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 ------- 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 ------- 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 ------- 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 ------- |