Perry GA FY22 USEPA Brownfield Cleanup Grant .pdf

1211 Washington Street | P.O. Box 2030 | Perry, Georgia 31069-6030 478-508-1571 | http://www.perry-ga.gov/

1. Applicant Identification: City of Perry, 1211Washington Street, P.O. Box 2030, Perry, GA 31069

2. Funding Requested:

a. Grant Type: Single Site Cleanup

b. Federal Funds Requested:

i. $500,000

ii. Not Applicable

iii. Not Applicable

3. Location: a.) City of Perry, b.) Houston County, c.) Georgia

4. Property Information: Stanley Assemblage, 7 parcels totaling 2.7 acres, located at 1101, 1107, 1119, & 1121 Macon Road and 1102 & 1104 Meeting Street, Perry, Georgia 31069

5. Contacts: Project Director: Robert Smith, Assistant Manager, 478-988-2757, robert.smith@perry-ga.gov, 1211Washington Street, P.O. Box 2030, Perry, GA 31069

Chief Executive/Highest Ranking Elected Official: Mayor Randall Walker, 478-988-2700, randall.walker@perry-ga.gov, 1211Washington Street, P.O. Box 2030, Perry, GA 31069

6. Population: City of Perry. Population (www.census.gov): 16,595

7. Other Factors:

Sample Format for Providing Information on the Other Factors Page # Community population is 10,000 or less.

The applicant is, or will assist, a federally recognized Indian tribe or United States territory.

The priority site(s) is impacted by mine-scarred land.

Secured firm leveraging commitment ties directly to the project and will facilitate completion of the project/reuse; secured resource is identified in the Narrative and substantiated in the attached documentation.

The priority site(s) is adjacent to a body of water (i.e., the border of the priority site(s) is contiguous or partially contiguous to the body of water, or would be contiguous or partially contiguous with a body of water but for a street, road, or other public thoroughfare separating them).

The proposed site(s) is in a federally designated flood plain.

The reuse of the proposed cleanup site(s) will facilitate renewable energy from wind, solar, or geothermal energy.

mailto:randall.walker@perry-ga.gov http://www.census.gov/

1211 Washington Street | P.O. Box 2030 | Perry, Georgia 31069-6030 478-508-1571 | http://www.perry-ga.gov/

The reuse of the proposed cleanup site(s) will incorporate energy efficiency measures.

The target area(s) is located within a community in which a coal-fired power plant has recently closed (2011 or later) or is closing.

8. Letter from the State or Tribal Environmental Authority: See attached

9. Releasing Copies of Applications: The applicant understands that the information included will be treated in accordance with 40 CFR §2.203. No passages are considered confidential.

https://www.ecfr.gov/cgi-bin/text-idx?SID=df0298e9bb3c2b42c5e5f4f2454a6eb6&mc=true&node=se40.1.2_1203&rgn=div8 https://www.ecfr.gov/cgi-bin/text-idx?SID=df0298e9bb3c2b42c5e5f4f2454a6eb6&mc=true&node=se40.1.2_1203&rgn=div8

Richard E. Dunn, Director

Land Protection Branch 2 Martin Luther King, Jr. Drive Suite 1054, East Tower Atlanta, Georgia 30334 404-657-8600

October 20, 2021

VIA ELECTRONIC Mail robert.smith@perry-ga.gov Mr. Robert Smith Assistant City Manager 1211 Washington Street P.O. Box 2030 Perry, GA 31069

RE: State Acknowledgement Letter – Brownfield Cleanup Grant Application– Stanley Assemblage 1101, 1107, & 1109 Macon Road and 1102 & 1104 Meeting Street, Perry, Houston County, Georgia

Dear Mr. Smith:

This letter serves as acknowledgement from the Georgia Environmental Protection Division (“GA EPD”) that the City of Perry will be submitting an application to the U.S. Environmental Protection Agency (“EPA”) for funding assistance under the federal Cleanup Grant. GA EPD understands that the City is applying for $500,00 that will be used to clean up petroleum and hazardous constituents on the brownfield property, Stanley Assemblage, located at 1101, 1107, & 1109 Macon Road and 1102 & 1104 Meeting Street, in Perry, Houston County, Georgia (hereinafter “subject property”).

The subject property was accepted into the Georgia Brownfield Program on April 22, 2021 under an approved brownfield corrective action plan (CAP). The CAP enumerates the corrective actions that will be employed to bring the property into compliance with the appropriate cleanup standards.

EPD would like to take this opportunity to encourage EPA’s positive decision in making a grant award to the City of Perry for this cleanup. A successful award would greatly assist the City in its redevelopment efforts. Thank you for your consideration.

File: FFY 2022 EPA Grant Applications, City of Perry-Cleanup Grant mailto:robert.smith@perry-ga.gov

City of Perry, Georgia Stanley Assemblage (ACRES ID#238676), FY2022 USEPA Cleanup Grant

1. PROJECT AREA DESCRIPTION AND PLANS FOR REVITALIZATION

1. a. Target Area and Brownfields

1. a. i. Background and Description of Target Area: After the U.S. Civil War ended in 1865, Perry, Georgia remained a bustling city with textile mills and factories supporting a significant portion of its workforce. However, the jobs that once underpinned the economy of this small town in middle Georgia are now overseas – higher shipping costs outweighed by vastly cheaper labor and raw material costs. The buildings where people once earned a living to provide for their families are all that remain of this prosperous history; now empty, neglected and falling into disrepair. This is the story of the City of Perry.

Founded in 1824, this historic community in Houston County is now home to 16,595 residents and encompasses approximately 27 square-miles along Interstate 75 in the center of Georgia (US Census, 2019 5-year estimates – abbreviated as CENSUS throughout). Textile mills and raw material processing plants were a natural fit for the small community of Perry, at an advantageous location in the geometric center of the largest cotton producing state of the day, and along major transportation routes (stagecoach, railways and later, highways). A healthy ranching industry and complimentary landscape laid the foundation for the meat packing industry to thrive here. The tide turned as significant and transformative changes in the local and national economy took hold in the mid-1990s; one by one the plants in Perry shut their doors, victims of offshore outsourcing. According to state and local records, well over 1,200 living wage jobs were lost in Perry between 1994 and 1998 due to a series of facility closures, including: Textile Mill closure, 434 jobs lost (http://www.georgia.org/competitive-advantages/workforce-division); Northrop Grumman Corporation plant closure, 755 jobs lost (http://cnnfn.cnn.com/1997/01/15/companies/northrop/); and PPG Glass Plant closure, 170 jobs lost (https://www.glassonline.com/ppg-perry-plant-closure-announced/). The closures resulted in the vacancy of hundreds of thousands of square-feet of industrial space, and nearly 30% of the work force lost their job in a three-year time period (Total workforce estimate (1995) 3,914;

http://censusviewer.com/city/GA/Perry ).

Today, more than twenty years later and in a period of robust economic growth nationally, Perry is still struggling to rebrand and rebuild along its commercial corridor. The loss of the textile industry devastated the middle class and left an industrial graveyard behind, which caused the decline of the commercial center of downtown Perry. The City’s period of economic decline is evident in the abandoned commercial properties lining Main Street, Macon Road, and Commerce Street, which serve as the gateway and main thoroughfares in downtown Perry. The target area for this cleanup grant is the downtown Perry district, in which the target site is centrally located; geographically defined by Houston County Census Tract (CT) 212.02. While being the smallest CT in the City, it contains a large portion of its residents (5,658), has the highest minority population (36.8%), (CENSUS). The City prioritized the target area and the target site’s assessment under its FY18 Assessment Grant and has worked diligently to further redevelopment efforts in and adjacent to the census tract as evidenced by the City’s commitment to acquire the Stanley assemblage. Once the cleanup is complete, this site will be shovel ready to create a public park and recreation area that will revitalize the community, remove blight, and address a state-level superfund site plaguing its community.

1. a. ii. Description of the Proposed Brownfield Site(s): The Stanley Assemblage consists of an approximately 2.7-acre assemblage of seven parcels, containing a community center building, water tower, and vacant land formerly improved with a shopping center and dry cleaner. Environmental assessments of the site have revealed soil and groundwater is impacted with dry-cleaning compounds released from the former on-premise dry cleaner.

Situated between Macon Road and Meeting Street, this assemblage is located in downtown Perry at the heavily trafficked corner of Macon Road and Commerce Street, just north of Main Street. Historically, the assemblage supported residential dwellings from the 1930s until it was redeveloped with a thriving commercial shopping center in the 1960s, which included a gym (later converted to the Perry Community Center in the 1980s and now the Perry Arts Center), the Stanley Furniture store, a dry-cleaning facility, and a gas station. The gas station in the southeast corner was decommissioned in the 1970s and leveled to provide parking for the shopping center. The dry cleaner space on the northeast portion was occupied between 1963 and 2011 by various tenants (One Hour Martinizing, Star Cleaners, and Fabra Care), and performed on-premise dry-cleaning using tetrachloroethylene (PCE) between the 1960s and late 1980s. Environmental investigations conducted by the former owner and on behalf of the City under the FY18 Assessment grant verified significant PCE impacts to the soil and groundwater throughout the assemblage, with the potential for contaminant migration via groundwater onto off-site commercial and institutional properties. Additionally, the soil impact was verified to extend onto the neighboring Arts Center property, which hosts community events and public meetings. These impacts were reported to the Georgia Environmental Protection Division (EPD), and the site was subsequently listed on the state’s superfund list, the Hazardous Site Inventory (HSI #10940) in 2017 and entered into the Georgia Brownfield Program in 2021.

Unfortunately, the prior owner of the commercial parcels did not initiate remedial actions as required under the state’s Hazardous Site program. Further compounding the issues, the commercial structure was vacated in 2011 and left in a state of disrepair, which caused asbestos-containing materials in the building to deteriorate. Largely due to the financial limitations caused by the environmental conditions, the blighted environmentally-impaired property was left open for vagrancy and crime in downtown Perry.

Due to the blighting force and immediate health hazards to the community, the City of Perry purchased the property in April 2021, abated the asbestos and demolished the shopping center in August 2021. The approximately 1,500 cubic yards (CY) of impacted soil at the property is mostly covered with asphalt and/or building foundation to act as a temporary cap, limiting resident exposure to impacted soils on the target site.

The rest of the property is vacant with exception of the Arts Center and water tower to the north. This temporary fix is not sustainable, and without near-term action there is potential for PCE exposure to our citizens on a heavily trafficked downtown corridor.

1. b. Revitalization of the Target Area

1. b. i. Reuse Strategy and Alignment with Revitalization Plans: The City of Perry is included in Houston County’s Joint Comprehensive Plan (Plan), which was recently updated in 2017 with significant community input and is currently undergoing community planning meetings for its 2022 update. The Plan focuses on regional strategies, partnerships, and solutions to strengthen and diversify the economic competitiveness and quality of life within the County and City of Perry. Keys to developing a strong diverse economy include addressing blight in downtown Perry, focusing on nodal and smart growth commercial redevelopment along gateway corridors (including Main Street and Highways 127 and 341 in the target area) instead of new structures on undeveloped land, and the need for community facilities such as recreation trails and greenspace.

The Plan’s major long-term work elements specifically include assessment and reuse of priority sites that lay the groundwork for new investments by facilitating interest from private funding and resources, thus creating jobs, as well as generating higher wages, improving property values, and increasing property tax revenues for the City.

As outlined in the Plan, solutions for economic needs align directly with the redevelopment of the target area and Stanley Assemblage (target site). Specifically, the Plan references smart development of Perry’s downtown area, removing blighted properties with cohesive, pedestrian/bicycle-safe connectivity, nodal developments that group homes, shops, and small businesses in attractive mixed-use centers. This redevelopment of sporadic strip shopping centers will focus on continuity of all traffic flow with pedestrian safe walkways and connectivity to recreational trails and pathways. The target site cleanup and redevelopment into a public park ties directly into this plan by creating a safe/attractive walkable connection between gateway thoroughfares into the city center, through the removal a blighted obstacle (parking lot and vacant buildings) which cut-off public walking access along Macon Road. Further, City of Perry ordinances will allow for pocket retail (such as a café) and food truck operations on the target site, furthering the ability for local businesses to reach the community in a safe, walkable destination within the downtown district.

The redevelopment strategy for the Stanley Assemblage (Target Site) is to create a recreational and interactive greenspace on the former shopping center portion of the property (approximately 1.4 acres).

Specifically, this development will serve as an extension of the Perry Arts Center event and educational space, with immersive educational landscapes such as interactive signage, exhibits, and outdoor classroom space that will teach the public about Perry’s local natural wildlife and cultural history. In addition, this greenspace will provide pedestrian safe pathways, connecting the downtown center to the commercial corridor along Main Street and Highways 127 and 341, which directly aligns with the Plan. This redevelopment plan, heavily influenced by community residents, intends to energize Perry’s blighted downtown which in turn will spur the local economy with smart infill development.

1. b. ii. Outcomes and Benefits of Reuse Strategy: This project’s outcomes and benefits will directly correlate with the 2017 Comprehensive Plan, by promoting key objectives from this plan and working in concert with additional economic incentive initiatives such as the Federal Opportunity Zone surrounding the target area. The resulting outcomes will benefit the target area’s disadvantaged communities as well as the City’s business community and overall population. To support this effort, this project will provide design phase assessment, cleanup planning, and reuse planning services necessary to position the target property for redevelopment as a greenspace with open air educational features and classroom space, pedestrian safe pathways, and community event space, with the option for a children’s park with play equipment, and pocket retail or food trucks and farm stands (a top priority identified by the community). Previously, after the property was vacated, the parking lot of the shopping center served as the location of a popup farm stand, selling fresh fruit and vegetables to a neighborhood denoted “Low Access” on the USDA Food Access Research Atlas (census tracts in which at least 33% of an urban population lives farther than 1 mile from the nearest supermarket). The City has expressed interest in keeping this farm stand, but in a more safe and pedestrian friendly location in the proposed greenspace redevelopment.

In addition to addressing food insecurity, the redevelopment of this blighted property into a communal greenspace will benefit the surrounding disadvantaged community by linking existing plans for new pathway networks providing pedestrian safe public greenspace and pathways, which is greatly desired considering City’s high rate of households without a vehicle (17.5% vs. the state average of 6.5%, USC, 2019). This safe public greenspace will reduce crime and blight, and increase the desirability for mixed-use development in downtown Perry. Finally, the City is developing plans to power the interactive components of the proposed greenspace, as well as the community arts center, through a mix of renewable energy methods, including a 68-megawatt solar farm six miles south of Perry that is currently under construction.

A more direct and significant benefit is the remediation of a state-level superfund site that adversely impacts the City’s residents via potential direct exposure to contaminated soil, as well as the potential to vapor intrusion from impacted soil and ground water.

1. c. Strategy for Leveraging Resources

1. c. i. Resources Needed for Site Reuse: The reuse and redevelopment projects proposed in this brownfield cleanup project will require both public and private investment. The City’s FY18 EPA Assessment Grant has expended funds to assess key properties in the target area, including the Eastgate Shopping Center along Highway 127 and the Walker Rhodes Tractor repair facility, both of which are currently scheduled for redevelopment. The FY18 grant also funded $93,750 on the Stanley Assemblage (target site), which funded a Phase I ESAs, a Phase II ESA, one asbestos and lead-based paint inspection, two supplemental soil and groundwater investigations, entry into the Georgia EPD Brownfields program, Analysis Brownfield Cleanup Alternative cleanup planning, and an updated Phase I ESA prior to site acquisition. To aid in supporting the interactive/educational components planned for the target site redevelopment, the City is developing a strategy to cultivate local and regional corporate donor, private benefactor, and/or philanthropic contributions.

In addition, for the target site, the City has invested $75,000 out of its general funds to acquire the blighted property from the previous owner and an additional $116,000 to address the asbestos abatement and building demolition. Further, the City is planning to apply for a USDA grant of up to $50,000 to provide support the development of its community greenspace. This demonstrates the City’s commitment to ensuring redevelopment of the target site. Additional resources being considered include Georgia Department of

Transportation (GDOT) funding for road improvements on corridors leading to the target area from nearby I- 75.

1. c. ii. Use of Existing Infrastructure: The City is working to utilize existing infrastructure and create sustainable development opportunities within the target area. The Stanley Assemblage site has an existing building (community arts center), roadways, and utilities, such as power, water, sewer, and broadband. These grant activities will help the City of Perry preserve the existing water tower by removing contaminated soil around this critical piece of infrastructure, and understand the short- and long-term availability of public and private infrastructure servicing the brownfield sites and to identify necessary infrastructure improvements and priority investments as outlined in the Plan, such as transport and accessibility to its downtown corridor.

Currently, Perry is working with GDOT to access funding for road improvements in the target area.

2. COMMUNITY NEED AND COMMUNITY ENGAGEMENT

2. a. Community Need

2. a. i. The Community’s Need for Funding: The City’s median household income is only $49,219 (vs.

$58,700 in the state) and 26% of households have a median income below $25,000 (CENSUS). Moreover, with a small population and therefore small tax base, local taxes are barely sufficient to support normal government operations. Absent intervention, the City will struggle to transition the target area’s historic building stock into a valued community resource for jobs and improved community aesthetics, ultimately leading to an attractive market for goods and service providers such as grocery stores. Local businesses have been struggling and do not generate enough sales tax revenue for the City to combat blight in the target areas, or elsewhere in the community, driving the need for outside funding to aid in rehabilitating the target area.

This will ultimately foster the development of important tax base resources. Due to the existing economic limitations and small population (<20,000), the City has limited discretionary resources to implement remediation and reuse projects without this EPA grant. Given the extent of environmental impacts, EPA funding will allow the City to comprehensively characterize and excavate over 1,500 CY of hazardous soil, delineate groundwater impacts, design and implement groundwater remediation, and complete additional reuse planning, as described in section 3 that would not otherwise be possible. Ultimately, the grant funds will be used to transform this site into a safe centrally located communal greenspace and food truck/farm stand venue, which will encourage redevelopment in the surrounding commercial corridor in downtown Perry.

With assistance from this grant, the City will be able to complete a key piece in the target area’s reuse strategy, and provide a public asset which will directly benefit a portion of our population most in need of safe walkable infrastructure and access to goods and services. This need is apparent in the lack of grocery stores and other healthy food providers in the City’s business district, evidenced by the CT being in a low-income food desert due to lack of transportation options (USDA), limiting the ability for low-income residents (84th percentile EJScreen for low-income population in comparison to the state) to easily access these goods and services. This hardship is compounded by the City’s high rate of households without a vehicle (17.5% vs.

the state average of 6.5%, CENSUS).

2.a.ii. Threats to Sensitive Populations

(1) Health or Welfare of Sensitive Populations: The City of Perry is home to several sensitive populations, including: minors (24% aged <18); disabled (10.7%); families living below the poverty line (14.1%); and minority residents (mainly African American at 36%; CENSUS). The target area’s populations for ages under 5 and over 64 are listed in the EJ Demographic Indicators in 92nd and 64th percentiles, respectively, in comparison to the state. Additionally, the EJ Demographic Indicator for low income populations in the target area is in 84th percentile when compared to the state (EJScreen). African-American residents in CT 212.06 are nearly three times more likely to live in poverty as compared to white residents and have a $35,755 household income, which is significantly lower than the rest of the City ($49,219) and state ($58,700) (CENSUS). The unemployment levels increased dramatically with COVID-19, which prompted a 6-percentage point increase in jobless rates with a disproportionate impact on minority workers, statistically twice as likely to experience unemployment during the pandemic (GA DOL). According to CENSUS data, the 6.3% of the City population is unemployed, nearly double the percentage listed for the nation (3.4%).

Sensitive populations are more susceptible to the risks of exposure to environmental contamination suspected at the Stanley Assemblage site. Residents in the target area are exposed to dangerous constituents through a variety of ways, especially citizens located in single-family residences and a multi-family apartment complex located adjacent to the north of the community arts center, less than 200 feet away from documented soil and groundwater impacts. The known PCE plume in soil and groundwater has the potential to further migrate into this residential area, as well as nearby commercial business to the west and south, causing respiratory issues and cancer from prolonged vapor intrusion exposure to volatile organic compounds.

Additionally, without near-term corrective action contaminated soils containing dry-cleaning compounds may continue to leach into the groundwater table resulting in increased groundwater concentrations, or migrate onto neighboring properties via dust or storm water runoff.

Given the blighted unsecure state of the Stanley Assemblage (target site), efforts to keep trespassers and criminal activity out were determined to be futile. Due to immediate health concerns from the known asbestos and lead-based paint impacts and overall dilapidated condition of the commercial structure, the City could not wait and elected to abate asbestos/lead and demolish the structure with its own general funds. Unfortunately, the target site in its current form is unfenced and is open to the public, with the asphalt parking lot and the former concrete foundation acting as a temporary barrier over the heavily impacted soil. By redeveloping the Stanley Assemblage site in the target area, known environmental impacts that affect the health of our citizens will be cleaned up, blight will be removed, and will increase the overall quality of life for surrounding sensitive populations.

(2) Greater Than Normal Incidence of Disease and Adverse Health Conditions: Area Health data is available at the county level: in Houston County, 15.4% (6.5% higher than Georgia overall) of adults and 9.5% of children are affected by asthma, and another 10% have been diagnosed with COPD (2020 Community Health Needs Assessment). In the 2021 Houston County Community Health Needs Assessment, the annual average death rate per 100,000 persons for Chronic Lung Disease was significantly higher in Houston than in the state and US; 57.2 for Houston as compared to 46.4 in Georgia and 40.4 in the US. People with these respiratory diseases are especially sensitive to poor air quality and are disproportionately affected by airborne contaminates, such as VOC-contaminated dust originating from the Stanley Assemblage. Benzene in petroleum and dry-cleaning solvents (such as PCE) are known carcinogens. Area residents can be exposed to benzene and PCE through inhalation of vapors from migrating groundwater, or by direct contact with contaminated soils since the site is unsecured and only partially paved (atsdr.cdc.gov). The annual average death rate per 100,000 persons in Houston with lung cancer is 42.6 vs. 39.0 in the state and 36.6 in the US (2021 Houston County Community Health Needs Assessment). Like many cities in Georgia, Perry was affected by Covid-19 and with a population consisting of 36% African Americans, a group more highly affected by the virus, the city was greatly affected by the impacts of the pandemic (CDC).

(3) Promoting Environmental Justice: The 1-mile radius around the Stanley Assemblage have the following EJ Index percentiles in comparison to the EPA Region:

PM 2.5 NATA Cancer Risk

NATA

Respiratory HI

Lead Paint Indicator

Hazardous Waste Proximity

68 68 69 75 73

As indicated by EPA EJ Screen, the Stanley Assemblage site and overall target area are in an area with greater environmental risk for cancer, respiratory health problems, and particulate dust, which indicates an environmental impact to the City. Implementation of this grant will help the community cleanup and achieve what we would otherwise struggle to accomplish due to limited financial resources. Cleanup of the Stanley

Assemblage site will be one step of many the City of Perry can take to begin to correct for decades-long environmental injustices disproportionately endured by the African American population. Over the past 40+ years, these community members have (and continue to):

borne a disproportionate burden of exposure to harmful contaminants compared to other residents in the city;

experienced a disproportionate amount of negative health issues and outcomes as compared to their white counterparts in Perry;

endured a significantly lower quality of life than other Perry residents;

enjoyed significantly less access to quality open spaces, trails, and recreational amenities than other Perry residents; and had little access to retail outlets, jobs, and economic opportunity as their neighborhood has faced decades of disinvestment and isolation associated with brownfield conditions of the Stanley Assemblage site.

Encouraging the reuse of the site, as outlined in our comprehensive plan, will attract new commercial developments that will help facilitate local job growth, increase access to safe walkable trails and greenspace, and promote healthier communities. Moreover, the outcomes of this project would facilitate the abatement or mitigation of known and contributing factors currently present on a brownfield property and facilitate redevelopment that would have positive benefits and create a means for the City to address these disparities.

2. b. Community Engagement

2. b. i.-ii. Project Involvement and Project Roles: The City of Perry has successfully engaged the community through recent planning events like the Houston County 2022 Comprehensive Plan Update and its FY18 EPA Brownfields Assessment Grant. The City will build off existing community involvement efforts.

Project partners will facilitate community involvement in the brownfields project as described below. Perry is a small rural community with limited numbers of available local partners. However, the City has been able to foster significant support, regardless of perceived limited resources, through communication with schools, non-profits, and word of mouth. Below are community organizations that have made firm commitments to planning and implementation of the EPA Brownfields Cleanup Grant:

Community Based Organization

Contact Information Role

Central Georgia Technical College

Andrea Griner, VP for ED agriner@centralgatech.edu

Workforce Training Partner

Perry Main Street Advisory Board Jazmin Thomas, Downtown Manager

Jazmin.thomas@perry-ga.gov

Promotion, marketing, and redevelopment of the targeted corridor.

Perry Downtown Development Authority

Marketing, outreach, and information dissemination to Downtown District.

Steering Committee Service.

Faith Bible Fellowship Willie King, Pastor & Councilmember Willie.king@perry-ga.gov

Outreach to African American Community, Provide Meeting Space, Steering Committee Service.

Habitat for Humanity Bill Goggins, Executive Director hocohabitat@att.net

Will commit to service on steering committee

Perry Chamber of Commerce

Maggie Schuyler, President maggie@perrygachamber.com

Moving into project area, Meeting Space & Outreach

iii. Incorporating Community Input: The City will build on the community involvement activities under its successful FY2018 EPA Brownfields Assessment Grant to communicate progress and solicit input on cleanup/reuse plans. The existing Community Involvement Plan is designed to explain and communicate project activities to the target community as a whole, and appropriate interested parties, including its Hispanic population. While Covid-19 has changed the way community input occurs, it has not stalled resident engagement. Specific to the subject site, the City met with residents of the immediate neighborhood to the north, commercial business owners, the community center, and the Main Street Advisory Board, all through a series of Zoom meetings. Two in-person public meetings were held to discuss this proposal on Wednesday, October 30th and November 4th, and 6 attendees were present; additionally, the meetings were covered by local news outlets who published online articles and broadcast television stories spotlighting the proposed cleanup and application for EPA Cleanup grant funding. Moving forward, the City will display meeting notices on the LED board outside of City Hall approximately 0.15 miles northwest of the target site. Info will also be emailed, announced at neighborhood meetings, and updated on the City website and social media platforms (Facebook & Twitter) in English and Spanish. The City will use their committed partners and a variety of media (mailings, postings at transit stops, social media) to engage the local community throughout the grant cycle. In the event that the community experiences high volumes of people affected by Covid-19, social distancing will be implemented, such as virtual meetings conducted via Zoom. Prior to conducting cleanup activities, the City will host a community-wide forum where residents and stakeholders will have the opportunity to learn about proposed cleanup plans and provide comment and input on the final cleanup decisions. Four community meetings/charrettes are planned for the project. The City will evaluate all suggestions and will respond to the input.

3. TASK DESCRIPTIONS, COST ESTIMATES, AND MEASURING OUTPUTS

3.a. Proposed Cleanup Plan: A draft Analysis of Brownfield Cleanup Alternatives (ABCA) was completed in October 2021. The document summarized the findings of assessment work completed and presented three environmental cleanup alternatives for each of the recognized environmental concerns identified. In summary, the following issues were identified with the appropriate cleanup plan selected based on cleanup standard and intended reuse.

Soil Contamination (PCE): Given the potential to impact human health and the environment, the selected alternative is excavation, proper disposal (at a Subtitle D landfill) of 1,500 CY of impacted soil, and backfilling and compacting with clean soil. At this time, PCE impacts are primarily located in the upper 3 feet, in an area around the former dry cleaners and extending north onto the Perry Arts Center and water tower areas, with deeper impacts (0-15′) at the northwest portion of the former dry cleaners. Additional sampling to confirm the vertical and horizontal extent of impacted soil is proposed as confirmatory sampling during excavation. Once delineated to within applicable regulatory limits, the impacted soil will be excavated, profiled and transported off site for disposal. If impacts are encountered at depths greater than anticipated based on assessment results, then additional soil excavation may be required to achieve unconditional closure status. A contingency has been built into the cleanup budget to account for any unforeseen cost overages, and is reflected in the following section. To profile for proper disposal, a toxicity characteristic leachate procedure (TCLP) VOC test will be performed on all soil, asphalt parking, and concrete building slab waste removed from the site.

Groundwater Contamination (PCE): While the target site is currently enrolled in the Georgia Brownfields program, which offers limitation of liability from dissolved phase groundwater impacts, it is also listed under the Georgia Hazardous Site Inventory (HSI) or state superfund program. To facilitate compliance with HSI cleanup assessment and cleanup procedures, further assessment of groundwater will be required to determine the extent of impacts from dry cleaning solvents and resulting exposure pathways on the target site and nearby properties. After PCE source soil removal, further groundwater investigation is required. Currently three shallow aquifer monitoring wells are located on-site, with an average depth of 50 feet below ground surface (bgs). Based on discussions with Georgia EPD, a minimum of three additional shallow aquifer wells (one located upgradient and two located downgradient) and one deep aquifer well at the source is needed to adequately delineate impacts and verify groundwater flow direction. If necessary, additional monitoring wells may be required off-site to further delineate the downgradient extent of the PCE plume. As mentioned above, a contingency is included in the budget to account for this potential.

3.b. Description of Tasks/Activities and Outputs:

Task/Activity 1: Programmatic Support

i. Project Implementation EPA Funded Activities: cooperative agreement oversight; budget management, scheduling and coordinating of subcontractors, monthly team meetings (Qualified Environmental Professional (QEP)/City); quarterly and annual reporting to EPA; ACRES entries; final report and closeout documentation; annual reporting; Davis-Bacon & Historic Preservation; City staff travel to conferences, workshops for purposes of staff development and improvement of project efficiencies Non-EPA grant resources needed: Oversight by Project Director (Robert Perry) and City Staff

ii. Anticipated Project Schedule: Pre-award through closeout in Month 15; kick-off meeting in Month 1 (October 2022); monthly status meetings (Months 1-15); quarterly reports (Months 4, 7, 10, 13, 15);

closeout report in Month 15

iii. Task/Activity Lead (s): Project Director with support from QEP and project staff

iv. Output(s): quarterly reports, ACRES data entry; notes from monthly team meetings; close-out report Task/Activity 2: Community Involvement

i. Project Implementation EPA Funded Activities: completion of CIP, community meetings/charrettes to provide updates on cleanup process/progress; preparation of Stanley Assemblage Brownfield Brochures Non-EPA grant resources needed: in-kind resources including project team staff effort and efforts of community partners who will host and promote participation of community members

ii. Anticipated Project Schedule: Pre-award through closeout in Month 15; the CIP and Brochure will be created pre-award. The first community meetings/design charrettes is planned during months 0-3, with the remaining three meetings/charrettes during Months 3-15.

iii. Task/Activity Lead(s): Project Director with support from QEP and project staff

iv. Output(s): CIP; Stanley Assemblage Brownfield Brochure; 4 community meetings/charrettes with response to comments/documentation Task/Activity 3: Cleanup & Reuse Planning

i. Project Implementation EPA Funded Activities: Final ABCA; Development of QAPP and HASP;

Corrective Action Plan (CAP) under GA EPD HSI Program and Compliance Status Report (CSR) for GA EPD Brownfield review/approval. Reuse Planning: Revisions to existing site plan to incorporate additional community feedback and to ensure community benefit.

Non-EPA grant resources needed: Project Director/City staff oversight and coordination with GA EPD

ii. Anticipated Project Schedule: Cleanup Planning: Months 1-4 (ABCA will be subject to public input);

Reuse Planning: Months 1-15

iii. Task/Activity Lead(s): QEP with oversight by the City project director and technical director

iv. Output(s): Cleanup Planning: Final ABCA; QAPP and HASP; CAP for HSI and CSR for Brownfield Program; Reuse Planning: Revised site plans per environmental and community input considerations Task/Activity 4: Cleanup Activities Project Implementation EPA-funded activities: Soil excavation, testing/confirmatory sampling; disposal at Subtitle D landfill; soil backfill; groundwater delineation and sampling; groundwater monitoring and summary report; compliance reporting.

Non-EPA grant resources needed: Project Director/City staff oversight.

ii. Anticipated Project Schedule: Months 2-5 soil excavations, disposal, and backfilling; Months 5-10 groundwater delineation and modeling; Months 10-15: compliance reporting

iii. Task/Activity Lead(s): Project Director with assistance from QEP

iv. Output(s): Removal of approximately 1,500 CY of soil impacted with PCE; delineation of groundwater with adequate plume maps and groundwater flow.

3.b. Cost Estimates: The City is requesting a $500,000 Brownfields Cleanup grant.

Budget Categories Project Tasks ($)

Total Task 1 Task 2 Task 3 Task 4 Programmatic

Support Community Involvement

Cleanup & Reuse Planning

Cleanup Activities

D ire ct

C os t Travel $5,000 $0 $0 $0 $5,000.00 Supplies $0 $3,000 $0 $0 $3,000.00 Contractual $20,000 $20,000 $72,000 $480,000 $592,000

Total Direct Costs $25,000 $23,000 $72,000 $480,000 $600,000.00 Federal Funding $20,833 $19,167 $60,000 $400,000 $500,000.00 Cost Share $4,167 $3,833 $12,000 $80,000 $100,000.00 Total Budget $25,000 $23,000 $72,000 $480,000 $600,000.00

(Note Personnel, Fringe Benefits, Equipment, Other, and Indirect Costs not shown as amounts are zero.)

Task 1: Programmatic Support: $5,000 for travel to two EPA National Brownfields conferences and/or regional brownfields events for one City staff member (includes approximate costs of $800 in registration fees, $2,000 for 8 nights @ $250/night in the conference hotel(s), $1,200 airfare for 2 round trip tickets, $400 ground transportation/parking and $600 per diem expenses for 8 days @ $75 per day). Any remaining travel funds will be utilized by city staff for travel to meet with local/regional developers or property owners. $20,000 contractual support is also allocated to this task for the QEP to support city staff in drafting reports, updating EPA ACRES, scheduling meetings, Davis Bacon Act and Historic Preservation reporting, and overall project management activities ($125 per hour for 160 hours over the project period) Total: $25,000 Task 2: Community Involvement: One Community Involvement Plan (CIP) at a set fee of $4,000; four community engagement meetings with contractual support in planning and delivery at $16,000 ($125 per hour for 128 hours of work over the project period). City supplies (marketing materials, flyers, posters): $3,000.

Total: $23,000 Task 3: Cleanup & Reuse Planning: Final ABCA $5,000 (40 hrs @ $125); QAPP and H&S Plan will be created by the QEP for $10,000 (80 hrs @ $125); Corrective Action Plan (CAP) for GA HSI: $12,000 (96 hrs @ $125); and Compliance Status Report (CSR) for GA BF $15,000 (120 hrs @ $125). Reuse Planning: Updated site plans, including engineering considerations, will be produced for an estimated cost of $30,000 (240 hrs @ $125). Total: $72,000 Task 4: Cleanup Activities: Soil Remediation – Design and Subcontract Bidding: $15,000 (120 hrs @ $125);

Site Preparation (permitting, erosion and sediment control measures, utility locate, etc.): $10,000 (80 hrs @ $125); Soil Remediation: $240,000 - Excavation, disposal, and backfilling of approximately 1,500 CY (@ $160/CY); Project Oversight and Soil Sampling: $35,000 (10 days @ $2,000 plus rush analytical sampling).

Groundwater Delineation – Four new monitoring wells and two sampling events, with available budget for additional wells/sampling events as needed: $75,000; Groundwater Vapor Assessment and/or Modeling - $15,000 (120 hrs @ $125); Groundwater Summary Report with Remedial Action Recommendations (if necessary): $10,000 (80 hrs @ $125). Contingency: $80,000 (approx. 20%) will be available in the event additional remedial efforts are needed. Total: $480,000.

3.c. Measuring Environmental Results: The Project Director with support from key staff and the QEP will document, track, and evaluate the following outputs and outcomes continually through quarterly progress reports, annual disadvantaged business enterprise reporting, and in monthly calls with the EPA Project Officer.

The activities and outcomes will be tracked through an Excel project management spreadsheet, invoice management system, through EPA ACRES, and documented in a final closeout report. Outputs: CIP, Brownfields Brochure, final ABCA, cleanup design, selection of remedial contractors, completion of soil excavation, groundwater delineation, groundwater monitoring, compliance reports (CAP, CSR), and overall cleanup completion report. Outcomes: Acres of land redeveloped and community benefit from public greenspace positioned for adaptive reuse; amount of private investment and other funding leveraged; jobs created or retained; increased property and sales tax revenue generated. An overall gauge of success will be acres of land redeveloped, the creation of temporary jobs during cleanup and improvements in environmental justice concerns (reduction of blight, access to greenspace and food stands, and removal of contaminants from environment). Most importantly, the cleanup and redevelopment of the Stanly Assemblage as a public space will serve to further improve the City of Perry’s downtown by providing a venue for all to enjoy.

4. PROGROMMATIC CAPABILITY AND PAST PERFORMANCE

a. Programmatic Capability

i. Organizational Capacity ii. Organizational Structure and iii. Description of Key Staff: The City of Perry has the internal capability to manage all technical and administrative aspects of the subject grant.

Robert Smith, the City of Perry’s Assistant City Manager will serve as Project Director. Mr. Smith has eight years’ experience in municipal government and holds a Master’s degree in Public Administration. He has successfully administered a wide array of local, state, and federal grants including CDBG grants, EDA grants, and DNR grants. As manager of the Department of Economic Development for the City of Perry, Robert works with Mayor and Council which includes oversight of the Perry Main Street Advisory Board and associated Perry Downtown Development Authority. Mr. Smith will be assisted by Ansley Fitzner, Public Works Superintendent, who will serve as Project Coordinator. Mr. Smith will also serve as the Financial Director, ensuring compliance with all terms and conditions and financial obligations under this grant. In addition, the City will dedicate an on-staff communications manager to the project. Ms. Fitzner will serve as Public Outreach Communications Manager and will be responsible for successful implementation of the City’s formal CIP, program materials, newsletters and media updates.

iv. Acquiring Additional Resources: The funding used to develop the ABCA for this project was completed by the City’s QEP under our FY18 EPA Assessment grant, contracted in accordance with local and federal procurement requirements at 40 CFR 200.317-200.326, which included the advertisement of a Request for Qualifications and the review of multiple proposals by a selection committee. Under a separate procurement process, City will select a QEP for this Cleanup grant project through a fair and open bid process, fully consistent with federal procurement requirements 2 CFR 200 and EPA’s Rule 2 CFR 1500. We will select a QEP with experience in Brownfield Cleanup project implementation. Procurement of any licensed abatement contractors or subcontractor(s) will follow all state and federal fair and open competition requirements as outlined in 2 CFR Part 200 and Part 1500. The City has formal systems in place to replace critical staff and hire additional contractors, if needed.

b. Past Performance and Accomplishments

i. Currently Has or Previously Received an EPA Brownfields Grant

(1) Accomplishments: The City received a FY2018 EPA Assessment Grant. The project team who achieved the results outlined in the table below remain the same. These accomplishments have been recorded in the EPA ACRES Database.

Agency Program Amount Funds Remaining Date Grant Accomplishments US EPA Brownfields

Assessment $300,000 $33,007.04 as of 9/10/21 2018 8 Phase I ESAs, marketing materials; 8 asbestos surveys, one wetland assessment, and 9 Phase II ESAs (ACRES as of 10/21/21)

(2) Compliance with Grant Requirements: The City complied with work plans, schedules, terms and conditions for the FY18 grant. Quarterly reports and deliverables were submitted to EPA and entered into ACRES in a timely fashion. All terms/conditions have been met. As of September 23, 2021, 85% of funds have been drawn down in ASAP. The City will submit its closeout report in the next quarter with no funds remaining as the activities conducted over the last two months of the project have indeed utilized those funds, and the invoices are in the payment process.

Stanley Assemblage, FY2022 USEPA Cleanup Grant

Documentation of Leveraged Funds

321114Invoice # :

Invoice Date :

**Invoice Group :

0002420000Project :

10/27/2021

City of Perry, GA PO Box 2030 Perry GA 31069

Robert SmithAttention:

For Professional Services Rendered through:

Contract Number:

Project Name : ATLBF Perry,GA EPA Assessment Grant 9/30/2021

Comp Amount CurrentPrevious

AmountPhase FeePhase Code / Name Pct.Total Invoiced

To Date

95.33 10,486.34 0.00 11,000.00A1 -- Meetings & Correspondence 10,486.34

100.00 5,000.00 0.00 5,000.00A2 -- Quarterly Reporting 5,000.00

100.00 2,000.00 0.00 2,000.00A3 -- ACRES Support & Forms 2,000.00

0.00 0.00 0.00 2,000.00A4 -- Closeout Reporting 0.00

100.00 3,000.00 0.00 3,000.00B1 -- CIP Development 3,000.00

83.63 3,629.44 1,922.65 6,638.67B2 -- Community Mtg Attendence 5,552.09

100.00 2,000.00 0.00 2,000.00B3 -- Property Owner Meetings 2,000.00

100.00 5,000.00 0.00 5,000.00C1 -- Generic QAPP 5,000.00

100.00 8,100.00 0.00 8,100.00C2A -- Stanley Phase I/ ALBP 8,100.00

100.00 3,500.00 0.00 3,500.00C2AA -- Stanley Assemblage SSQAPP 3,500.00

100.00 3,500.00 0.00 3,500.00C2B -- Eastgate Shopping Ctr Phase I ESA 3,500.00

100.00 5,600.00 0.00 5,600.00C2C -- Hwy 341 Service Station Phase I ESA 5,600.00

100.00 5,600.00 0.00 5,600.00C2D -- Goodroe Site Phase I ESA 5,600.00

100.00 14,000.00 0.00 14,000.00C2E -- Kellwood Phase I ESA/ACM 14,000.00

100.00 3,200.00 0.00 3,200.00C2F -- 203 South St PH I ESA 3,200.00

100.00 3,600.00 0.00 3,600.00C2G -- Jernigan Property PH I ESA 3,600.00

89.13 1,782.50 0.00 2,000.00C2I -- Stanley Assemblage Ph I Update 1,782.50

100.00 39,800.00 0.00 39,800.00C3A -- Phase II ESA Stanley Assemblage 39,800.00

100.00 17,250.00 0.00 17,250.00C3B -- Phase II ESA Perry Community Center 17,250.00

100.00 30,650.00 0.00 30,650.00C3C -- Phase II ESA Eastgate 30,650.00

100.00 23,000.00 0.00 23,000.00C3D -- Phase II ESA 203 South St 23,000.00

100.00 2,750.00 0.00 2,750.00C3E -- Stanley GW Sampling 2,750.00

100.00 40,800.00 0.00 40,800.00C3F -- Walker…