During the site reconnaissance component of a Phase I ESA under ASTM E1527-21, the environmental professional observes stressed vegetation in a pattern consistent with subsurface contamination, stained soil near a utility corridor, and an odor of petroleum at a former equipment storage area. How should these observations be documented?
- AAs de minimis conditions requiring no further action
- BAs potential RECs requiring disclosure in the Phase I ESA report
- CAs Business Environmental Risks (BERs) outside the scope of Phase I
- DAs data gaps that preclude Phase I completion