FAQ: What are RECs in a Phase I Environmental Site Assessment?

Learn about Recognized Environmental Conditions (RECs)

Learn more about Recognized Environmental Conditions (RECs) in Phase I Environmental Site Assessments.

Phase I Environmental Site Assessments can be a complex endeavor if you get deeper into details.   You should learn about a common factor seen in any Phase I Environmental Assessment, even if your property or project seems immaculate and attractive.

What are RECs in a Phase I Environmental Site Assessment?

REC stands for Recognized Environmental Conditions.  That doesn’t mean a lot to most people.  So exactly what is a recognized environmental condition?”

When a Phase I site assessment is conducted, a key factor is to evaluate the possibility for any Recognized Environmental Condition (REC) at or around the property that is being evaluated.  You need to know if you are letting yourself in for a shock before you go through with the transaction.

In terms of property deals, the use of a Phase I Environmental Site Assessment is your best guarantee for knowing if you are getting involved with a risky property before you need to make a business decision. Additionally, it restricts your responsibility, if anything is found later that you were uninformed of.   A Phase I Site Assessment simply makes good business sense and should be part of every environmental due diligence process.

Defined: Recognized Environmental Conditions in a Phase I Environmental Site Assessment

A Phase I Site Assessment is administered to search for discharges to the environment, or potential discharges to the environment – of hazardous substances or petroleum products on or in the proximity of the property under review. These risky releases would be a Recognized Environmental Condition.

Recent modifications to the Phase I Standards (ASTM 1527-13) define environmental conditions as follows:

Recognized Environmental Conditions (REC)

The presence or likely presence of hazardous substances or petroleum products in, on, or at a property, due to any release to the environment, under any conditions indicative of a release to the environment, or under conditions that pose a material threat of a future release to the environment. An example would be indications of an oil spill or chemical spill at a property.

Historical RECs (HREC)

These are prior releases that have transpired and which have been addressed to the satisfaction of the applicable regulatory oversight agency (usually either a state environmental agency or the Federal USEPA), or which meet unrestricted use criteria without the addition of any required controls (such as property use restrictions, engineering controls, activity and use limitations, etc.). For example, this might be a release to the environment that has been cleaned up to the satisfaction of the applicable regulatory agency.

Controlled RECs (CREC)

These are past releases that have occurred and which have been addressed to the satisfaction of the applicable regulatory oversight agency, but at which the hazardous material or petroleum product has been allowed to remain in place subject to the use of some form of required control. An example would be the presence of soil contamination which is allowed to remain in place by the regulatory agency at a property, but the property is required to construct an impermeable cap above the contamination or prohibit soil disturbance or the drilling of potable water well.

Are RECs in a Phase I Report ESA bad?

REC’s are not always serious, or possible deal destroyers.  Many factors are involved, such as the severity of the release, the status of the release, are controls in place, what is the desired property use, etc.  Deciding if any on-site conditions are dangerous is exactly why a Phase I ESA conducted by an experienced Environmental Professional.  You need the Phase I ESA first so that cautious business choices are made based on the outcomes and guidance of the Phase I Site Assessments.

That is why it is imperative that the Phase I ESA is done by a skilled professional.

Do you need a Phase I ESA, and you are worried about the results?  We’ve conducted hundreds of Phase I Environmental Assessments and you can count on us to perform your ESA with the utmost care and to your satisfaction. To learn more, click here to contact us.

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