environmental
may be used instead of standard sources if they are of similar professional. Because such sources provide information about
or better reliability and detail, or if a standard source is not the geologic, hydrogeologic, hydrologic, or topographic char-
reasonably ascertainable. acteristics of a site, discretionary physical setting sources shall
7.1.5 Coordination— If records are not reasonably ascer- be sought when: (1) conditions have been identified in which
tainable from standard sources or alternative sources, the hazardous substances or petroleum products are likely to
environmental professional shall attempt to obtain the re- migrate to the property or from or within the property into the
quested information by other means specified in this practice ground water or soil and (2) more information than is provided
such as questions posed to the current owner or occupant(s) of in the current USGS 7.5 Minute Topographic Map is generally
the property or appropriate persons available at the source at obtained, pursuant to local good commercial or customary
the time of the request. practice in initial environmental site assessments in the type of
7.1.6 Sources of Standard Source Information—Standard commercial real estate transaction involved, in order to assess
source information or other record information from govern- the impact of such migration on recognized environmental
ment agencies may be obtained directly from appropriate conditions in connection with the property.
government agencies or from commercial services. Govern- Standard Physical Setting Source: Current USGS
ment information obtained from nongovernmental sources may 7.5 Minute Topographic Map
be considered current if the source updates the information at If this map is unavailable, obtain the USGS 15 Minute Map,
least every 90 days or, for information that is updated less if available. If neither the USGS 7.5 Minute Topographic Map
frequently than quarterly by the government agency, within 90 nor the 15 Minute Map are available, a larger scale (for
days of the date the government agency makes the information example, 1:250 000) USGS topographic map should be con-
available to the public. sidered. Where appropriate, a comparable topographic map,
7.1.7 Documentation of Sources Checked—The EBS report prepared by the Defense Mapping Agency, may be used instead
shall document each source that was used, even if a source of the USGS 7.5 Minute Topographic Map.
revealed no findings. Sources shall be sufficiently described, Other Physical Setting Sources:
including name, date request for information was filled, date The following sources may also be utilized if requested:
information provided was last updated by source, date infor- • USGS and/or State Geological Survey—Groundwater
mation was last updated by original source (if provided other Maps
than by original source; see 7.1.4) so as to facilitate reconstruc- • USGS and/or State Geological Survey—Bedrock Geology
tion of the research at a later date. Maps
7.1.8 Significance— If a standard environmental record • USGS and/or State Geological Survey—Surficial Geology
source (or other sources in the course of conducting the EBS) Maps
identifies the property or another site within the approximate • Soil Conservation Service—Soil Maps
minimum search distance, the EBS report shall include the • Other physical setting sources that are reasonably credible
environmental professional’s judgment about the significance (as well as reasonably ascertainable)
of the listing to the analysis of recognized environmental 7.2.2 Department of Defense (DoD) Component records
conditions in connection with the property (based on the data maintained on the property or elsewhere, but reasonably
retrieved pursuant to this section, additional information from obtainable, which are relevant to classification of environmen-
the government source, or other sources of information). In tal condition of property area types, including, but not limited
doing so, the environmental professional may make statements to records of:
applicable to multiple sites (for example, a statement to the 7.2.2.1 Ongoing and completed site remediation and envi-
effect that none of the sites listed is likely to have a negative ronmental response activities, including IRP activities, correc-
impact on the property except ...). tive action programs, LUST responses, and similar activities.
7.2 EBS Step 1: Records Gathering—In accordance with This includes all records in the Administrative Record main-
6.2.1, this section specifies the general level of effort required tained under CERCLA.
to complete EBS Step 1 tasks associated with records gather- 7.2.2.2 Records of reported spills of hazardous substances
ing. At a minimum, records to be gathered and reviewed when and responses.
an EBS is initially conducted include the following: 7.2.2.3 Records of hazardous waste accumulation, storage,
7.2.1 Background and Physical Setting Records. treatment, or disposal, including satellite accumulation records,
7.2.1.1 Physical Setting Sources—A current USGS 7.5 manifests, and records maintained in connection with permit-
Minute Topographic Map showing the area on which the ted hazardous waste activities.
property is located shall be reviewed, provided it is reasonably 7.2.2.4 Records of hazardous substance and petroleum us-
obtainable. If a current USGS 7.5 Minute Topographic Map is age and/or storage.
not readily obtainable, a current 15 Minute Topographic Map 7.2.2.5 Records of potential hazard surveys, including, but
showing the area on which the property is located shall be not limited to asbestos surveys, lead-based paint surveys,
reviewed, provided it is reasonably obtainable. It is the only radioactive materials surveys, mercury surveys, PCB surveys,
standard physical setting source and the only physical setting and radon surveys.
source that is required to be obtained (and only if it is 7.2.2.6 Environmental compliance records not specifically
reasonably obtainable). One or more additional physical setting included in other required records. This includes, but is not

12
 D 6008 – 96
limited to Safe Drinking Water Act reports, Clean Water Act identification of uncontaminated property), and DoD guidance
permits and discharge reports, Clean Air Act permits and mandate that the federal real property be evaluated in order to
discharge and emission reports, EPCRA reports, hazardous categorize real property into applicable environmental condi-
waste minimization plans and reports, and pollution prevention tion of property area types. One component of this evaluation
plans and reports. is the review of all reasonably obtainable federal, state, and
7.2.2.7 Additional records to include planning maps, base local government records for each adjacent facility where there
historian records, the base comprehensive plan or base master has been a release or likely release of any hazardous substance
plan, military construction records, real property records, fire or any petroleum product, and which is likely to cause or
department records, historical photographs, and facility and contribute to a release or threatened release of any hazardous
utility records. substance or any petroleum product on the real property or
7.2.3 Federal, state, and local agency records. which might migrate to the federal real property. In this
7.2.4 Recorded chain of title documents. connection, adjacent has the meaning provided in 3.3.1 and
7.3 EBS Step 2: Records Analysis—Upon review of the includes those properties near enough to the federal real
required records gathered to complete EBS Step 1, the user or property to present a reasonable probability of affecting the
environmental professional shall indicate in the EBS Report environmental condition of property on the federal real prop-
whether the search revealed any of the following on the erty.
property: 8.1.1 Objective—The objective of the adjacent facility
7.3.1 Spills of hazardous substances or petroleum products, records search and review is to perform those parts of Steps 1
or both, and 2 of the EBS process pertaining to identifying, obtaining,
7.3.2 Leaks of hazardous substances or petroleum products, and reviewing those reasonably available Federal, State, and
or both, local agency records that might disclose information which
7.3.3 Discharges of hazardous substances or petroleum would affect the environmental condition of property area type
products, or both, determination regarding the federal real property.
7.3.4 Leaching of hazardous substances or petroleum prod- 8.1.2 Approximate Minimum Search Distance—Adjacent
ucts, or both, facility records pertain not only to facilities adjacent to the
7.3.5 Injection of hazardous substances or petroleum prod- federal real property, but also pertain to properties within an
ucts, or both, additional approximate minimum search distance in order to
7.3.6 Dumping of hazardous substances or petroleum prod- help assess the likelihood of problems from migrating hazard-
ucts, or both, ous substances or petroleum products. When the term approxi-
7.3.7 Abandoned or discarded barrels, containers, or other, mate minimum search distance includes areas outside the
7.3.8 Receptacles containing hazardous substances or petro- property, it shall be measured from the nearest property
leum products, boundary. The term approximate minimum search distance is
7.3.9 Automotive batteries, used instead of radius in order to include irregularly shaped
7.3.10 Industrial batteries, properties.
7.3.11 Pesticides in containers, cartons, sacks, storage bins, 8.1.2.1 Reduction of Approximate Minimum Search
canisters, Distance—When allowed by 8.2.1.1, the approximate mini-
7.3.12 Paints in containers, cartons, sacks, storage bins, mum search distance for a particular record may be reduced at
canisters, the discretion of the environmental professional. Factors to
7.3.13 Drums containing hazardous substances or petro- consider in reducing the approximate minimum search distance
leum products, or both, include: (1) the density (for example, urban, rural, or suburban)
7.3.14 Tanks containing hazardous substances or petroleum of the setting in which the property is located; (2) the distance
products, or both, that the hazardous substances or petroleum products are likely
7.3.15 Fill dirt from a contaminated site, to migrate based on local geologic or hydrogeologic condi-
7.3.16 Fill pipes, tions; and (3) other reasonable factors. The justification for
7.3.17 PCBs in transformers or capacitors, each reduction and the approximate minimum search distance
7.3.18 Heavy industrial equipment, including hydraulic actually used for any particular record shall be explained in the
equipment in storage or use, EBS report.
7.3.19 Ditches subject to contaminated runoff or discharges,
8.1.3 Accuracy and Completeness—See 7.1.2.
7.3.20 Railroad loading/unloading areas,
7.3.21 Ordinance, 8.1.4 Reasonably Obtainable/Standard Sources—See 7.1.3.
7.3.22 Medical/biohazardous waste, 8.1.4.1 Publicly Available—See 7.1.3.1.
7.3.23 Radioactive materials and mixed wastes, or 8.1.4.2 Reasonable Time and Cost—See 7.1.3.2.
7.3.24 Mercury, for example, seals. 8.1.4.3 Practically Reviewable—See 7.1.3.3.
7.4 If the records review revealed any of the above, the EBS 8.1.5 Alternatives to Standard Sources—See 7.1.4.
Report shall document it/them. 8.1.6 Coordination— See 7.1.5.
8. Adjacent Facility Records Search and Review 8.1.7 Sources of Standard Source Information—See 7.1.6.
8.1 Introduction— Reasonable prudence, CERFA require- 8.1.8 Documentation of Sources Checked—See 7.1.7.
ments (in the case of an EBS performed to support the 8.1.9 Significance—See 7.1.8.

13
 D 6008 – 96
8.2 EBS Step 1: Adjacent Facility Records Gathering—In Types of Local Records
accordance with 6.2.1, this section specifies the level of effort Lists of Landfill/Solid Waste Disposal Sites
required to complete EBS Step 1 tasks associated with adjacent Lists of Hazardous Waste/Contaminated Sites
facility records gathering. At a minimum, the following records Lists of Registered Underground Storage Tanks
are to be searched: Records of Emergency Release Reports (SARA Part 304)
8.2.1 Standard Environmental Sources—The following Records of Contaminated Public Wells
standard environmental record sources shall be reviewed, Local Sources
subject to the conditions of 7.1.1-7.1.8: Department of Health/Environmental Division
8.2.1.1 Standard Environmental Record Sources: Federal Fire Department
and State—The approximate minimum search distance should Planning Department
be established for each installation or portion of an installation, Building Permit/Inspection Department
based on the physical setting and surrounding land use. Table Local/Regional Pollution Control Agency
1 includes recommended approximate minimum search dis- Local/Regional Water Quality Agency
tances. An approximate minimum search distance for a par- Local Electric Utility Companies (for records relating to PCBs)
ticular record may be reduced at the discretion of the environ- 8.2.3 Physical Setting Sources—See 7.2.1.
mental professional. Factors to consider in reducing the 8.3 EBS Step 2: Adjacent Facility Records Analysis—Upon
approximate minimum search distance include: (1) the density review of adjacent facility records listed in 8.2, the environ-
(for example, urban, rural, or suburban) of the setting in which mental professional shall indicate in the EBS report whether or
the property is located; (2) the distance that the hazardous not the search revealed any of the following on the property:
substances or petroleum products are likely to migrate based on 8.3.1 Potential or actual migration of hazardous substances
local geologic or hydrogeologic conditions; and (3) other or petroleum products, or both, into the area in question from
reasonable factors. The justification for each reduction and the sources of these substances.
approximate minimum search distance actually used for any 8.3.2 The presence of actual sources of hazardous sub-
particular record should be explained in the EBS report. stances or petroleum products, or both, on adjacent property
8.2.2 Additional Environmental Record Sources: State or and facilities with suspected migration that has not been
Local—One or more additional state sources or local sources evaluated or characterized.
of environmental records may be checked, at the discretion of 8.3.3 Uncontrolled migration of hazardous substances or
the environmental professional, to enhance and supplement petroleum products, or both, in the immediate vicinity of a
federal and state sources identified in Table 1. Factors to boundary of the area in question.
consider in determining which local or additional state records, 8.4 If the records review revealed any of the preceding, the
if any, should be checked include: (1) whether they are EBS report shall document it/them.
reasonably ascertainable, (2) whether they are sufficiently
useful, accurate, and complete in light of the objective of the 9. Aerial Photography Analysis
records review (see 7.1.1), and (3) whether they are generally 9.1 Introduction— Analysis of aerial photography can pro-
obtained, pursuant to local good commercial or customary vide an extremely useful source of supplemental information
practice, in initial environmental site assessments in the type of regarding both land use and the environmental condition of
commercial real estate transaction involved. To the extent property area type. This analysis may encompass both the
additional state sources or local sources are used to supplement federal real property and the adjacent facilities. Analysis of
the same record types listed in Table 1, approximate minimum aerial photography should be focused on patterns of land use
search distances should not be less than those specified and human activities as well as direct and indirect evidence of
(adjusted as provided in 8.1.2.1 and 8.2.1.1). Some types of the potential existence of a recognized environmental condi-
records and sources that may be useful include: tion.
9.1.1 Objective—The objective of the aerial photography
analysis is to perform those parts of Steps 1 and 2 of the EBS
TABLE 1 Recommended Approximate Minimum Search process pertaining to assembling, if reasonably available, an
Distances
adequately complete set of adjacent properties encompassing
Approximate Minimum Search
Record(s) Source Distance,
both the federal real property and the adjacent facilities,
miles (kilometres) analyzing those photographs for patterns of land use and
Federal NPL site list 1.0 (1.6) human activities as well as direct and indirect evidence of the
Federal CERCLIS list 0.5 (0.8) potential existence of a recognized environmental condition,
Federal RCRA TSD facilities list 1.0 (1.6) and thereafter, incorporating that information into the overall
Federal RCRA generators list property and adjoining properties
Federal ERNS list property only environmental condition of property area type. Aerial photo-
State lists of hazardous waste sites 1.0 (1.6) graphs will be sought for the period encompassing the past 60
Identified for investigation or years of facility use.
remediation (NPL and CERCLIS
equivalents) 9.2 EBS Step 1: Aerial Photography Gathering—In accor-
State landfill and/or solid waste disposal 0.5 (0.8) dance with 6.2.1, this section specifies the level of effort
site lists required to complete EBS Step 1 tasks associated with identi-
State leaking UST lists 0.5 (0.8)
State registered UST lists property and adjoining properties fying and gathering adjacent properties. At a minimum, the
following sources are to be searched:

14
 D 6008 – 96
9.2.1 Standard Sources: Aerial Photographs—Aerial pho- 10.2 EBS Step 1: Interviews with Site Personnel—In accor-
tographs are commonly available from government agencies or dance with 6.2.1, this section specifies the level of effort
private collections unique to a local area, and may also be required to complete EBS Step 1 tasks associated with inter-
obtained from universities, colleges, and history museums. viewing current or former personnel, or both, and appropriate
9.2.2 Optional Sources— Other sources of similar informa- local governmental officials. At a minimum, the following
tion, including, but not limited to satellite reconnaissance may should be incorporated into this process:
be sought where the environmental professional feels that these 10.2.1 Content—Interviews with site personnel consist of
records would be reasonably available and would materially questions to be asked in the manner and of persons as described
enhance the analysis required in this section. in this section. The content of questions to be asked shall
9.3 EBS Step 2: Aerial Photography Analysis—The envi- attempt to obtain information about uses and conditions as
ronmental professional shall perform the analysis of photo- described in Section 9, as well as the information described in
graphs using an accepted photo interpretation land use and land Sections 11-13.
cover classification system. Analyzed photographs should pref- 10.2.2 Medium—Questions to be asked pursuant to this
erably be at a 1:24 000 scale or smaller scale (that is, more section may be asked in person, by telephone, or in writing, at
magnified) to reveal adequate surface detail and necessary the discretion of the environmental professional.
spatial coverage. Upon review of adjacent properties in accor- 10.2.3 Timing—Except as specified in 9.8 and 9.9, it is at
dance with the previously stated guidelines, the environmental the discretion of the environmental professional whether to ask
professional shall specify the analysis method used in the EBS questions before, during, or after the site visit described in
Report and also indicate whether any of the following were Section 11, or in some combination thereof.
identified on the property: 10.2.4 Who Should be Interviewed:
9.3.1 Evidence of excavation activities of unknown type, or 10.2.4.1 Key Site Manager— Prior to the site visit, the
of industrial operations. owner can be asked to identify a person with good knowledge
9.3.2 Evidence of dumping or disposing of waste materials. of the uses and physical characteristics of the property (the key
9.3.3 Evidence of significant storage activities involving site manager). Often the key site manager will be the installa-
drums, tanks, or pipelines containing hazardous substances or tion or base commander, base civil engineer, public works
petroleum products. commander or other property manager, chief physical plant
9.3.4 Evidence of staining associated with industrial activi- supervisor or head maintenance person. (If the user is the
ties or activities of unknown origin or type. current property owner, the user has an obligation to identify a
9.4 If the aerial photography analysis revealed any of the key site manager, even if it is the user himself or herself.) If a
preceding, the EBS report shall document it/them. key site manager is identified, the person conducting the site
visit shall make at least one reasonable attempt (in writing or
10. Interviews by telephone) to arrange a mutually convenient appointment
10.1 Introduction— Reasonable prudence, CERFA require- for the site visit when the key site manager agrees to be there.
ments (in the case of an EBS performed to support the If the attempt is successful, the key site manager shall be
identification of uncontaminated property), and DoD guidance interviewed in conjunction with the site visit. If such an
mandate that the federal real property be evaluated in order to attempt is unsuccessful, when conducting the site visit, the
categorize real property into applicable environmental condi- environmental professional shall inquire whether an identified
tion of property area types. One component of this evaluation key site manager (if any) or if a person with good knowledge
are interviews of current or former occupants, or both, involved of the uses and physical characteristics of the property is
in operations on the property that are conducted to aid in available to be interviewed at that time; if so, that person shall
identifying a recognized environmental condition on the fed- be interviewed. In any case, it is within the discretion of the
eral real property and other information necessary to determine environmental professional to decide which questions to ask
standard environmental condition of property area types. In- before, during, or after the site visit or in some combination
terviews of current or former personnel, or both, on the federal thereof.
real property and interviews of appropriate local government 10.2.4.2 Occupants, Including Current and Former
officials supplement documented information and may also Employees—A reasonable attempt shall be made to interview a
provide keys to effective interpretation of such information. reasonable number of occupants of, if any, and current em-
Where available information indicates the presence of recog- ployees involved in operations on the property.
nized environmental conditions, it may be necessary to conduct (1) Residential Properties—For residential properties, resi-
interviews relating to those portions of the installation that dential occupants do not need to be interviewed, but if the
have been, or are currently being, actively investigated under property has nonresidential uses, interviews can be held with
the IRP or similar investigation effort. the nonresidential occupants based on criteria specified in
10.1.1 Objective—The objective of conducting interviews 10.2.4.2.
is to perform those parts of Steps 1 and 2 of the EBS process (2) Major Occupants—Except as specified in residential
pertaining to obtaining information indicating recognized en- properties, if the property has five or fewer current occupants,
vironmental conditions in connection with the property, so that a reasonable attempt shall be made to interview a representa-
environmental condition of property area type determinations tive of each one of them. If there are more than five current
can be made. occupants, a reasonable attempt shall be made to interview the

15
 D 6008 – 96
major occupant(s) and those other occupants whose operations by first class mail or by private, commercial carrier and no
are likely to indicate recognized environmental conditions in answer or incomplete answers have been obtained and at least
connection with the property. one reasonable follow-up (telephone call or written request)
(3) Reasonable Attempts to Interview—Examples of rea- was made again asking for responses.
sonable attempts to interview those occupants specified in 10.2.8 Questions About Helpful Documents—Prior to the
major occupants include (but are not limited to) an attempt to site visit, the property owner, key site manager (if any is
interview such occupants when making the site visit or calling identified), and user (if different from the property owner) shall
such occupants by telephone. In any case, when there are be asked if they know whether any of the documents listed in
several occupants to interview, it is not expected that the site 10.2.8.1 exist and, if so, whether copies can and will be
visit must be scheduled at a time when they will all be available provided to the environmental professional within reasonable
to be interviewed. time and cost constraints. Even partial information provided
(4) Occupant Identification—The EBS report shall identify may be useful. If so, the environmental professional conduct-
the occupants interviewed and the duration of their occupancy. ing the site visit shall review the available documents prior to
10.2.4.3 Local Agency Offıcials—A reasonable attempt shall or at the beginning of the site visit.
be made to interview at least one staff member of any one of 10.2.8.1 Helpful Documents:
the following types of local government agencies: (1) Environment site assessment reports, including PA, SI,
(1) Local fire department that serves the property, or other similar reports.
(2) Local health agency or local/regional office of state (2) Environment audit reports.
health agency serving the area in which the property is located, (3) Environmental permits (for example, solid waste dis-
or posal permits, hazardous waste disposal permits, wastewater
(3) Local agency or local/regional office of state agency permits, NPDES permits).
having jurisdiction over hazardous waste disposal or other (4) Registrations for underground and above-ground stor-
environmental matters in the area in which the property is age tanks.
located. (5) Material safety data sheets.
10.2.5 Prior Assessment Usage—Persons interviewed as (6) Community right-to-know plan.
part of a prior EBS consistent with this practice do not need to (7) Safety plans; preparedness and prevention plans; spill
be questioned again about the content of answers they provided prevention, countermeasure, control plans, and so forth.
at that time. However, they can be questioned about any new (8) Reports regarding hydrogeologic conditions of the
information learned since that time, or others can be questioned property or surrounding area.
about conditions since the prior EBS consistent with this (9) Notices or other correspondence from any government
practice. agency relating to past or current violations of environmental
10.2.6 Quality Of Answers—The person(s) interviewed laws with respect to the property or relating to environmental
should be asked to be as specific as reasonably feasible in liens encumbering the property.
answering questions. The person(s) interviewed should be (10) Hazardous waste—generator notices or reports.
asked to answer in good faith and to the extent of their (11) Geotechnical studies.
knowledge. 10.2.9 Proceedings Involving the Property—Prior to the site
10.2.7 Incomplete Answers—In accordance with 10.2.7.1 visit, the property owner, key site manager (if any is identified),
and 10.2.7.2, the person conducting the interview(s) has an and user (if different from the property owner) shall be asked
obligation to ask questions, in certain instances the persons to whether they know of: (1) any pending, threatened, or past
whom the questions are addressed may not have an obligation litigation relevant to hazardous substances or petroleum prod-
to answer them. ucts in, on, or from the property, (2) any pending, threatened,
10.2.7.1 User/DoD Component Personnel—If the person to or past administrative proceedings relevant to hazardous sub-
be interviewed is the user (an employee of a DoD component stances or petroleum products in, on, or from the property, and
on whose behalf the EBS is being conducted), the user has an (3) any notices from any governmental entity regarding any
obligation to answer all questions posed by the person con- possible violation of environmental laws or possible liability
ducting the interview, in good faith, to the extent of his or her relating to hazardous substances or petroleum products.
actual knowledge, or to designate a key site manager to do so. 10.2.10 Interview Questions—The person conducting each
If answers to questions are unknown or partially unknown to interview shall, at a minimum, ask and document responses to
the user or such key site manager, this interview section of the the following questions:
EBS shall not thereby be deemed incomplete. 10.2.10.1 Was or is the area in question used as a gasoline
10.2.7.2 Non-User—If the person conducting the inter- station, motor repair facility, dry cleaners, photo developing
view(s) asks questions of a person other than a user but does laboratory, plating shop, medical or dental facility, junkyard or
not receive answers or receives partial answers, this section of landfill, training area, or as a waste treatment, storage, disposal,
the EBS shall not thereby be deemed incomplete, provided that processing, or recycling facility?
( 1) the questions have been asked (or attempted to be asked) 10.2.10.2 Has there been any damaged or discarded auto-
in person or by telephone and written records have been kept motive or industrial batteries, or pesticides, paints, or other
of the person to whom the questions were addressed and the chemical or individual containers stored or used in the area in
responses, or (2) the questions have been asked in writing sent question?

16
 D 6008 – 96
10.2.10.3 Are there drums, sacks, cartons, or other contain- inspection of the installation property. At a minimum, the
ers of chemicals located on the property in question? following should be incorporated into this process:
10.2.10.4 Was or is the area in question used for any waste 11.3.1 Observation— On a visit to the property (the site
generation or disposal activities? visit), the environmental professional shall visually and physi-
10.2.10.5 Was or is the area in question used as a firing or cally observe the property and any structure(s) located on the
bombing range, or both? property to the extent not obstructed by bodies of water,
10.2.10.6 Have there been or are there storage tanks con- adjacent buildings, or other obstacles. The environmental
taining hazardous substances or petroleum products located on
professional shall also prepare a visual inspection record of the
the property in question?
visit. The visual inspection record, which can be field notes and
10.2.10.7 Have spills, leaks, or other releases of hazardous
the like, will be used to prepare the EBS report preserved to
substance or petroleum products occurred to the best of your
knowledge? supplement the EBS report.
10.2.10.8 Have unidentified waste materials, tires, automo- 11.3.1.1 Exterior—The periphery of the property shall be
tive or industrial batteries, ordnance or any other waste visually and physically observed, as well as the periphery of all
materials been dumped, buried, or burned, or a combination structures on the property, and the property should be viewed
thereof, in the area in question? from all adjacent public thoroughfares. If roads or paths with
10.3 EBS Step 2: Interview Analysis—Upon completion of no apparent outlet are observed on the property, the use of the
Step 1 of the EBS process related to interviews, the environ- road or path should be identified to determine whether it was
mental professional shall refer to 7.3 and indicate in the EBS likely to have been used as an avenue for disposal of hazardous
report whether or not the responses revealed any of the items substances or petroleum products. For each road without an
in 7.3 on the property. If the responses revealed any of these apparent outlet, the environmental professional shall travel or
items, the EBS report shall document it/them. overfly the length of the road and observe whether areas
11. Visual and Physical Inspections adjacent to the road appear to have been used for waste
disposal.
11.1 Introduction— Reasonable prudence, CERFA require-
ments (in the case of an EBS performed to support the 11.3.1.2 Interior—On the interior of structures on the prop-
identification of uncontaminated property), and DoD guidance erty, accessible common areas expected to be used by occu-
mandate that the federal real property be evaluated in order to pants or the public (such as lobbies, hallways, utility rooms,
categorize real property into applicable environmental condi- recreation areas, and so forth), maintenance and repair areas,
tion of property area types. One element of this evaluation is including boiler rooms, and a representative sample of occu-
the requirement that visual inspections be conducted of the pant spaces, should be visually and physically observed. It is
installation property and adjacent property. The visual inspec- generally not necessary to look under floors, above ceilings, or
tion supplements the documentary record, including inter- behind walls. The environmental professional shall exercise
views, records developed during records search, aerial photog- best professional judgment and appropriately coordinate with
raphy analysis, and the other components of the EBS. The the DoD component when observing the interior of structures
terms “visual inspection” and “visual site inspection” as used on the property.
in this practice are synonymous. For the purpose of this 11.3.1.3 Methodology— The environmental professional
practice, visual inspection includes two similar, but distinct shall document, in the EBS report, the method used (for
inspections, the visual inspection of the federal real property example, grid patterns or other systematic approaches used for
and the visual inspection of the adjacent property. The visual large properties, which spaces for owner or occupants were
inspection of the federal real property will be conducted as observed) to observe the property. For example, representative
described in 11.3. The visual and physical inspection of the inspections may be appropriate for structures: (1) that were
adjacent property will be conducted as described in 11.4. The built using like construction methods, during a fixed time
environmental professional and the user should exercise rea- period, (2) are geographically co-located, (3) were subjected to
sonable prudence in scoping and executing the tasks described
similar categorical use throughout their history, and (4) have no
in this section, recognizing that it is not the purpose of the EBS
significant differences in their other investigations criteria (for
visual inspection to take the place of other regulatory program
example, records search, interviews, and aerial photos). Com-
requirements, for example, asbestos surveys.
mon examples would include: military housing units, barracks,
11.2 Objective—The objective of the visual inspection is to
perform those parts of Steps 1 and 2 of the EBS process officer and enlisted quarters. In consultation with the user, the
pertaining to visually obtaining information indicating the environmental professional may determine the percentage of
likelihood of recognized environmental conditions in connec- structures/properties to be inspected and establish an inspection
tion with the property, so that environmental condition of pattern that provides sufficient representation of the area in
property area type determinations can be made. question.
11.3 EBS Step 1: Visual Inspection—In accordance with 11.3.1.4 Limitations— The environmental professional shall
6.2.1, this section specifies the level of effort required to document, in the EBS report, general limitations and bases of
complete EBS Step 1 tasks associated with making a visual review, including limitations imposed by physical obstructions

17
 D 6008 – 96
such as adjacent buildings, bodies of water, asphalt, or other substances or petroleum products on the property or on nearby
paved areas, and limiting conditions (for example, snow and properties and those hazardous substances or petroleum prod-
rain). ucts are of a type that may migrate, topographic observations
11.3.1.5 Frequency—It is not expected that more than one shall be analyzed in connection with geologic, hydrogeologic,
visit to the property shall be made by the environmental hydrologic, and topographic information obtained pursuant to
professional in connection with an EBS. The one visit consti- records review (see 7.2.3) and interviews to evaluate whether
tuting part of the EBS may be referred to as the site visit. hazardous substances or petroleum products are likely to
11.3.2 Prior EBS Usage— The information supplied in migrate to the property, or within or from the property, into
connection with the visual inspection portion of a prior EBS ground water or soil.
may be used for guidance but shall not be relied upon without (4) General Description of Structures—Generally, the EBS
determining through a new visual inspection whether any report shall describe the structures or other improvements on
conditions that are material to recognized environmental con- the property for example: number of buildings, number of
ditions in connection with the property have changed since the stories each, approximate age of buildings, ancillary structures
prior EBS. (if any), and so forth.
11.3.3 Uses and Conditions—The environmental profes- (5) Thoroughfares—Public thoroughfares adjoining the
sional(s) conducting the visual inspection should note the uses property shall be identified in the EBS Report, and any roads,
and conditions specified in 11.3.3.1-11.3.3.4 to the extent streets, railroads, and parking facilities on the property shall be
visually or physically observed during the site visit. The uses described in the EBS Report.
and conditions specified in 11.3.3.1-11.3.3.4 should also be the (6) Potable Water Supply—The source of potable water for
subject of questions asked as part of interviews of owners and the property shall be identified in the EBS report.
occupants (see Section 10). Uses and conditions to be noted (7) Sewage Disposal System—The sewage disposal system
shall be recorded in field notes of the environmental profes- for the property shall be identified in the EBS report. Inquiry
sional(s) conducting the visual inspection but are only required shall be made as to the age of the system as part of the process
to be described in the EBS report to the extent specified in under Sections 7, 9, or 10.
11.3.3.1-11.3.3.4. The environmental professional(s) perform- (8) Storm Drains—The storm drains for the property shall
ing the EBS are obligated to identify uses and conditions only be identified in the EBS report.
to the extent that they may be visually and physically observed (9) Access Vaults—Access vaults occurring on the property
on a site visit, as described in this practice, or to the extent that shall be identified in the EBS report.
they are identified by the interviews (see Sections 9 and 10) or 11.3.3.2 Interior and Exterior Observations:
records search (see Section 7) processes described in this (1) Current Use(s) of the Property—The current use(s) of
practice. the property shall be identified in the EBS report. Any current
11.3.3.1 General Site Setting: uses likely to involve the use, treatment, storage, disposal, or
(1) Current Use(s) of the Property—The current use(s) of generation of hazardous substances or petroleum products shall
the property shall be identified in the EBS report. Any current be identified in the EBS Report. Unoccupied occupant spaces
uses likely to involve the use, treatment, storage, disposal, or should be noted. In identifying current uses of the property,
generation of hazardous substances or petroleum products shall more specific information is more helpful than less specific
be identified in the EBS report. Unoccupied occupant spaces information. (For example, it is more useful to identify uses
should be noted. In identifying current uses of the property, such as a commissary or base exchange rather than simply
more specific information is more helpful than less specific retail use.)
information. (For example, it is more useful to identify uses (2) Past Use(s) of the Property—To the extent that indica-
such as a commissary or base exchange rather than simply tions of past uses of the property are visually or physically
retail use.) observed on the site visit, or are identified in the interviews or
(2) Past Use(s) of the Property—To the extent that indica- records review, they shall be identified in the EBS report, and
tions of past uses of the property are visually or physically past uses so identified shall be described in the EBS report if
observed on the site visit, or are identified in the interviews or they are likely to have involved the use, treatment, storage,
record review, they shall be identified in the EBS report, and disposal, or generation of hazardous substances or petroleum
past uses so identified shall be described in the EBS report if products. (For example, there may be signs indicating a past
they are likely to have involved the use, treatment, storage, use or a structure indicating a past use.)
disposal, or generation of hazardous substances or petroleum (3) Hazardous Substances and Petroleum Products in
products. (For example, there may be signs indicating a past Connection with Identified Uses—To the extent that present
use or a structure indicating a past use.) uses are identified that use, treat, store, dispose of, or generate
(3) Geologic, Hydrogeologic, Hydrologic, and Topo- hazardous substances and petroleum products on the property.
graphic Conditions—The topographic conditions of the prop- The hazardous substances and petroleum products shall be
erty shall be noted to the extent visually or physically observed identified or indicated as unidentified in the EBS report, and
or determined from interviews, as well as the general topog- the approximate quantities involved, types of containers (if
raphy of the area surrounding the property that is visually or any) and storage conditions shall be described in the EBS
physically observed from the periphery of the property. If any report. To the extent that past uses are identified that used,
information obtained shows there are likely to be hazardous treated, stored, disposed of, or generated hazardous substances

18
 D 6008 – 96
and petroleum products on the property, the information shall (3) Drains and Sumps—To the extent visually or physically
be identified to the extent it is visually or physically observed observed or identified from the interviews, floor drains and
during the site visit or identified from the interviews or the sumps shall be identified in the EBS report. Floor drains and
records review. sumps where a release or suspected release occurred should be
(4) Storage Tanks—Above-ground storage tanks, or sol- further described in the EBS report.
vents or vent pipes, fill pipes or access ways indicating solvents 11.3.3.4 Exterior Observations:
shall be identified (for example, content, capacity, and age) to (1) Pits, Ponds, or Lagoons—To the extent visually or
the extent visually or physically observed during the site visit physically observed or identified from the interviews or records
or identified from the interviews or records review. review, pits, ponds, or lagoons on the property shall be
(5) Odors—Strong, pungent, or noxious odors shall be identified in the EBS report, and further described if they have
described in the EBS report and their sources shall be identified been used in connection with waste disposal or waste treat-
in the EBS report to the extent visually or physically observed ment. Pits, ponds, or lagoons on properties adjoining the
or identified from the interviews or records review. property shall be described in the EBS report to the extent they
(6) Pools of Liquid—Standing surface water (other than are visually or physically observed from the property or
common rain puddles) shall be noted. Pools or sumps contain- identified in the interviews or records review.
ing liquids likely to be hazardous substances or petroleum (2) Stained Soil or Pavement—To the extent visually or
products shall be described in the EBS report to the extent physically observed or identified from the interviews, areas of
visually or physically observed or identified from the inter- stained soil or pavement shall be described in the EBS report.
views or records review. (3) Stressed Vegetation—To the extent visually or physi-
(7) Drums—To the extent visually or physically observed cally observed or identified from the interviews, areas of
or identified from the interviews or records review, drums shall stressed vegetation (from something other than insufficient
be described in the EBS report, whether or not they are leaking, water) shall be described in the EBS report.
unless it is known that their contents are not hazardous (4) Solid Waste—To the extent visually or physically
substances or petroleum products (in that case, the contents observed or identified from the interviews or records review,
should be described in the EBS report). Drums commonly hold areas that are apparently filled or graded by nonnatural causes
55 g (208 L) of liquid, but containers as small as 5 g (19 L) (or filled by fill of unknown origin) suggesting trash or other
should also be described. solid waste disposal, or mounds or depressions suggesting
(8) Hazardous Substance and Petroleum Products Contain- trash or other solid waste disposal, shall be described in the
ers (Not Necessarily in Connection With Identified Uses)— EBS report.
When containers identified as containing hazardous substances (5) Waste Water—To the extent visually or physically
or petroleum products are visually or physically observed on observed or identified from the interviews or records review,
the property and are or might be a recognized environmental waste water or other liquid (including storm water) or any
condition: the hazardous substances or petroleum products discharge into a drain, ditch, or stream on or adjacent to the
shall be identified or indicated as “unidentified” in the EBS property shall be described in the EBS report.
report, and the approximate quantities involved, types of (6) Wells—To the extent visually or physically observed or
containers (for example, cartons, tanks, cans), and storage identified from the interviews or records review, all wells
conditions shall be described in the EBS report. (including dry wells, irrigation wells, injection wells, aban-
(9) Unidentified Substance Containers—When open or doned wells, or other wells) shall be described in the EBS
damaged containers containing unidentified substances sus- report.
pected of being hazardous substances or petroleum products (7) Septic Systems—To the extent visually or physically
are visually or physically observed on the property, the observed or identified from the interviews or records review,
approximate quantities involved, types of containers, and indications of on-site septic systems or cesspools should be
storage conditions shall be described in the EBS report. described in the EBS report.
(10) PCBs—Electrical or hydraulic equipment known to 11.4 Visual Inspection of Adjacent Property—The visual
contain PCBs or likely to contain PCBs shall be described in inspection of adjacent property will be accomplished when
the EBS report to the extent visually or physically observed or consent has been obtained to enter the adjacent facility. The
identified from the interviews or records review. Fluorescent user or environmental professional shall visually and physi-
light ballast likely to contain PCBs does not need to be noted. cally observe the adjacent property to evaluate and identify, if
11.3.3.3 Interior Observations: possible, conditions which could give rise to recognized
(1) Heating/Cooling—The means of heating and cooling environmental conditions on the property, through migration or
the buildings on the property, including the fuel source for other transport of petroleum products or hazardous substances.
heating and cooling, shall be identified in the EBS report (for 11.4.1 Consent of Owner/Operator of Adjacent Property—
example, heating oil, gas, electric, radiators from steam boiler Access to the adjacent property is required to undertake a
fueled by gas). visual and physical inspection of the adjacent property. Written
(2) Stains or Corrosion—To the extent visually or physi- consent will be sought by either the DoD Component or the
cally observed or identified from the interviews, stains or environmental professional. Where voluntary consent is ob-
corrosion on floors, walls, or ceilings shall be described in the tained, a visual and a physical inspection will be conducted, as
EBS report, except for staining from water. described in this section. If consent is not given, a visual

19
 D 6008 – 96
inspection will be conducted from outside the facility bound- 12.3 EBS Step 1: Contamination Source Identification—In
aries, for example, from public rights of way, or adjacent accordance with 6.2.1, this section specifies the level of effort
facilities where consent has been given and from other suitable required to complete EBS Step 1 tasks associated with con-
sites. If voluntary consent is not obtained, no direct access to tamination source identification. At a minimum, this step
the adjacent property will be sought through involuntary should be completed by following the procedures described in
means, for example, condemnation of an easement or right of Sections 7-11. If current records are incomplete regarding the
entry or obtaining an administrative warrant. nature and extent of contaminant sources, the user or environ-
11.4.2 General Site Setting: mental professional will note the status of records search
11.4.2.1 Current Uses of Adjacent Properties—To the ex- efforts and which records remain incomplete.
tent that current uses of adjacent properties are visually or 12.4 EBS Step 2: Contamination Source Identification
physically observed on the site visit, or are identified in the Analysis—If records are complete for a contaminant source, its
interviews or records review, they shall be identified in the nature and extent will be used to determine the environmental
EBS report, and current uses so identified shall be described in condition of the real property. If current records are incomplete
the EBS report if they are likely to indicate recognized regarding the nature and extent of contaminant sources, the
environmental conditions in connection with the adjoining user or environmental professional will note the strategy for
properties or the property. completing relevant records so that a determination other than
11.4.2.2 Past Uses of Adjacent Properties—To the extent environmental condition of property area Type 7 can be made
that indications of past uses of adjacent properties are visually (for example, “contaminant source currently being character-
or physically observed on the site visit, or are identified in the ized through remedial investigation; anticipated completion in
interviews or record review, they shall be noted by the month/year”).
environmental professional, and past uses so identified shall be
described in the EBS report if they are likely to indicate 13. Ongoing Response Actions
recognized environmental conditions in connection with the 13.1 Introduction— The identification of ongoing response
adjacent properties or the property. actions is required by published DoD policy statements relating
11.4.3 Current or Past Uses in the Surrounding Area—To to each of the actions that require an EBS, particularly the DoD
the extent that the general type of current or past uses (for FOST guidance. It is anticipated that, in the ordinary course of
example, residential, commercial, industrial) of properties events, all relevant records to accomplish this task will be
surrounding the property are visually or physically observed on obtained through the records search and review tasks, inter-
the site visit or going to or from the property for the site visit, view tasks, site visit tasks, and other data collection efforts
or are identified in the interviews or record review, they shall prescribed in this practice. The principal additional goal of this
be noted by the environmental professional, and uses so section is to fulfill Step 1 and Step 2 EBS requirements, by
identified shall be described in the EBS report if they are likely analyzing information and data, where necessary to specifically
to indicate recognized environmental conditions in connection identify ongoing response actions and determine relevant
with the property. information regarding effectiveness and completeness of any
11.5 EBS Step 2: Visual Inspection Analysis—If the visual ongoing response actions, so that an accurate environmental
inspection revealed any conditions indicating the storage, condition of property area type determination can be made.
release, or disposal of hazardous substances or petroleum 13.2 Objective—Identify ongoing response actions and de-
products, the EBS report shall document them. termine what portion of the property is affected and whether
the environmental condition of the property satisfies the
12. Contamination Source Identification requirements of CERCLA § 120(h)(3), including whether all
12.1 Introduction— The identification of sources of actual required remedial action has been taken.
or potential contamination is required by published DoD policy 13.3 EBS Step 1: Ongoing Response Actions—In accor-
statements relating to each of the actions that require an EBS, dance with 6.2.1, this section specifies the level of effort
particularly the DoD FOST guidance. It is anticipated that, in required to complete EBS Step 1 tasks associated with identi-
the ordinary course of events, all relevant records to accom- fication of ongoing response actions at the installation or on
plish this task will be obtained through the records search and properties that would affect environmental condition of prop-
review tasks, interview tasks, site visit tasks, and other data erty area type determinations for all or parts of the installation.
collection efforts prescribed in this practice. The principal At a minimum, this step should be completed by following the
additional goal of this section is to fulfill Step 1 and Step 2 EBS procedures described in Sections 7-11. If current records are
requirements, by analyzing information and data, where nec- incomplete regarding ongoing response actions, the user or
essary to specifically identify sources of actual or potential environmental professional will note the status of records
contamination (recognized environmental conditions), leading search efforts and which records remain incomplete.
to the identification of an environmental condition of property 13.4 EBS Step 2: IRP and Other Ongoing Response Action
area type. Analysis—The purpose of the Step 2 analysis is to support the
12.2 Objective—Identify sources of actual or potential con- objective of 13.2. This analysis can be critical to the differen-
tamination so as to evaluate whether they affect or may affect tiation between or among certain environmental condition of
the categorization of the environmental condition of the property area types (for example, between area Type 5 areas,
property, including whether all required remedial action has which are not transferrable by deed, and area Type 4 areas,
been taken. which are), as performed as EBS Step 3.

20
 D 6008 – 96
14. Determining Environmental Condition of Property 14.3.3 Process for Determining ECP Area Type 3
Area Type Property—Complete Steps 1 and 2 of the EBS process (see
6.2.1 and 6.2.2). If a determination can be made that concen-
14.1 Introduction— The user or environmental professional
trations of hazardous substances or petroleum products are
will generally take information obtained from the activities
below action levels, in accordance with the criteria contained
described in Sections 7-13 and classify federal real property
in the Standard Classification, the real property may be
into the seven standard environmental condition of property
classified as ECP area Type 3. The ECP area Type 3 real
area types identified in the Standard Classification. Steps 1 and
property may be identified at any time after completion of
2 of the EBS process are intended to collect and analyze
Steps 1 and 2 of the EBS process.
information that will provide the basis for assigning, in EBS 14.3.4 Process for Determining ECP Area Type 4
Step 3, an environmental condition of property (ECP) area type Property—Complete Steps 1 and 2 of the EBS process (see
for each portion of the installation. The actual classification of 6.2.1 and 6.2.2). If the determination can be made that all
any portion of installation property is based on both the required remedial actions have been taken, in accordance with
information and analyses at hand and on a variety of site- CERCLA and the criteria contained in the Standard Classifi-
specific conditions (for example, geologic conditions, hydro- cation, the real property may be classified as ECP area Type 4.
logic conditions, nature, and extent of contamination, and so The ECP area Type 4 real property may be identified at any
forth) and, with the exception of the general guidelines time after completion of Steps 1 and 2 of the EBS process.
presented in this section, is beyond the scope of this practice. 14.3.5 Process for Determining ECP Area Type 5
Ideally, the classification of any property into an ECP area type Property—Complete Steps 1 and 2 of the EBS process (see
should reflect a consensus among the Military Department and 6.2.1 and 6.2.2). If the determination can be made that a
the federal and state regulators. In general, Steps 1 and 2 of the remedy has been selected but that all required remedial actions
EBS process will have accomplished their purpose if they have not yet been taken, in accordance with CERCLA and the
provide all information and analyses required to make accurate criteria contained in the Standard Classification, the real
Step 3 ECP area type determinations. property may be classified as ECP area Type 5. The ECP area
14.2 Objective—The objective of this section is to identify Type 5 real property may be identified at any time after
a general process to guide the EBS Step 3 classification of completion of Steps 1 and 2 of the EBS process.
areas of federal real property into one of seven standard ECP 14.3.6 Process for Determining ECP Area Type 6
area types. The ECP area type classification is a tool that is Property—Complete Steps 1 and 2 of the EBS process (see
intended to provide an EBS user with a complete and accurate 6.2.1 and 6.2.2). If the determination can be made that
“snapshot” of relevant aspects of the environmental condition concentrations of hazardous substances or petroleum products
of installation property in support of property transfer and are above action levels, in accordance with the criteria con-
reuse decisions (see also Section 1). tained in federal, state, and local statutes and the Standard
14.3 General Process for EBS Step 3—Determining ECP Classification, the real property should be designated as ECP
Area Types: area Type 6. The ECP area Type 6 real property may be
14.3.1 Process for Determining ECP Area Type 1 identified at any time after completion of Steps 1 and 2 of the
EBS process.
Property—Complete Steps 1 and 2 of the EBS process (see
14.3.7 Process for Determining ECP Area Type 7
6.2.1 and 6.2.2). Identify ECP area Type 1 property in
Property—Complete Steps 1 and 2 of the EBS process (see
accordance with CERFA criteria (see 1.1.3). The ECP area
6.2.1 and 6.2.2). If the real property cannot be conclusively
Type 1 property may be identified as either part of the CERFA
categorized into area Types 1 through 6, as defined in the
process or subsequent to the CERFA statutory deadline.
Standard Classification, the real property should be designated
14.3.2 Process for Determining ECP Area Type 2 as ECP area Type 7. The ECP area Type 7 real property may be
Property—Complete Steps 1 and 2 of the EBS process (see identified at any time after completion of Steps 1 and 2 of the
6.2.1 and 6.2.2). Identify ECP area Type 2 property in EBS process.
accordance with CERFA criteria (see 1.1.3). Identify real
property where only storage for less than one year occurred 15. Keywords
(CERFA uncontaminated) and where only storage occurred for 15.1 environment; environmental assessment; environmen-
more than one year. Real property may be proposed as ECP tal baseline; environmental condition; environmental condition
area Type 2 through the CERFA process or subsequent to the of property; restoration; site assessment; site characterization;
CERFA statutory deadline. site remediation

21
 D 6008 – 96

ASTM International takes no position respecting the validity of any patent rights asserted in connection with any item mentioned
in this standard. Users of this standard are expressly advised that determination of the validity of any such patent rights, and the risk
of infringement of such rights, are entirely their own responsibility.

This standard is subject to revision at any time by the responsible technical committee and must be reviewed every five years and
if not revised, either reapproved or withdrawn. Your comments are invited either for revision of this standard or for additional standards
and should be addressed to ASTM International Headquarters. Your comments will receive careful consideration at a meeting of the
responsible technical committee, which you may attend. If you feel that your comments have not received a fair hearing you should
make your views known to the ASTM Committee on Standards, at the address shown below.

This standard is copyrighted by ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959,
United States. Individual reprints (single or multiple copies) of this standard may be obtained by contacting ASTM at the above
address or at 610-832-9585 (phone), 610-832-9555 (fax), or service@astm.org (e-mail); or through the ASTM website
(www.astm.org).

22