DRAFT _ Former Ideal School ABCA _ 10172024.pdf

Analysis of Brownfield Cleanup Alternatives

Brownfields Asbestos Cleanup Former Ideal School: Acres ID 251632 106 MLK Drive Ideal, Macon County, Georgia

September 30, 2024 | Terracon Project Number: HP217183, Task 04A1 EPA Brownfields Cooperative Agreement BF-00D94519-0

Prepared for:

The City of Ideal Ideal, Macon County, Georgia C/O of River Valley Regional Commission

Prepared By:

Terracon Consultants Columbus, Georgia

Former Ideal School; Acres ID 251632 106 MLK Drive

Ideal, Macon County, Georgia

EPA Cooperative Agreement No. BF-00D94519-0 Date: September 30, 2024

Prepared by:

Terracon Consultants, Inc.

PROJECT MANAGER ________________________________ Date ________________ Jason A. Cooper / Terracon, Inc.

QA REVIEWER _________________________________ Date ________________ Kevin R. Strumpler / Terracon, Inc.

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Table of Contents

1.0 INTRODUCTION AND BACKGROUND

1.1 Background

1.2 Site Assessment Findings

2.0 PROJECT GOALS AND RE-USE PLAN

3.0 APPLICABLE REGULATIONS AND CLEANUP STANDARDS

3.1 Cleanup Responsibility

3.2 Cleanup Standards

3.3 Laws and Regulations Applicable to the Cleanup

4.0 EVALUATION OF CLEANUP ALTERNATIVES

4.1 Cleanup Alternative A: Pre-Renovation ACM Removal

4.1.1 Effectiveness – Including Climate Change Considerations

4.1.2 Implementability

4.1.3 Cost

4.2 Cleanup Alternative B: ACM Encapsulation

4.2.1 Effectiveness – Including Climate Change Considerations

4.2.2 Implementability

4.2.3 Cost

4.3 Cleanup Alternative C: No Action

4.3.1 Effectiveness

4.3.2 Implementability

4.3.3 Cost

4.4 Cost Comparison Alternatives

5.0 RECOMMENDED CLEANUP ALTERNATIVE

Appendices

Appendix A - Exhibits

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The Analysis of Brownfields Cleanup Alternatives reported herein was funded wholly or in part through a cooperative agreement between the Environmental Protection Agency’s (EPA’s) Brownfield and Land Revitalization Program and the River Valley Regional Commission (RVRC) (EPA Cooperative Agreement No. BF-00D94519-0). The contents of this document do not necessarily reflect the views and policies of the EPA or the RVRC, nor does the EPA or RVRC endorse trade names or recommend the use of commercial products mentioned in this document.

BF-00D94519-0

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1.0 INTRODUCTION AND BACKGROUND

This Analysis of Brownfield Cleanup Alternatives (ABCA) evaluates cleanup alternatives and establishes the costs for cleanup activities necessary to address hazardous substances such as asbestos-containing material (ACM) to support redevelopment of the Former Ideal School (Site) located at 106 MLK Drive in Ideal, Georgia. The City of Ideal (City), intends to remove the hazardous materials from the site in support of their goal to demolish the current site structures and build a regional community center.

This ABCA is intended to briefly summarize information about the site and contamination issues, cleanup standards, applicable laws, cleanup alternatives considered, and the proposed cleanup, and includes information on the effectiveness, the ability of the grantee to implement each alternative, the cost of each proposed cleanup alternative, an evaluation of how commonly accepted climate change conditions might impact proposed cleanup alternatives, and an analysis of the reasonableness of the various cleanup alternatives considered, including the one chosen. The ABCA is intended as a brief document summarizing the larger and more detailed technical and financial evaluations performed in addressing each of these areas. The ABCA may be modified technically and financially or in more depth relative to each of these areas upon award of funding and in response to community interaction.

Cleanup alternatives were evaluated in accordance with EPA Region 4 protocols and general guidance required prior to implementation of a cleanup design using EPA Brownfields Grant funding. More specifically, viable cleanup alternatives based on site-specific conditions, technical feasibility, resiliency to climate change conditions, and preliminary cost/benefit analyses are summarized herein. Specific cleanup alternatives and associated recommendations are presented in the applicable sections of this report.

1.1 Background

The site is located at 106 MLK Drive in Ideal, Macon County, Georgia and is comprised of one tax parcel. The site encompasses approximately 18.7 acres and consists of a building that was formerly used as a school. The building, which was constructed sometime between 1951 and 1970, is still in its original configuration and totals approximately 30,000 square feet.

According to tax records, the site has been owned by the City of Ideal since 1981. A review of environmental database listings indicated that a portion of the site was also previously used as an inert landfill in the 1990s. The location of the site is depicted on Exhibit 1 of Appendix A, which was reproduced from a portion of the USGS 7.5-minute series topographic map. The site vicinity and site layout are depicted on Exhibit 2 of Appendix A.

A Phase I Environmental Site Assessment (ESA), dated April 5, 2022, was conducted on the property, as part of the same Cooperative Agreement. The Phase I identified one REC (an

Former Ideal School; AI 251632 ■ Ideal, Georgia

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Facilities | Environmental | Geotechnical | Materials 2 inert landfill) and suspect asbestos containing material and suspect lead-based paint materials. After approval of the Site-Specific Quality Assurance Project Plan, dated May 31, 2023, a Phase II ESA and Hazardous Material Inspection were conducted at the site. No evidence of the inert landfill was identified on the subject property during the Phase II;

therefore, no further action was recommended to address the REC.

1.2 Site Assessment Findings

A Hazardous Materials Inspection of the site was conducted by Terracon, and a report was issued on April 19, 2024. The inspection included an asbestos survey, and asbestos samples collected were analyzed using Polarized Light Microscopy (PLM) by a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory. The asbestos survey identified asbestos in floor tiles, flooring adhesive, and exterior metal window frame caulking.

The report recommended that the asbestos-containing materials (ACM) to be disturbed during renovation or demolition activities be abated by a State licensed asbestos abatement contractor.

The following table provides a summary of the ACM that were identified in the structure in the Hazardous Materials Assessment – Former Ideal School report dated April 19, 2024:

Homogeneous Area ID

Material Description Material Location Estimated Quantity

1 12”X12” VFT; Mastic Throughout Structure 7,500 SF

2 Black Mastic on Concrete Throughout Structure 7,500 SF

6 Exterior Window Caulking Throughout Structure 100 SF

SF=Square Feet

Additionally, the April 2024 Hazardous Materials Inspection included the testing of building materials for TCLP lead, to determine if the demolition waste stream could be disposed a C&D landfill. The results of the TCLP testing indicated that lead was not present above applicable regulatory thresholds. During the site visit for this testing, coatings were observed at the site that could contain lead; however, testing the individual coatings for lead was not performed, as this is not required for structures that are to be demolished. Should the selected site redevelopment option include renovation of a portion of the structure(s), then the observed coatings will need to be tested for paint, to determine an appropriate abatement strategy. If needed, this testing will be performed prior to June 15, 2025.

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2.0 PROJECT GOALS AND RE-USE PLAN

The City of Ideal owns the site and intends to demolish the current structure and construct a new building(s) for use as a community center.

EPA brownfield funding will be used to abate ACM from the former Ideal School structure prior to demolition. This allows immediate and definitive resolution of the public health issue, while demolition can then proceed on a schedule that time and resources allow without worry or expense of maintaining and isolating damaged materials from public exposure.

3.0 APPLICABLE REGULATIONS AND CLEANUP

STANDARDS

The regulated contaminant of concern for remedy is asbestos and lead (in paint).

Asbestos is the name given to a group of six different fibrous minerals that occur naturally in the environment. Asbestos minerals have separable long fibers that are strong and flexible enough to be spun and woven and are heat resistant. Because of these characteristics, asbestos has been used for a wide range of manufactured goods, mostly in building, friction products, heat-resistant fabrics, packaging, gaskets, and coatings. Asbestos fibers can enter the air or water from the breakdown of natural deposits and manufactured asbestos products.

Asbestos fibers do not evaporate into air or dissolve in water. Small diameter fibers and particles may remain suspended in air for a long time and be carried long distances by wind or water before settling down. Larger diameter fibers and particles tend to settle more quickly.

Asbestos fibers are not able to move through soil. Asbestos fibers are generally not broken down to other compounds and will remain virtually unchanged over long periods. Exposure to asbestos usually occurs by breathing contaminated air in workplaces that make or use asbestos. Asbestos is also found in the air of buildings containing asbestos that are being torn down or renovated. Asbestos exposure can cause serious lung problems and cancer.

Lead is regulated by the Georgia Environmental Protection Division (GAEPD) and the USEPA through the United States Occupational Safety and Health Administration (OSHA). As such, lead safe work practices will be required if lead paints are identified. USEPA and GAEPD regulations would also apply for disposal of lead-containing demolition waste. Occupational exposure to lead occurring in the course of construction work, including renovation activities, painting, alteration, and repairs is subject to the OSHA lead standard (29 CFR 1926.62). The presence of lead in demolition debris from non-residential buildings has the potential to impose limitations on where and how the debris may be disposed. The Resource Conservation and Recovery Act (RCRA) requires each waste generator to determine if the wastes are hazardous.

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3.1 Cleanup Responsibility

The City of Ideal, Georgia will be the funding recipient responsible for hiring contractors and will use a qualified Environmental Professional to assist with contracting documents, cleanup contractor oversight and final documentation. The cleanup will be conducted by an asbestos abatement contractor licensed in the State of Georgia. Demolition and new construction permits and notifications will be obtained from the Georgia Environmental Protection Division (GAEPD) and local agencies, as needed. Applicable documentation will be submitted as required to the GAEPD.

3.2 Cleanup Standards

Asbestos

Any individual or company contracted to perform a demolition or renovation activity that disturbs RACM in excess of the established thresholds must be recognized by the Georgia Environmental Protection Division (GA-EPD) to perform asbestos abatement. Asbestos removal shall be conducted according to applicable Federal, State, and local rules/regulations, including but not limited to, NESHAP 40 CFR Part 61, Subpart M, OSHA regulations under 29 CFR 1910.1001 and 1926.1101, the GA-EPD Solid Waste Management Rule, Chapter 391-3-4, and GA-EPD Asbestos Removal and Encapsulation Rule, Chapter 391-3-14.

The United States Occupational Safety and Health Administration (USOSHA) asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos. The USOSHA standard requires that employee exposure to airborne asbestos must not exceed 0.1 fibers per cubic centimeter of air (0.1 f/cc) as an eight-hour time weighted average (TWA) and not exceed 1.0 fibers per cubic centimeter of air (1.0 f/cc) over a 30-minute time period known as an excursion limit (EL). The TWA and EL are known as USOSHA’s asbestos permissible exposure limits (PELs). The USOSHA standard classifies construction and maintenance activities that could disturb ACM and specifies work practices and precautions that employers must follow when engaging in each class of regulated work. The standard also specifies requirements for handling materials containing asbestos in concentrations less than or equal to 1%.

After abatement is complete, the asbestos abatement contractor shall conduct a visual assessment to ensure the work area is clean of all ACM debris. If the contractor deems the area is visibly clean, Terracon shall perform a final visual assessment to confirm that abatement has been completed and surfaces are free of visible residue, dust, debris and asbestos contaminated equipment and wastes. The visual assessment will be performed in general accordance with ASTM International (formerly known as the American Society for Testing and Materials) Designation E1368-23 Standard Practice for Visual Inspection of Asbestos Abatement Projects.

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Lead-Based Paint

OSHA does not define lead-containing coatings. Any detectable level of lead presents a potential source of exposure depending on how the material is disturbed. Therefore, Terracon recommends that potential contractors are made aware of the findings of this limited lead paint survey. Personnel and/or contractors should utilize work practices pursuant to the OSHA lead standard (29 CFR 1926.62) when impacting lead-containing components.

Standards have been established by OSHA to limit exposure of workers in the workplace and establish work standards for lead. The occupational exposure limits are as follows:

Lead Action Level (8-hour time-weighted average permissible exposure level): 30 µg/m3

Lead PEL (8-hour time-weighted average permissible exposure level): 50 µg/m3

Potential PCB Containing Ballast; Liquid Mercury in Thermostats; and other Universal Waste

The disposal of Fluorescent Light Ballasts (FLB) should be performed in accordance with EPA Toxic Substance Control Act (TSCA) disposal requirements for FLB. Disposal options should follow the TSCA Storage Disposal Requirements outline by EPA. The PCB ballast abatement for the project should meet the cleanup standards of unrestricted building use and/or renovation upon completion.

Removal of mercury-containing devices, such as liquid mercury containing thermostats and fluorescent lighting, will be performed in accordance with EPA 905-F-11-008 Recommended Management Practices for Pre-Demolition Removal of Mercury-Containing Devices from Residential Buildings and USEPA Title 40 Part 273- Standards for Universal Waste Management. The liquid mercury-containing device abatement for the project should meet the cleanup standards of unrestricted building use and/or renovation upon completion.

3.3 Laws and Regulations Applicable to the Cleanup

Asbestos is regulated by the Asbestos Hazard Emergency Response Act (AHERA), the National Emission Standards for Hazardous Air Pollutants (NESHAP).

The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The asbestos NESHAP regulation also requires the identification and classification of existing ACM according to friability prior to demolition or renovation activity. Under NESHAP, ACM is identified as either friable, Category I non-friable or Category II non-friable ACM. Friable ACM is a material containing more than 1% asbestos that, when dry, can be crumbled, pulverized or reduced to powder by hand

Former Ideal School; AI 251632 ■ Ideal, Georgia

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Facilities | Environmental | Geotechnical | Materials 6 pressure. All friable ACM is considered regulated asbestos containing material (RACM).

RACM includes all friable ACM; Category I non-friable ACM that has become friable or will be or has been subjected to sanding, grinding, cutting, or abrading; and Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder in the course of renovation or demolition activity.

Category I non-friable ACM are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor covering mastics and asphalt roofing products that contain more than 1% asbestos. Category II non-friable ACM are all other non-friable materials other than Category I non-friable ACM that contain more than 1% asbestos. Category II non-friable ACM generally includes but is not limited to cementitious material such as: cement pipes, cement siding, cement panels, glazing, mortar and grouts.

The following work practices should be followed prior to the initiation of demolition activities on the project site:

Prepare abatement specifications by a Georgia Accredited Asbestos Project Designer;

Notify the GA-EPD of intention to demolish by the required notification form and receive approval for abatement activities;

Remove all ACM from facilities being demolished;

Handle and dispose of ACM in an approved manner (USEPA, 2006a: Asbestos/NESHAP

Regulated Asbestos-Containing Materials Abatement and GA-EPD Asbestos Removal and Encapsulation Rule, Chapter 391-3-14);

Comply with applicable OSHA standards;

All asbestos abatement materials (i.e. filters from control devices, bags, poly sheeting, disposable equipment, clothing and used PPE) are to be removed and disposed as Asbestos-Containing Waste Materials (ACWM) before demobilizing from the site; and

Prepare an asbestos abatement close-out report at the conclusion of the project. The report should include the post-abatement visual clearance report, waste manifest documentation, and any other pertinent information collected during the demolition operations.

OSHA 29 CFR 1926.62 Subpart D, Lead, applies to all renovation/demolition where an employee may be occupationally exposed to lead. The employer shall communicate information concerning lead hazards and communicating information concerning hazards and appropriate protective measures to employees, including training. Where lead is present, it should be assumed that workers will be exposed to lead above the action level and personal protective measures (based on the type of disturbance) should be implemented until an exposure assessment is completed.

RCRA gave the USEPA authority to regulate the waste status of demolition or renovation debris, including lead containing materials. Specific notification and testing requirements must

Former Ideal School; AI 251632 ■ Ideal, Georgia

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Facilities | Environmental | Geotechnical | Materials 7 be addressed prior to transporting, treating, storing, or disposing of hazardous wastes. Lead containing wastes are considered hazardous waste under RCRA if TCLP results exceed 5 mg/L.

The Resource Conservation and Recovery Act (RCRA) states that the generator of hazardous waste is required to follow certain procedures when generating, storing, transporting, and/or disposing of the waste generated. Wastes are defined as hazardous by EPA if they are specifically named on one of four lists of hazardous wastes (listed wastes) or if they exhibit one of four characteristics (characteristic wastes), including ignitability, corrosivity, reactivity, or toxicity.

3.4 Climate Change Considerations

Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic Performance, establishes an integrated strategy for sustainability within the Federal Government. Under the Executive Order, each agency is required to evaluate their climate change risks and vulnerabilities to manage the effects of climate change on the agency's mission and operations in both the short and long-term as part of the formal Strategic Sustainability Performance Planning process.

Effective with Fiscal Year 2013, EPA’s Brownfields Program initiated a change to cooperative agreements for Cleanup and Revolving Loan Fund awards. It requires cooperative agreement recipients to evaluate the resilience of remedial options funded by the award in light of reasonably foreseeable changing climate conditions. As directed under EPA’s Climate Change Adaptation Plan, the ABCA must include a discussion of observed and forecasted climate change conditions for the area of the project and the associated site-specific risk factors.

Specifically, this is to be presented as part of the ABCA. As the possibility exists that Cleanup grant funds may be utilized for cleanup actions at the site, climate change has been considered in this ABCA.

3.4.1 General Considerations

In considering remedy resiliency Terracon consulted the following resources as authoritative sources.

Climate Resources on Data.gov

U.S. Global Change Research Program (USGCRP)

U.S. Climate Resilience Toolkit

EPA Climate Change on EPA.gov

USDA Climate Hub

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3.4.2 Site-Specific Considerations

The site and Georgia are in EPA’s climate designation of Southeast. In this region, rising temperatures, extreme weather events, and drought are the primary climate change conditions. These changing conditions have significant effects on the Southeast’s most widespread economic contributions: forestry and agriculture. According to the USDA, the Southeast is the largest producer of timber, which is the region’s largest valued crop, in the United States. Other major agricultural and agriculture-related commodities of the Southeast include hogs, poultry, peanuts, tobacco, and sweet potatoes. The site is located in the small rural community of Ideal and is currently developed as a vacant, former school. Site redevelopment options for the subject property include development as a community center or development of a multi-family housing complex to serve the citizens of Ideal. Site redevelopments plans would include minor clearing and grading and would not involve a major change in land use.

These considerations do not identify property-specific risks in considering resiliency of remedy at this property as part of feasibility and implementability.

4.0 EVALUATION OF CLEANUP ALTERNATIVES

Asbestos is considered a hazardous substance relative to grant funding. EPA requires the ABCA, at a minimum, to consider two different cleanup remedies and a “no action” alternative.

Asbestos mitigation in the environmental industry is an established practice. Due to its chemical and physical nature, asbestos can, generally speaking, only be managed. Unlike chemical contamination, it cannot be readily altered or broken down. The industry has historically evolved two basic approaches: removal with off-site management and in-place isolation and on-site management.

In addition to effectiveness, implementability, and cost considerations, consideration was given to the sustainability of cleanup alternatives in regard to current and future climate change concerns. According to the National Oceanic and Atmospheric Administration’s (NOAA) National Climate Assessment, the primary climate change conditions identified for the southeast region include increased weather activity. Increased weather activity has been identified as site-specific climate change considerations and the resiliency of each cleanup alternative will be evaluated against these considerations.

Cleanup Alternatives Considered

To address hazardous substances at the Site, three different alternatives were considered.

These alternatives are outlined below. The following subsections present each alternative in greater detail, including estimated costs and potential contingency items:

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Cleanup Alternative A: ACM Removal Pre-Demolition Cleanup Alternative B: ACM Encapsulation Cleanup Alternative C: No Action

4.1 Cleanup Alternative A: Pre-Demolition ACM

Alternative A includes conventional removal/abatement of ACM using standard industry practices. Abatement areas would be contained prior to the removal using polyethylene sheeting, controlled negative pressure conditions and/or other applicable measures to prevent asbestos fiber migration beyond the work zone. Asbestos abatement procedures require wet removals to further control potential spreading of damaged or friable asbestos and airborne particulates. During and following the abatement, dust, particulates and other residual materials would be vacuumed and filtered out using a high efficiency particulate air (HEPA) filtration system.

ACM would be removed in accordance with GA-EPD and/or US-EPA regulations, as applicable, and containerized for off-site landfill disposal as a special or regulated waste. Waste will be containerized (commonly double bagged) to contain ACM in manageable quantities.

Leak-tight containers may also be used. Landfill disposal authorizations would be secured prior to initiating the work. These authorizations are specific to the disposal facility.

ACM removal must be performed by a Georgia-licensed abatement contractor. In addition, this work requires a 10-business day notification to Georgia EPD and appropriate coordination with Georgia EPD representatives, as needed, throughout the abatement project. An air monitoring program will be required for removal of friable or highly damaged ACM, termed regulated asbestos-containing materials (RACM).

Potential PCB containing ballasts; Liquid mercury in thermostats, and other universal waste in the structure(s) at the site will be removed as part of this alternative.

4.1.1 Effectiveness – Including Climate Change Considerations

The ACM is permanently removed. This approach is technically effective as a definitive and direct physical elimination of the contaminants that produce unacceptable public risk. The remedy usually does not significantly alter structural conditions due to typical ACM uses.

Demolition restrictions would not remain following demonstration of clearance criteria.

Excluding clearance sampling, follow-up inspections and maintenance will not be required.

With removal and off-site disposal of contaminants, the approach requires no special post-remedy institutional or land use controls for the property.

Errors will be prevented and minimized by utilizing accredited abatement contractors to conduct the abatement activities in accordance with state regulations and best management practices. Final clearance would be granted following a visual examination of the work area

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Facilities | Environmental | Geotechnical | Materials 10 followed by receipt of acceptable air quality testing results.

The site-specific climate change conditions identified include increased weather activity which could affect building integrity (damaged from storms). Removal of ACM reduces the potential for environmental contamination.

4.1.2 Implementability

This alternative is technically achievable. It is a mature remedy common in the remediation industry. The approach requires specialized equipment readily available in the local demolition and engineering markets. A specialized labor force exists in Georgia to accomplish the remedy. The implementation period is shorter-term and can be conducted during any time of the year.

4.1.3 Cost

Based upon Terracon’s experience with similar projects, the estimated cost to remove ACM from the structure is approximately $257,000, including third-party industrial hygiene consulting services, waste removal, and disposal. Due to the deteriorated state of the building, there are costs associated with debris removal that must take place prior to abatement activities included in the cost above. An additional $115,000 would be required to complete the demolition of the building. These funds would be raised by the City of Ideal and their stakeholders. The total budget for demolition of the building is estimated to be $372,000.

4.2 Cleanup Alternative B: ACM/LBP Encapsulation and/or Enclosure

Alternative B involves encapsulating or enclosing the ACM and/or LBP within the structure.

Encapsulation (asbestos) is defined as the treatment of ACM with a liquid that covers the surface with a protective covering or embeds the fibers with an adhesive matrix to prevent the release of asbestos fibers; whereas encapsulation (LBP) is defined as a process that makes LBP inaccessible by providing a barrier (formed using a liquid-applied coating or adhesively bonded covering material) between the LBP and the environment. Enclosing the ACM and/or LBP would consist of covering the materials with a rigid and permanent material such as plywood. Encapsulation of friable and non-friable regulated asbestos containing materials (RACM) is considered an abatement activity. Abatement areas would be contained prior to the encapsulation using polyethylene sheeting, controlled negative pressure conditions and/or other applicable measures to prevent asbestos fiber migration beyond the work zone.

Abatement procedures require wet removals of damaged ACM or ACM debris to further control potential spreading of damaged or friable asbestos and airborne particulates. Following the removal of any damaged ACM or ACM debris the remaining ACM would be sprayed with a bridging compound (similar to Fiberlock® Asbestos Binding Compound). Similarly, following removal of any damaged LBP or LBP debris the remaining LBP would be sprayed with an

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Facilities | Environmental | Geotechnical | Materials 11 encapsulant (similar to Ecobond Lead Defender ® LBP Sealant and Treatement). During and following the abatement, ACM/LBP dust, particulates and other residual materials would be vacuumed and filtered out using a high efficiency particulate air (HEPA) filtration system.

ACM and/or LBP would be encapsulated in accordance with applicable state regulations and may require GA-EPD notifications. Any waste generated would be containerized for off-site landfill disposal as a special or regulated waste. Landfill disposal authorizations would be secured prior to initiating the work. These authorizations are specific to the disposal facility.

ACM encapsulation for RACM must be performed by a Georgia-licensed abatement contractor.

LBP encapsulation must be performed by a Georgia-licensed abatement or RRP (renovation, repair and paint) contractor. In addition, this work requires a 10-business day notification to Georgia EPD and appropriate coordination with Georgia EPD representatives, as needed, throughout the abatement project. An air monitoring program will be required for removal of friable or highly damaged ACM. Final clearance would be granted following a visual examination of the work area followed by receipt of acceptable air quality testing results (for

RACM).

Potential PCB containing ballasts; Liquid mercury in thermostats, and other universal waste in the structure(s) at the site will be removed as part of this alternative.

4.2.1 Effectiveness – Including Climate Change Considerations

The ACM/LBP are isolated in a manner in which the ACM/LBP does not come into direct contact with humans. This approach is technically effective as a direct physical elimination of the contaminants available to public exposures. However, follow-up inspections and maintenance would be required. Damaged materials will still require abatement. Additionally, renovation of the structure can potentially disturb the ACM/LBP and cause a fiber release and/or lead dust contamination. Based on the current deteriorated condition of the structure, this alternative is an ineffective option.

Potential disadvantages include errors during the application that could potentially release asbestos fibers to the environment, encapsulating materials is not a long-term solution and may fail in some environments. This option also creates a waste generation stream from removal of damaged materials and associated liabilities for the generator. Not all ACM/LBP lends itself to encapsulation, such as window glazing, therefore abatement activities will still be required to remove select materials. Asbestos/LBP that will remain will need to be managed in-place under an operations and management plan that would limit the ability to do certain minor activities such as hanging items on ACM/LBP walls, as well as maintenance activities.

Encapsulation of some of the ACM/LBP that is present within the existing structure is not feasible due to the advanced degradation of the material; the material that is unable to be encapsulated would require removal from the structure. Additionally, as the building has suffered severe structural damage, renovation of the building would present unfeasible costs

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The site-specific climate change conditions identified include increased weather activity which could affect building integrity (damaged from storms). Encapsulation still leaves the asbestos-containing materials and lead-based paint in-place and has the potential for environmental contamination with damage.

4.2.2 Implementability

This alternative is not technically achievable for all ACM/LBP at this project and is deemed an ineffective option for this project, due to the deteriorated state of the structure. Asbestos-containing materials and lead-based paint in the structure are damaged and/or the materials present do not lend themselves to encapsulation. Damaged materials cannot be encapsulated without repair.

4.2.3 Cost

Based upon Terracon’s experience with similar projects, the estimated cost to encapsulate ACM/LBP within the structure is approximately $284,000, including professional environmental consulting services, waste removal/disposal and encapsulation. Additional costs of approximately $115,000 can be anticipated to perform the abatement of the materials not able to be encapsulated due to the current condition of the building or likely to be disturbed by proposed renovations of the facility. Also, portions of the building would have to be rebuilt/remodeled and significant upgrades would be required for the electrical, HVAC, and fire suppression systems throughout the building. The costs for these additional scopes of work are estimated to be approximately $320,000. The total cost for AMC/LBP encapsulation and remodeling of the building is estimated to be $719,000.

4.3 Cleanup Alternative C: No Action

The “no action” scenario is required by the EPA ABCA process. This alternative is to not address contaminants and trust that exposures as airborne particulate/fibers or dust through further weathering and degradation of the structure do not make contaminants available for human exposure by inhalation.

4.3.1 Effectiveness

This alternative is deemed ineffective and unacceptable for continued Brownfield redevelopment for this Site because:

It is likely to be considered unacceptable to the community because citizens, nearby workers and construction workers could unknowingly be placed at risk in the future.

No-action provides neither remedy nor preventive value to site conditions or in support of improved public health.

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This approach is unacceptable technically in that the microscopic asbestos fibers are known human carcinogens and lead is a toxic metal; and neither provide a readily discernable exposure warning mechanism such as odor or other sensory identification.

Without an expensive and long-term outdoor air/dust sampling program, there is no ability to identify if and when residual contaminants may be available for exposure.

The continued presence of ACM and LBP in the building would continue to pose a long-term health risk to the public and also to workers entering the building. The No Action Alternative would make no progress toward achieving the goals of reduction of health risks to the surrounding public and facilitating the demolition of the building for redevelopment.

4.3.2 Implementability

By its definition, taking no action precludes a discussion of implementation. The structure would be left in the unused, deteriorated state in which it currently exists. The identified ACM and potential LBP would still pose a hazard to those entering the building and asbestos fibers/lead would be a continued threat to be released to ambient air. The value of the building would continue to decrease due to deterioration.

4.3.3 Cost

By its definition, taking no action precludes a discussion of cost to implement. This cleanup alternative would not include any specific efforts to remove or maintain ACM/LBP in-place.

There would be no direct cleanup costs associated with this alterative. Further, this alternative may later result in demolition complications, delays, and increased demolition costs due to ACM/LBP remaining within the structures. Direct costs associated with the No Action Alternative and associated non-use of the building would consist of providing site security.

Expanded costs could occur if fugitive asbestos/lead is released during future storms or weathering of damaged structures that might result in secondary deposition and contamination of soils. This would impair re-use and value of surrounding property adjacent to the structure.

4.4 Cost Comparison Alternatives

The table below presents a summary of the estimated costs for all alternatives under consideration. There would be no capital cost if the site were to remain as an unused, vacant building.

ALTERNATIVE CAPITAL COST ANNUAL COST

A – Pre-demolition ACM & LBP $372,000 N/A B – ACM Encapsulation $719,000 $6,000‡

C – No Action $0 $6,000‡

Former Ideal School; AI 251632 ■ Ideal, Georgia

September 30, 2024 ■ Terracon Project No. HP217183, Task 04A1

Facilities | Environmental | Geotechnical | Materials 14

‡ - Includes costs for annual re-inspection of ACMs & LBPs to document condition.

5.0 RECOMMENDED CLEANUP ALTERNATIVE

The recommended cleanup approach is Alternative A: Asbestos Removal Pre-Demolition. This alternative would address exposure risks using a proven approach consistent with recognized industry standards while at the same time easily garnering GA-EPD approval. This option would remain comparably cost-effective under most abatement scenarios and building conditions. ACM removal would not require the need for subsequent inspections, maintenance and/or regulatory oversight. This alternative addresses ACM liabilities, potential contaminant sources or potential limitations to future land use and brownfields redevelopment potential consistent with the City’s goals and re-use planning.