If there is a risk that the Bank might be considered a PRP under CERCLA, a Phase I should be performed in accordance with ASTME 1527-13. If such a Phase I is performed along with any additional appropriate investigation, the Bank will likely be successful in asserting one of these defenses under the Brownfield Act. A Phase I done in accordance with ASTM 1527-05 would also provide strong evidence of a defense under the TSWDA.