When is a liability assessment based on a phase I environmental site assessment acceptable (Type C liability estimate)?
When a complete phase I site assessment that thoroughly assesses both historical and current conditions of the site indicates that there are no contaminant concerns, physical disturbance, or reclamation issues warranting further assessment. A completed phase I assessment must include the following: a) Review of past records regarding operations, waste management, and environmental impacts of the facility or well from when the facility was first built to until it was decommissioned. This includes records, correspondence, notes, plot plans, and, where available, as-built construction diagrams. A complete record review must examine records as described above from both company and government sources and, to the extent available, third party sources to develop a detailed understanding of the past operations of the site and assessment of potential liability issues associated with that. b) A review of time series air photographs from before facility construction to decommissioning with regula
