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EPA BF Assistance Amendment Request No. 3 09.10.14 Page 1 of 5 City of Moscow, Idaho Brownfields Coalition Assessment Grant - Project Extension Request Grantee City of Moscow Grantee Title Greater Moscow Area Coalition Assistance ID Number BF-00J24101-2 Grantee Point of Contact Alisa Anderson, [PHONE REDACTED], [EMAIL REDACTED] Current Grantee Period of Performance 09/12/2010 — 09/30/2014 End Date Requested 09/30/2015 1. Financial Snapshot: Project Award Expended Amount to Date 8/31/2014 Remaining Balance as of 8/31/2014 Remaining Balance on Current Task Orders as of 8/31/2014 Remaining Balance after Obligated Task Orders as of 8/31/2014 Estimated Task Orders 8/30/2014- 9/30/2015 Remaining Balance 9/30/2015 $475,000 $361,283.34 $113,716.66 $31,027.84 $82,262.79 $82,262.79 $ 2. Estimated amount that will be unspent (no invoice in hand) by the end of the current period of performance (9/30/2014): $101,716.66 3. Explain why the project cannot be completed within the current period: ---PAGE BREAK--- Grantee ID Number: BF-00J24101-1 - Extension Request Page 2 of 5 Timeline of assessment grant activities and sequence of events causing delays in the Moscow Area Coalition (MAC) Assessment Grant schedule: May 3, 2010 Memorandum of Understanding between City, County, and Moscow Urban Renewal Agency (MURA) executed and submitted to EPA. June 11, 2010 Brownfields Assessment Cooperative Agreement Work Plan was approved by EPA. July 2010 Travis Carey, Program Manager, resigned and relocated to California. July 14, 2010 Date of Award of EPA-OSWER-OBLR-09-04 FOR $475,000 Brownfields Assessment Grant Program – Greater Moscow Area Coalition. October 1, 2010 EPA Original Cooperative Agreement executed. October 12, 2010 EPA Assistance Amendment dated October 9, 2010, changed the project period start date of October 1 to October 12, 2010, in order for staff to attend EPA sponsored training - Western Brownfields Conference Training in Missoula, MT. Start date changed so travel and training cost would be within the grant period and therefore grant expense eligible. December 2010 Jeff Jones was hired and assigned as Program Manager for MAC Assessment Grant. May 18, 2011 Brownfields Assessment Cooperative Agreement Work Plan dated June 11, 2010 was modified and resubmitted by Jeff Jones. June 24, 2013 EPA Assistance Amendment dated June 25, 2013, changed the project end date of September 30, 2013 to September 30, 2014. August 23, 2013 MURA awarded an EPA Brownfields Cleanup Grant of $115,317 for the property located at 6th and Jackson which was also enrolled in the MAC assessment grant. April 2014 Idaho Department of Environmental Quality (IDEQ) requested the MURA enroll the 6th and Jackson property into the Voluntary Cleanup Program and execute a Voluntary Remediation Agreement. May 2014 Jeff Jones, Program Manager, resigned and relocated to Utah. June 2014 – Current Mr. Steele and Ms. Anderson assigned to replace Mr. Jones to manage the MAC Brownfields Assessment Grant. ---PAGE BREAK--- Grantee ID Number: BF-00J24101-1 - Extension Request Page 3 of 5 Detailed outline of project activities and delays in completing Work Plan tasks within the current project period ending September 30, 2014: • In July of 2010 the Economic Development Specialist, Travis Carey, who had been assigned the management of the Brownfields Assessment grant resigned from his position. The City was unable to fill the position until the December 2010 at which time Jeff Jones took over the management of the grant. Mr. Jones updated the Work Plan in May 2011 and released a Request for Proposal/Qualifications to contract with consulting firms to perform environmental assessment and public outreach components of the award. During the next three years, staff was able to enroll six eligible properties into the assessment grant program and held a public outreach event to include a tour of the properties. During this time period, 60% or $285,000 of the original $475,000 award was expended. Staff anticipated an additional $22,000 to be expended on the six properties enrolled in the program; however, the final expenses billed by the environmental consultants for the original task orders issued came less than originally budgeted which allowed more available funding to work with additional properties. • In June of 2013 staff requested a one-year time extension of the grant award changing the end date from September 30, 2013 to September 14, 2014. At the time the extension request was submitted to EPA, there were two properties staff had anticipated joining the MAC Brownfield Grant Portfolio. Unfortunately, both properties ended up not enrolling in the program. The first property owned by Union Pacific Railroad (UPR) located on College Drive in Moscow was declined because the property owners were not willing to comply with grant requirements. UPR refused to execute the standard access agreement and requested the City to enter into a licensing agreement that would indemnify UPR from all liability and requested program findings to remain confidential. Unfortunately, the City as representative for the MAC was not able to move forward in the process with the UPR property. • The second parcel, the Goodman Oil property which the City anticipated would enter the program in the fall of 2013 was located in Latah County just outside the area of city impact. Staff and IDEQ met with Latah County in March 2014 and there was still uncertainty as to what was going to happen with the property due to non-payment of back taxes and eligibility requirements. At this time, the MAC was still hoping to at least assist with funding a Phase I ESA with the remaining balance of approximately $8,000 in the Assessment Grant for a petroleum site. The property was sold on June 4, 2014, at a public auction by Latah County after foreclosing due to delinquent property taxes. However, since the County foreclosed on property, a Phase I ESA was not necessary according to EPA December 2010 “CERCLA Liability and Local Government Acquisitions and Other Activities” Fact Sheet. The new owner met the petroleum rule for being two-owners removed; therefore, there was no need for a Phase I ESA and the decision was made to utilize IDEQ’s funds rather than MAC’s as there was not enough petroleum funding remaining to cover the needed Phase II Assessment. At this point, IDEQ stepped in to handle the project and issued a task order $49,992.30 with a state-procured environmental consultant through the State Response Grant 128(a) fund. ---PAGE BREAK--- Grantee ID Number: BF-00J24101-1 - Extension Request Page 4 of 5 • In April of 2014 the MURA was contacted by IDEQ requesting the Agency to submit an application for the 6th and Jackson property (aka 217 and 317 West Sixth Street) to enroll in their Voluntary Cleanup Program and execute a Voluntary Remediation Agreement. This requirement delayed the final assessment activities to be performed under the MAC Assessment grant prior to initiating the activities in the cleanup award EPA Grant No. 00J81501. • In May of 2014, Jeff Jones, Project Manager, resigned his position with the City as the Economic Development Specialist and MURA Executive Director. The responsibility of managing the grant has been transferred to existing City staff. Alisa Anderson, Grant Manager, who wrote the original grant request and has been working on the project for the last four years will now be the main contact person. Kyle Steele, a prior IDEQ employee and currently the Environment Compliance Coordinator for the City working in the Water/Sewer Department, has been assigned to work with Ms. Anderson and the environmental consultants to manage the grant through completion. Mr. Steele has a Bachelor’s Degree in Environmental Science and spent five years working for IDEQ as Senior Analyst prior to joining the City of Moscow. At IDEQ, Mr. Steele applied and interpreted a broad range of state and federal environmental statutes, rules, and guidance dealing with the Clean Air Act, Clean Water Act, Safe Drinking Water Act, RCRA, CERCLA, and underground storage tanks along with writing and reviewing technical documents and facilitating public processes to develop and implement environmental improvement plans. His responsibilities with the City as the Environmental Compliance Coordinator include regulatory oversight of the City’s NPDES Wastewater permit and associated laboratory QA/QC standards, public drinking water system and associated programs, environmental assessments for public works related projects and current management of the MAC and MURA Brownfields Assessment and Cleanup grants. Gary Riedner, City Supervisor and also an attorney, will continue to work with Ms. Anderson and Mr. Steele to provide program oversight and management. The staff members currently assigned to manage the grant are long-term employees and we do not anticipate and further staffing transitions in completing this award. 4. List the project site(s)/estimated date of completion/tasks at risk if an extension is not granted: • TerraGraphics, the environmental consulting firm working with the MAC on the 6th and Jackson property is currently in the process of completing a new Draft QAPP to be submitted to IDEQ and EPA by September 22, 2014. After the QAPP is approved, TerraGraphics will be on-site to complete the sampling work to fulfill the data gap concerns from IDEQ. After the data is obtained, the reports will be updated and TerraGraphics will work with IDEQ to finalize a remediation strategy. They will then update and/or prepare a new ABCA during the fall of 2014 with remediation to occur under the Cleanup Grant in the spring of 2015. See attached 6th and Jackson Gantt Chart prepared by TerraGraphics outlining the remaining project tasks. The MAC Assessment Grant will fund the project activities through the updated ABCA and the remaining tasks will be funded from the MURA Cleanup Grant. ---PAGE BREAK--- Grantee ID Number: BF-00J24101-1 - Extension Request Page 5 of 5 • The current project goal is to continue working to complete all tasks needed to be ready to remediate the 6th and Jackson property in the spring of 2015. The goals over the next 12- months, if awarded an extension, will be to enroll additional properties in assessment program and to complete the tasks outlined in the original Work Plan to include community outreach and media releases. Staff has also identified three other potential properties located in the City that may be eligible. The environmental consultants and IDEQ are also working with us to follow up on other sites they are familiar with or are working with property owners to submit for eligibility. • After payment to TerraGraphics of the activities to complete the ABCA for the 6th and Jackson property there will be approximately $74,262 remaining in the Hazardous Substances grant budget. Also, the $8,000 remaining in the Petroleum Substances grant budget will more than likely find assessment needs during this 12-month extension. The one year extension would also make it possible for the MAC to host a final public meeting in September 2015 and to close-out the grant as per EPA requirements. 5. Explain how you will ensure the project is completed within the extended period of performance: The MAC anticipates completing the assessment process for the 6th and Jackson property by the end of January 2015 as shown in the attached Gantt Chart. IDEQ and the current environmental consulting firm the MAC is continuing to contract with have shared with us that they are working with owners of properties in Moscow that need the assistance of an assessment grant in order to move forward with redevelopment and they are confident the remaining funding of approximately $82,262 can used on eligible properties within the next 12 months. City staff is currently in contact with two sets of property owners which we anticipate will come forth in the next two months to seek eligibility into the program. To date, the City of Moscow has a strong record of compliance and believes that the schedule set forth in this request represents a realistic approach.