Several questions have been raised regarding the requirement for a draft Analysis of Brownfields Cleanup Alternatives (ABCA) required to be submitted with a cleanup grant proposal. The attached Content and Background document [SEE BELOW] is presented as supplemental information for the Webinar material. Applicants are not required to use this format, but it may be useful in preparing a Cleanup proposal. Specific information on the ABCA requirement is also contained in Item #71 of the FAQ document released with the Request for Proposals.
Also, under a grant from EPA, Kansas State University (KSU) has
developed a software tool that can assist communities who are applying for grants under EPA's Fiscal Year 2012 Brownfields Assessment, Revolving Loan Fund and Cleanup (ARC) grant competition. TAB EZ was developed by KSU and CABEM Technologies, Inc. as a public service. TAB EZ is available free of cost to everyone nationwide. TAB EZ is not a substitute for reading the guidelines.
TAB EZ is available at http://www.tabez.org/
Lastly, for communities or non-profit organizations intending to apply for cleanup or site-specific assessment grants, we urge you to pay careful attention to site eligibility requirements for both hazardous substance properties and petroleum properties (or both). We have had many questions on qualification for BFPP Status (Bona Fide Prospective Purchaser), and the requirement that there not be a viable responsible party for petroleum grants. We urge you to read the Grant Guidelines carefully for these two items before attempting to prepare and submit a
grant proposal.
-------------------------------------------------------------
Analysis of Brownfields Cleanup Alternatives (ABCA)
Content
I. Introduction & Background
a. Site Location (address)
b. Previous Site Use(s) and any previous cleanup/remediation
c. Site Assessment Findings (briefly
summarize the environmental investigations that have occurred at the site,
including what the Phase I and Phase II assessment reports revealed in terms of
contamination present, if applicable)
d. Project Goal (site reuse
plan)
II. Applicable Regulations and Cleanup Standards
a. Cleanup Oversight Responsibility (identify the entity, if any, that will oversee the cleanup, e.g., the state, Licensed Site Professional,
other required certified professional)
b. Cleanup Standards for major contaminants (briefly summarize the standard for cleanup
e.g., specify state standards for residential or industrial reuse)
c. Laws & Regulations Applicable to the Cleanup (briefly summarize any federal, state, and local laws and
regulations that apply to the cleanup)
III. Evaluation of Cleanup Alternatives
a. Cleanup Alternatives Considered (minimum two different alternatives plus No Action)
b. Cost Estimate of
Cleanup Alternatives (brief discussion of the effectiveness,
implementability
and a preliminary cost estimate for each alternative)
c. Recommended Cleanup Alternative
Background
The ABCA must be available, along with the proposal, for
public comment at least two weeks prior to submission to EPA. Please see
Section III.C.6. of the 2012 Cleanup Proposal Guidelines for more details. The
information should be derived from the response to the Project Description
criterion.
The ABCA is intended as a brief preliminary document.
As part of the Threshold review, Cleanup proposals will be checked to
ensure the ABCA is attached. EPA will
not perform a detailed review of the ABCA, and state review is not needed. The
content of the ABCA will not be scored as part of the Ranking process. If the proposal is selected for funding,
applicants will be required to finalize the ABCA as a part of their pre-cleanup
activities.
The pre-proposal ABCA requirement
is intended to allow additional public review “prior to EPA funding” consistent
with national environmental and grant-funding policies.
EPA
Region 4, 10/19/2011