The  CMC Roundhouse proposal was written for Powell County and Sage Resources of Missoula, Mont., in application for a grant from the Montana Department of Environmental Quality.

Reclamation and Development Grants Program

Grant Application for:

Site Cleanup:

CMC Roundhouse,

Deer Lodge, Montana

Submitted by:

Powell County Commissioners

409 Missouri Avenue

Deer Lodge, Montana 59722

Mr. Tom Hatch, Chair

Submitted To:

Department of Natural Resources and Conservation

Conservation and Resource Development Division

Resource Development Bureau

1625 Eleventh Avenue

Helena, Montana

TABLE OF CONTENTS

1                   Grant Application Summary

2                   Project Abstract

3                   Technical Description and Alternative Analysis

4                   Scope of Work

5                   Budget

6                   Public Benefits Narrative

7                   Need and Urgency Narrative

8                   Project Management and Organization

9                   Environmental Checklists

10             Liable Party Determination

11             Crucial State Need Documentation

12             Application Checklist

STEP 2- PROJECT ABSTRACT

Project Title:                 Site Cleanup: CMC Roundhouse,

                                      Deer Lodge, Montana

Project Sponsor:           Powell County Commissioners

This project will enable PowellCounty to remove petroleum, and other industrial-related, contamination from the former Chicago-Milwaukee Railroad Roundhouse facility.  Specific activities to be funded will include;

• Complete a detailed site assessment and characterization of the site,
• Remove the concrete fuel tank,
• Remove the oil separator and underground waste lines,
• Remove soils contamination at the roundhouse,
• Remove various areas of contaminated soils on the site,
• Support DEQ efforts for CECRA site remediation and closure

During the last 10 years the Montana Department of Environmental Quality (DEQ) has struggled to fully assess the environmental damage at this site.  The site is on the Montana State Superfund (CECRA) list and has been ranked as a “high priority” site, but the DEQ has not had the necessary funding to manage the site remediation.  This project will allow local government, in concert with the DEQ, to implement necessary remediation activities for the benefit of the entire Butte Economic Region.

Support and commitment from the State of Montana is critical to the success of this project.  The project area and the surrounding lands are a prime economic and environmental resource.  The immediate environmental mitigation of industrial related contamination will ensure this site becomes an important economic component of the Butte Economic Region, PowellCounty and the City of Deer Lodge.

The eventual reclamation and redevelopment of this site will have an important impact on the immediate economies and the region in general.  This project will provide the support and leverage needed to bring a number of other investment and funding mechanisms to bear on the local community and local natural resources.  Brownfield (EPA) and Economic Development Administration (EDA) funding applications are currently underway and this project will provide an important initial support for those efforts.

The CMC Roundhouse site can be fully, and effectively, remediated through the funding of this program.  The project site has lain bare, underutilized, and potentially polluting for the past 20 years.  The dedicated effort, funded by this grant, can remove this site from the CECRA listing.  Now is the time to support these local, and DEQ, efforts in cleaning the site and returning the area to a productive use of natural and economic resources.

STEP 3- TECHNICAL DESCRIPTION AND ALTERNATIVE ANALYSIS

The CMC Roundhouse site is located adjacent to the city limits of Deer Lodge, Montana (Figure 1).  The site is currently owned by the CMC Real Estate Corporation, located in Chicago, Illinois. The roundhouse was built in 1908, abandoned in 1980, and demolished in 1984.  The roundhouse area contained refueling and repair facilities for the electrified rail line between Harlowton, Montana, and Avery, Idaho.  Steam and electric engines were serviced and refueled at the site.

Previous remedial investigations at the CMC Roundhouse have defined elevated levels of volatile organic compounds (VOCs), diesel range organics (DRO and TEH), and oil/grease substances.  A significant amount of information has been obtained from these studies.  A detailed site characterization is needed to assimilate this information and complete remediation planning.  Future redevelopment activities require CECRA site closure.

The principal contaminants of concern include heavy petroleum fuels (Bunker C), diesel and waste oils.  Known and potential sources of contamination include the concrete storage tank, the former oil separator area, various contaminated surface soils, and the former roundhouse.

Steam engine fuel (Bunker C) was stored in a large underground concrete tank (Figure 2) located approximately 700 feet north of the roundhouse.  The tank was approximately 120 feet long, 70 feet wide, and 10 feet deep.  The tank was abandoned and backfilled with debris and nearby fill in the 1950’s.  An above ground tank, also used to store Bunker C fuel, was located north of the concrete tank, but removed in 1980.

An oil separator was located 80 feet north of the roundhouse and collected waste oil and water from the roundhouse operations.  A gravity drain system extended from the oil separator to a series of sumps, ending at a large wood-lined sump located on TinCupJoeCreek near the north end of the site.  The last sump was removed in March of 1999.

The former roundhouse is located near the southern end of the site.  The roundhouse was used for lacquering train cars and lacquer solvents may have been used, and disposed of, in and near the roundhouse. The repair shop was located 300 feet south of the roundhouse and various degreasing solvents may have been used and disposed of nearby. Analytical results, from groundwater monitoring wells, are below recommended clean-up guidance levels.

Numerous small areas of petroleum contamination occur throughout the site, removed from the around the storage tank and oil separator.  These areas have noticeable surface staining, asphalt surface waste, contaminated subsurface soils, and/or strong petroleum odors during warm summer days.

PREVIOUS INVESTIGATIONS

Six remedial investigations have been completed at the CMC Roundhouse.  Progress to this point includes the installation of a monitoring well network, soil/groundwater sampling, removal of one sump tank, excavation of 37 test pits, and analytical testing.  The individual studies include;

1. Preliminary Characterization of a Fuel Containment Area at Deer Lodge, Montana (Phase I, II, III), Hydrometrics, 1989.
2. Final Report for Milwaukee Roundhouse, Deer Lodge, Montana. MSE, August, 1990.
3. Milwaukee Roundhouse Prescore, Deer Lodge, Montana, Ecology and Environment Inc, August, 1991.
4. Expanded Site Inspection Report for the Milwaukee Roundhouse Site, Deer Lodge, Montana, Pioneer, October 14, 1993.
5. Additional Activities at the CMC Milwaukee Roundhouse Site, Deer Lodge, Montana, Pioneer, 1998.
6. Groundwater Sampling and Analysis Report for the CMC Milwaukee Roundhouse Site, Deer Lodge, Montana, August, 2000.

SITE CHARACTERIZATION

Known and potential sources of contamination include the former roundhouse and repair shop, the concrete storage tank, areas of Bunker C and diesel fuel contaminated soils, and the former oil separator area.  Soil analytical results from samples collected from test pits, near the specified areas of concern, are summarized in Table 1.  The data represent total extractable hydrocarbon concentrations and petroleum range hydrocarbons and DEQ regulatory limits.

Nine monitoring wells have been completed on the site.  The wells have been sampled in 1988, 1989, 1990, 1993, 1998, and 2000. Sampling events have analyzed for polynuclear aromatic hydrocarbons (PAHs), Diesel Range Organics (DROs), oil, grease and volatile organic compounds (VOCs).

The concrete storage tank is located in the northwest portion of the roundhouse area.  This 120-foot by 70-foot tank by 10-feet deep was used to store Bunker C and diesel fuels.  The tank was abandoned in the 1950’s and backfilled with debris and fill.  Soil samples taken near the storage tank in 1990 contained high concentrations of polynuclear aromatic hydrocarbon (PAH) compounds, and heavy (C12-C22) petroleum hydrocarbons.  Test Pit 12 (TP12s) excavated immediately north of the tank contained over 6’ of petroleum-contaminated soils. Analytical results (Table 1) are consistent with heavy petroleum fuels (diesel and Bunker C) and waste product sources.

The oil separator was located about 80 feet north of the roundhouse, near the center of the site.   Water and waste oils draining from the roundhouse were separated and the water discharged to the concrete drainpipe.   Contaminated soils occur near, and north of, the separator.  Test Pit 16 (TP16s), excavated immediately north of the oil separator contained approximately 5’ of petroleum-contaminated soils.  Analytical results (Table1) indicate petroleum hydrocarbons are probably derived from heavy oils, and diesel fuel.  Backhoe trenching (80 feet north of the oil separator) encountered 2 feet of petroleum saturated soils at depths of 5-10 feet during the excavation.

The former roundhouse and repair shop structures were located near the southern end of the site.  The roundhouse was used for lacquering train cars and lacquer solvents may have been used, and disposed of, in and near the roundhouse. The repair shop was located 300 feet south of the roundhouse and various degreasing solvents may have been used and disposed of nearby. Groundwater sampling has detected industrial solvents, but all results are below recommended clean-up guidance levels.  Excavations immediately north (TP20s) and south (TP1s) intercepted clean sands and gravel, with no staining or odor.  Analytical results (Table 1) confirm the relatively clean soils in these areas.

Several smaller surface areas of petroleum contamination occur throughout the site, around the concrete storage tank and north of the oil separator.  These areas have noticeable surface staining and strong petroleum odors during warm summer days.

TABLE 1:  Test Pit (subsurface soil samples) Analytical Results

COST/BENEFIT ANALYSIS

The primary benefits of this project will be the elimination of human health and natural resource risks, the remediation and closure of the CECRA listing, and the economic redevelopment of a prime commercial and recreational property.  Direct benefits include protection of the ecological resources, including wetlands, near the Clark ForkRiver and along TinCupJoeCreek.  Economic redevelopment will provide both direct benefits to the local community and to the State of Montana in general.  Additional open space and recreational development will provide indirect benefits to the citizens of Montana and the visiting population.

It is impossible to accurately quantify the benefits gained by the elimination of numerous health risks on the property, or the benefit gained by a healthy local ecosystem.  It is however a principal tenet of the Department of Natural Resources and the State of Montana that a healthy environment is a key component of economic growth and citizen well-being in the state.

A more definitive picture can be estimated for the economic benefits gained by the State of Montana, the Deer Lodge community and PowellCounty.  Economic development at the site has been non-existent for the past 20 years.  Several private investors have expressed interest and pursued development, but were unable to accept, or discern, the potential remediation liability at the site.

The current site owner (CMC) has been unable, or unwilling, to meet the financial demands of the Montana DEQ efforts.   CMC is however, willing to allow a prospective purchase of the site, if the purchase includes an assumption of environmental liability.  The grant monies from this RDGP program would allow PowellCounty to fund the environmental cleanup and reduce the county risk in procuring the site.  This will enable new business to locate on the site, and neighboring business to expand.

These are tremendous benefits to the State, the county and the local community.  The increased economic activity, especially in a relatively depressed area of the state will increase employment opportunities, increase the tax base and provide the type of economic development activity needed in the state.

PROJECT ALTERNATIVES

Alternative 1 – Thermal Desorption

Thermal desorption is often used as a treatment of petroleum contaminated soils.  Thermal desorption results in volume reduction and complete destruction of organic compounds.  Carbon dioxide, water vapor and ash are emitted during the process.  Contractors with mobile units are available to provide on-site soil treatment.

Unit costs range from $50 to $100 per ton depending on petroleum content, soil characteristics, and treatment volumes. Cost estimates for thermal desorption at the Deer Lodge site are estimated to be about $75 per cubic yard.  This alternative is not cost effective, and it was rejected.

Alternative 2 – Recycling at an Asphalt Batch Plant

The incorporation of petroleum-contaminated soils into asphalts is used at batch plants throughout the country.  The process incorporates, and treats, the soils in a rotary kiln at the asphalt batch plant.  The treated soil is blended with additional gravels and oil to produce asphalt.  Transport to the plant site is a significant portion of the treatment cost.  In addition, concentrations of hydrocarbons, sand, and clays are important cost factors.

Cost estimates for recycling the site material will vary between soils that have high concentrations of heavy hydrocarbons (fuel tank area), and soils with lower hydrocarbon concentrations and/or high clay content.  Soils saturated with Bunker C fuel, may be recycled at effective costs.  That is, the transportation costs to the batch plant will be minimized by the value at the plant.  This treatment would be an option for a limited tonnage of highly saturated soils, probably those in the Bunker C concrete tank.

Other contaminated soils in the site have higher percentages of clay, and low concentrations of heavy hydrocarbons.  The recycling value of these soils is appreciably lower, and the additional clay content may make the material unsuitable for use.  At an estimated cost of $30 per cubic yard, and no marketable value, this alternative is rejected for the majority of contaminated soils at the site, but may be used for material from the concrete tank area.

Alternative 3 – No Action

The remediation and subsequent redevelopment of this site cannot be achieved without further funding and action at the site.  The soil, sludge, and groundwater contamination at the site will continue to be a source of contamination if no actions are taken at the site.  In addition, the economic activities (or general malaise) of site activity over the last 20 years will likely continue if no action is taken.  This alternative will preclude the opportunity to increase the natural resource and economic values at the site, and it is rejected.

Alternative 4 – Landfarming

This alternative includes the excavation of contaminated materials, transport to the landfarm, and tilling of soils to allow volatile components to vent from the contaminated material.  Commercial landfarm facilities are present in Belgrade, Polson, and Great Falls, Montana.  A temporary facility could be established and permitted locally to significantly reduce transportation costs.

Estimated costs to transport and treat hydrocarbon-contaminated soils to a commercial facility are approximately $45 per cubic yard.  A substantial savings of at least $20 per cubic yard is possible if a local, or on-site, facility is used.  This alternative is the least costly and most implementable alternative, and is selected as the most appropriate remediation alternative for most of the hydrocarbon-contaminated soils.

The proposed budget for this project is based on landfarming the petroleum-contaminated soils.  This appears to be both the most cost effective and most appropriate alternative to meet CECRA criteria for site remediation.  This approach will provide the maximum protection to human health and the environment, it can comply with all appropriate regulations, and it is a technically sound approach to the remediation.

STAFFING AND ADMINISTRATION

Granted funds will be administered by the Powell County Planning Department, which will have the responsibility for disbursement of grant funds.  The county’s project environmental consultant, Jed Thomas (Tetratech/MFG) will support the project by preparing planning documents for the project, overseeing, investigation and construction activities, and preparing a summary report.  Jed Thomas has extensive experience in investigation, evaluation and remediation of similar petroleum and railroad related waste sites in Montana and throughout the U.S.  MFG has performed similar project for the Montana Department of Environmental Quality and under the management of the US EPA Region VIII.  Mr. Jed Thomas of MFG will also coordinate DEQ project approval and serve as the project liaison.

The use of subcontractors represents a significant portion of the scope of work.  All contractors will be selected in accordance with state laws governing the procurement of professional and/or construction services.

ADDITIONAL INFORMATION

Deeds, Easements and Rights-of-Way

Research of potential responsible parties has determined that the current owner, CMC Real Estate Corporation, is responsible for contamination and cleanup of this site.  However, this entity is currently, and has consistently been, in arrears in reimbursing DEQ remediation efforts at the site.  In addition the DEQ has no current staffing to support, or conduct, remediation efforts at the site.

If this grant request is accepted, PowellCounty will negotiate a prospective purchaser agreement with the current property owner, CMC Real Estate Corporation, to acquire title to the complete site.  A letter of committal, from the Powell County Attorney’s Office, is attached to this application.

Permits

Any, and all, necessary permits for the completion of site activities will be obtained prior to the related fieldwork assignments.  The following permits will be required during excavation activities, and will be obtained prior to construction;

DEQ UST removal permit

Storm Water Discharge permit

County/local construction permit

Waste disposal permit

Maps and Photos

Figure 1 is a site map, which shows the location of the site and surrounding features.  Figure 2 is a site layout showing features within the site, which are discussed in relation to the contaminant issues.  Figure 3 is a location map of the existing monitoring wells located on the property.

The photo pages present ground views of the site illustrating current conditions, previous remediation, and general property layout.

Plans and Specifications

Formal plans and specifications have not been prepared for the project and are not considered necessary for the limited scope of activities planned.  Conceptual design plans for the project include five major activities, as follows:

Complete a detailed site characterization and assessment.  This activity will include a compilation of all existing site data, plotting of all pertinent data, and a technical evaluation of the site conditions.  Meetings with DEQ representatives will be conducted to review currently available information, previous activities, and future site investigation activities.   After conferencing with DEQ the workplan for additional site sampling or data requirements will be developed.  A complete and detailed site assessment report will be completed after the field activities.

The former concrete storage tank, associated sludge, and contaminated soils will be remediated or removed from the site.  The concrete tank will be excavated and removed if necessary based on analytical sample results.  All remaining oil, oil-saturated soils, and sludge will be removed and transport remediation site, or treated to remove contamination.  The resulting excavation will be backfilled with clean fill, the area reseeded and weeds controlled until vegetation is established

A former oil separator and associated underground piping will be removed from the area north of the roundhouse, extending to the terminal sump near TinCupJoeCreek.  Underground piping and sumps will be removed, as needed based on analytical results from soil samples.  Contaminated soil will be transported to a permitted, remediation site.

Confirmation samples will be collected to ensure that all contamination is removed.  All excavations will be backfilled, reseeded and weed controlled until vegetation is established.

Contaminated soils from several areas near the tank, the separator and other areas.  This activity will include backhoe trenching, as an exploratory tool, to map and confirm soil contamination limits.  Analytical sample results will be used to determine excavation areas for soil removal.  Contaminated soils will be transported to a permitted, remediation, site.  Soil samples will be taken to ensure that all contamination is removed.  Upon completion all excavations will be backfilled, reseeded, and weeds controlled until vegetation is established.

A large amount of surface waste, debris and discarded items has collected on the property over the last 20 years.  This material constitutes a physical hazard to children, and adults, on the site and needs to be removed.  Most of the materials are steel or iron and may be transported to local salvage dealers in the area.  All existed surface debris, waste and physical hazards will be removed from the site and transported to a proper disposal area.

STEP 4- SCOPE OF WORK

1.         GOALS AND OBJECTIVES

The goal for the proposed site remediation is to eliminate risks to human health, enhance natural resources, complete CECRA site closure, and provide an appropriate site for future economic development.  The remediation will allow the site to be safely incorporated into the local trails system and will allow commercial development to proceed.

The principal objectives for the project are:

1. Complete a detailed site characterization and assessment
2. Remove the concrete storage tank and associated contaminated sludge and soil
3. Remove the former oil separator and associated underground piping
4. Remove contaminated soils from the site
5. Remove surface waste, debris and hazardous junk from the property
6. Complete related site reports and CECRA closure reports

2.         TASKS AND ACTIVITIES

Task one will be completed for project objectives described above, and includes,

Task 1:   Project Planning/Documentation.  The project planning/documentation task will include:

1. Preparation of field work plans
2. Preparation of a project schedule
3. Preparation of health and safety plan
4. Obtaining all necessary permits
5. Advertising and letting bids
6. Evaluate and award bids
7. Coordination of activities with DEQ

The following task descriptions apply to specific project objectives.

Complete a detailed site assessment

Task 2:  The preferred alternative for the site assessment is to:

Compile all existing site data (DEQ, CMC, local, etc.)

Review and plot all existing data and site description

Recommend additional site investigations, as needed

Site sampling activities

Develop plots of all new analytical data

Complete detailed site assessment report

Remove the concrete storage tank and associated contaminatation

Task 3:  The remedial construction task includes all site construction activities.  The preferred alternative for the storage tank removal is to:

Excavate the concrete storage tank

Remove sludge and contaminated soil

Transport contaminated soil to a hazardous waste, or remediation, site

Collect confirmation samples to ensure that all contamination is removed

Backfill the excavation

Reseed the area and provide weed control until vegetation is established

Remove the former oil separator and associated underground piping

Task 4:  The preferred alternative for the storage tank removal is to:

Excavate the oil separator

Remove the underground piping and sumps leading to Tin Cup Joe

Transport contaminated soil to a waste, or remediation, site

Collect confirmation samples to ensure that all contamination is removed

Backfill the excavation

Reseed the area and provide weed control until vegetation is established

Remove contaminated soils from the site

Task 5:  The remedial construction task includes site activities related to the preferred alternative for the removing contaminated soils, including:

            Backhoe trenching to define limits of soil contamination

Excavate known areas of soil contamination

            Transport contaminated soil to a hazardous waste, or remediation, site

Collect confirmation samples to ensure that all contamination is removed

Backfill the excavation

Reseed the area and provide weed control until vegetation is established

Remove surface debris, waste and physical hazards from the property

Task 6:  Site construction activities for the preferred alternative for removing surface debris, waste and physical hazards, includes:

            Detail all surface debris, waste and physical hazards

Remove all surface debris, waste and physical hazards

Preparation of draft and final project reports

Task 7:  The preferred alternative for the preparation of draft and final project reports is to:

          Complete a report of all site activities

Provide recommendations for additional remediation, or site closure

Coordinate, and lead site reviews for County, State agencies

Coordinate, support, and lead site reviews

Complete CECRA site closure applications

3.         PROJECT SCHEDULE

The progress of this project depends on the award schedule of the grant.  All dates are defined in days from availability of the grant.  The project completion dates are as follows:

Task 1

Draft Field Work Plan                          +60 days

MDEQ review                                      +90 days

Final Field Work Plan                           +120 days

Health and safety plan               +120 days

Obtaining permits                                  +120 days

Advertising and letting bids                    +120 days

Evaluate and award bids                       +150 days

Task 2

Compile all existing site data                  +10 days

Data review and plotting                       +30 days

Recommendations                                +50 days

Site sampling (after workplan)   +70 days

Plot new analytical data             +90 days

Site assessment report                          +120 days

Task 3-7

Tasks 3-7 will be completed as soon after the award of bids as weather allows.  Site remedial activities, and investigations are anticipated to require approximately 360 days to complete.  Final reports and closure applications are anticipated to require approximately 640 days to complete.

MONITORING PLAN

The monitoring plan will consist of:

Contractual Administration:       Design and construction monitoring will be conducted throughout the project with milestone dates set for the draft design, final design, start of construction, 20 percent construction, 50 percent construction, 90 percent construction, and the end of construction.

Environmental Monitoring:         Confirmation samples will be collected for each separate removal action to ensure that all the contamination is removed.  It may be necessary to collect additional groundwater samples to determine the impact of the removal actions on groundwater.

EQUIPMENT

No capital equipment will be purchased with this grant.  Disposable health and safety equipment and sampling supplies will be purchased to support site remediation activities.  All durable equipment required for sample collection and site construction activities will be rented or provided by site contractors.

STEP 5- PROJECT BUDGET

Total Reclamation and Development Grants Program (RDGP) funding that is being requested is $270,450.  The cleanup/construction and investigation costs estimated for this project reflect the actual costs that will be incurred.  Matching funds, and in-kind services from PowellCounty total $135,425.  Additional funds are being requested from the EPA Brownfield program, and the Economic Development Administration.  Outside sources of funding, or in-kind services, include current and prior investigation activities by the environmental consultant. The total project budget is $412,050.  The following presents a brief explanation of key proposed budget items.

Salaries and wages requested under the RDGP include those for MDEQ oversight and document review.  Oversight will include; review of fieldwork plans, field activities, drafts and final project reports.

Contracted services include; consulting, laboratory analysis, soils disposal, backfill material, monitoring well installation.  A breakdown of construction expenses by task is as follows:

Applicant contributions include PowellCounty time spent on grant administration, equipment hours, project planning, review of work plans, site closure applications, and final reports.  PowellCounty will provide backhoe and dump truck equipment for some of the initial soils testing, and investigations of the concrete tank and oil separator lines.  PowellCounty has agreed to complete a prospective purchase agreement with the current property owner (CMC) for full title to the site property (see letter of commitment).  This may confer a significant liability to PowellCounty but is needed to complete the remediation, and redevelopment, goals.

Consulting fees include the preparation of fieldwork plan, the summary reports and the supervision of all construction activities.  Confirmation sampling is included in the analytical budget to confirm remediation goals have been met.

PROJECT BUDGET SUMMARY FORM

PROJECT BUDGET DETAIL FORM

STEP 6- PUBLIC BENEFITS RANKING CRITERIA

Applicant Name:           PowellCounty

Project Title:                 Site Cleanup: CMC Roundhouse

The project develops and ensures the quality of natural resources:          This project is designed to remove historic site contamination and provide full site remediation to ensure the quality of the local natural resources.  Remediation, and protective measures, will develop and ensure the quality of surface soils and groundwater in the surrounding areas.

The project conserves natural resources:    Removing petroleum and railroad-related contamination enhances the soils, groundwater, and surface waters of the area.  The natural values of the area are conserved by the removal of introduced contaminants and conservation of local natural resources.  This 14.5-acre site occupies a strategic location adjacent to the city and along principal transportation corridors.  By aiding in the redevelopment of this vacant, and unused, property the DNRC is promoting the practical use, and conservation of existing lands and natural resources.

The project protects the public health, safety, and welfare of Montanans:  Reclamation of the CMC Roundhouse will protect the public health, safety, and welfare of Montana residents in the Deer Lodge area.  In addition, site reclamation will protect, and enhance the health, safety and welfare of Montana visitors.  The improved water quality to the Montana groundwater and surface waters of the Clark ForkRiver will benefit all Montanans.

Montanans will directly benefit from the project:  Montana residents will directly benefit in the economic redevelopment made possible by this project.  Deer Lodge residents will have employment opportunities from redevelopment, and the availability of clean water for future wells.  Residents who fish, swim, or float in the area will benefit from the improved water quality in the Clark ForkRiver.

Montanans will indirectly benefit from the project:  Economic redevelopment of this site will benefit all Montanans by increasing economic opportunities in the state and enhancing the state tax base.  Removal of potential contamination to the Clark ForkRiver benefits all Montanans.  Improving Montana’s rivers improves the state’s natural resources, provides healthier communities, and cleans the water for down stream users.

The project benefits are certain and long-term:  Reclamation insures that petroleum, and other railroad related contamination would be removed from the groundwater, surface water, and soil.  Thus providing a long-term benefit for residents of Deer Lodge and all Montanan’s who use the area impacted by the contamination and the Clark ForkRiver.

STEP 7- NEED AND URGENCY NARRATIVE AND SUPPORTING DOCUMENTS

Applicant Name:           PowellCounty

Project Title:                 Site Cleanup: CMC Roundhouse

Need for the project: Contamination at the former roundhouse site needs to be cleaned up to prevent further contaminant migration into surface and ground waters.   It is imperative that contaminated soils and oil storage structures be removed to allow economic redevelopment of this strategically located area.  Future site redevelopment will only occur after remediation and CECRA closure is complete.

Immediacy of the need, cause and how long has it existed: The site was operated as a major railroad repair center, and refueling facility, from 1908 to 1980.  Petroleum releases to surface waters and ground waters have occurred for the past 20 years.  The site is lying bare, and unused, due to the potential liability associated with contaminant remediation.  This project is needed immediately to allow, and support, immediate economic development efforts.

Impact of a “no action” alternative:  Previous investigations have indicated that contamination from fuel storage, oil separations, and industrial solvents is impacting soils and groundwater.  If no action is taken, economic redevelopment in the area will be stymied and potential contaminant migration to the Clark ForkRiver will remain.  Based on previous investigations a “no action” alternative should not be considered.

Severity of the problem and the extent of the area involved:  Reclamation of the site is critical because of the impact to groundwater and soils, and the threat of petroleum, and solvent, contamination migrating into the Clark ForkRiver.  The Montana Department of Environmental Quality has recognized the site as a threat and has assisted in this application.  Interested commercial developers have expressed interest in this site but are unwilling to participate because of the potential for environmental liability.  Site contamination and CECRA listing are affecting the entire Deer Lodge area.

Number and type of natural resources affected:  Contamination from the former railroad repair and refueling center has impacted groundwater, surface water, and soils.  The site conditions threaten human and ecological health by potentially impacting a regional surface water system and exposing residents in nearby parks and tourist areas.

STEP 8- PROJECT MANAGEMENT AND ORGANIZATION CAPABILITY RANKING

Applicant Name:           PowellCounty

Project Title:                 Site Cleanup: CMC Roundhouse

Applicant ability to implement the project: 

PowellCounty is a legally incorporated entity in the State of Montana, pursuant to Section 2-7-504, MCA.  As such, PowellCounty has the legal jurisdiction and authority to finance, operate and maintain community property and services.

Applicant’s past record of performance: 

PowellCounty has completed one, and is currently managing a second DNRC funded program.  The county has recently completed a reclamation program at the historic Charter Oaks Mine and is working on remediation at the former Ontario Mine.  PowellCounty has developed an Economic Development Corporation to design and implement long-term solutions to economic displacement in the Deer Lodge area.  PowellCounty has established good working relations with the State of Montana in the implementation and administration of these and other projects.

Skills, qualifications, and experience of the project manager, key personnel, and contractors:

The county’s project consultant Mr. Jed Thomas (Sage Resources) will support the project by preparing planning documents for the proposed project, overseeing investigation and construction activities, and preparing summary reports.  Mr. Thomas has extensive experience in investigation, evaluation, and remediation of petroleum and hazardous waste sites in Montana and the western U.S.  Sage Resources has performed similar projects in Montana for the DEQ on railroad and petroleum tank related projects.  Mr. Jed Thomas will also coordinate DEQ project approval and serve as the project liaison.

The use of subcontractors represents a large portion of the scope of work (drilling, analytical, waste disposal).  All contractors will be selected in accordance with state laws governing the procurement of professional and/or construction services.

STEP 9- ENVIRONMENTAL CHECKLIST

Project Title:                 Site Cleanup: CMC Roundhouse

Applicant Name:           PowellCounty

Address:                       801 Milwaukee Road, Deer Lodge, Montana, 59727

Project Description:

Checklist Preparer:       Jed Thomas (Tetratech/MFG)               Phone   406-728-4600

POTENTIAL IMPACTS ON THE PHYSICAL ENVIRONMENT

List all groups or agencies contacted and the contact person’s phone number:

STEP 9- LIABLE PARTY DETERMINATION

Project Title:                 Site Cleanup: CMC Roundhouse

Applicant Name:           PowellCounty

Legal description of the site:  27 acres in T 7 N, R 9 W, Sec 4, Powell County, Montana

Name of the current owner:  CMC Real Estate Corporation

Dates of damage:  1908 to 1980

Who was the owner/operator at the time of damage?  Chicago, Milwaukee, St. Paul and Pacific Railroad Company, and its predecessor corporation, Chicago, Milwaukee, and St. Paul Railway Company.

Subsequent owners/operators:  CMC Real Estate Corporation

Taxpayer over the past 10 years:  CMC Real Estate Corporation

Landowner statement regards pending nuisance action:  Not Applicable

Is the project now, or has it ever been, permitted, licensed, or regulated by federal, state, or local rules, regulations, or statues?

We know of no permits issued in connection with the site.  The current project is regulated as a Montana State Superfund Site under the provisions of the Comprehensive, Environmental Cleanup and Responsibility Act (CECRA).

STEP 11- CRUCIAL STATE NEED DOCUMENTATION

Project Title:                 Site Cleanup: CMC Roundhouse

Applicant Name:           PowellCounty

The Department of Environmental Quality (DEQ), Remediation Division listed this site on the Comprehensive Environmental Cleanup and Responsibility Act (CECRA) state list in 1989 as a “high priority” site.  The initial investigation concludes, “a hazard ranking is recommended for this site because of the significant near-term threats requiring prompt action.”

Potential Threat to Public Health and Safety:

The DEQ Site Response Section, under the CECRA program, lists the CMC Roundhouse facility as a “high priority” site.  A high priority classification indicates contamination at the site poses a risk to human health and the environment.  Exposure pathways identified at the site include dermal contact, ingestion, and inhalation of vapors from petroleum contaminated soils, sediment, and water.  The high priority designation was given because the site exhibits the following criteria (from the CECRA ranking form dated 4/25/00)

a)      Documented and extensive contamination of exposed shallow soil or exposed sediment with uncontrolled facility access.

b)      Documented impact to a sensitive environment such as a terrestrial or aquatic resource; including wetlands, or area with unique or highly valued environmental or cultural features, or a fragile natural setting.

c)      Imminent threat to a drinking water source from migration of contamination from soils to surface water, groundwater, or a water line that is a drinking water source.

d)      Potential migration of contamination to a utility corridor that is currently in use from documented contamination to a utility corridor that is not is use.

Validity of the Problem or Need

Previous investigation activities supported by the DEQ indicate petroleum and industrial solvent contamination is present at the site at levels exceeding Montana standards and regulations.  The level of contamination exceeds state water quality standards and soils contamination exceeds screening levels for protection of human health and the environment.

Consequences of No Action or Delayed Reaction:

PowellCounty and the local community are actively implementing economic redevelopment opportunities for the area, including the CMC Roundhouse site.  The opportunity to design and implement a remediation strategy for this site will be lost, or significantly limited by the loss of funding momentum at this time.  Although the releases occurred more than 15 years ago, there were no plans for economic redevelopment at that time.  In addition, the contamination has the potential for pose a threat to human health and the environment for over 100 years in left in place with no action.  At this time, PowellCounty, and the DEQ, does not view the “no action” alternative as an appropriate alternative.

Severity of the Problem or Need:

As noted above, this facility is listed as a “high priority” site on the DEQ CECRA facility list, because of the presence of petroleum, or industrial chemicals, and receptors located at or near the site.  Cancer causing chemicals have been detected in site soils and sediment.

Number of people Affected:

The Powell County Progress organization has plans to incorporate development of this property with additional work linking the Old State Prison Museum with the National Park Service’s Grant-Kohrs Ranch.  The current and future use of the property will affect the Butte Economic Region, and the many visitors to the general area.

Agency and Public Support for the Project:

This grant application is supported the DEQ, and the City of Deer Lodge, in order for Powell County to ensure protection to Deer Lodge residents, visitors, and the environment.  The following agencies and organizations have indicated their support to the investigation and cleanup at this facility;

• National Parks Service Grant-Kohrs Ranch
• City of Deer Lodge
• PowellCounty Commissioners
• Department of Environmental Quality
• Headwaters Economic Development Council

Project’s Stated Objective will Meet Need:

This project will meet the stated objectives of a significant reduction in petroleum, and industrial chemical, contamination in soils, and potential migration threats to groundwater and surface waters.  The success of the efforts will be thoroughly documented by confirmation sampling.

LETTERS OF SUPPORT

SITE PHOTOGRAPHS

Roundhouse Area

South end of Site

Looking North

Debris and Waste

West side of site

Looking West towards Territorial Prison

Oil Separator Line

Open Lines

Center of Site

Buried Oil Separator Line

Concrete Tank Area:  West side of site

Monitor Wells: West side of site