Help for Brownfield Properties

What is a Phase I Environmental Site Assessment?

A Phase I, or Phase I ESA, is a report which identifies potential or existing environmental contamination. It addresses not only pollutants that may be located in the structures of a property but also any contaminants in the soil and groundwater under a property. It includes a review of both current and historic operations as well as environmental issues. If environmental concerns are identified, they will be called out as “Recognized Environmental Conditions” or RECs.

Typically, a Phase I ESA will cost $2,500+ depending on property size and complexity. A Phase I ESA is an important part of pre-acquisition site due diligence to assess business risk from a property purchase. A Phase I ESA is required as part of an application to obtain federal funding for site cleanup as well. Free Phase I ESA services can be obtained without charge through PartnerTulsa, Oklahoma Department of Environmental Quality, Oklahoma Corporation Commission, and US EPA for eligible applicants.

What is a Phase II Environmental Site Assessment?

If Recognized Environmental Conditions, or RECs, are identified in a Phase I ESA, a Phase II ESA may be recommended. A Phase II ESA may involve sampling of suspect building materials, soil, groundwater, air, or vapor to confirm whether an environmental issue is present and to define the extent of the concern. A Phase II ESA typically costs $10,000 – $25,000, or more, depending on the size of the site and the extent of environmental concerns. This step is also an important part of pre-acquisition due diligence and can help a prospective purchaser understand what steps may be needed to make the site ready for reuse. Conversely, a Phase II ESA may also confirm that the suspected risks are not present and redevelopment can proceed without further action.

Free Phase II ESA services, as well as cleanup planning, can be obtained without charge through the PartnerTulsa, Oklahoma Department of Environmental Quality, Oklahoma Corporation Commission, and US EPA to eligible applicants.

What is Environmental Cleanup?

Environmental Cleanup, also known as abatement or remediation, refers to actions taken to clean up environmental contamination. These actions may be conducted to address issues in soil and groundwater or on inside physical structures. Some examples include removal of buried fuel storage tanks or excavation of contaminated soil, abatement of asbestos or removal of lead-based paint from a building.

Depending upon the type of material to be remediated, a State agency will be involved in providing oversight of cleanup activities. Asbestos abatement is overseen in the State of Oklahoma by the Department of Labor. Fuel and oil cleanup is managed by the Oklahoma Corporation Commission. Soil and groundwater cleanup is overseen by the Department of Environmental Quality. These agencies can provide additional information on cleanup objectives for property reuse.

Finding Funding for Environmental Cleanup

Once due diligence has been completed that identifies an environmental concern, many owners and prospective purchasers will begin looking for resources to support site cleanup and redevelopment. In Oklahoma, several funding sources are available to support site cleanup including:

• In the city of Tulsa, low interest environmental cleanup loans and subgrants are available to for-profit entities and non-profit groups, respectively, through PartnerTulsa and the city’s  Brownfield Revolving Loan Fund (BRLF). In 2023, an additional $900,000 was made available locally. You can review the city’s BRLF process online as well as prepare your application.
• The Oklahoma Corporation Commission (OCC) provides funding for former gas station cleanup, through the OCC Brownfield RLF.  The OCC also administers a Leaking Underground Storage Tank (LUST) Indemnity Fund, created by the Legislature in 1989 to assist the owners of former gas stations with the legacy of leaking tanks.
• The Oklahoma Department of Environmental Quality Brownfield RLF provides cleanup loans to for-profit entities and subgrants to municipalities and non-profit groups.
• Owners of abandoned oil and natural gas well sites can obtain cleanup services from the Oklahoma Energy Resource Board. Since that program began, over 19,000 oilfield properties have been cleaned up across the state – free of charge to the landowner.

In 1941 the War Department built Air Force Plant No. 3 (AFP3) on the east side of the Tulsa International Airport and used the one-mile long structure as to construct over 3,000 bombers during World War II. Following World War II, Rockwell International built key parts of the rocket that sent men to the moon and the space shuttle. And in 1999, the Air Force transferred AFP3 to the City of Tulsa.

During the plant’s operations since 1941, aircraft maintenance, underground fuel storage, fire training, debris landfilling, and aboveground drum storage resulted in environmental contamination of the base.  Hazardous waste issues were addressed by the Air Force upon vacating the property. However, the long-term effects of asbestos used in construction of the 2.89 million square foot space remains an ongoing environmental issue.

The City of Tulsa has progressively rehabbed most of the facility, allowing occupation by Navistar, a school bus manufacturer, and Nordam Aerospace, an aviation manufacturer. Additional reuse of the structure requires abatement of asbestos-containing building materials (ACBM) to enable economic development.

In 2019, the EPA awarded the City of Tulsa $500,000 for AFP3 cleanup and in 2021, cleanup of AFP3 Building 006 was completed. In 2024, the Oklahoma Department of Environmental Quality awarded the City an additional $500,000 for the cleanup of AFP3 Building 007. Planning documents related to the cleanup of both buildings are provided below:

Notice of Availability of 2024 Analysis of Brownfield Cleanup Alternatives

Analysis of Brownfield Cleanup Alternatives (ABCA) 2024

Community Involvement Plan (CIP) 2024

Quality Assurance Project Plan (QAPP) 2019

Building 006 Cleanup Report