Obstacles in Applying ASTM E1527-05 in Central and Eastern EuropeMar 2nd, 2010 | By Peter Temesvary | Category: Due Diligence, Environmental Management
Standard practice for performing a Phase I environmental site assessment (ESA) in the United States is described in American Society for Testing and Materials (ASTM) Standard E1527-05, Standard Practice for Environmental Site Assessments. This standard specifies the scope of work and required components of the assessment, such as records review, site reconnaissance, interviews and report preparation. Multinational companies increasingly specify the performance of due diligence assessments worldwide to the ASTM standard, but some of the techniques and data sources described in the standard are not available in countries outside of the United States.
Limitations in Central and Eastern Europe
In Hungary, and in fact throughout the Central and Eastern European (CEE) countries, access to public records is difficult at best. There are very few published databases, and those that are published are often unreliable. Requirements for reporting site investigations, remedial activities or chemical use and storage to regulatory authorities are not always clear or universally followed. Furthermore, even where environmental data are reported to the authorities, there is often no public access to the records. Discussed below are some of the critical limitations associated with implementing ASTM E1527-05 in Hungary. These problems are commonly found throughout the CEE region.
In Hungary, a database listing potentially contaminated sites (FAVI-KARINFO) was created in the late 1990s. The database focuses on potential sources and is based mostly on unverified information. It has not been updated since its initial inception more than 10 years ago. Furthermore, public access is limited even to what information is in the database. In most CEE countries the situation is similar; perhaps the notable exceptions are the Czech Republic and Slovakia, where the so-called GEOFOND database is a relatively reliable catalog of sites where environmental or geotechnical investigations have been performed since the mid to late 1990s.
Until 1989, aerial photographs were considered military secrets in the former Eastern Bloc. As a result, historical aerial photographs may not be available for a site. While the availability of satellite photographs is increasingly common, image libraries typically contain only current or very recent photos that are not helpful in assessing historical activities. In Hungary there are two sources of aerial photographs. One is a former military library that has aerial photographs starting in the 1950s and going up to the present, but in each year only a small section of the country was photographed. The other source has photographs only from 2000 and 2005. In both cases, the lead time for obtaining aerial photographs can take from ten to fourteen days.
Agency File Reviews
In the United States, regulatory information on industrial sites is often available to the public. Information on the permit status of a facility or remedial actions conducted at an individual site can be requested and reviewed at the regulatory agencies that were responsible for overseeing the activity.
In Hungary, such information is not made automatically available. A written request can be made to the appropriate agency to review such information, but the agency has 30 days to respond, and most agencies do not consider the inquiry of a potential buyer of a site to be sufficient grounds for providing information. In almost no case would information regarding neighboring sites be made available.
Telephone inquiry to regulatory authorities or the local municipality generally leads to more information than a formal inquiry, especially if the person who oversaw the work in question can be identified and interviewed. However, even in these cases, it is rare to be allowed the opportunity to review actual site records.
In spite of the obstacles in applying ASTM E1527-05 when conducting Phase I ESAs in the CEE region, it is still possible to assemble a reasonably complete site profile through diligent inquiry. However, the methods used to assemble the site profile will likely not include the standard information sources that are available in the United States or other countries with advanced public information libraries.
Purchase ASTM E1527-05 at http://www.astm.org/Standards/E1527.htm.
About the Author
Peter Temesvary is a partner at Environmental Resources Management (ERM), where he serves as the Managing Director of ERM’s Budapest, Hungary office. He has 15 years of environmental consulting experience in the areas of strategic due diligence, compliance management, and site investigation and remediation. Mr. Temesvary has performed over 300 environmental due diligence assessments and compliance audits in a variety of industry sectors. He has worked in and managed projects throughout the western U.S.A. and the Central and Eastern European region (Hungary, Romania, Slovakia, Czech Republic, Austria, Bulgaria, Serbia, Slovenia, Croatia). He has extensive experience in remediation by soil vapor extraction (SVE) and has also conducted the soil, groundwater, and free-phase hydrocarbon remediation of numerous facilities. Prior to joining ERM, Mr. Temesvary served as the Production Department Manager of the Budapest Water Works, which supplies potable water to 2 million customers.
Image: Digital World by Ilco, Izmir, Turkey.