Environmental Site Assessment: All Appropriate Inquiries
Author: STP ComplianceEHS
Environmental Site Assessment: All Appropriate Inquiries provides an audit checklist for conducting all appropriate inquiries (AAI) to qualify for landowner liability protections under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) or “Superfund.” These include:
- Innocent landowner defense
- Bona fide prospective purchaser liability protection
- Contiguous property owner liability protection
The checklist covers the U.S. Environmental Protection Agency’s (EPA’s) rule for conducting AAI, as codified under 40 CFR 312, and also incorporates certain criteria from the EPA-recognized standard ASTM E1527-13.
This guide uses STP’s standard audit checklist format, with a single module including the following:
- Introduction, providing a discussion of the applicability of the guide, an overview of how it addresses the regulatory requirements for conducting AAI, and key definitions for terms used in the checklist.
- Rulebook, providing audit criteria based on EPA requirements under specific sections of 40 CFR 312, with detailed Guide Notes to help users assess conformance with the criteria. The rulebook sections cover the different aspects of AAI, as follows:
- All Appropriate Inquiries – General
- Inquiry by an Environmental Professional (EP)
- Additional Inquiries
- Interviews with Owners, Operators, and Occupants
- Reviews of Historical Sources of Information
- Searches for Recorded Environmental Cleanup Liens
- Reviews of Federal, State, Tribal, and Local Government Records
- Visual Inspections of the Facility and of Adjoining Properties
- Specialized Knowledge or Experience
- Relationship of the Purchase Price to the Value of the Property, If the Property Was Not Contaminated
- Commonly Known or Reasonably Ascertainable Information
- Degree of Obviousness of the Presence or Likely Presence of Contamination
- Disclosure Requirements (Release Notification)
- Scoresheet, allowing quick recording of the organization’s compliance status.