PHASE I (AAI) AND PHASE II ASSESSMENTS

Phase I

The Environmental Protection Agency established federal standards and practices for conducting all appropriate inquiries (AAI) as required by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The final rule, effective November 1, 2006, established specific regulatory requirements and standards for examining previous ownership and uses of a property to qualify for certain landowner liability protections under CERCLA. The standards and practices also will be applicable to persons conducting site characterization and assessments with the use of grants awarded under CERCLA section 104(k)(2)(B).
The new rules provide protection for a bona fide prospective purchaser, contiguous property owners, and innocent landowners. Pertinent details for obtaining protection in each category are listed below:

• A bona fide prospective purchaser is one who bought the property after January 11, 2002, conducted all appropriate inquiries before purchase, and complied with a several other requirements.
• A contiguous property owner may be protected from liability for encroaching releases from someone else’s property by showing through AAI and other requirements that they are not the cause of the release, i.e., that the release occurred elsewhere and migrated to its site after his property was purchased. AAI must be conducted before property ownership changes.
• The innocent landowner defense relies on the landowner having no knowledge or reason to know that any hazardous substance was released or disposed of on the property. Conducting AAI before the property is purchased and complying with several requirements afterward protect the new landowner from liability under CERCLA.
• Additional Requirements: Conducting all appropriate inquiries alone does not provide a landowner with protection against CERCLA liability. Landowners who want to qualify must comply with all of Statutory requirements.
  
  
  

The additional statutory requirements that the landowner must meet include:
1	To have acquired a property after disposal of all hazardous substances at the site ceased;
2	Provide all legally required notices;
3	Take reasonable steps to stop any continuing releases or threatened future release, prevent or limit any additional exposure to a previous release;
4	Comply with land use restrictions;
5	Not impede the effectiveness or integrity of institutional controls;
6	Comply with CERCLA requests for information; and
7	Not be potentially liable for response costs at the property or be associated with any other person who is

• CCA personnel have conducted Phase I Environmental Assessments from South Carolina to West Virginia.
• All of our assessments are conducted by Licensed Professionals.
• We have data sources in place that allow for a quick resolution to your needs.
• CCA is also qualified to provide Phase II Assessments as needed.

Phase II Assessments and Remediation

CCA understands that you are mostly interested in satisfying regulatory requirements so that you can focus on your primary business. We recognize that you want to meet this objective with minimal cost and inconvenience. Our objective is to provide this service with the degree of involvement you prefer. Our professional staff is well qualified to conduct assessments with minimal client interaction or with providing whatever detail you desire.

Only licensed professionals conduct assessments at CCA. This provides you with the best service possible. Our services are tailored to each site specifically, completing only the necessary tasks. CCA developed several innovative and cost-saving approaches to assessing and remediating a site. Our professionals understand that integrating the entire geological and hydrological circumstances is critical to achieving satisfactory results. We have assessed undeveloped, residential, commercial, and industrial properties in urban and country locations.

Key CCA personnel have extensive experience in remediating sites. Groundwater cleanup methods include pump and treat systems, air sparge/vacuum extraction systems, and natural attenuation. Wherever possible, we close sites through risk-based rules, often by demonstrating the technological and economical unfeasibility of additional work. Thus, sites are often closed through deed restrictions for soil and/or groundwater, or by obtaining a variance to the groundwater rules. Our professionally licensed associates provide engineering services when needed.