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The Difference between a REC, a HREC, and a CREC

By Kerry Asetta, Vice President

ASTM logoThe new ASTM Standard 1527-13 utilized in the preparation of Phase I Environmental Site Assessments (ESA) went into effect in November of 2013. One of the changes in the new standard is the revised definition of a Recognized Environmental Condition (REC) and a Historical Recognized Environmental Condition (HREC); and the addition of a new term, Controlled Recognized Environmental Condition (CREC).

 

Since the identification of RECs is a critical part of the Phase I Site Assessment process, a new simplified definition of a REC was added since many felt that the old definition was too vague and left Environmental Professionals (EPs) with a lot of questions. The new REC definition is as follows: “the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to any release to the environment; (2) under conditions indicative of a release to the environment; (3) under conditions that pose a material threat of a future release to the environment”.

 

The revision of the HREC definition is intended to clarify this definition for EPs and end users. The HREC definition is applicable to properties that meet unrestricted land use requirements after some sort of cleanup occurs. A HREC would include a property with a past release that has been addressed, and there are no use limitations. The new HREC definition is as follows: “a past release of any hazardous substances or petroleum products that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted use criteria established by a regulatory authority, without subjecting the property to any required controls (e.g. property use restrictions, AULs, institutional controls, or engineering controls). Before calling the past release an HREC, the EP must determine whether the past release is a REC at the time the Phase I ESA is conducted (e.g. if there has been a change in regulatory criteria”.

 

A new term, Controlled Recognized Environmental Condition (CREC) was introduced to ASTM 1527-13, which applies to past releases that have been addressed, but where contamination still remains and is subject to Activity and Use Limitations (AULs). It is noted that a CREC is also considered a REC and should be listed as both in the findings of a Phase I ESA report. The new CREC definition is meant to provide a term that more effectively addresses situations in which land use restrictions or controls are associated with the cleanup of a site. The new CREC definition is as follows: “a REC resulting from a past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory agency (e.g. as evidenced by the issuance of a NFA letter or equivalent, or meeting risk-based criteria established by regulatory authority), with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls (e.g., property use restrictions, AULs, institutional controls, or engineering controls)…a CREC shall be listed in the findings section of a Phase I ESA report, and as a REC in the conclusions section of the report”.

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