Step 1: Assess The Site
Purpose
Determine the likelihood of contamination at a particular site by collecting and reviewing information about the site.
The collection of data during this step of the cleanup process is important for use in identifying and evaluating the applicability of site assessment and cleanup technologies, as well as in determining whether the property can be cleaned to the level necessary for its intended reuse. It also is essential to assess and address the needs and concerns of the community. The data to be collected includes information about past and current environmental conditions and historical uses of the site.
Questions to Ask
- What is known about the site?
- What records exist that indicate potential contamination and past use of the property?
- Have other environmental actions occurred (such as notices of violation)?
- Has an environmental audit been conducted?
- What level of site assessment is needed to identify the types and extent or the absence of contamination?
- Is the site located in an area targeted for redevelopment?
- Is the site being considered for cleanup under a Federal or State Superfund cleanup initiative?
- Are there Federal, State, Local, or Tribal regulatory requirements for site assessment?
- Is there a voluntary cleanup program (VCP)?
- What agency (Federal, State, Local, or Tribal) would be responsible for managing oversight of cleanup?
- What is the special needs and concerns of the community?
- How can we encourage community involvement?
- How will the community make its views known?
- What environmental conditions will the community accept?
- What environmental conditions are unacceptable or will hinder redevelopment and the planned reuse?
- If the site shows evidence of contamination, who and what will be affected?
- Who will pay for the cleanup?
Steps to Take
- Determine whether contamination is likely. This process is similar to a Phase I site assessment or environmental audit, during which a records search is performed and the site is visited, but no sampling of soil or groundwater occurs.
- Identify past owners and the uses they made of the property.
- Review and analyze government and other historical records to identify past use or disposal of hazardous or other waste materials at the site.
- Review Federal and state lists that identify sites that may have environmental contamination; such lists include.
EPA's Comprehensive Environmental Response, Compensation and Liability Inventory System (CERCLIS) of potentially contaminated sites, the National Pollutant Discharge Elimination System (NPDES) of permits issued for discharges into surface water, and state records of "emergency removal" actions (for example, the removal of leaking drums or the excavation of explosive waste).
- Interview property owners, occupants, and others associated with the site including previous employees, neighbors, and local planners.
- Perform a physical or visual examination of the site, including examination of existing structures for structural integrity and asbestos-containing material.
- Test for the presence of various contaminants (For example -lead paint, polychlorinated biphenyl's (PCB), and radon.
- Review the applicability of government oversight programs.
- Identify and consult with the appropriate state, local, and tribal regulatory agencies to include them in the decision-making process as early as possible.
- Determine the approach (such as the Superfund program, property transfer laws, or Voluntary Clean Up Programs) that is required or available to facilitate the cleanup of sites.
- Identify whether environmental incentives, such as benefits from state Voluntary Clean Up Programs, can be obtained. Iowa's Contact Person.
- Determine whether contamination has been identified previously.
- Contact the EPA regional Brownfields coordinator to identify and determine the availability of EPA support programs. (Iowa is in EPA Region 7.)
- Determine how to incorporate and encourage community participation.
- Identify regulatory requirements.
- Assess community interest in the project.
- Review any community plans for redevelopment.
- Identify future plans for reuse and redevelopment.
- Identify factors that may impede redevelopment and reuse.
- Begin identifying potential sources for funding site investigation and cleanup activities at the site, if necessary.
- Examine unacceptable environmental conditions in terms of initial costs for site improvement and long-term costs for operation and maintenance. This may include potential cleanup options and constraints that may affect redevelopment, such as project schedules, cost, and potential for achieving the desired reuse.
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