|From:||peter strauss <firstname.lastname@example.org>|
|Date:||Mon, 3 May 1999 18:09:09 -0700 (PDT)|
|Subject:||Definitions - VCPs and Brownfields|
I have had the following dialogue with Kristen Yount and thought that it would be worthwhile to bring it to the attention of the group. Can anyone shed additional light on this subject. Peter Strauss "As a follow-up to Peter Meyer's response, not all voluntary cleanup programs (VCPs) apply to "Brownfield" sites. I have seen many non-brownfield type sites in California where a VCP was entered into. Peter Strauss" "Peter -- I read your cpeo message and I'm puzzled. How could a non-brownfield site enter into a VCP when VCPs are designed only for brownfields? What is your definition of a brownfield?" "Kristen, In California, sites not on the NPL have been allowed to enter into voluntary cleanup programs with the state. Essestially, these VCPs are a lower form of regulatory oversight. I have been personally involved with two in the Bay Area, but I am informed that this is a standard regulatory practice. One site should have been a brownfield site, the other is adjacent to an NPL site. Brownfield can have many meanings: but it is my understanding that it has become a "term of art". That is, it refers to urban, non-NPL sites that could qualify under EPA's general brownfields program. Peter Strauss" "Ah ha. I thought our problem stemmed from definition. I use the EPA's = "A brownfield is a site, or portion thereof, that has actual or perceived contamination and an active potential for redevelopment or reuse." In discussions, EPA reps often clarify that the term brownfields excludes NPL sites and also excludes petroleum product problems. (Also - I believe that most VCPs explicitly exclude NPLs.) Difference in definition is a source of many misunderstandings (e.g., cities will conduct inventories of brownfields but some will define them as ABANDONED sites while others use definitions closer to EPA's). I think the biggest problem with EPA's concept of a brownfield stems from their organizational structure. That is, RCRA projects (that include LUSTs) are handled by one office while CERCLA projects (brownfields) are handled by another. The result is that LUST problems can't be dealt with under assistance provided by the CERCLA folks (e.g., the brownfield cleanup revolving loan fund can't be used to clean LUSTs). An inventory of definitions and discussion about definitional problems would be useful. Unfortunately, I don't have the time (and my guess is, others don't either). Good luck on your work! Kristen"
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