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EPA BROWNFIELDS CLEANUP GRANT Shelby Middle School 133 6th Ave. South Shelby, MT 59474 WORKPLAN 1. PROJECT OVERVIEW: The City of Shelby is committed to renovating and revitalizing the Middle School building. The Shelby Middle School was originally Shelby’s high school, built in 1931. The building served as a high school until Shelby High School was built in 1962. The building was converted to a middle school and served in that capacity until students were integrated into the high school building and the new K-6 elementary school was built in 2003. Community members were ensured during the bid for construction of a new elementary school that this building would be revitalized and the greenspaces and play areas maintained for the children of our community. Working in partnership with School District #14, the city is working to convert the abandoned school building into the Shelby Learning Center. Cleanup of hazardous substances is the first phase of a conversion into a multi-faceted education center for the benefit of the community of Shelby. The second phase of the process will be the renovation of the building to house several educational programs. Plans include an expanded Head Start program, a Boys & Girls Club, an adult education and satellite learning classroom and alternative secondary education classrooms. The site will also become the permanent home of the Toole County Community Theatre group and offer space for additional school activities and community events. The City of Shelby is committed to providing the community education resources to better their lives, those of their children and generations to come. The community will benefit from a clean, safe building that poses no potential threat to human health or the environment, while at the same time providing the opportunity for a more educated work force, an alternative for youth in completing their education and provide a safe, protective environment for many children in our community who so desperately need this. It will create an incredible learning environment that the entire community can grow with. WORK SCHEDULE
PROPOSED BUDGET
2. Management and Coordination: Lorette Carter, Community Economic Development Director for the City of Shelby will be the primary project contact. Mayor Larry Bonderud is the project manager with the Shelby city council and city building inspector, Jim Yeagley acting as the designated cleanup authority for the cleanup and removal of hazardous substances in the Middle School building. Lorette Carter and Larry Bonderud will develop the RFPs with the council awarding contracts for consultation and remediation. The City of Shelby will seek the professional advice of the EPA and/or DEQ for an evaluation of the cleanup plan prepared by the consultant and advice on how to proceed with the cleanup project. Mayor Bonderud will manage the contracts and Teri Ruff; the city’s financial officer will administer the contracts. The above work schedule will be followed with Mayor Bonderud conducting weekly reviews and necessary site visits, evaluating the adequacy of the cleanup. As specified in the RFP, the consultant will prepare and submit the QUAPP, Quarterly Progress Reports, and any other reports necessary for the cleanup project. Lorette Carter will draft the Community Relations Plan and oversee the development of the Health & Safety Plan, and Analysis of Brownfields Cleanup Alternatives. The city will also initiate a task force to oversee the project. Task force members invited will be: Karen Salo, Public Health Dept., Tom Rogers, Supt., Shelby Public Schools, Mark Cross, Administrator, Marias Medical Center, Donna Sparks, Chairperson, Boys & Girls Club of Toole County, Mayor Bonderud, Jim Yeagley, a Shelby council member and a representative from Opportunities Inc. The task force will then direct the tasks outlined in the work schedule. A qualified environmental professional will be hired through an RFP process. 3. Description of Cleanup Activities: The City of Shelby, in partnership with School District # 14 sought funding for the identification and removal of hazardous substances and remediation of the Shelby Middle School property. With awarding of an EPA Brownfields Cleanup Grant, the school district has issued a resolution to transfer the ownership of the property to the city for rehabilitation. Transfer of the property will take place July 1, 2005. As indicated in the Environmental Site Assessment completed by Maxim Technologies, engineers noted that additional asbestos inspections and sampling will be required. The report suggests that several more bulk samples be collected. Asbestos-containing thermal system insulation appeared to have been removed from the property. Thermal system insulation on and around the boiler system and into the visible extents of the crawl spaces appeared to consist solely of fiberglass insulation. Lead-based paints were identified on doors, windows and trim with the school. Additionally, a large quantity of LBP was identified on the lower wall areas. The lead-based paint will need to be abated and disposed of separate from the general waste stream according to the site assessment. The Environmental Site Assessment recommends a completion of the asbestos inspection. This inspection should include sampling and analysis of bulk samples and be performed using applicable portions of the currently recognized standard protocol developed for schools under the Asbestos Hazard Emergency Response Act (AHERA), as promulgated in 40 CFR 763, Subpart E, dated October 30, 1987, and incorporated by reference in ARM 17.74. The lead-based paint is of concern both as a source of direct exposure through ingestion of paint chips and as a contributor to lead in interior dust and exterior soil. Lead may be liberated from the substrate during renovation activities and may become a respiratory hazard to renovation workers and the public proximate to the renovation site. Residual lead in dust and soil may subsequently become a respiration and ingestion hazard to employees. The assessment recommends performing a Negative Exposure Assessment (NEA) as part of renovation or demolition activities. Within the contract for removal, a professional will be hired to conduct an air monitoring review to ensure the building meets the standards for use as a school. The first step in remediation will be a request for proposals to develop an Analysis of Brownfields Cleanup Alternatives (ABCA), a Health and Safety Plan and a Quality Assurance Project Plan for the remediation work. Working within approved guidelines and timeframes, the city will then award the bid to begin work. Once the ABCA has been prepared, an administrative record will be compiled and public comment will be solicited on the cleanup alternatives. The contracted company will then do the recommended inspections and sampling including a Negative Exposure Assessment and Lead Engineering Evaluation and asbestos sampling and analysis, if necessary. With information provided, a remediation design can be completed and work schedule for actual removal and disposal implemented. 3.1 Community Relations Plan (CRP) The City of Shelby will follow workplan guidelines to establish a CRP. The city will keep the community informed about the project and its progress through Mayor Bonderud’s weekly radio reports. The city will also allow public comment and review prior to the city council meeting on the first Monday of each month. The city will also submit press releases to our local newspaper on a regular basis as the work progresses. The City of Shelby would also like to initiate a cooperative program through our school system to educate and inform our young people about the EPA Brownfields program and its goals and the future of the Shelby Middle School site. We hope to interest the high school science classes in studying the cause and effects of contaminated sites and issues facing Montana and in particular, our community. We see this project as an invaluable educational opportunity for our young people and the value of protecting human health and the environment. A draft of the “Analysis of Brownfields Cleanup Alternatives” will be available for review and public comment at the Shelby City Hall, Monday through Friday from 8:00 am to 5:00 pm and our website – www.shelbymt.com . A reasonable comment period will be allowed in accordance with standards and regulations regarding the comment period. The City of Shelby will address or respond to public comments through the mayor’s office. 3.2 Administrative Record The City of Shelby will establish an Administrative Record for the cleanup of the Shelby Middle School site. The Administrative Record will be available for public review at the Shelby City Hall, Monday through Friday from 8:00 am to 5:00 pm. The Administrative Record will include any site investigation reports, a CRP, the Analysis of Brownfields Cleanup Alternatives, a determination that documents cleanup is authorized under CERLCA 104(k) and that the site is an eligible brownfields site, responses to public comment and a final cleanup report. 3.3 Analysis of Brownfields Cleanup Alternatives (ABCA) As stated earlier, the city will draft an Analysis of Brownfields Cleanup Alternatives with consideration of the site characteristics, surrounding environment, land use restrictions, potential future uses and cleanup goals. The ABCA will be available at City Hall and on our website – www.shelbymt.com . The report will include information about the characteristics of the site and contamination issues. It will provide information and analysis of cleanup alternatives considered for the site, including “no-action” as an alternative. The ABCA will include information about the alternatives considered including a range of proven cleanup methods and the proposed report will assess whether land use controls will be necessary and if so, how they will be implemented and maintained. 3.4 CERCLA 104(k) Determination Documentation: The City of Shelby will prepare a written determination that documents cleanup is authorized under CERCLA 104(k). Determination will include documentation that the site is an eligible Brownfields site; there is a presence of hazardous substances, pollutants, or contaminants; a description of the selected environmental cleanup; an explanation of why the cleanup is authorized by the regulatory agency; an explanation of the rationale for selecting that particular action and why/how it meets cleanup goals; any responses to public comments on the ABCA; and a discussion of how the selected cleanup will conform to all applicable Federal and State laws. 3.5 Compliance with Other Federal Requirements: The City of Shelby has previously worked within the parameters of Occupational, Safety and Health Administration safety standards, MBE/WBE requirements, and the Davis-Bacon Act of 1931. The city will comply and meet the requirements of these regulations and all applicable Federal and State laws. 3.6 Environmental Cleanup: Because of the present condition of the site and the scope of cleanup planned, the City of Shelby will not initiate a state voluntary cleanup program. There is no risk of release to the environment. The empty building’s present condition is not a threat to human health or the environment as is, because School District #14 followed AHERA requirements to abate and maintain the school over the last 17 years. However, the proposed renovation and revitalization of the Shelby Middle School for a learning center has prompted the ASTM Phase 1 Assessment and grant submission for an EPA Brownfields Cleanup Grant. The structure was abated, but before renovation, the site needs all hazardous substances removed. The city will follow all specifications and requirements as designated by the Department of Environmental Quality Asbestos Control Program and any other government agency to ensure that the proposed cleanup is protective to human health and the environment. The city will also work with the Montana Department of Labor and Industry to comply with all worker safety issues in relation to the hazardous substance removal and disposal. The city will complete a written description of cleanup tasks and complete all necessary documentation throughout the life of the project. The city ensures that the site is secure and poses no immediate threat to human health or the environment. All necessary land use controls will be implemented and once cleanup is completed, will notify the appropriate state agency and EPA to ensure an orderly transition to other appropriate cleanup activities and write a final report for inclusion in the Administrative Record. 4. EPA Reporting Requirements/Deliverables: 4.1 Quality Assurance Project Plans (QAPPs): The Shelby Middle School cleanup project will include environmental samples with use of the grant funds. The city provides assurance that the QAPP will be submitted and approved by the EPA Project Officers prior to any field sampling. 4.2 Health and Safety Plans: The City of Shelby will prepare a Health and Safety Plan, complying with OSHA 29 CFR 1910.120 entitled, “Hazardous Waste Operations and Emergency Response”. 4.3 Quarterly Reports: The City of Shelby, through the hired consultant will prepare and submit a quarterly progress report, to include site profiles. 4.4 Copies of Other Grant Documents: The City of Shelby will submit to EPA a copy of any and all documents relating to the request for proposals for contractors, any contracts that have been entered into between the grantee and contractor, and copies of the cleanup/remediation plan. 4.5 Financial Status Reports: The City of Shelby will submit to EPA annual Financial Status Reports in accordance with the Cooperative Agreement. 4.6 Final Report: The City of Shelby will submit to EPA a final performance or progress report of all work conducted under the grant after the expiration or termination of the agreement. |
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