Phase II ESA Regulatory Database Review: What Records to Pull and How to Document Findings

The Phase I ESA on the former metal-fabrication parcel flagged a recognized environmental condition: a 1971 fire on an adjacent property that involved unknown drum quantities, plus the subject site’s own listing in two state databases as a former generator of chlorinated solvent waste. Your scope of work for the Phase II investigation now includes soil and groundwater sampling, but the regulatory database review from the Phase I has gaps the buyer’s lender wants closed before the loan commitment. This is what to pull, where to pull it from, and how to document findings when a Phase II ESA regulatory database review needs to extend the Phase I work.

The standard practice that governs this is ASTM E1527-21 for Phase I ESAs, which prescribes a specific set of standard environmental record sources, and ASTM E1903-19 for Phase II ESAs, which assumes the Phase I database review has already happened but explicitly allows for additional records review during Phase II to refine the conceptual site model. In practice, almost every Phase II includes a database review pass — either to update Phase I records that have aged out (E1527-21 records have a 180-day shelf life), to chase a specific REC the Phase I identified, or to investigate findings the sampling has surfaced.

Why the Phase II Database Review Is a Distinct Task

A Phase I database review answers “what regulatory records exist for this site and its surroundings?” A Phase II database review is more targeted. It answers questions like: what other facilities reported releases of the same compound class we’re finding? Is there an upgradient source that explains our groundwater hits? Has any of the Phase I information been superseded since the report was issued? The records you pull are the same ones an environmental data resource (EDR or similar) would pull, but the questions are sharper.

The other distinction matters for the user of the report: a lender, a buyer, or state-agency reviewer is going to compare the Phase II database review against the Phase I database review and look for justification of any differences. If the Phase II adds a record the Phase I missed, you owe an explanation of why that record matters now and didn’t appear before. If the Phase II drops a record the Phase I included, you owe a citation showing the record was retracted, expunged, or no longer relevant.

The Standard Federal Records to Pull

The federal record sources required by ASTM E1527-21 (and applicable to a Phase II follow-up) are well-defined. The current authoritative pull list:

• National Priorities List (NPL) — CERCLA Superfund sites. Source: EPA National Priorities List.
• Delisted NPL — Sites removed from the NPL.
• SEMS / SEMS-ARCHIVE — Superfund Enterprise Management System (formerly CERCLIS). Includes both active and archived CERCLA inventory sites.
• RCRA CORRACTS — RCRA facilities subject to corrective action.
• RCRA non-CORRACTS TSD — Treatment, Storage, Disposal facilities without active corrective action.
• RCRA generators (LQG, SQG, VSQG) — Hazardous waste generator facilities by quantity classification. Source: RCRAInfo.
• Federal ERNS — Emergency Response Notification System reports of oil and hazardous substance releases.
• Federal IC / EC registry — Institutional and engineering controls on federal cleanup sites.
• Federal Brownfields — ACRES (Assessment, Cleanup, and Redevelopment Exchange System) database.

The State and Tribal Records to Pull

State records are jurisdiction-specific and often the highest-yield sources for routine Phase II work, because most contaminated sites are managed under state cleanup programs, not federal CERCLA. The categories ASTM E1527-21 requires:

• State NPL-equivalent or state hazardous waste sites (e.g., NJ Known Contaminated Sites List, MA M.G.L. c. 21E sites with state DEP file numbers, CA Cortese List).
• State CERCLIS-equivalent or voluntary cleanup program lists.
• State landfill and solid waste facility lists.
• State leaking underground storage tank (LUST) lists.
• State registered underground storage tank (UST) lists.
• State engineering control / institutional control registries.
• State voluntary cleanup program (VCP) sites.
• State brownfields lists.

Tribal records apply only when the site is on or adjacent to tribal land, and pull from the relevant tribal environmental program plus EPA Region 9 or applicable region records.

Search Distances Per ASTM E1527-21

ASTM E1527-21 prescribes minimum search distances by record type. The standard distances are measured from the property boundary outward:

Phase II investigations frequently expand the search radius when the conceptual site model implicates an upgradient source beyond the Phase I default. If your Phase II is chasing a chlorinated solvent plume, increasing the search radius for state CERCLIS-equivalent records to 1.0 mile is defensible and routine.

How to Document the Pull

The deliverable is the same shape as the Phase I database section but with sharper attribution. For each record, document:

• Source database name and access date. “EPA RCRAInfo, accessed 2026-04-15.” Date matters because government databases update.
• Search radius applied. ASTM-required minimum or expanded; cite the reason if expanded.
• Number of hits within the radius. Zero hits is a finding; document it explicitly.
• Listing-by-listing detail for every hit: facility name, address, distance and direction from the subject property, EPA ID or state ID, listing date, status, contaminants of concern.
• Hydrogeologic context. Whether each hit is upgradient, downgradient, or cross-gradient relative to the subject property, based on the Phase II groundwater flow characterization.
• Disposition. What you concluded about each hit’s relevance to the subject site — whether it is a likely contributing source, a potential off-site source not contributing, or a record screened out.

EDR vs Direct Agency Pull

For Phase I work, most consultants use a commercial environmental data resource (EDR Radius, Banks Information Solutions, ERIIS, GeoSearch). For Phase II refinement work, a direct agency pull is often faster and more accurate for the specific records you care about. The trade-off:

The pragmatic Phase II approach: order a fresh EDR for the comprehensive pull, then direct-pull the two or three specific listings the conceptual site model implicates. The EDR documents radius completeness; the direct pull documents listing currency and detail.

Connecting the Database Review to the Conceptual Site Model

The reason Phase II database review matters more than Phase I is that you now have data. A nearby LUST site that was a low-priority listing in the Phase I becomes a primary suspect when your downgradient monitoring well at the subject property shows free-product contamination matching the LUST’s historical petroleum types. The database review section should explicitly link findings to the conceptual site model:

• Which off-site listings could be sources of the contaminants observed in Phase II sampling?
• What do the listing dates tell you about likely release timing relative to the contamination distribution observed?
• Are there listings that the Phase I missed because the radius was tight, but which the Phase II findings now make relevant?
• If your Phase II results are clean, do the database listings still implicate latent risk that warrants institutional controls or a documented determination of no further action?

For sites with environmental data spanning multiple sampling events, organizing the database review findings alongside analytical results in a single tracking system — the same discipline used for groundwater monitoring data management — lets you flag the database hit that best explains each contaminant signature without rebuilding the analysis from scratch each project.

What Goes to the Lender or Regulator

The Phase II database review section should be self-contained — readable without referring to the Phase I report. Include the agency citations for ASTM compliance, the search-distance table, the listing-by-listing detail, the disposition statement for each hit, and a one-paragraph reconciliation if any Phase I findings have been superseded. Lenders rarely read the database tables in detail; they read the disposition column and the conclusion. State reviewers do read the tables, and they look for completeness against ASTM’s required source list. Both audiences are served by the same table format properly attributed.