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A Cleanup, is a Cleanup, is a Cleanup …

28 Jun 2018 4:03 PM | Anonymous member (Administrator)

By Stephen Merrill Smith, Esq.

NSCW attendees were provided the USEPA Venn diagram, the “Universe of Contaminated Sites” as a tool to understand the different types of sites and  their magnitude in the contaminated sites universe of NPL sites, LUSTs, CAMUs, SMUs, and AOCs. 


USEPA doesn’t give brownfield funding money to RCRA and CERCLA remedial sites.  But, USEPA realizes the great economic benefits of redeveloping sites and putting them into beneficial reuse. Moreover, the Build Act of 2018 amended the Brownfields law and added more money to get sites into reuse.

The Superfund Task Force, which NSCW speakers Charles Howland of USEPA and Colleen Kokas of Environmental Liability Transfer participate on and have spoken about and written about for BCONE, is encouraging redevelopment.  

Gloria Sosa of USEPA Region 2 noted that there are many different parties interested in redeveloping sites. Unlike brownfields, with Superfund the timeline is of utmost importance because by the time the Reasonable Anticipated Future Use (RAFU) decision is made, one cannot go back and change the remedy for changes in redevelopment use. The Record of Decision (ROD) is a point at which the RAFU is considered.

Elizabeth Barton, Esq. of Day Pitney emphasized practical aspect: she said that from the trenches, cooperation is priceless, not just state and federal, but also between agencies and even within agencies. Without cooperation, you end up like a” ping pong ball going between floors to get a project done.”  Beth also reminded the group that last year New York State overhauled its waste management regulations  to enhance availability of beneficial reuse with regard to clean fill use on sites. One of the benefits of this is the finality that comes with fill that meets the health standards and then is no longer considered solid waste. 

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