EPA Brownfields Assessment Grant (CA #01J86301)

The U.S. Environmental Protection Agency (EPA) awarded the Coquille Indian Tribe and Mith-ih-kwuh Economic Development Corporation (Tribal One) a $350,000 Site-Specific Brownfields Assessment Grant to conduct an environmental assessment and subsequent reuse strategy for the 30-acre Ko’Kwel Wharf property. The grant-funded project began October 1, 2020, and ended December 31, 2023.

Tribal One managed all aspects of the Cooperative Agreement (CA #01J86301) beginning with development of a budget and workplan to meet EPA objectives. Tribal One assembled a project team of staff and consultants who completed all aspects of the EPA-approved workplan including the following.

• A market study/analysis was performed by Johnson Economics and completed in May 2021. The study provided key information about the potential market for development options on the property and allowed the project team to prepare a preliminary conceptual plan for development. That plan helped shape the subsequent environmental assessment.
• Tribal One contracted with Stantec Consulting to serve as the Qualified Environmental Professional for the project. Stantec developed a Master Quality Assurance Project Plan (QAPP) and a Sampling and Analysis Plan (SAP) for the environmental assessment. The plan called for base sampling of an area designated for industrial development. The remaining area designated for commercial development was divided into six decision units for more intensive sampling.
• Sampling was completed in April 2022 during a week that saw wind, rain, hail and a lightning strike next to the wharf property. Final sampling results revealed three areas where levels of dioxins and furans exceeded Occupational Direct Contact thresholds published by Oregon DEQ. Exceedances were detected in incremental (averaged) samples in two decision units and one discreet (specific) sample collected in the industrial area. A Phase II Environmental Site Assessment was completed.
• A second round of sampling was conducted to further define the impacted area. The two decision units (DU 5&6) were divided into quadrants and samples were taken in a grid pattern within each quadrant. Samples from each quadrant were prepared for composite testing, while archive samples were held and later tested to further define the area. Results from the archived samples suggested that the impacted area was confined to a half-acre parcel that straddles the border between the two decision units. Later, additional samples were taken to further define the western edge of the area that was unreachable during the supplemental sampling. A Supplemental Phase II Environmental Site Assessment was completed.
• With this information Stantec completed a draft Analysis of Brownfield Cleanup Alternatives (ABCA) that presented four alternatives: 1) capping impacted soils and managing in place, 2) excavation and off-site disposal of impacted soils, 3) on-site incineration of impacted soils and 4) no action. The project team unanimously selected the second option – excavation and off-site disposal – as the most cost-effective course of action.
• A final Reuse Strategy and Action Plan was prepared and approved by Tribal One management. The document includes a brief history of the project, a reassessment of the market study and a description of a revised conceptual plan along with a six-point action plan outlining the next steps in the process.

Tribal One performed all grant management functions, including reporting requirements, under the Cooperative Agreement and under the Uniform Guidance (2 CFR Part 200).