Brownfields Assessment Program

NRPC works in partnership with the EPA and the NH Department of Environmental Services (NHDES) together with our Environmental Consulting Firm, to identify, assess, and characterize sites that are known or believed to be contaminated with hazardous substances or petroleum. The goal of the program is to help facilitate the redevelopment of vacant or underutilized properties by covering the cost of Phase I and Phase II environmental assessments, Phase III Site Investigations (i.e., Additional Characterization), and the development Remedial Action Plans. There is no cost to property owners to participate in the assessment program.

The first step to revitalizing your Brownfields site is is to contact NRPC staff to see if your site has the potential to qualify for the program. If the site appears to meet the criteria, a Site Nomination Form will be completed and sent to EPA for confirmation.

Assessment Program FAQ

In partnership with the EPA, NRPC works to identify, assess and characterize known or potential sites contaminated with hazardous substances or petroleum. The goal of the program is to work with member communities on the identification, assessment, and redevelopment of vacant or underutilized properties. There is no cost to property owners to participate in the assessment program.
The Environmental Protection Agency (EPA) defines a brownfield as a property where the expansion, redevelopment, or reuse may be complicated by the presence or potential presence of petroleum or hazardous substances. It is estimated there are more than 450,000 brownfields in the U.S.
It is difficult to determine the exact number of brownfield sites in the region; however, the number is expected to be over 100. NRPC is currently in the process of developing an Environmental Site Inventory of potential brownfields sites in the Commissions’ region of 13 municipalities.
Brownfield sites are typically abandoned, vacant, or under-used industrial or commercial properties. They can also be junk or salvage yards, gas stations, dry cleaners, warehouses, or auto repair shops. Single family residential properties are generally not considered brownfield properties.
Generally, sites that have a real or perceived environmental concern are eligible to participate. Public or private property may be eligible. NRPC works with its Qualified Environmental Professional (QEP) Credere Associates, and the EPA to confirm eligibility according to EPA criteria. In most cases, the current and immediate past owner cannot be the party responsible for the contamination unless the owner is determined to be financially non-viable.
Since 2004 NRPC has been the recipient of four separate EPA Brownfields Cooperative Agreements
which have enabled us to conduct work on many sites in the region, including Hudson, Merrimack,
Milford, Nashua, and Wilton. Visit our Brownfields Assessments Project Portfolio for specifics on each
project.
If you are interested in participating in the NRPC Brownfields Assessment Program, contact NRPC staff to discuss the property and any redevelopment plans that you may have. If it appears that the property is a fit for the program, NRPC will submit a Site Nomination form to the EPA for approval. If approved, NRPC and our environmental consultant will work with the applicant to undertake a Phase I Site Assessment and any subsequent characterization required. An access agreement must also be signed by the current owner of the property after the site is accepted into the program.
The Brownfields Assessment Program adheres to environmental due diligence procedures utilized for commercial real estate
transactions. The Program covers 100% of the cost of the following tasks:

  1. Phase I Environmental Site Assessment: The purpose of the Phase I Environmental Site Assessment (ESA) is to identify recognized environmental conditions (RECs) which include the presence or likely presence of any hazardous substances or petroleum products at the property. EPA’s “All Appropriate Inquiry” requires an environmental professional complete a thorough site review regarding previous owners and uses of the property. The assessment at a minimum includes; A records review of federal, state, and local databases, and research of the physical settings such as topographic and geological maps and aerial photographs; Site reconnaissance including a site-walk of the property and observation of the vicinity; and Interviews with past and present owners and occupants, and state and/or local government officials, if able. Completion of a Phase I ESA affords a prospective purchaser, innocent landowner, or contiguous property owner, protection of future liability for contamination that is currently present at the site.
  2. Site-Specific Quality Assurance Project Plan: If a Phase II ESA is recommended for a property to confirm or dismiss identified RECs during Phase I, a Site-Specific Quality Assurance Project Plan (SSQAPP) is developed that will detail the types of explorations, number of samples, and methods to be used to meet the ESA’s objectives. The SSQAPP is equivalent to an environmental work plan and is prepared in a format approved by the EPA and NHDES. The SSQAPP also specifies Standard Operating Procedures for sample collection, laboratory analytical methods and Data Quality Objectives. Each SSQAPP is reviewed and approved by the EPA and the NHDES prior to beginning any Phase II ESA field work.
  3. Phase II Environmental Site Assessment: Phase II ESA investigations are initiated once the SSQAPP is approved. A Phase II ESA is a more comprehensive review of site conditions and will potentially involve the following:
    1. Conducting soil borings or test pits with the collection and analysis of soil samples
    2. Installation of groundwater monitoring wells with the collection and analysis of groundwater samples
    3. Assessing the presence or absence of hazardous building materials (asbestos, lead, PCBs, etc.)
    4. If detected contaminants of concern exceed regulatory safety levels, a Phase III Investigation and/or Remedial Action Plan will typically be recommended.
  4. Phase III Site Investigation (i.e., Additional Characterization) and Remedial Action Plan: Phase III Investigations and Remedial Action Plans are typically the final stage of a Brownfields Assessment Program. Phase III investigations may consist of additional collection of soil and groundwater samples, further assessment of hazardous building materials, and waste disposal characterization. Remedial Action Planning will include an Analysis of Brownfields Cleanup Alternatives (ABCA), which weighs the feasibility, practicality, cost, and benefits to human health and the environment among at least three cleanup alternatives, and a proposed Remedial Action Plan based on the evaluated alternatives. Completion of a Phase III/ABCA/Remedial Action Plan will initiate on-site cleanup efforts. Any parties that have been found not liable for contamination can receive a covenant from the EPA or NHDES.
Environmental clean-up and site redevelopment is not covered by this program. However, there are felxible term low-interest rate revolving loans available for property remediation based on eligibility through NRPC as well as through the City of Nashua, the Regional Economic Development Center (REDC), the Monadnock Economic Development Corporation (MEDC), and NHDES. Limited clean up grants may also be available through the EPA.