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Under ASTM E1527-21, which of the following best describes a Historical Recognized Environmental Condition (HREC)?

A condition where hazardous substances remain in place subject to land-use restrictions

Any prior industrial use of a property that predates 1980

A past release of hazardous substances that has been addressed to the satisfaction of the applicable regulatory authority under conditions that allow unlimited use and unrestricted exposure

A condition where contamination was suspected but never confirmed by sampling

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2026 Statistics

Key Facts: REPA Exam

100

Total Exam Questions

NREP REPA program

75%

Passing Score

NREP

3 hours

Exam Duration

NREP

$350

Exam Fee

NREP 2026

180 days

Phase I ESA Validity Period (ASTM E1527-21)

ASTM E1527-21 / 40 CFR Part 312

1 mile

NPL Site Search Distance (ASTM E1527-21 Table 3)

ASTM E1527-21

The NREP REPA exam is a 100-question, 3-hour, closed-book online proctored multiple-choice exam with a 75% passing score and a $350 fee. It covers Phase I ESA practice under ASTM E1527-21, the EPA AAI rule (40 CFR Part 312), CERCLA liability defenses for property purchasers (BFPP, Innocent Landowner, Contiguous Property Owner), and REC/HREC/CREC classification. The credential is designed for environmental professionals conducting or reviewing Phase I and Phase II ESAs in real estate due diligence contexts.

Sample REPA Practice Questions

Try these sample questions to test your REPA exam readiness. Each question includes a detailed explanation. Start the interactive quiz above for the full 100+ question experience with AI tutoring.

1What is the primary standard that governs Phase I Environmental Site Assessments (ESAs) for purposes of CERCLA All Appropriate Inquiries (AAI)?

A.ASTM E1527-13

B.ASTM E1527-21

C.ASTM E2018-15

D.40 CFR Part 280

Explanation: ASTM E1527-21, published in November 2021, is the current standard practice for Phase I ESAs and was formally designated by the EPA as satisfying CERCLA AAI requirements (40 CFR Part 312). It superseded E1527-13 and introduced updates including refined definitions of RECs, HRECs, and CRECs, as well as new vapor encroachment screening guidance. Using the current standard is necessary to qualify for CERCLA landowner liability protections.

2Under ASTM E1527-21, which of the following is the correct definition of a Recognized Environmental Condition (REC)?

A.Any prior industrial use of a property, regardless of whether contamination is present

B.The presence or likely presence of hazardous substances or petroleum products in, on, or at a property due to a release, likely release, or material threat of a future release

C.A condition that has been fully remediated and closed by a regulatory agency

D.A de minimis condition that does not pose a material risk of exposure

Explanation: ASTM E1527-21 Section 3.2.86 defines a REC as 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; or (3) under conditions that pose a material threat of a future release to the environment. De minimis conditions are explicitly excluded from RECs.

3A Phase I ESA reveals that a former dry cleaner occupied a property from 1965–1990. Soil and groundwater contamination from tetrachloroethylene (PCE) was confirmed, and the state environmental agency issued a No Further Action (NFA) letter in 2005 with a deed restriction prohibiting residential use and requiring annual groundwater monitoring. How should the environmental professional classify this condition under ASTM E1527-21?

A.Recognized Environmental Condition (REC)

B.Historical Recognized Environmental Condition (HREC)

C.Controlled Recognized Environmental Condition (CREC)

D.De minimis condition

Explanation: A Controlled REC (CREC) is a past release that has been addressed to the satisfaction of the applicable regulatory authority, with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls (activity and use limitations, engineering controls, or institutional controls). The deed restriction and ongoing monitoring requirement are controls that must be maintained, preventing unrestricted use — the defining feature of a CREC versus an HREC.

4Under the EPA's All Appropriate Inquiries rule (40 CFR Part 312), which of the following is NOT one of the eight specific inquiries that must be conducted?

A.Review of federal, tribal, state, and local government records

B.Visual inspection of the property and adjoining properties

C.Environmental cleanup liens on the subject property

D.Phase II soil and groundwater sampling

Explanation: 40 CFR Part 312 specifies eight inquiries for AAI: (1) current and past property uses; (2) records review; (3) site reconnaissance; (4) interviews with owners, operators, and occupants; (5) searches for environmental cleanup liens; (6) review of government records; (7) visual inspection of adjoining properties; and (8) the EP's qualifications and declaration. Phase II sampling (intrusive investigation) is not part of AAI — AAI is a non-intrusive assessment process.

5Which CERCLA landowner liability defense requires a prospective purchaser to conduct All Appropriate Inquiries prior to acquisition, exercise appropriate care after purchase, cooperate with response actions, and comply with land-use restrictions?

A.Innocent Landowner Defense

B.Bona Fide Prospective Purchaser (BFPP) Defense

C.Contiguous Property Owner Defense

D.Secured Creditor Exemption

Explanation: The Bona Fide Prospective Purchaser (BFPP) defense under CERCLA Section 107(r) allows a person who purchases property with known contamination to avoid CERCLA liability if they: (1) conducted AAI prior to acquisition; (2) provide all legally required notices; (3) exercise appropriate care; (4) cooperate with response actions; (5) comply with land-use restrictions and institutional controls; (6) do not impede the performance of a response action or natural resource restoration; and (7) are not potentially liable or affiliated with a PRP. This is the only CERCLA defense available when the buyer knows about contamination before purchase.

6Under ASTM E1527-21, how far back must historical research extend when conducting the records review component of a Phase I ESA?

A.20 years from the date of the assessment

B.50 years from the date of the assessment

C.To the property's first developed use, or back to 1940, whichever is earlier

D.To 1900, regardless of development history

Explanation: ASTM E1527-21 requires that historical use research extend to the property's first developed use, or back to 1940, whichever is earlier. This threshold was established because the industrial period beginning around World War II correlates with the widespread introduction of synthetic chemicals and hazardous substances. Sources used include Sanborn fire insurance maps, aerial photographs, topographic maps, city directories, and historical zoning records.

7ASTM E1527-21 requires consultation of standard historical sources for records review. Which of the following is NOT listed as a standard historical source?

A.Sanborn fire insurance maps

B.Aerial photographs

C.City directories

D.Phase II soil boring logs from adjacent properties

Explanation: ASTM E1527-21 lists standard historical sources for the records review component as: aerial photographs, fire insurance maps (Sanborn maps), property tax files, recorded land title records, USGS 7.5-minute topographic maps, local street directories or city directories, building department records, and zoning/land use records. Phase II soil boring logs from adjacent properties are not a standard historical source under E1527-21 — they are intrusive investigation records that would be part of a Phase II scope.

8Under ASTM E1527-21, what are the required government regulatory database search distances for a National Priority List (NPL) site from the subject property boundary?

A.¼ mile minimum search distance

B.½ mile minimum search distance

C.1 mile minimum search distance

D.No minimum specified — professional judgment only

Explanation: ASTM E1527-21 Table 3 specifies that NPL (Superfund) sites require a minimum search radius of 1 mile from the subject property boundary. This is the longest standard search distance in the E1527-21 database search requirements, reflecting the large scale and potential far-field impact of Superfund sites. Other databases have shorter search distances (e.g., LUST at ½ mile, RCRA TSD at 1 mile, registered USTs at ½ mile).

9Which of the following databases is REQUIRED to be searched as part of a Phase I ESA regulatory database review under ASTM E1527-21 for a property where underground storage tanks may have been present?

A.Leaking Underground Storage Tank (LUST) list

B.RCRA Biennial Reporter list

C.TSCA 8(e) Substantial Risk notification database

D.OSHA inspection history database

Explanation: ASTM E1527-21 Table 3 designates LUST (Leaking Underground Storage Tank) lists — federal and state — as mandatory databases for regulatory database review. The LUST list is particularly relevant when USTs may have been present and is required within a ½-mile search radius. RCRA Biennial Reporter, TSCA, and OSHA databases are not included in the mandatory E1527-21 database list.

10Under ASTM E1527-21, what is the standard search distance for the subject property itself when reviewing the Federal RCRA Treatment, Storage, and Disposal Facility (TSDF) database?

A.Subject property only

B.½ mile

C.1 mile

D.5 miles

Explanation: ASTM E1527-21 Table 3 requires searching the RCRA TSDF (Treatment, Storage, and Disposal) database within a 1-mile radius of the subject property. TSDFs can be significant contamination sources given the volume and variety of hazardous wastes handled. The 1-mile search distance matches that for NPL sites, reflecting the potentially large-scale contamination threat from hazardous waste facilities.

About the REPA Exam

The NREP Registered Environmental Property Assessor (REPA) is a professional credential for environmental practitioners who evaluate environmental risk in real estate transactions. The exam validates command of Phase I Environmental Site Assessments (ASTM E1527-21), EPA All Appropriate Inquiries (40 CFR Part 312), CERCLA landowner liability defenses (BFPP, ILD, CPO), recognized environmental condition classification (REC/HREC/CREC), regulatory database review, historical records research, vapor encroachment screening (ASTM E2600), and Phase II ESA scoping.

Questions

100 scored questions

Time Limit

3 hours

Passing Score

75%

Exam Fee

$350 (NREP (National Registry of Environmental Professionals))

REPA Exam Content Outline

30%

Phase I ESA Process & ASTM E1527-21

Phase I ESA components, EP declaration, 180-day viability, data gaps, user responsibilities, site reconnaissance, interviews, records review, report contents

20%

Recognized Environmental Conditions

REC, HREC, CREC, de minimis, and VEC definitions; classification scenarios; off-site sources; migration pathways; vapor encroachment (ASTM E2600)

15%

All Appropriate Inquiries (40 CFR Part 312)

EPA AAI rule requirements, EP qualification, eight required inquiries, user responsibilities, relationship to ASTM E1527-21

15%

CERCLA Liability & Landowner Defenses

PRP categories, strict joint-and-several liability, BFPP defense, Innocent Landowner Defense, Contiguous Property Owner Defense, windfall lien, brownfields

10%

Records Review & Historical Research

Sanborn maps, aerials, city directories, topographic maps, regulatory database review, ASTM Table 3 search distances, title search, physical setting

Phase II ESA Scoping & Sampling

Conceptual site model, workplan, sampling methods, VOC preservation, groundwater monitoring, QA/QC, NAPL/DNAPL characterization

Non-Scope Considerations & BERs

Asbestos, lead-based paint, radon, mold, PCBs, UST/AST regulations (40 CFR 280), Property Condition Assessments (ASTM E2018)

How to Pass the REPA Exam

What You Need to Know

Passing score: 75%
Exam length: 100 questions
Time limit: 3 hours
Exam fee: $350

Keys to Passing

Complete 500+ practice questions
Score 80%+ consistently before scheduling
Focus on highest-weighted sections
Use our AI tutor for tough concepts

REPA Study Tips from Top Performers

1Memorize the REC/HREC/CREC/de minimis definitions precisely: HREC requires regulatory closure + unrestricted use (UU/UE); CREC requires regulatory closure + ongoing controls (AULs, deed restrictions); de minimis means too small to warrant regulatory action

2Know ASTM E1527-21 Table 3 search distances cold: NPL and RCRA TSDF = 1 mile; LUST, Registered USTs, RCRA Generators = ½ mile; CERCLIS NFRAP, state equivalents = ¼ mile

3Distinguish the three CERCLA landowner defenses: BFPP = knew about contamination before purchase + AAI; ILD = did NOT know + AAI; CPO = contamination migrated from neighbor's property

4Understand that vapor encroachment (ASTM E2600 Tier 1) is now part of the standard Phase I scope under E1527-21 — a key difference from the prior E1527-13 standard

5Memorize the five key Phase I task dates for the 180-day viability clock: records review, site reconnaissance, interviews, government records, and EP declaration — validity measured from the earliest date

Frequently Asked Questions

How many questions are on the NREP REPA exam?

The REPA exam contains 100 multiple-choice questions completed in a single 3-hour session. The exam is closed-book and delivered online with live NREP proctoring.

What score do I need to pass the REPA exam?

You must score at least 75% (75 of 100 questions correct) to pass the NREP REPA exam. The REPA passing score of 75% is higher than the 70% required for the NREP REM credential.

What topics are covered on the REPA exam?

The REPA exam focuses on Phase I ESA practice under ASTM E1527-21, EPA All Appropriate Inquiries (40 CFR Part 312), CERCLA landowner liability defenses (BFPP, ILD, CPO), REC/HREC/CREC classification, regulatory database search distances, historical records research (Sanborn maps, aerials), vapor encroachment screening (ASTM E2600), and Phase II ESA scoping.

How is the REPA exam delivered?

The REPA exam is administered online through NREP's proctored platform. Candidates test from home or their workplace on a computer with working audio, video, and stable internet. An NREP proctor monitors the session in real time.

How much does the REPA exam cost?

The NREP REPA exam fee is approximately $350, which includes the application and exam. Annual recertification requires continuing education units (CEUs) and a renewal fee.

What ASTM standards are tested on the REPA exam?

The primary standard tested is ASTM E1527-21 (Phase I ESA). ASTM E2600 (Vapor Encroachment Screening) is also tested as it was incorporated into the Phase I scope by E1527-21. ASTM E2018-15 (Property Condition Assessments) is tested as a non-scope comparison item.

What are the CERCLA liability defenses covered on the REPA exam?

The REPA covers three CERCLA landowner liability defenses: the Bona Fide Prospective Purchaser (BFPP) defense for buyers who know about contamination, the Innocent Landowner Defense (ILD) for buyers who conducted AAI and found no contamination, and the Contiguous Property Owner (CPO) defense for owners whose property was contaminated by neighboring releases.

How does REPA differ from NREP REP or REM?

REPA is NREP's specialty credential for professionals conducting environmental due diligence in real estate transactions — focusing on Phase I/II ESAs, CERCLA liability defenses, and property risk assessment. REM (Registered Environmental Manager) covers broader environmental regulatory compliance (CAA, CWA, RCRA, CERCLA). REP is the senior multi-discipline credential. REPA is narrower and more focused on the real property transaction context.