RCRABrownflelds
EPA Working with State and
Local  Partners to Achieve
Cleanup and  Redevelopment
  RCRABrownfield
  Pilots provide case
 studies of techniques,
 tools, and strategies
  that can be used to
 address RCRA issues
 that affect brownfields
 redevelopment efforts.
 RCRABrownfield Pilots:

 The Resource Conservation and Recovery Act (RCRA) primarily regulates the
 generation, treatment, storage, and disposal of hazardous wastes. However, if the
 property was subject to a RCRA permit or if RCRA-regulated waste was disposed
 of on-site, RCRA also may affect the cleanup of contamination at the site. In March
 2000, EPA announced the first round of RCRA Brownfield Pilot projects. These
 projects were initiated to provide case studies of techniques, tools, and strategies that
 can be used elsewhere where RCRA issues are confronted during brownfields
 redevelopment.

 Although EPA provides no direct funding for the pilots, after only six months, the
 projects began to yield results. While work continues at each pilot, preliminary results
 highlight innovations that may be transferable to other brownfield properties. These
 first RCRA Brownfields Pilots have shown that frequent communication among
 federal, state, and local government and owner/operators, combined with the
 corrective action reforms' emphasis on "results over process," can speed cleanup.
 This will, in turn, allow for redevelopment at RCRA facilities.

 Building upon the success of the first round of RCRA pilots, EPA selected five
 additional RCRA brownfield pilots for 2001. This fact sheet summarizes the first four
 pilots, their initial accomplishments, and describes the "lessons learned" to date. The
 results of the second round of pilots selected in 2001 will be publicized in the future.

 Pilot Case Studies:

 I. CBS/Viacom

 The CBS/Viacom site, located in Bridgeport, Connecticut, was a Westinghouse
 electrical components manufacturing facility. Plans called for the transfer of the
 property to the City of Bridgeport, which would then transfer it to a third party who
 would develop it for a new industrial use.  But first, some major challenges had to be
 addressed.

 The State of Connecticut is not authorized for RCRA, so EPA administers the
 program directly. However, Connecticut's Property Transfer Act contains
 requirements that also must be met prior to the sale of contaminated property. As a
 result, differences and similarities between state and federal requirements threatened
 to lead to duplication and confusion, thereby delaying cleanup and redevelopment

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RCRABrownfields
       RCRA
Brownfields Pilots
    already have
     shown that
      frequent
  communication
  among federal,
   state and local
 governments and
 owner/operators,
combined with the
 corrective action
reforms' emphasis
  on "results over
    process" can
speed cleanup and
      facilitate
  redevelopment.
efforts. Another challenge was the need to enhance stakeholder communication
through collaborative problemsolving and improve communication of site activities to
local residents.

A successful process was created in which EPA worked cooperatively with a non-
authorized state program to reconcile and streamline differing program requirements.
To address these differences, EPA staff compared state and federal requirements
and were satisfied that the state standards would ensure that federal corrective action
goals for the protection of human health and the environment could be met. Next, a
workgroup was formed to include federal, state, city, owner/operator representatives,
and developers. Monthly meetings were held to quickly identify and work through
issues, which helped expedite site assessment, remediation, and redevelopment
activities. Finally, an informative fact sheet was developed and distributed for
community outreach.

II. Bethlehem Steel

The Bethlehem Steel Corporation (BSC) facility in Lackawanna, New York, is a
former steel plant occupying approximately 2.5 square miles (1,600 acres) and
extending one mile along the eastern shoreline of Lake Erie. Steel was manufactured
on site from the early 1900s until 1983. Since then, manufacturing operations have
been reduced significantly. The pilot focuses on a  102-acre parcel that holds promise
for industrial or commercial reuse. Goals for the pilot were to coordinate the federal,
state, and local requirements applicable to the facility and to bolster community
involvement.

A successful stakeholder workshop and public meeting was held on June 27,2000.
Federal, state and local government officials, planning experts, developers, and
residents discussed the cleanup and revitalization efforts. Creating a cooperative
working relationship among the diverse stakeholders was essential to the prompt
investigation, cleanup, and resolution of any conflicting regulatory program
requirements.

Although EPA had previously issued a "no further action" letter to BSC for the solid
waste management units on the 102-acre parcel, this parcel remained part of a 1990
EPA Administrative Order for cleanup. A critical task under the pilot was to remove
the  102-acre parcel from the EPA Order in advance of the entire site being declared
clean, which would make that portion of the site eligible for New York State's
Voluntary Cleanup Program (VCP). This was accomplished on January 12, 2001,
when EPA issued the release of the 102-acre parcel from the order. In order to
satisfy BSC's request to proceed under state cleanup authority and Erie County's
desire for further investigation of the 102-acre parcel, BSC elected to enter into a
voluntary consent order with the New York State Department of Environmental
Conservation (NYSDEC).  The consent order, modeled after the VCP agreement,
will provide BSC with industrial use-based cleanup levels and liability releases once
they have satisfactorily met the requirements of the order.

III. PECO

The PECO site (previously the Pennsylvania Electric Company, and now part of the
Exelon Corporation), occupies 88 acres and has roughly 3,000  feet of waterfront
                                                             Solid Waste and
                                                             Emergency Response
                                                             (5303W)
                                                       EPA 530-F-02-002
                                                       October 2002
                                                       www.epa.gov/osw/cleanup.htm

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along the Delaware River in Chester, Pennsylvania. This is a low-income, urban,
industrialized area that has been the subject of some controversy in recent years with
respect to the environmental permitting of facilities. The EPA project manager for the
PECO site has worked closely with the Regional Environmental Justice Office to
facilitate communication and ensure that all stakeholders are kept informed of the
cleanup and redevelopment activities.

Seventeen of the 88 acres are currently under a RCRA Consent Order to investigate
past contamination. The RCRA site investigation revealed petroleum in the
groundwater. PECO implemented interim measures to recover the petroleum and
prevent sheens from forming on the river surface. PECO is committed to cleaning up
the property for redevelopment and cleanup activities are moving forward.

There were two major goals for the pilot. The first goal was to expedite cleanup and
redevelopment without compromising protection of human health and the environment.
The second goal was to craft a cleanup approach for the entire property that would
integrate the requirements under RCRA Corrective Action with Pennsylvania's
Voluntary Cleanup (often referred to as Act 2) program. This would avoid duplication of
effort by PECO and conserve state and federal agency resources. By eliminating the
need for a second RCRA Consent Order to investigate the remaining 71 acres and a
third order to implement the remedy, EPA and PECO saved valuable resources and an
estimated 24 to 36 months in the cleanup process.

In May 2001, PECO sold most of the property for redevelopment. Renovations began
with the old coal-fired power plant, which  was converted into an office building. The
developer plans to convert the rest of the property into additional office space and other
commercial ventures. In addition, PECO donated a portion of the property adjacent to
the city boat ramp to the city for recreational opportunities. The planned redevelopment
will provide attractive commercial and recreational space to a disadvantaged community
and create an estimated 3,000 jobs.

IV. Blue Valley Redevelopment

The Blue Valley is a blighted industrial area located in the Blue River flood plain in east
Kansas City, Missouri, that includes several RCRA-regulated facilities. This RCRA
Brownfields Pilot builds on the work of the pre-existing interagency Blue Valley
Redevelopment Team that was formed to examine redevelopment opportunities created
by the U.S. Army Corps of Engineers' (USAGE) channelization project on the Blue
River. The team partners include EPA Region 7, USAGE, City of Kansas City (various
offices), Missouri Department of Natural  Resources, Hanson/Beazer East, CEC, Inc.,
and the Blue Valley Industrial Association. Frequent communication among
stakeholders and a willingness to bridge the differences among government agencies
and their regulatory programs has been critical to success.

The primary goal of the pilot was to perform an area-wide environmental assessment of
the Blue River Industrial Corridor in order to facilitate cleanup and redevelopment of
properties within this area, starting with the Beazer East site. The area-wide
environmental assessment includes the use of geographic information system (GIS)
maps to compile and integrate environmental data from the USAGE, RCRA permits,
and Superfund assessments with other pertinent economic redevelopment information in
order to  create a Redevelopment Opportunity Portfolio for properties within the Blue
RCRABrownfields

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 RCRABrownfields

3*::-v-"-:/": --
Valley. Another goal was to demonstrate how to efficiently utilize clean fill material
(dredged from the USACE's Blue River channelization project) while remediating
and regrading the Beazer East site.

The team compiled and reviewed existing data from RCRA permits and other
sources and completed GIS maps for the Blue Valley region. EPA has coordinated
the RCRA Corrective Action program with the state's Corrective Action Levels for
Missouri (CALM) program and identified and resolved discrepancies in the data.
Approval was obtained from Missouri and the USAGE to use clean dredged material
as fill at the Beazer East site to help stabilize the site for subsequent assessment and
possible further remediation. As a result, EPA's corrective action process was
successfully integrated with  USACE's dredged material management program.

For additional information on RCRA Pilots, please visit the RCRA Brownfields
Prevention Initiative web site at http://www.epa.gov/swerosps/rcrabf

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