OSWER 9365.0-33 Guidance for Preparing Superfund Ready for Reuse Determinations I. Introduction Overview The U.S. Environmental Protection Agency (EPA) has developed a new document called a Ready for Reuse (RfR) determination that EPA may use to communicate that all or a portion of a Superfund site is protective for specified types of uses.1 RfR determinations are intended to provide helpful information to the real estate marketplace about the environmental status of Superfund sites to facilitate their reuse. RfR determinations are technical documents that do not provide any legal rights or legally enforceable commitments, and do not include any statements about EPA's enforcement intentions or any party's potential liability regarding a specific site. The issuance of RfR determinations is not mandatory - EPA Regions have discretion in deciding whether to issue RfR determinations, and should balance the potential value of a RfR determination in supporting site reuse with the work involved, considering other program priorities and the availability of resources. Purpose The purpose of this guidance is to provide information to EPA Regional and Headquarters staff on the use and preparation of RfR determinations at Superfund sites. When EPA decides to prepare a RfR determination to facilitate reuse, this guidance will assist the Region in determining what information is sufficient to support the RfR decision and how to document the RfR determination. Attachments 1 and 2 to this guidance provide an outline and model language, respectively, to use when preparing RfR determinations. This guidance is not a regulation itself, nor does it change or substitute for any regulations. Thus, it does not impose legally binding requirements on EPA, States, or the regulated community. This guidance does not confer legal rights or impose legal obligations upon any member of the public. Interested parties are free to raise questions and objections about the substance of this guidance and the appropriateness of the application of this guidance in a particular situation. EPA and other decision makers retain the discretion to adopt approaches on a case-by-case basis that differ from those described in this guidance or not to issue a RfR determination at a particular site. Readers please note that the use of the word "should" in this document means that something is suggested or recommended, but not required. 1 As part of its Land Revitalization Agenda, EPA has adopted the Ready for Reuse (RfR) determination as a tool for facilitating reuse of cleaned up sites. EPA also intends to develop One Cleanup Program RfR determination procedures to ensure a consistent application of RfR determinations across cleanup programs and to distinguish RfR determinations from other cleanup determinations. For additional information about EPA's Land Revitalization Agenda, please see www.epa.gov/swerrims/landrevitalization. EPA issued its first Superfund RfR determination at the Tex Tin Superfund site, Operable Unit No. 2, on July 1, 2003, a copy of which can be viewed at http://www.epa.gov/superfund/ programs/recvcle/reuse/index.htm. ------- Background In some instances, Superfund sites have been difficult to market and return to productive reuse. In some cases information about the sites is lacking; while in others the available information is difficult for the real estate marketplace to interpret. Many properties that now present low environmental risks are stigmatized because they are or were part of Superfund sites. The RfR determination is intended to aid the real estate marketplace by making an affirmative statement that a site identified as "ready for reuse" will remain protective of human health and the environment, as long as all required response conditions and use limitations identified in the site's response decision documents and land title documents continue to be met. The RfR determination can further aid the real estate marketplace by providing documentation, written in plain English, to support EPA's determination that the site conditions are ready for specified appropriate types of uses. RfR determinations will communicate information that, where appropriate, will support both public (e.g., ecological, recreational, governmental) and private (e.g., industrial, commercial, residential) reuse. It is in the public's interest to make the best possible information available to the real estate marketplace for these sites for two key reasons. First, it is EPA's mission to protect human health and the environment, which includes protecting future users of sites. By restating decision document requirements in an easily understood fashion for operation and maintenance (O&M) of a response and institutional controls (ICs), RfR determinations can be used to communicate any land use limitations or land use restrictions on the site, helping to ensure that the response remains protective. Second, RfR determinations give the public notice of the status of EPA's cleanups. Starting in FY 2004, EPA will implement a new Superfund performance measure pursuant to the Government Performance and Results Act (GPRA) that modifies the routine Superfund pipeline process to include an evaluation of whether there are any sites or portions of sites in which the land is ready for reuse. These GPRA-based evaluations are different from and independent of the RfR determinations that are the subject of this guidance. EPA expects to make a GPRA-based evaluation at a site at the same time that the response decision documents for the site are prepared. The results of this GPRA-based evaluation will be documented in CERCLIS after completing the "Checklist for Documenting Ready for Reuse Evaluations" (see Attachment 3). RfR determinations are related to this new GPRA performance measure only in the sense that EPA Regions have flexibility in deciding whether to turn information used during the GPRA-based evaluation into a stand-alone RfR determination consistent with this guidance. While the ready for reuse evaluation is a necessary activity for meeting the GPRA performance measure, preparing RfR determinations is discretionary. II. Definition The RfR determination is an environmental status report that documents a technical determination by EPA, in consultation with States, Tribes, and local governments, that all or a portion of a real estate property can support specified types of uses and remain protective of human health and the environment, based upon the exposure scenarios evaluated for the site.2 The RfR determination should communicate the cleanup status of the property and provide a summary of EPA's knowledge about the environmental conditions of the site or portion of the site as of a specified date. The RfR determination should also clearly state that the determination that all or a portion of the site is protective for specified types of uses is based upon the 2 RfR determinations in no way affect CERCLA's requirements that remedies must be protective of human health and the environment and comply with ARARs unless a waiver is justified. (See 40 CFR 300.430). ------- information then in EPA's possession. Thus, the public should be cautioned that the RfR determination is accurate at the time issued, but may not be if the site's conditions change or if new or additional information is discovered regarding the contamination or conditions at the site. See page 6 below for additional discussion of changed circumstances. The RfR determination does not prohibit any use of property; instead, it states that EPA has determined that the site's conditions, including restrictions, are protective for specified types of uses. The actual selection and determination of the land use for the site remains as a decision within the jurisdiction of the local government. Whether conditions at a site are protective for additional types of uses beyond those specified in the RfR determination may have to be determined by additional evaluations. RfR determinations are intended to complement Superfund cleanup decisions (e.g., deletion, construction completion), and cannot be used in any way to address CERCLA enforcement, liability, or other legal matters3 and does not replace or substitute for decision documents required by the National Contingency Plan (NCP)4. III. Guidance Applicability RfR determinations can be issued for proposed and final NPL sites, non-time critical removal action sites5, and Superfund Alternative sites. Although Federal facilities have certain statutory requirements to transfer property (which are further elaborated on in implementing regulations and policy and guidance documents to foster reuse) site managers at Federal facilities may use this guidance if they find it appropriate.6 While RfR determinations could be appropriate for groundwater or surface waters in the future, this document only addresses the reuse of land. A RfR determination may be issued for all or a portion of any Superfund site where EPA has sufficient information through assessment and/or response actions to evaluate specific exposure scenarios to determine what is a protective reuse of the site. A RfR determination should not be issued prior to a Record of Decision (ROD) or other response decision document, which gives the public notice of the exposure pathways and risks evaluated for the site. However, when the site investigation leads to the conclusion that a portion of the land that can be segregated is not contaminated and should be removed from the description of the site, a RfR determination may be appropriate. 3 Please see www.epa.gov/enforcement/superfund for a link to EPA policies and guidances that address enforcement and liability matters at Superfund sites. 4 National Contingency Plan, 40 C.F.R. 300. This Guidance is generally not appropriate for use at time-critical removal sites because typically time-critical removals are carried out to address immediate threats and do not necessarily generate the type or amount of information sufficient to make use determinations, and may not involve public notice or comment. 6 Examples of other tools that Federal facilities can use to foster reuse of Federal real property may be found in: EPA Guidance on the Transfer of Federal Property by Deed Before all Necessary Remedial Action has Been Taken Pursuant to CERCLA Section 120(h)(3), June 16, 1998. See CERCLA § 120(h)(3),(4) for Federal Facility specific real property transfer requirements. See http://www.epa.gov/swerffrr/documents/earlytrans.htm for EPA's Federal Facilities Restoration and Reuse web site for their guidances and policies. GSA also has certain requirements for the disposition of federal property. See www.gsa.gov. The Brooks Air Force Base, San Antonio, Texas had minimal contamination and a RfR determination (signed on July 22, 2002) was used when the property was transferred. ------- A RfR determination should not be issued at a Superfund site until the specified property meets CERCLA standards of protectiveness. A RfR determination maybe issued when the site meets CERCLA standards of protectiveness and EPA is not aware of any potential circumstances or any EPA or state or local government environmental restrictions that would make the site conditions not protective for the specified types of uses. For example, if the Superfund investigation showed no need for a Superfund response action, but identified a leaking underground storage tank with apparent petroleum product, a RfR determination should not be issued unless the tank problem is addressed. A RfR determination may also be issued when property has been remediated and all physical requirements in the response decision documents have been fully implemented (e.g., the site is construction complete and engineering controls and ICs are in place and operating properly) to ensure that the response remains protective. RfR determinations maybe issued either for sites with unrestricted use and exposure or for restricted use sites. The RfR determination should be consistent with the cleanup goals established for the site. If a RfR determination is issued for restricted use site, then it should clearly and precisely specify the types of uses for which the conditions of the property are determined to be protective,7 and any ongoing activities or obligations that are required (e.g., maintenance of a fence or land use controls) or prohibited (e.g., no digging below 18 inches) in EPA decision documents. The RfR determination creates no rights, duties or obligations. The purpose of the RfR determination is to provide a technical declaration that also clearly identifies the scenarios under which the property is and remains ready for use. All requirements or conditions discussed in RfR determinations should refer to requirements or conditions created in other EPA documents (e.g., a ROD or Consent Decree). RfR determinations should not be issued in instances where ICs are required by the ROD or other decision documents and have not been implemented. If the ICs have not been implemented, the site may not be protective for the types of uses that would be specified in a RfR determination. However, there may be limited circumstances where the Region determines that issuing a RfR determination may be appropriate even though all ICs have not been implemented. Specifically, if neither EPA nor the party benefitting from the RfR determination has the authority to implement the ICs or cannot directly influence the party who does, the Region could consider whether all the use limitations required by the ROD, other response decision documents, and land title documents are being met and, therefore, whether it would be appropriate to issue the RfR determination. For example, if a State does not place an enforceable notice in the property deed restricting residential use, then issuance of a RfR determination might serve as a useful information device, similar to an unenforceable deed notice. In such a situation, the RfR determination should declare that, since the required ICs have not yet been fully implemented, the RfR determination remains accurate only as long as all the use limitations required by the ROD, other response decision documents, and land title documents are being met. RfR determinations do not supersede or modify ICs. Therefore, RfR determinations should be consistent with ICs already in place and with any that will be established. 7 Uses should be specified according to the exposure scenarios evaluated in the risk assessment, e.g., specification of "industrial uses" might include only worker and trespasser exposures, but not exposures associated with an on-site day care center. Regions issuing RfR determinations should be prepared to respond to RfR determination recipients' requests for clarification of specific types of uses covered by the RfR determination. ------- IV. Format and Content of RfR Determinations RfR determinations consist of two documents: (1) the RfR Determination Cover Sheet, which provides a summary of EPA's determination (including any requirements or restrictions) and the signatures of EPA and, if possible, state or tribal and local government officials; and (2) the RfR Determination Report, which provides detailed information supporting EPA's determination that the site or portion of the site is protective for certain specified types of uses. Attachment 1 provides a detailed outline of the specific elements of these two documents. To facilitate national consistency, the outline, headings, and model language (see Attachment 2) should be used for all RfR determinations. Additional information that supports the RfR determination may be included, if available. For example, when delineating the boundaries of a site, there should be a geographical description of the site or portion of the site addressed by the RfR determination that allows the public and other stakeholders to understand what portions of the site are specifically addressed. Additional information, such as a map showing the site or portion of a site's boundaries, tax map numbers, or latitude/longitude coordinates, should be included if they are readily available. Each RfR determination should clearly specify the types of uses that a site can support while the response remains protective of human health and the environment, based upon the exposure assumptions evaluated for the site. While EPA decision documents often refer to use categories, such as industrial, commercial, residential, ecological, or recreational, these terms do not have standard definitions, especially in the many zoning laws across the country. Therefore, each RfR determination should, whenever possible, use local land use authority language and definitions and describe the type of uses the site can support, based on the scenarios of the risk assessment. Although the RfR determination is a technical document, it should be written (in plain English) so that it can be readily understood by community representatives and the real estate marketplace. EPA technical, legal, and other terminology and acronyms should be used sparingly and, where used, be fully explained. V. Process Situations When EPA May Issue a RfR Determination There may be several situations in which EPA may decide to prepare a RfR determination. For example, Regions have the flexibility to turn a GPRA-based evaluation (of whether there are any sites or portions of sites in which the land is ready for reuse) into a stand-alone RfR determination. This would be done by taking the information used as part of the GPRA-based evaluation and preparing the RfR Determination Cover Sheet and RfR Determination Report as outlined in Attachment 1. Alternatively, a RfR determination may be created independently from the GPRA-based evaluations. For example, at some sites there may be no pending decision document necessitating a GPRA-based evaluation, although there may be current interest in developing the property. In other instances, EPA may receive a request for a RfR determination but have insufficient information upon which to make the determination and not be scheduled to collect the information in the near future. If the landowner is willing to pay for the investigation, the Region may work with the landowner to conduct the investigation as part of the regular NCP process through an administrative order. ------- Preparing the RfR Determination Generally, the site manager (usually a Remedial Project Manager or On-Scene Coordinator) will be responsible for preparing the RfR determination. The site manager should consult with the Regional enforcement attorney before preparing the RfR determination to ensure there are not unintended consequences on enforcement actions. The Regional Superfund Division Director, after consulting with the Regional enforcement attorney, is responsible for signing the RfR determination. The views of States, Tribes, and local governments regarding the appropriateness of the RfR determination should be solicited and considered as early in the process as possible. Further, States, Tribes, and local governments should be invited to participate in the development and signature of the RfR determination, although State, Tribal, or local government concurrence is not necessary. The site manager should also coordinate with the landowner and/or the person who requested the RfR determination, if not the landowner. Public Notice and Access So long as public notice and comment has occurred in the context of developing the response decision documents supporting the RfR determination, additional notice and comment may not be necessary. Once EPA signs the RfR determination, the document should be given to the landowner and should be made available in the local repository established for the site, as well as online at the EPA Region's web site and at EPA's Superfund Redevelopment Initiative web site, www.epa.gov/superfund/programs/recycle/. Monitoring and Revising RfR Determinations The RfR determination is a technical assessment of the types of uses that a property may support and remain protective of human health and the environment, at a particular time. The public should be cautioned that the RfR determination is accurate at the time it is signed and remains current as long as the conditions and information that formed the basis for the RfR determination remain substantially unchanged. The public should also be made aware that EPA does not expect to maintain an active monitoring program to review the continuing accuracy of RfR determinations. However, when a five-year review is conducted at a site, it should include an evaluation of any RfR determinations that EPA has issued for the site. If EPA becomes aware, either through a five-year review or other information that changed circumstances or additional information may have rendered a RfR determination inaccurate, EPA may, as appropriate, decide to revise a RfR determination but is under no obligation to do so. A revision may, depending on the circumstances, include a retraction of the original RfR determination. For example but without limitation, EPA may revise a RfR determination if: EPA learns that a site or portion of a site covered by a RfR determination presents a risk to human health or the environment (e.g., revised toxicity factors for contaminants of concern) and might require additional action; EPA discovers new information about a site's conditions that may indicate that the response may no longer be protective; or a party fails to maintain ICs, or to meet its responsibilities regarding a site's required O&M and monitoring actions. Mechanisms are established to maintain engineering controls and ICs should be listed in the RfR determination. If a Region plans to revise a RfR determination, it is recommended that the Region inform the landowner and any property occupants of the reasons for doing so. Appropriate stakeholders (i.e., state, tribal, local governments) should be notified of a RfR determination revision and a notice should be made available at the local repository established for the site. As with an original RfR determination, the Region may consult with the landowner, any property occupants, and stakeholders regarding the revised RfR determination. ------- Because the RfR determination addresses a site or portion of a site (and not the owner), a change of ownership does not, by itself, affect the RfR determination. A successor owner might request a new RfR determination, but Regions should generally consider such a request only if there is new or additional information about the environmental status or proposed types of uses of the site. A successor owner typically would obtain a copy of the RfR determination from the prior owner or from the local repository established for the site. VI. Enforcement Considerations The scope of RfR determinations is limited to technical matters, focusing on the protective reuse of sites after a response is in place. Thus, RfR determinations should not include any statements about EPA's enforcement intentions or any party's potential liability regarding a specific site. EPA Regions can take a number of steps to ensure that RfR determinations remain distinctly technical and are not misunderstood to be providing legally enforceable commitments or addressing any party's legal rights. The Regional attorney responsible for enforcement matters at the site should review the RfR determination to ensure that explicit and implicit assurances regarding liability are not provided. RfR determinations should not be used as, nor combined in the same document with, a comfort/status letter or with any document that provides explicit liability/legal assurances. In addition, RfR determinations should avoid references to statutory or regulatory liability or enforcement provisions. For example, RfR determinations should omit any reference to the statutory liability or enforcement provisions provided in the Brownfields Amendments to CERCLA.8 Such reference in that instance could have the unintended consequence of creating an implicit assurance that a person has taken "reasonable steps" or made "all appropriate inquiry" and thus satisfied one of the conditions for a liability exemption. RfR determinations will not address these issues because they reflect only the environmental status of the property; not activities taken by individuals. Both the RfR Determination Cover Sheet and the RfR Determination Report should include explicit disclaimers making it clear that the RfR determination addresses technical matters only and that it should not be construed as a statement about EPA's enforcement intentions or that it conveys legal rights (see Attachment 2 for model language). In addition, the RfR Determination Cover Sheet should explicitly refer to the attached RfR Determination Report, thus assuring that the RfR determination is fully understood. EPA should not characterize RfR determinations as "certificates." The term "certificate" connotes a "warranty" and could imply that the RfR determination is extending legal rights to the recipient. In addition, the term "certificate" could easily be confused in the real estate marketplace with a State voluntary cleanup program "certificate" that typically includes a release from liability under State law. RfR determinations do not supersede or modify local, county, and State land use decisions and requirements and/or title documents, including, but not limited to, easements, restrictions, and ICs. Thus, RfR determinations should be consistent with and not appear to supersede applicable local land use decisions and requirements. RfR determinations are also not a substitute for compliance with the response decision documents as they relate to local land use requirements (e.g., recording deed restrictions). In addition, RfR 8 The Small Business Liability Relief and Brownfields Revitalization Act, Public Law No. 107-118 (Jan. 11, 2002). ------- determination should focus on the types of uses that sites will be protective for, rather than determine or suggest that certain uses of property are "allowed" or "disallowed." Such land use decisions remain a local government determination and these are not intended to cross into land use type of decisions. Regional enforcement attorneys should ensure that the RfR Determination Cover Sheet and RfR Determination Report identify the entity responsible for ensuring that the site remains protective of human health and the environment. This includes identifying the entity responsible for the implementation, maintenance, monitoring, and integrity of ICs required by the response decision documents, even if the ownership of the property is transferred in the future. Regional enforcement attorneys should ensure that the RfR determination is consistent with any ICs required by the response decision documents. Finally, as stated above (see "Preparing the RfR Determination"), the site manager should consult with the Regional enforcement attorney before preparing the RfR determination to ensure that there are not unintended consequences on enforcement actions. For example, EPA generally should not provide RfR determinations on properties subject to CERCLA liens unless EPA and the property owner have agreed to a plan for resolution. ------- Attachment 1. Outline for Ready for Reuse Determination Documents RfR Determination Cover Sheet Key Elements RfR Cover Sheet Description of the site or portion of the site (be explicit if addressing specific OU) Purpose (see Attachment 2 for model language) EPA and State/Tribal/Local signatures and date Applicable local land use regulations Reference back to RfR Determination Report Institutional controls and engineering controls Operation and maintenance and monitoring actions Entity responsible for ensuring protectiveness of site RfR Determination Report Key Elements Executive Summary Description of the site or portion of the site (be explicit if addressing specific OU) Purpose (see Attachment 2 for model language) EPA signature and date State/Tribal/Local signatures (optional) How to obtain relevant documents EPA and State/Tribal/Local point of contact Location of Site or Portion of Site Geographic descriptors (preferred: maps delineating site boundaries, tax map numbers, latitude/longitude coordinates, survey of land parcel) Site Summary (brief) Site and contaminant history Summary of cleanup activities Redevelopment/reuse history Time line of EPA activities to date (optional) EPA's Basis for the Determination Description of risks associated with specified types of uses, related to risk based action levels (e.g., exposure pathways, contaminants) List of primary documents used to determine site's suitability for reuse Inclusion of documents as an appendix Ongoing Limitations and Responsibilities Institutional controls and engineering controls Operation and maintenance and monitoring actions Entity responsible for ensuring protectiveness of site Applicable local land use regulations ------- Attachment 2. Model Language for RfR Determinations Model Purpose Language: This Ready for Reuse Determination provides that EPA has made a technical determination that the [ABC Site] located in [City, County, State] is ready for reuse and will remain protective of human health and the environment, subject to any limitations identified in the ROD, other response decision documents, the land title documents, and below regarding the use of the site and the activities that must be performed to ensure the continued protectiveness of the site: • [uses supported, use restrictions] • [summary of required activities, e.g., ICs, O&M, monitoring, etc. and entity responsible for ensuring protectiveness] This Ready for Reuse Determination is a technical decision document and does not have any legally binding effect and does not expressly or implicitly create, expand, or limit any legal rights, obligations, responsibilities, expectations, or benefits of any party. EPA assumes no responsibility for reuse activities and/or any potential harm that might result from reuse activities. EPA retains any and all rights and authorities it has, including but not limited to legal, equitable, or administrative rights. EPA specifically retains any and all rights and authorities it has to conduct, direct, oversee, and/or require environmental response actions in connection with the site, including but not limited to instances when new or additional information has been discovered regarding the contamination or conditions at the site that indicates that the response and/or the conditions at the site are no longer protective of human health or the environment for the types of uses identified in the Ready for Reuse determination. The types of uses identified as protective in this RfR determination remain subject to (i) applicable federal, state, and local regulation, including, but not limited to, zoning ordinances and building codes, and to (ii) title documents, including, but not limited to, easements, restrictions, and institutional controls. Model Executive Summary Language: For unrestricted use sites: In [ month, year], EPA [State, Tribe, PRP] conducted an investigation of the site [site or portion of a site, OU]. During that investigation, EPA [State, Tribe, PRP] evaluated [media]. As a result of the investigation, EPA determined in its decision document that Superfund response actions were unnecessary, and is not aware of any potential circumstances or any EPA, State or local government restrictions for this site [site or portion of a site, OU] that would make the site conditions not be protective for the designated land uses in this document. For restricted use sites: During EPA's [State's, Tribe's] investigation in [month, year] of the site [site or portion of a site, OU], EPA [State, Tribe, PRP] performed an assessment of the human and environmental risks associated with using the site for [land use] purposes. The risks that were identified for this site [site or portion of a site, OU] were [human, environmental] exposure to [primary contaminants of concern] through [media]. In its [decision document], EPA selected response actions to [manage, eliminate] these risks to human health and the environment. With the completion of these response actions, EPA [State, Tribe, PRP] has attained the CERCLA cleanup goals and remedial action objectives for the site [site or portion of a site, OU]. As a result, based on information available as of this date, EPA has determined that the unacceptable levels of risk to current and future users of the site have been abated and the site may be used for [type of land use] purposes and will remain protective of human health and the environment. ------- Attachment 3. Checklist for Documenting Ready-for-Reuse Evaluations for the Superfund Reuse Performance Measure SITE NAME: SITE ADDRESS (street, city, state, zip): EPA ID: SITE ID: 1. Indicate the total acres of land on the site that is ready for reuse: 2. The site, or portion of the site, is ready for: Q Unrestricted use (i.e., the site or portion of the site can support residential reuse). Q Restricted use (i.e., the site, or portion of the site, cannot support residential use). Q Both (i.e., a portion of the site can support residential use and another portion of the site cannot support residential use). 3. The site, or portion of the site, is ready for reuse because: Q Superfund response actions are unnecessary based on an assessment of the site and EPA is not currently aware of other EPA, state, or local environmental or land use restrictions. Q Cleanup goals for the land have been attained. ------- 4. What is the source of information used to support the finding that all or a portion of this site is ready for reuse? Q Preliminary Assessment Report Q Site Inspection Report Q Record of Decision (ROD) Q Interim/Final RA Report Q Preliminary Close-Out Report Q Final OSC Report (for removals) Q Notice of Deletion/Partial Deletion Q Five-Year Review Q Findings of Suitability to Lease (FOSL) Q Finding of Suitability to Transfer (POST) Q Finding of Suitability for Early Transfer (FOSET) Q Final Ready-for-Reuse Determination 5. What is the source of information used to determine the acreage that is ready for reuse? Q Information from an EPA document (e.g., ROD, RI Report) Q Official State or Local Government Document Q Information from Property Owner Q Land Survey Q Newspaper/Media Report Q Best Professional Judgment Q Other (specify): 6. Is the entire site or a portion(s) of the site ready for reuse? Q Entire Site Q Portion(s) of Site 7. Which operable unit(s) contain land that is ready for reuse? Please indicate OU number(s): ------- 8. Provide a brief geographic description of the site or portion(s) of the site that is ready for reuse. ------- |