EPA Brownfields Cleanup Grant: Compliance Requirements

Submit progress reports to EPA Project Officer within 30 days after each reporting period (quarterly or annual as specified in cooperative agreement terms and conditions), including work status, financial expenditures, preliminary data, and key personnel changes.

Deadline: within 30 days after each reporting period ends

Source: EPA Programmatic Requirements for Brownfield Grants; 11-1, 11-15, 11-16, 11-17

Submit site-specific accomplishments on Property Profile Forms to EPA's ACRES (Assessment, Cleanup and Redevelopment Exchange System) database to demonstrate project progress and measurable site accomplishments.

Deadline: within 30 days of reporting period end; must use ACRES 6.0

Source: EPA Programmatic Requirements for Brownfield Grants; 11-18, 11-19; 12-1, 12-2

Maintain site ownership throughout the period in which Brownfields Cleanup Grant funds are disbursed; loss of ownership eligibility triggers grant suspension and cost clawback.

Deadline: continuous during entire grant disbursement period

Source: FY26 Brownfields Cleanup Guidelines Section 2.B; 1-29

Procure contractors and consultants in compliance with 2 CFR 200.325 (Uniform Guidance) requirements for fair and open competition, including competitive bidding processes and EPA Project Officer review of proposed procurements.

Deadline: prior to issuing any RFP, RFQ, or contract; EPA will review for fair competition compliance

Source: FY26 Brownfields Cleanup Guidelines Section 4.D; 2 CFR 200.5, 200.325; NOFO (2-5, 2-10)

Protect all nearby populations, including sensitive populations, from contaminants during assessment and cleanup work through implementation of procedures to mitigate potential exposure.

Deadline: must be implemented throughout all assessment and cleanup activities

Source: EPA Programmatic Requirements for Brownfield Grants; 11-13, 11-14; 20-12, 20-13

Correct any deficiencies identified by EPA in All Appropriate Inquiries (AAI) documentation within 30 days of notification; failure to correct deficiencies results in disallowance of costs for the entire AAI report.

Deadline: within 30 days of EPA deficiency notification

Source: EPA Programmatic Requirements for Brownfield Grants; 3-2, 3-3, 3-19

Submit Quality Assurance Project Plan (QAPP) to EPA for prior approval before collecting any environmental samples for assessment, characterization, verification, or confirmation sampling.

Deadline: at least 30 days prior to initiation of sampling activities; PO approval required

Source: EPA Programmatic Requirements for Brownfield Grants; 3-11

Consult with EPA prior to any on-site activity (sampling, cleanup) that may affect historic properties or threatened and endangered species to ensure compliance with National Historic Preservation Act § 106 and Endangered Species Act § 7(a)(2).

Deadline: prior to conducting on-site activity; recipient must plan for consultation requirements

Source: EPA Programmatic Requirements for Brownfield Grants; 3-13, 11-6; 2 CFR 1500.11

Prepare Analysis of Brownfield Cleanup Alternatives (ABCA) for each site cleaned with EPA funding, signed by authorized representative, including site characterization, cleanup standards, alternatives analysis, implementation feasibility, cost analysis, and resilience evaluation for climate impacts.

Deadline: prior to initiating cleanup activities; must be submitted for EPA review and approval

Source: EPA Programmatic Requirements for Brownfield Grants; 3-24, 3-25, 3-26

Document successful cleanup completion through final report or letter from qualified environmental professional showing cleanup is complete and remedial goals met; documentation must be included in Administrative Record.

Deadline: upon completion of cleanup; must be included in final report and Administrative Record

Source: EPA Programmatic Requirements for Brownfield Grants; 20-15, 20-16, 20-17