Site Assessment

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Environmental Schedule

There can be a number of issues impacting the progress and success of environmental assessment and cleanup activities that are unknown at the start of the revitalization project. Detailed planning and the development of a dynamic, critical path schedule can limit project delays due to environmental activities. The participation of revitalization team members from a variety of areas of expertise will ensure that the environmental schedule is developed in a manner that promotes smooth transition among environmental and revitalization activities.
The sequencing of issues related to specific media (soil or groundwater) may vary based upon priorities. A detailed timeline and schedule for the work should be developed. The schedule should include all major project milestones with a critical path analysis of the impact associated with environmental issues. Some issues to consider include:
  • Environmental Work Plans, Quality Assurance Project Plan (QAPP), Health and Safety Plan (HASP), and Revitalization Plan Preparation, review and approval
  • Permitting approvals
  • Environmental sampling activities, site infrastructure inspection and improvement
  • Report preparation and review
  • Remediation alternative screening, selection, and approval
  • Coordination of environmental activities with other site activities
  • Contingency planning to rapidly address unanticipated conditions. For example, if procedures are in place to address leaking underground storage tanks (USTs) that may be found during development, such findings will not slow the overall schedule.
Contaminated sites may require flexibility and continual adjustment and modification of the team schedule and methodologies. Each step should be justified and defensible from an environmental, regulatory, and financial standpoint, and in keeping with the focus of the planned reuse.
There are several means by which developers can work with environmental regulators to reduce the time to achieve cleanup and reuse of potentially contaminated sites. These include:
  • Using private sector parties to perform oversight roles previously performed by agency staff under a voluntary cleanup program
  • Allowing phased or partial site cleanups (this is the approach often incorporated into state voluntary cleanup programs) as approved by project stakeholders including regulatory agencies
  • Coordinating the permitting process under all applicable regulatory programs
  • Providing for timely participation by the locally affected public in the administrative review process
  • Prioritizing cleanup of conditions that most threaten public health and, if unattended, are most likely to aggravate ultimate cleanup costs
  • Conducting voluntary cleanups in accordance with approved state or local VCPs
  • Incorporating remediation into the revitalization plan
  • Obtaining a “No Further Action” letter or equivalent contingent upon revitalization
  • Modifying the agency review process (local governmental representatives and revitalization coordinators can assist with this)
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