The purpose of this step is to evaluate the potential for contamination at a particular site by collecting and reviewing existing information. The site assessment, typically referred to as an ASTM Phase I environmental site assessment, is an initial investigation usually limited to a search of historical records. The data collected also includes information about past and current environmental conditions and historical uses of the site. The site assessment is the most crucial step in the brownfields process, because any further environmental investigation and cleanup will hinge on whether potential environmental concerns are identified during that phase.

During the site assessment phase, it is important to consider the activities and requirements described in the subsequent chapters and determine how they will be affected by the initial site assessment. Because the information obtained in this phase will determine whether any future work must be done at the site, the site assessment must be thorough and tailored to meet specific data objectives. As discussed in the section Before You Begin, decisions made about the end use of a site and the long-term goals of the brownfields project will determine the types and quantity of data that must be collected, as well as the level of quality the data must attain. The data quality objectives (DQO), in turn, will serve as the basis upon which the best decisions will be made about the most appropriate technologies and techniques to be used in collecting and analyzing the data at a particular site (see the List of Acronyms and the Glossary of Key Terms, for a definition of DQO).

The Triad approach is applicable to many elements of monitoring and measurement activities that occur on site - from early investigations aimed at risk estimation, through designing, implementing, and monitoring the implementation of a remedy. The key to the Triad approach, and the benefit to brownfields sites, is that decisions are made with the full consideration of existing information developed during past site use and cleanup activities, and with a thorough understanding of how the site might be reused. Using this approach, activities are performed that target the principal sources of uncertainty that can affect the confidence of site decisions. Use of the Triad approach for site assessments at brownfields sites allows decision-makers to economically collect the volume and quality of data necessary to reassure regulators and communities that a property is safe for reuse.

The data collected during this initial step of the cleanup process is extremely 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 up to the level necessary for its intended reuse. If it is carefully planned, some of the follow-on work, such as limited sampling, may also be accomplished during this phase. The site assessment also can provide a preliminary indication of what types of cleanup technologies might be available. It also is essential to assess and address the needs and concerns of the community (for example, the development of social and economic profiles and the identification of acceptable environmental risk).

Technologies that detect possible contamination in the air may be applicable at this stage as well as some analytical sampling technologies useful for assessing contamination in soil or groundwater. Examples of sampling and analysis technologies that may be applicable during this phase are presented in Table A-2, Technologies for Analyzing Contaminants at Brownfields Sites. However, the use of technologies may be somewhat limited, since much of the work at this stage involves a search of paper and electronic records.

The following section is intended as a general planning guide and is not a comprehensive listing of assessment activities required under state and federal regulations. For a better understanding of these requirements, users should consult the references identified and work with their appropriate regulatory authority.

Factors that should be considered during this phase include:

1. Has a redevelopment plan been prepared or a proposed end use identified? Is the site located in an area targeted for redevelopment? Is the site located in an industrial area? Will it remain industrial or be rezoned for commercial use? Is a residential development planned? Will community members who use the property be exposed directly to the soil or sediment?
2. What data are needed to support the long-term goals of the project, address concerns related to it, and ensure its acceptability? What decisions need to be made, and what data should be collected to support those decisions? What level of quality is necessary and what level of uncertainty is acceptable to meet those goals?
3. 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 information is needed to identify the types and extent or the absence of contamination?
4. If the site is located in an area targeted for redevelopment, is the site being considered for cleanup under a federal or state Superfund cleanup initiative?
5. Will the site be entered into a Voluntary Cleanup Program (VCP)? If not, what agency (federal, state, local, or tribal) would be responsible for managing oversight of cleanup? Are there other federal, state, local, or tribal regulatory requirements for site assessment? (See the definition of a VCP in the List of Acronyms and the Glossary of Key Terms)
6. What are the special needs and concerns of the community? How can community involvement be encouraged and meaningful? How will community views be solicited?
7. What environmental conditions will the community find acceptable? What environmental standards should be considered to ensure that community stakeholders are satisfied with the outcome of the cleanup, in light of the identified and proposed reuse?
8. If the site shows evidence of contamination, who and what will be affected? Who will pay for the cleanup? Who will be responsible for long-term monitoring and oversight, particularly if residual contamination is left in place?

The following box depicts the linkages among the decisions to be made, the data to be collected, and the selection of technologies to expedite the collection of data.

Linking the Decision, Data, and Technologies 1. WHAT NEEDS TO BE DONE? Determine: What you are trying to accomplish at the site - redevelopment, cleanup, etc. 2. WHAT DECISIONS ARE NEEDED TO SUPPORT SITE GOALS? Determine: Are contaminant levels above or below acceptable limits to a specified degree of certainty? 3. WHAT INFORMATION DO I NEED TO MAKE THE DECISION? Identify: Data or information necessary to make the decision(s) or answer the question(s) Consider: Level of data quality required (detection limits and accuracy) 4. HOW SHOULD I COLLECT THE DATA? Evaluate & Select: Various sampling and analysis designs to achieve required data and data quality Consider: Technologies available to provide more data quickly and cost-effectively at a level of quality required by decisions 5. WHAT DOES THE DATA TELL ME? Evaluate/Interpret Data: Can decision(s) be made? Can question(s) be answered? If you can answer "Yes" to both questions, go to step 6. Otherwise, return to step 3. 6. TAKE APPROPRIATE ACTION Based on the decision made or question answered.

Activities to be conducted during the initial survey of a site include:

• Establish the technical team and take advantage of the team’s expertise to determine the adequacy of existing site information and identify potential data gaps
• Ensure that the brownfields decision-makers (such as regulators; citizens; property owners; and technical staff, such as chemists and toxicologists) are involved in the decision-making process
• Develop the conceptual site model (CSM). The CSM is the planning tool that organizes existing site information, provides a framework to identify project goals and data gaps, and directs site activities and team communications.
• Identify future plans for reuse and redevelopment and goals of the site
• Identify data that must be collected to support the goals of the site
• Determine whether contamination is likely through the conduct of an ASTM Phase I environmental site assessment or its equivalent. A records search is performed and the site is visited, but no sampling of soil or groundwater occurs. The effort includes the following activities:
  • Identify past owners and the uses they made of the property by conducting a title search and reviewing tax documents, sewer maps, aerial photographs, and fire, policy, and health department documentation related to the property
  • Review and analyze city 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, but are not limited to: (1) EPA’s Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) of potentially contaminated sites, (2) the National Pollutant Discharge Elimination System (NPDES) of permits issued for discharges into surface water, and (3) 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, such as previous employees, residents, 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-based paint, asbestos, and radon in structures

  The practice of conducting site assessments, or all appropriate inquiries, is intended to satisfy one requirement for obtaining protection from CERCLA liability. To obtain protection from CERCLA liability as a bona fide prospective purchaser, an innocent landowner, or a contiguous property owner; prospective property owners must conduct all appropriate inquiries, or a phase I site assessment, prior to acquiring a property. The Brownfields Law requires EPA to promulgate federal standards and practices governing the conduct of all appropriate inquiries. The Law also established interim standards for conducting “all appropriate inquiry” to determine the environmental condition of a property prior to its acquisition. The interim standard for properties purchased after May 31, 1997, which remains in place until EPA promulgates a final rule establishing federal standards for all appropriate inquiries, is the ASTM E1527-97 or ASTM E1527-00, entitled “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process.” Spotlight 3, All Appropriate Inquiry: Standards and Practices to Provide CERCLA Liability Protections provides additional information on the requirements for all appropriate inquiries.

• Review the applicability of government oversight programs:
  • Determine whether there is a state VCP and consult with the appropriate federal, state, local, and tribal regulatory agencies to include them in the decision-making process as early as possible
  • Determine the approach (such as redevelopment programs, the Superfund program, property transfer laws, or a state Brownfields Program) that is required or available to facilitate the cleanup of sites (see the section, Before You Begin, for an overview of applicable regulations and regulatory guidelines)
  • Identify whether economic incentives, such as benefits from state Brownfields Programs, or federal brownfields tax credits, can be obtained
  • Contact the EPA regional brownfields coordinator to identify and determine the availability of EPA support programs and federal financial incentives
• Determine how to incorporate and encourage community participation:
  • Identify regulatory requirements for public involvement (see Hazardous Substance Research Centers under Information Centers, Training, and Other Resources for a description of community services provided by HSRCs)
  • Assess community interest in the project
  • Identify community-based organizations
  • Review any community plans for 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 —include potential cleanup options and constraints that may affect redevelopment, such as project schedules, cost, and potential for achieving the desired reuse
• Conduct work at the site and collect data as necessary to define site conditions or to resolve uncertainties related to the site

Show all resources as one list

Examples of technology resources that are available to assist in assessing a site are listed below. Although many of the resources are more applicable in later stages, it may be useful to begin thinking now about options and tools for investigation and cleanup.

A. Resources for Site Assessment

The documents listed below are resources that provide general information about the availability of technology resources in the form of bibliographies, status reports, and user guidelines.

B. Site-Specific Resources for Site Assessment

Listed below are survey reports and online tools pertaining to the application of innovative technologies to specific contaminants and site types.

C. Technology-Specific Resources for Site Assessment

The documents listed below provide detailed information about specific innovative technologies and the application of those processes to specific contaminants and media in the form of engineering analyses, application reports, technology verification and evaluation reports, and technology reviews.

Result of Site Assessment		Course of Action
No evidence of contamination is found and there is no reason to suspect other media are contaminated. Concerns of stakeholders have been addressed adequately.		Discuss results with appropriate regulatory officials before proceeding with redevelopment activities.
Contamination is found that poses a significant risk to human health or the environment.		Contact the appropriate federal, state, local, or tribal government agencies responsible for hazardous waste. Based on feedback of government agency, determine what cleanup levels are required for redevelopment, and proceed to the Site Investigation phase.
Contamination possibly exists.		Proceed to the Site Investigation phase.
Contamination definitely exists, BUT no site investigation has been conducted.		Proceed to the Site Investigation phase.
Contamination definitely exists, AND a site investigation has been performed.		Proceed to the Site Investigation phase if additional investigation is needed; otherwise, proceed to the Cleanup Options phase.