Brownfield Assessment/Environmental Site Assessment
The “Brownfield Assessment Application” form (780-1955) is available online at http://www.dnr.mo.gov/forms/780-1955-f.pdf
What are brownfields?
The term brownfield means real property, the expansion, redevelopment or reuse of which is complicated by the presence, potential presence or perceived presence of a hazardous substance, pollutant, or contaminant.
Why are environmental site assessments important?
Environmental site assessments determine if contamination is present, and to some degree, the extent of the contamination present at a property. The assessment provides answers to many of the questions regarding potential cleanup costs and environmental liability associated with brownfield properties. Potential buyers of a brownfield may reduce their liability if the appropriate environmental site assessments are performed prior to purchase. An environmental site assessment conducted in a manner to meet the requirements of an all appropriate inquiry (AAI) gives the purchaser certain protections from liability under the federal Superfund Law.
What is all appropriate Inquiry?
All appropriate Inquiry, or AAI, is a process of evaluating a property’s environmental conditions and assessing potential liability for any contamination. Participants who receive EPA grant funding to assess brownfield properties must comply with the AAI standards. A phase I environmental site assessment (ESA) conducted according to the ASTM International, standard 1527-13 satisfies the AAI requirement.
What type of information is collected during the inquiry and phase I
The following information is collected during the phase I assessment:
- Records review - All state and federal environmental records will be reviewed to identify any contaminated sites in the vicinity of the property.
- Physical setting - This review will include identification of all physical characteristics of the property including geologic and topographic conditions.
- Property uses - All historic uses of the property and adjacent properties will be identified and all recorded land and title information will be collected back to original development or 1940 whichever is earlier
- Site reconnaissance - The property and adjacent properties will be observed visually and physically. All evidence of current and historical facilities and uses will be documented.
- Interviews - Owners and occupants or adjacent property owners and occupants will be interviewed to obtain information about the recognized environmental conditions in connection with the property.
- Historical sources such as chain of title documents, aerial photographs, building department records and land use records will be reviewed to determine previous ownership, uses and occupancy since first development.
- Data gaps will be identified and documented when usage information is not available.
The goal of the phase I assessment is to identify recognized environmental conditions that may be further investigated in the phase II assessment. A recognized environmental condition is defined by ASTM International 1527-13 as the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, ground water or surface water of the property. If the phase I assessment does not identify any recognized environmental conditions, a phase II assessment is not needed. If a phase I assessment identifies any recognized environmental conditions, a phase II assessment may be conducted.
What types of sampling may be conducted during the phase II
The following media may be sampled during a phase II assessment:
- Surface water
- Drums and other containers
- Building materials (e.g., asbestos and lead paint)
How does an eligible entity receive brownfields site-specific
assessment assistance from the department?
An eligible entity (city, county, quasi-governmental or non-profit) would fill out the “Brownfields Assessment Application” along with the consent for access agreement signed by the property owner and submit both to the program. After the application process is complete, the department would hire an environmental contractor to provide a proposal for an assessment. The “Brownfield Assessment Application” form (780-1955) is available online at http://www.dnr.mo.gov/forms/780-1955-f.pdf
Why is redevelopment of brownfields
Redevelopment of brownfields potentially benefits the environment, the community and industry by:
- Preserving undeveloped greenspace
- Cleaning up contaminated properties, thereby mitigating potential health risks
- Returning properties to tax rolls
- Creating employment opportunities
- Removing blight/rejuvenating dilapidated areas
What type of report is generated by the department?
The department’s contractors will complete a phase I assessment report in compliance with ASTM International 1527-13 standards to include, at a minimum, the following sections:
- Property description
- Property history
- Soil characteristics, geology and hydrogeology
- Property reconnaissance and sampling
- Analytical results
What if contamination is found on the property?
Should the assessment reveal contamination on the property, the department will contact the applicant to discuss the following options:
- Possible participation in the department’s Brownfields/Voluntary Cleanup Program where the applicant can pursue cleanup if necessary prior to redevelopment and can receive a certificate of completion letter for the property
- Cleanup standards, goals and technologies
- Available funding mechanisms
- Redevelopment suitability regarding environmental issues (e.g., land use restrictions, non-residential or residential redevelopment)
For more information
If you are interested in requesting a brownfields site-specific assessment on your property or a property you are considering purchasing contact the department at:
Missouri Department of Natural Resources
Hazardous Waste Program
Brownfields/Voluntary Cleanup Program
P.O. Box 176
Jefferson City, MO 65102-0176
800-361-4827 or 573-526-8913