United States
                     Environmental
                     Protection Agency
                     Washington, D.C. 20460
   Solid Waste
   and Emergency
   Response (5101)
EPA500-F-01-349
September 2001
www. epa. gov/brownfields/
 vEPA     RCRA  Brownfields
                     Prevention  Initiative:
                     Lessons  Learned  from Pilots
Outreach and Special Projects Staff (5105)
                      Quick Reference Fact Sheet
U.S. Environmental Protection Agency's (EPA's) Brownfields Economic Redevelopment Initiative is designed
to empower states, communities, and other stakeholders in economic redevelopment to work together in
a timely manner to prevent, assess, safely clean up, and sustainably reuse brownfields. A brownfield is a
site, or portion thereof, that has actual or perceived contamination and an active potential for redevelopment
or reuse.

The Resource  Conservation and  Recovery Act (RCRA) Brownfields Prevention Initiative is a  U.S.
Environmental Protection Agency effort designed to use opportunities for statutory and regulatory flexibility
in the RCRA cleanup program to  accelerate site cleanup, facilitate dialogue, and integrate reuse and
redevelopment issues, as appropriate, into cleanup decisions. In the longer term, it is EPA's goal that this
initiative will help accelerate cleanups at brownfields sites, thus enabling the creation  of new jobs,
businesses, and green space for communities. RCRA Brownfields Prevention  pilots are cleanup projects
that showcase innovative approaches that integrate the use of RCRA reforms and Brownfields tools to
expedite the cleanup, redevelopment, and reuse of RCRA properties.
BACKGROUND

The EPA launched the RCRA Brownfields Prevention
Initiative in June 1998 The initiative responds to
concerns raised by cities, industries, and communities
who have recently begun emphasizing the importance to
look beyond Superfund to address issues at brownfields
in a more comprehensive manner. Three initial goals of
the  initiative  were  to  raise stakeholder awareness,
identify any RCRA barriers to redevelopment, and try
new approaches raised by pilot partners. EPA is hopeful
that longer-term benefits of this initiative will be new
jobs, new  businesses,  and more green  space  for
communities. The initiative is designed to improve how
federal and state governments implement the RCRA
programs  and  work with stakeholders regarding
property reuse  to yield more effective results  for
communities and the environment.

In March 2000, EPA announced four pilot projects
intended to provide case studies of techniques,  tools,
and  strategies   that  integrate  future  land  use
considerations into RCRA cleanup decisions, thereby
encouraging brownfields redevelopment at sites subject
to RCRA.
The four selected pilots are:

• CBS/Viacom in Bridgeport, Connecticut: A
  former electrical wiring manufacturing site that
  operated  from  1888  to  1998,  with  soil and
  groundwater  contamination.   Assessment  and
  remediation are continuing at the site. Pilot goals are
  to  resolve differences between the Connecticut
  Property Transfer Act and RCRA corrective action
  requirements, develop a public communication fact
  sheet, and form a pilot project stakeholder team to
  address reuse issues at the site. To date, state and
  federal cleanup requirements have been integrated,
  a local  community-wide fact  sheet  has  been
  distributed,  and   remediation  activity   and
  redevelopment   planning  is  proceeding.  Also,
  Viacom  and the City of Bridgeport  signed an
  agreement under which Viacom agreed to complete
  its  cleanup  obligations  under RCRA and the
  Connecticut  Property Transfer Act. As a result,
  Prime Resources, a developer, has been provided
  "comfort" and is working with Viacom to complete
  the purchase of the  site. The future plan is to
  develop a light manufacturing facility.

-------
  Bethlehem  Steel  Corporation  in  Lackawanna,
  New York:  A former major integrated steel mill, a
  manufacturing portion of which is  still operating,
  includes two parcels (102 acres and 500 acres) with
  good redevelopment potential that are covered by a
  RCRA  Facility Investigation  (RFI)  order.  The
  primary pilot goal  is to release the 102-acre parcel
  from the order and move it into the  state voluntary
  cleanup program. Experience gained may be applied
  to the cleanup and redevelopment  of the second
  parcel.  Broadened stakeholder  involvement and
  public outreach have  been  integral to the  process.
  EPA has released the  102-acre parcel from the RFI
  order and will turn over cleanup of the entire site to
  the New  York   Department  of  Environmental
  Conservation (NYDEC). The future plan is to build
  a light industrial park.

  PECO-Energy in Chester, Pennsylvania: A former
  utility site that contains a 17-acre portion that was
  leased for hazardous waste recycling and is under a
  RCRA consent order. The primary pilot goal is to
  integrate  RCRA   corrective  action   with  the
  Pennsylvania Land Recycling and Reclamation Act
  (Act  2)  requirements  in  order  to  eliminate
  duplication,  expedite redevelopment, and revitalize
  an Environmental Justice community. The regulatory
  integration process  continues along with the ongoing
  cleanup. A property developer has purchased a major
  portion of the site and plans to renovate an old power
  plant building into  commercial office space.

  Blue  Valley  Redevelopment  in  Kansas  City,
  Missouri: A multi-facility industrial area in the Blue
  River flood plain that contains RCRA facilities such
  as wood treaters and  scrap recyclers. The  primary
  goal is to  meld  RCRA issues into an  existing
  interagency  redevelopment  effort by consolidating
  RCRA, geographical information system (GIS), and
  other   environmental   data  into  the  city's
  "Redevelopment Opportunity Portfolio" for the area.
  A secondary goal is to test the use of clean dredged
  material as  fill on  RCRA facilities. The collected
  environmental  and GIS information  have been
  included in the city's  "Redevelopment Opportunity
  Portfolio." However, it was also decided to use the
  collected  information as  part  of  an  area-wide
  background  study  that will  be used as  a  baseline
  comparison   of   contaminants   in   site-specific
  investigations. The background  study is about to
  begin  pending  the  approval   of  the Missouri
  Department  of Natural Resources. Also, the reuse of
  the dredged  materials is awaiting the approval of the
  City of Kansas, Missouri. The future plans are to
  place new industrial facilities on  old  industrial
  properties and to revitalize the area.

ACCOMPLISHMENTS

In just one year, the four pilots already have yielded
results and innovations that can be readily transferred
to other sites. Overall, the four pilots demonstrated that
frequent   communication   among  all   levels  of
government and facility owners/operators, combined
with the RCRA corrective action reform emphasis on
"results over process," can speed cleanup, which will
in turn, enhance the  opportunity  for redevelopment.
The  pilots provided a forum for diverse stakeholder
interests to start communicating while focusing on
cleanup and process improvement. As a consequence,
issues  and problems became  clearer and  possible
solutions more readily identified.

Site  assessment  and  cleanup  activities  are well
underway, as are redevelopment plans, at all four pilot
sites. The pilots also have created generally cohesive
teams with positive working relationships that bode
well for further progress on cleanup and reuse.

LESSONS  LEARNED FROM THE PILOTS

There are several lessons learned from the pilots that
may have implications for the RCRA program.

Better  Integrate   Brownfields  Redevelopment
Opportunities   into  RCRA  Corrective   Action
Programs, as Appropriate.

Regional and state personnel are more  empowered to
accommodate  redevelopment,  but   need   more
awareness of the flexibility that existing Brownfields
and RCRA tools can provide to satisfy the site-specific
needs of stakeholders. Similarly, these personnel need
a better understanding of the particular issues that
developers have  and how to  address those  issues
through federal and  state programs to help address
issues posed at idled RCRA properties.

Encourage High-Quality Owner/Operator-Initiated
RCRA Investigations and Cleanups.

The owners/operators of all four pilot sites pro-actively
participated in a variety of activities depending on the
circumstances at their individual sites.  The ability of
EPA and  the  state to  act on these owner/operator
initiated efforts eliminated years  of procedural time.
RCRA Brownfields Prevention Initiative
September 2001	
                            Lessons Learned Fact Sheet
                                   EPA 500-F-01-349

-------
Efforts to involve the public were  enhanced by the
stakeholder process as well as the pilot teams' focus on
public communication.

Forge Cooperative Relationships between EPA and
the States.

All of the pilots in effect created "one stop shopping"
for the  community,  the  owner/operator, and  the
redeveloper  because state  and federal cleanup issues
were resolved in a more holistic manner. For example,
EPA and the State of Connecticut, a state not authorized
for RCRA  correction  action, coordinated program
requirements and work  assignments smoothly. Also,
EPA's partnership with  Pennsylvania's  Voluntary
Program has enabled PECO to use one administrative
process to satisfy both state and federal corrective action
goals, saving valuable resources.

Be Receptive to  "Carving Out" Portions of RCRA
Permitted or Interim Facilities, where Appropriate.

Local officials are concerned about pursuing potential
redevelopment opportunities where the property at issue
is, or potentially will be, subject to RCRA corrective
action. Specifically, local officials are concerned that
the potential liability might be conveyed with title to the
property. EPA should address how sites can be deleted
or carved out from potential RCRA cleanup liability
status and  make  available examples of  successful
approaches.

Encourage  States to  Allow Appropriate  Use  of
Voluntary Cleanup Programs (VCPs) for Specific
RCRA Sites.

Some states, either by statute or policy, consider RCRA
sites to be ineligible for entry into their VCPs. States
whose VCP  meets  or  exceeds  the  substantive
requirements of the federal RCRA program for cleanup
and public participation might offer an expeditious
complement  to  their  authorized  corrective  action
programs.

Encourage New  Thinking by, and  a  Willingness to
Engage with, the Regulated Community on Ways to
Integrate Reuse into the Corrective Action Process.

Government and private parties should focus on the goal
of getting properties into  productive use. At one pilot, a
fresh approach resulted in noteworthy and very positive
shifts in attitude. At all four pilots, the newly  opened
lines  of  communication  enhanced  the  working
relationships   between   regulators   and  industry
representatives, which fostered innovative strategies to
meet   regulatory   obligations  while   achieving
environmental and economic success.

ADDITIONAL INITIATIVE COMPONENTS

In addition  to the  pilots,  the RCRA Brownfields
Prevention Initiative includes targeted site  efforts,
training and outreach, and streamlining and clarifying
the cleanup and reuse process.

Targeted Site Efforts (TSE) are designed to showcase
Brownfields and RCRA reforms at up to 20 sites. The
goal is to "jump-start" activity at a facility to move it
closer  to  cleanup   and  redevelopment.  Sites  with
redevelopment potential will be identified in each EPA
Region, and a small amount of EPA mission contractor
support will  be provided  for short-term  activities
directed  to  overcoming barriers to  cleanup  and
redevelopment.

The Training and Outreach component of the initiative
will focus on  workshops in each EPA Region. The
purposes of the workshops  are to: 1) educate RCRA
staff about brownfields tools that can  help expedite
cleanup and redevelopment; 2) educate brownfields
staff about the special needs and  opportunities of
RCRA  sites;  and  3)  promote  interaction  with
stakeholders outside of EPA to incorporate their ideas
and address their concerns.

RCRA  Corrective   Action  Reforms   are   a
comprehensive effort to address the key impediments
to cleanups, maximize program flexibility, and spur
progress towards a set of ambitious national cleanup
goals. The RCRA Brownfields Prevention Initiative
enhances implementation of the RCRA reforms  by
clarifying the role of reuse in the cleanup process and
streamlining cleanup approaches.

FOR MORE INFORMATION

For more information on  EPA's Corrective  Action
Reforms, please visit the RCRA corrective action web
site at http://www.epa.gov/correctiveaction.  For more
information about the RCRA Brownfields  Initiative
pilots and other brownfields program initiatives please
visit  the  brownfields   program  web  site  at
http://www.epa.gov/brownfields.
RCRA Brownfields Prevention Initiative
September 2001	
                            Lessons Learned Fact Sheet
                                   EPA 500-F-01-349

-------