I have been distressed at the limited description provided by the EPA for a RCRA brownfield. It always seems to involve the cleanup of a property prior to sale or redevelopment. A RCRA brownfield is no different from any other site that has been remediated and sold—it is the sale of a cleaned site and nothing more. To me, a true brownfield is not a site which is remediated, but a contaminated site that is controlled during redevelopment which allows for re-use. A RCRA brownfield should be a site that is actively undergoing cleanup and in pursuit of completion of its post-closure permit, while in use by subsequent owners.

One such site is an electronics manufacturing facility in North Charleston, S.C., which ended manufacturing operations while still remediating a large chlorinated solvent plume. The site is regulated under a RCRA Part B Post-Closure permit, which was effectively preventing the property’s sale because the state required prospective buyers to sign the RCRA permit. Thus, the state could seize the land as an asset to fund remediation if the Responsible Party attempted to stop cleanup activities. ...

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