Environmental federalism has studied the interaction of state, local and federal governments to understand how governments work together to accomplish environmental goals.  Many of the environmental laws which have been created since the 1970s involve federal standard setting with state and local implementation.  But there is also a recognition that environmental policies need to be more contextualized and flexible, which may complicate the federal-state relationship.  Brownfield laws were developed in a more bottom-up fashion, with states developing their programs first and the federal government following with legislation in 2002.  Studying the formal action situation created by legislation may be one way to better understand federalism and how different levels of government interact.  This method allows us to understand the actors, their roles and their interactions.  This paper will use the Institutional Grammar Tool from Crawford and Ostrom (2005) to examine the action situations for brownfields at the federal and state levels.  It will also examine their interactions and allow a better understanding of policy implementation for brownfields.