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EPA Brownfields Cleanup Grant Silver City Waterworks Notice to Reviewer: This is a draft application for an EPA Brownfields Cleanup Grant, for up to $200,000 in funding for abatement of lead-based paint, asbestos-containing materials and bat guano at the Town’s historic Silver City Waterworks building. The application must be made available for public review before it is submitted to EPA. Guidelines for the FY13 Brownfields Cleanup grant application can be downloaded at: http://www.epa.gov/brownfields/applicat.htm. The application has to have 1” margins, and minimum of 12 pt. font. The ranking criteria section is limited to 15 pages (it’s 17 now – please help!), but there is no page limit for attachments. Not all of the attachments have been included in this draft, like the transmittal letter and the letters of support. Also, the NM Environment Department is just now funding a consultant to develop a remediation plan, and will provide more precise cost estimates for the proposed budget. The Town would appreciate your input on this application. Comments can be sent to the Town at: P.O. Box 1188, Silver City, NM 88062, emailed to: [email protected] or posted on the Town’s website at http://www.townofsilvercity.org/, under “We need your ideas and input.” A public meeting will also be held October 22, 2012 at 4:00 pm in the upstairs conference room of the Bank of America building, 1203 N. Hudson Street. There will be a short presentation on the Waterworks and the proposed cleanup project. Public input is requested. Comments and responses will be summarized and included in the final grant application, which will be submitted by November 15, 2012. The grants aren’t awarded until summer of 2013, with the project starting about October 2013. Thank you for your support of this project. Sincerely, Nancy Gordon volunteer project manager Silver City Waterworks [email protected] October 1, 2012

EPA Brownfields Cleanup Grant Silver City Waterworks … Brownfields Cleanup Grant Silver City Waterworks Notice to Reviewer: This is a draft application for an EPA Brownfields Cleanup

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EPA Brownfields Cleanup Grant Silver City Waterworks

Notice to Reviewer: This is a draft application for an EPA Brownfields Cleanup Grant, for up to $200,000 in funding for abatement of lead-based paint, asbestos-containing materials and bat guano at the Town’s historic Silver City Waterworks building. The application must be made available for public review before it is submitted to EPA.

Guidelines for the FY13 Brownfields Cleanup grant application can be downloaded at: http://www.epa.gov/brownfields/applicat.htm. The application has to have 1” margins, and minimum of 12 pt. font. The ranking criteria section is limited to 15 pages (it’s 17 now – please help!), but there is no page limit for attachments. Not all of the attachments have been included in this draft, like the transmittal letter and the letters of support. Also, the NM Environment Department is just now funding a consultant to develop a remediation plan, and will provide more precise cost estimates for the proposed budget.

The Town would appreciate your input on this application. Comments can be sent to the Town at: P.O. Box 1188, Silver City, NM 88062, emailed to: [email protected] or posted on the Town’s website at http://www.townofsilvercity.org/, under “We need your ideas and input.”

A public meeting will also be held October 22, 2012 at 4:00 pm in the upstairs conference room of the Bank of America building, 1203 N. Hudson Street. There will be a short presentation on the Waterworks and the proposed cleanup project. Public input is requested. Comments and responses will be summarized and included in the final grant application, which will be submitted by November 15, 2012. The grants aren’t awarded until summer of 2013, with the project starting about October 2013. Thank you for your support of this project. Sincerely, Nancy Gordon volunteer project manager Silver City Waterworks [email protected] October 1, 2012

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Threshold – page 1

THRESHOLD CRITERIA Silver City Waterworks Brownfields Cleanup Grant

RFP No. EPA-OSWER-OBLR-12-09

Summary Statement:

The Town of Silver City, New Mexico is applying for a Brownfields Cleanup Grant for lead/asbestos/bat guano abatement at its historic Silver City Waterworks property.

1. Applicant Eligibility

a. Eligible Entity:

The Town of Silver City is eligible as a general purpose unit of local government, as defined under 40 CFR Part 31.3.

b. Site Ownership:

The Town of Silver City is the sole owner of the Waterworks property and will maintain ownership until cleanup work funded by this grant is completed and the grant is closed out. The Waterworks was built in 1886-1887 by a private company, and was sold to another private company in 1900. That company went into receivership in 1924. The Town purchased the property from the Receiver on August 1, 1925 (Grant Co. NM “City Deeds” Book 71, p. 151).

The property to be cleaned up is the historic Waterworks building. It was listed on the National Register of Historic Places in 1984.

2. Letter from the State or Tribal Environmental Authority

A letter is attached from the New Mexico Environment Department acknowledging that the Town of Silver City plans to conduct cleanup activities at the Silver City Waterworks and is planning to apply for an EPA Brownfields Cleanup Grant.

3. Site Eligibility and Property Ownership Eligibility

Site Eligibility:

a. Basic Site Information:

Name: Silver City Waterworks Address: 1721 Little Walnut Road, Silver City, NM 88061 Current owner: Town of Silver City P.O. Box 1188 Silver City, NM 88062

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Threshold – page 2

b. Status and History of Contamination at the Site:

Type of contamination: Hazardous substances (lead, asbestos and bat guano)

Operational history/current uses: Supplied water to the Town of Silver City. Waterworks building was used as a residence until 1967, currently vacant. Site has also been used by Town Utilities Department for storage of materials, maintenance shop and office. Pipe and fittings are still stored in a metal shop on the property built in 1949; this shop is not included in the request for brownfield cleanup funds (see Section h(iv)).

Environmental concerns: Health hazards are posed by exposure to lead-based paint, asbestos-containing materials and bat guano. There are also safety concerns because of the dilapidated condition of Waterworks building. The building is currently locked and boarded up, with only authorized entry permitted.

How the site became contaminated/nature and extent of contamination: Lead-based paint and asbestos were both commonly used prior to the 1970’s, and were likely introduced as early as 1887 when the Waterworks facility was developed. Approximately 6600 square feet of surfaces with lead-based paint and 230 square feet of asbestos-containing tile and mastic in the historic Waterworks building will require abatement. Cleanup of bat guano will be needed throughout the building.

c. Sites Ineligible for Funding:

The Waterworks property is: (a) not listed or proposed for listing on the National Priorities List; (b) not subject to unilateral administrative orders, court orders, administrative orders on consent, or judicial consent decrees issued to or entered into by parties under CERCLA; and (c) not subject to the jurisdiction, custody, or control of the United States government.

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Threshold – page 3

d. Sites Requiring a Property-Specific Determination:

There are no ongoing or anticipated environmental enforcement actions.

The Waterworks well provided drinking water prior to the Safe Drinking Water Act, and was never permitted. It is currently out of service.

e. Environmental Assessment Required for Cleanup Proposals:

The Brownfields Law defines a “Brownfield Site” as: “...real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant.”

In September of 2000, the Environmental Protection Agency approved the Town of Silver City’s application for a Brownfields Site Assessment Pilot Project grant and awarded the Town $200,000 plus an additional $50,000 for assessment and planning of greenspaces. The Town used the grant money to perform several environmental assessments at brownfields sites that included the Town’s old landfill, mill and mining sites, an old hospital, and the Waterworks. Other funds and assistance from non-profits and volunteers were obtained to redevelop Boston Hill, a historic mining area, as a popular recreation area, and to clean up a perennial section of an arroyo that passes through downtown to develop a nature trail with interpretive signs.

A Phase I Environmental Site Assessment was completed for the Waterworks property in February, 2002, by Engineers Inc. of Silver City, and a Phase II Site Assessment Report was completed in November, 2002 by INTERA of Albuquerque, NM. In 2012, the New Mexico Environment Department funded additional assessment work and a remediation plan for the Waterworks building.

Property Ownership Eligibility:

f. CERCLA §107 Liability:

Janet Brooks, then the Targeted Brownfields Assessment Coordinator for EPA Region 6, reviewed the Phase II Environmental Site Assessment for the Waterworks and consulted with EPA’s CERCLA attorney. Brooks notified the applicant by e-mail on May 6, 2011, that, “According to our eligibility attorney, this site [the Silver City Waterworks property] is eligible for a cleanup grant.”

In addition, the Town of Silver City may meet the landowner liability protection under CERCLA §101(20)(D) because it acquired the property in 1925 after the private owner of the Waterworks went into receivership.

g. Enforcement Actions:

There are no known ongoing or anticipated environmental enforcement actions related to the Waterworks property for which funding is sought.

The Town has recently taken action to dispose of transite (asbestos-cement) pipe stored on the property outside the building, and to further characterize arsenic levels in soils on site, as recommended in the Phase II report.

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Threshold – page 4

h. Information on Liability and Defenses/Protections:

i) Information on the Property Acquisition:

The Silver City Waterworks was completed in 1887 and provided Silver City’s first municipal water supply. The building had a two-story engineer’s residence and a single-story wing that once housed steam-powered pumps and wood-fired boilers (switched to coal in 1908). A 500-foot long “collection gallery” captured subsurface flow beneath the adjacent Silva Creek Arroyo and directed it to a 55-foot deep well, which connected to a pumping pit beneath the Waterworks building. Water was boosted from there to a reservoir on top of a hill, and then flowed under gravity into the Town’s water system.

The Waterworks was first developed and operated by a private firm, the Silver City Water Works Company. That company was purchased by the Silver Valley Water Company in 1900. Both water companies had trouble providing enough water to satisfy the Town’s demands. Additional water sources were tapped, including water from a mine shaft on Boston Hill – the site of a silver strike that gave Silver City its name – but the supply was still inadequate.

In 1924, the Silver Valley Water Works was “underwater” on its mortgage, its indebtedness greater than the value of the property. It could not afford to develop the additional water sources needed to meet its obligations. The company was declared insolvent, and a receiver was appointed. In 1925, the Town of Silver City purchased the Waterworks, water system, easements and equipment from Mr. Ralph T. Kellogg, Receiver of the Silver Valley Water Works, for $60,000.

The deed and bill of sale were approved on August 1, 1925, and recorded with the Grant County Clerk on August 27, 1925. The Town is currently the sole owner of the portion of the Waterworks property on which the Brownfields Cleanup will be conducted.

It is unknown if any Town employees personally had familial, contractual, corporate, or financial relationships with previous owners of the Waterworks at the time of its purchase in 1925. When the Silver Valley Water Works company operated the Waterworks, it had a franchise with the Town of Silver City to provide water to the Town. After the Town purchased the property, the Town became responsible for supplying citizens with water, including fire protection. A Town-employed operator lived in the Waterworks building with his family to maintain the pumping system. ii) Timing and/or Contribution Toward Hazardous Substances Disposal:

Lead-based paint was detected throughout the Waterworks building during Phase II testing. Floor tile and mastic in the Waterworks building were found to contain asbestos, as well as joint compound in the 1949 metal shop and transite (asbestos-cement) pipe on the property. A high level of arsenic was detected in one soil sample near the Waterworks building (see Section h(v)).

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Threshold – page 5

It is uncertain when lead-based paint (LBP) and asbestos-containing materials (ACM) were introduced into the historic Waterworks building. It can probably be assumed that the interior was painted at the time of its construction (1886-1887). A local resident who lived in the building in the 1940’s as a teenager said that the Town did some fixing up and repainting before her family moved in. It is not possible to determine what paint was added before and after the Town assumed ownership; however it is likely that the original paint is still there. Asbestos-containing tile and mastic may also be original. Prior to the 1970’s, LBP and ACM were not federally classified as hazardous materials.

Some older sections of the Town’s water system were built with transite pipe, and extra lengths of pipe were stored on the Waterworks property. It is unknown how long the pipe has been there. In July of 2011, the Town arranged for removal and disposal of the transite pipe on this property. Cleanup of hazardous materials in the 1949 shop adjacent to the historic Waterworks building will not be addressed in this grant application, but will be needed before renovation or demolition of that building can occur.

The Town has not arranged for disposal of hazardous substances at the site or transported hazardous substances to the site other than those mentioned. Rodent or weed control products may have been used when employees lived at the building and later when the Utilities Department’s office was located on the property. A 28-year Town employee interviewed during the Phase II investigation stated that chemicals were never stored at the site. iii) Pre-Purchase Inquiry:

No known inquiry was made into environmental conditions prior to the Town taking ownership in 1925. Information on previous ownership and use was obtained from researching newspaper records, the deed, past studies and reports, and historical summaries done by the Silver City Museum. iv) Post-Acquisition Uses:

All uses of the Waterworks property for which cleanup funding is requested have been Town-related since the Town acquired ownership (1925-present).

The Waterworks well provided water to the Town for municipal use including fire protection, although additional water sources were tapped. A pipeline was extended to Allen Spring, seven miles north across the Continental Divide, to supply supplemental water during the 1930’s and 1940’s.

When deep wells were drilled to the southwest of Silver City in the late-1940’s, the Town finally had a reliable source of water, and the Waterworks well was subsequently disconnected from the Town’s municipal water system. Water trucks continued to fill up with water for non-potable use from a standpipe at the Waterworks until 2000, when the pumping system failed.

Town employees lived in the residential section of the building until 1967. The Waterworks building was used up until about 1984 as a maintenance shop for the Town’s Utilities Department, and a now-retired water foreman remembered

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Threshold – page 6

a lunch room in the residential (south) part of the building. In 1984, it was listed on the National Register of Historic Places. Since then, it has been used for storage (e.g. for trash bags), but is currently empty.

A metal shop on the same property was built in 1949. A small blue metal building next to it was once the Utilities Department office. Both are still used for storage of spare pipe, fittings and other parts for the Town’s water and sewer systems. Because the 1949 shop and small metal building were constructed while the Town was owner of the property, they will not be addressed in this grant application.

Up until about ten years ago, the historic Waterworks building was occasionally opened for tours guided by volunteers with the Silver City Museum. In 2004, the non-profit Gila Conservation Education Center of Silver City initiated an agreement to lease the Waterworks with the intent of rehabilitating the historic building as a nature education center and office spaces. They successfully partnered with the Town to secure a National Park Service Preserve America grant that resulted in a Master Plan for the Waterworks in 2008; however, they did not follow through on the lease agreement.

The Waterworks building is currently empty and boarded up. However, a variety of wildlife has been observed in the building, including lizards, mice, bats, birds, squirrels, snakes, and skunks. Preventing entry by animals will be a challenge. v) Continuing Obligations:

There are serious potential and real concerns about hazards at the Waterworks because of the building’s dilapidated condition and presence of LBP and ACM. The building has some structural problems, including a collapsing floor in the pump room over the 30-foot deep pumping pit. A Phase I Environmental Assessment was done in 2002 under the Town’s EPA-funded Brownfields Program, followed by Phase II testing under the New Mexico Environment Department’s TBA program. The Brownfields Program also funded a reuse plan in 2003 to explore future possibilities for renovation and adaptive use of the historic Waterworks property.

The Town has taken reasonable steps to stop future releases of hazardous substances, and to prevent and limit exposure. Lead-based paint and asbestos-containing tile and mastic will not be used in future construction.

Actions have been taken to limit entry to the Waterworks property. It is fenced with a locked gate and “no trespassing signs,” although occasional trespass does occur. A fence constructed in 2012 along the corridor leading to the new “Safe Routes to School” bridge will further limit unauthorized entry. Other actions taken to increase security include repairing the front gate, installing new gate locks, replacing a door over the basement entry and locking it, and securing entry points to the underground collection gallery. The historic Waterworks building itself is boarded up and locked, and entry is limited to authorized persons. Dust masks and hard hats are advised.

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Threshold – page 7

The Town of Silver City has been diligent in addressing cleanup of hazardous materials. In the mid-2000’s, the Town purchased a dilapidated old hospital that had become an eyesore, and took responsibility for lead/asbestos abatement and demolition, completed in 2006. When portions of the Town’s Community-Built Park burned in 2009 and 2011, releasing arsenic from pressure-treated wood, the Town took appropriate measures to test and clean up the soils.

At the Waterworks, the Town recently followed up on recommendations in the Phase II report. One soil sample collected during the Phase II Assessment contained a high level of arsenic. It was considered an anomaly, but additional sampling was recommended. In May of 2011, additional sampling was performed by Azurite Consulting of Silver City to further characterize the levels of arsenic. The concentrations found were much lower and were considered “native or background.”

In July of 2011, the Town contracted with Southwest Hazard Control of Tucson, AZ for removal and disposal of transite (asbestos-containing) pipe on the Waterworks property. Approximately 75 linear feet of pipe were removed by the contractor. The Town fully cooperated in the cleanup, providing access to the property and a boom truck.

The Town will continue to evaluate and mitigate hazards at the Waterworks property, and will prevent hazardous materials from being stored on-site in the future. If the Brownfields Cleanup Grant is awarded, the Town will comply with all land-use restrictions, institutional controls, and information requests, provide legally required notices, and cooperate with contractors performing the cleanup to provide access to the property and other assistance.

4. Cleanup Authority and Oversight Structure

a. Oversight of Cleanup:

Lead-based paint (LBP) and asbestos-containing materials (ACM) in the 1887 Waterworks building require abatement as a critical step in its renovation. Approximately 6000 square feet of wall, ceiling, windows and other surfaces in the residential section and some 40 square feet of windows and door moldings in the boiler room contain lead-based paint. The pump room could not be accessed for sampling because the floor is collapsing, but would add approximately 550 square feet for the walls and balustrades, if these surfaces have lead-based paint. Abatement will require removal of wallpaper, peeling paint, and loose plaster from walls and ceilings.

The Town has previously been through the New Mexico Environment Department’s state response program, in connection with the Town’s Brownfields Pilot Project. The Brownfields Cleanup grant would follow up on assessments conducted during that project. The Town does not plan to enroll in a state response program for this cleanup project.

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Threshold – page 8

Appropriate levels of oversight will be implemented as follows:

Administrative oversight: Town Assistant Engineer and volunteer assistant project manager.

Fiscal management: Silver City Manager’s Office and Finance Department.

Technical expertise: Qualified environmental health consultant(s) will be hired with grant funds, preferably locally-based during the cleanup phase, with expertise in lead and asbestos abatement plus experience with Town and Federal procurement regulations. Consultant will prepare or assist with preparation of pre-cleanup documents including the QAPP and final Analysis of Brownfields Cleanup Alternatives, work plan, specifications for cleanup contractor, and will conduct oversight and monitoring during cleanup.

Cleanup contractor: Contractor hired with grant funds to carry out the cleanup of hazardous substances.

NMED and EPA will be consulted to develop qualifications for contractors and to assist with RFPs. All contractors will be selected through a competitive process consistent with the Town’s procurement code and/or provisions of 40 CFR 31.36, as approved by EPA. The Town will comply with all applicable federal and state laws to ensure that the cleanup protects human health and the environment. Technical expertise will be in place prior to beginning cleanup activities.

b. Neighboring properties:

The Waterworks property is bounded on the east and west by Town property, on the south by Jose Barrios Elementary School, and on the north by Royal Scepter Gems and Minerals. Lead, asbestos and bat guano abatement will occur mainly inside the Waterworks building. Appropriate scheduling and the use of barriers and other protective measures will keep hazardous materials from impacting neighboring properties. Access to neighboring properties is not anticipated, but if needed, permission would be obtained in writing from the principal at Jose Barrios and the owners of the Royal Scepter.

5. Cost Share:

a. Statutory Cost Share:

i) Budgeted cost share: The budget for the proposed project includes a 20% cost share for eligible expenses totaling $40,000. Contributions include $12,000 in labor by Town staff for project oversight and fiscal management, $8,000 in health/safety training from NMED, $2,000 from the Gila Conservation Education Center for educational outreach and publicity, $6,000 in volunteer labor for assistance with project management and cleanup activities, and a $12,000 cash match by the Town.

ii) Hardship waiver: The Town is applying for a hardship waiver of the cost share, based on a declining population, the uncertainty of an economy dependent on the price of copper, and the impact of recent wildfires on tourism. See attached Hardship Waiver Request.

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Threshold – page 9

6. Community Notification: [to be updated before submittal]

The Town of Silver City notified the community of its intent to apply for an EPA Brownfields Cleanup grant for the Silver City Waterworks building, and made the draft proposal available for review. The draft proposal included a draft Analysis of Brownfield Cleanup Alternatives (ABCA). If the grant is awarded to the Town, a Community Relations Plan will be developed before the start of cleanup activities.

Community notification included:

• Legal notice in the local newspaper, published [October 5, 2012].

• email notification to community members, Town staff, non-profits, and others on the Waterworks newsletter mailing list.

• A public meeting held October 22, 2012 to discuss the draft proposal and consider public comments.

• A resolution supporting the Town’s application for the grant, passed by the Town Council [October 23, 2012].

The draft proposal was posted on the Town’s website and copies were made available for review at the Silver City Public Library and Community Development Department (CDD) at the City Hall Annex. Written comments could be dropped off at the CDD office, posted on the website, mailed to the Town, or emailed to the Town’s Assistant Engineer. Comments were also collected at the public meeting.

Public comments and the Town’s responses were summarized and are attached, as well as copies of the legal ads, summary of the public meeting, and the resolution.

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Ranking – page 1

NARRATIVE PROPOSAL EPA Brownfields Cleanup Grant

RFP No: EPA-OSWER-OBLR-12-09 RANKING CRITERIA

1. COMMUNITY NEED

a. Health, Welfare and Environment

The Town of Silver City is a rural community located near the Gila National Forest in Southwestern New Mexico at an elevation of 5900 feet. It is the county seat for Grant County. About half of its some 10,000 residents are Hispanic. Flanked by two open pit copper mines, the Town is located in an area that is complex geologically and rich in mineral resources. In its early years, Silver City was a regional center for mining and ore processing. This legacy has left abandoned mines and mill sites that create potential environmental health risks. Smoke from

forest fires, exacerbated by the recent drought, affects respiratory health. Although cause and effect are difficult to determine, it is notable that rates of death from cancer and respiratory disease are higher in South-western New Mexico than in any other region of the state1.

The Cleveland Mill, located 5.5 miles north of Silver City was designated a Superfund site in 1989 and successfully remediated2. Brownfields sites include Boston Hill (500 acres), the location of the silver strike that gave Silver City its name and which later supplied manganiferous iron ore for use by the steel industry. Several mill sites on San Vicente Arroyo3 and its tributaries have been designated as brownfields: Wisconsin Mill, Ancheta Mill, Pope Mill, California Mill, and Hearst Mill, totaling some 30 acres.

An area along a perennial stretch of San Vicente Creek near downtown Silver City was used as the Town’s municipal dump in

the 1940’s through 1960’s, and afterwards experienced widespread illegal dumping. The Town’s next landfill (50 acres), located further south on San Vicente Creek, was closed in 1995, and was designated a brownfield due to groundwater contamination and methane migration.

1 New Mexico Selected Health Statistics Annual Report 2010 (at: vitalrecordsnm.org). 2 EPA Region 6, Five-Year Review Report for Cleveland Mill, August 2007. 3 San Vicente Arroyo is an intermittent stream that is perennial where it passes through downtown Silver City. Brownfields are listed on EPA’s “Cleanups in my Community” list for zip code 88061 (www.epa.gov).

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Ranking – page 2

The Town’s brownfields program, funded by an Brownfields Site Assessment Pilot Project grant in 2000, provided the impetus for reuse of Boston Hill and San Vicente Arroyo as popular open space recreational areas with trail systems. Contamination from tailings at an abandoned reduction works, and from an eroding dump face at the first landfill are still concerns. Part of the second landfill has recently been put to productive reuse with the installation of artificial turf to create new combination baseball/soccer fields.

Other brownfields include the old Hillcrest Hospital (3.72 acres) and the historic Silver City Waterworks property (26 acres), both of which were designated brownfields because of asbestos and lead-based paint and other possible contaminants. The old hospital was perceived as an eyesore and was purchased by the Town of Silver City in 2004, then demolished following abatement of asbestos, lead based paint and pigeon droppings. Exposure to airborne friable asbestos may cause serious lung diseases including asbestosis, lung cancer, and mesothelioma (exacerbated by smoking). Exposure to lead can cause reproductive problems, high blood pressure, nerve disorders, muscle and joint pain, and memory and concentration problems. Lead is especially hazardous for children, and exposure can lead to brain and nerve damage and hearing problems. Pregnant women can transfer lead to the fetus4.

Bats have been roosting in the old Waterworks building for many years. Although the odor from bat roosts is typically “pungent but not dangerous,” bat guano can provide a medium for growing types of fungi, the spores of which can cause histoplasmosis if inhaled5. Bats can also carry rabies, and can harbor bat bugs which are in the same family as bed bugs.

The 1887 Waterworks building is the focus of this application. The Town has been rehabilitating the property over the past few years, with the goal of reusing it as a nature center/water museum. Cleanup of lead-based paint, asbestos, and animal waste is an essential step in this process. Healthy environments are created not only by reducing exposure to contaminants in water, air, and soil, but also by encouraging healthy lifestyles. Drug and alcohol abuse, domestic violence and gangs are serious problems in Grant County. Grant County has a suicide rate more than twice the state average6. Obesity is an increasing problem in New Mexico as it is in the United States, exacerbated by poor dietary choices and lack of exercise. Ironically, although Grant County offers many opportunities for outdoor recreation, over a third of children in this area are overweight or obese, increasing their risk of illness from high blood pressure, high cholesterol, type 2 diabetes, heart disease and stroke. Hispanics have a higher risk of developing type 2 diabetes than Anglos.

These trends can be reversed by making communities more livable. A new “Safe Routes to School” bridge connecting the Waterworks site, a botanical garden, and adjacent elementary school, has promoted walking and bicycle use and renewed community interest in reuse of the Waterworks building and grounds. The planned reuse of the Waterworks as a nature center/water museum will increase interest in nature and local water issues, and improve the quality of life in the community. The proposed project would be Silver City’s first EPA Brownfields cleanup grant project, and would set an example for cleanup and reuse of other historical properties. 4 EPA publications on lead and asbestos at: www.epa.gov. 5 USAEHA TB No. 142, 1992 (US Army publication). 6 New Mexico Selected Health Statistics Annual Report 2010 (at: vitalrecordsnm.org).

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Ranking – page 3

b. Financial Need

Silver City suffers from problems common to frontier rural communities, including underdeveloped infrastructure, high poverty rates, and an aging population with young people seeking employment elsewhere. About half of the Town’s residents are Hispanic, and many speak Spanish. Relevant statistics are summarized as follows:

Silver City Grant County New Mexico United States Populationa: 10,269 29,380 2,082,224 311,591,917 Unemploymentb: (not avail.) 6.8% 7.0% 8.4% Poverty Ratec: 17.9% 14.8% 18.4% 13.8% Per Capita Incomec: $20,467 $21,164 $22,966 $27,334 Percent Hispanicd: 52.4% 48.3% 46.7% 16.7% Persons > age 65a 19.0% 22.1% 13.6% 13.3% a 2011 estimated population, from U.S. Census “Quickfacts” data (http://quickfacts.census.gov/qfd/states/). b NM Dept. of Workforce Solutions data, June 2012 (www.dws.state.nm.us). Rates are not seasonally adjusted. c2006-2010 data from U.S. Census Bureau “Quickfacts.” d2010 data for Silver City; otherwise 2011 estimates, from U.S. Census Bureau “Quickfacts.”

From 2000 to 2011, population declined in both Silver City (-2.6%) and Grant County (-5.2%). State representation for Southwestern New Mexico was affected as district boundaries were stretched to include more populous areas. This could mean less funding for rural areas in the future. The state legislature last provided capital outlays for infrastructure projects in 20087. Both Silver City and Grant County have a larger percentage of people over age 65 than in New Mexico or the nation. For Silver City, this population has grown by 2.8% since the 2000 Census, with corresponding losses from younger age brackets. School enrollment has been declining since the 1990’s, and this, as well as cuts in funding from the State, resulted in a loss of some 45 jobs in the Silver School District between 2008 and 20118.

Silver City’s isolation – two hours from Las Cruces, 3.5 hours from Tucson and 4.5 from Albuquerque – translates to higher costs for gasoline and food. Poverty is a pervasive problem in the Silver City area. Per-capita income in both Silver City and Grant County are lower than state and national averages and poverty rates exceed the national average. Some 30% of Grant County families with children under 18 years live below the poverty level. This increases to 65% for single-mother families with children under five9. High poverty contributes to other social woes like health problems, food insecurity, drug and alcohol abuse, domestic violence, and increased “nuisance” crime rates. Since the economic downturn in 2008, the Town’s beloved Community-Built Park was destroyed in two probable-arson fires. A high percentage of the area’s population depends on public support, with 22% of Grant County’s population receiving SNAP assistance (food stamps) and 24% eligible for Medicaid10. Many children do not have enough to eat. As of the beginning of the 2012-13 school year, 64% of students in the Silver Schools District received free or reduced fee lunches; at one downtown elementary school the percentage jumps to 79%.

7 Silver City Daily Press, August 12, 2011. 8 Silver City Daily Press, August 4, 2011 and August 22, 2012. 9 U.S. Census Bureau, 2006-2010 American Community Survey data (http://factfinder2.census.gov) 10 New Mexico Human Services Dept. Monthly Statistical Report, July, 2012 (www.hsd.state.nm.us/isd/).

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Ranking – page 4

Silver City acts as a hub for retail, commercial and governmental activity in the region. It is home to Western New Mexico University, the only 4-year university in southwestern New Mexico, and the county-owned Gila Regional Medical Center, which is the largest hospital in a 100-mile radius. Fast-food restaurants, motels, auto dealers, a WalMart, Albertsons grocery store, Ace Hardware store and new Tractor Supply store, border U.S. Highway 180 in “strip mall” fashion. The tourist-friendly historic downtown is off the main highway, and most of the gift shops, art galleries, coffee shops, restaurants and other small businesses are owner-operated. Major area employers are the U.S. Forest Service, the hospital, medical clinics, the university, schools, and the mines operated by Freeport McMoRan Copper and Gold. The economy of the region is inextricably tied to the boom and bust cycles of the copper market. In December, 2008, Freeport suspended milling and mining at one mine and laid off about 600 workers, citing falling copper prices. Unemployment skyrocketed to 13% in June-July, 2009. Mine closures have a “domino effect” as companies doing business with the mines close up shop, families move away, retailers are hurt, and tax revenues for local governments drop. Although copper prices have rebounded and the mines have been rehiring, the local economy remains sluggish. Unemployment as of July, 2012, was 7% in Grant County. While this rate is less than the national average, many jobs are in the lower-paying service sector. Family ties here are strong and many settle for minimal wages to stay in the area.

The Town of Silver City relies on Gross Receipts Taxes (GRT) as the foundation of its income. From 2008 to 2010, its GRT revenues dropped 9% and have yet to recover11. Because of increased costs for electricity and supplies, operational costs for the Town’s wells and water system have gone up, and the Town was forced to raise water rates for the first time in three years12. The Town took steps to self-fund various projects by refinancing existing loans at lower interest rates, and issuing municipal bonds. Devastating wildfires in the Gila National Forest in 2012 will undoubtedly affect outdoor recreation and tourism for many years, although they may have temporarily stimulated the local economy when firefighters, re-seeding contractors and support personnel poured into the area. As in most small towns, priority is given to essential services like police, fire, and maintenance of streets and water and sewer systems. Historic preservation is not seen as a critical need, especially in difficult economic times. Although a major project to rehabilitate the Waterworks building has been on the Town’s Infrastructure Capital Improvements Plan since about 2001, it has remained a low priority. Funding for a desperately-needed roof repair was finally approved this year, mainly because of a substantial contribution from an anonymous donor. It is extremely difficult to find grant money for “brick and mortar” historic preservation projects. The Town was fortunate to receive a grant from the Freeport McMoRan Foundation in 2011 that paid for several studies at the Waterworks and a volunteer service project in masonry repair to stabilize the stone walls. Volunteer labor will undoubtedly play a significant role in future rehabilitation efforts, although substantial funding will be required to transform the Waterworks from a blighted property into a community asset.

11 from Town of Silver City audits at New Mexico Office of the State Auditor website (www.osanm.org) 12 Silver City Daily Press, August 24, 2012.

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2. PROJECT DESCRIPTION AND FEASIBILITY OF SUCCESS

a. Project Description

The proposed project involves cleanup of hazardous materials from the Silver City Waterworks building. Abatement of lead paint, asbestos and bat guano is complicated by structural safety issues and the fact that the 1887 building is listed on the National Register of Historic Places.

i) Condition of the Property and Potential Reuse: The Silver City Waterworks was constructed in 1887 and provided Silver City’s first municipal water supply. Constructed of local sandstone, the Waterworks building has a two-story section that was once used as an engineer’s residence, and a single-story wing that housed boilers and steam-powered pumps. A 500-foot long tunnel (“collection gallery”) captured subsurface flow beneath the adjacent Silva Creek Arroyo and directed it to a 55-foot deep well, which connected to a 30-foot deep pumping pit within the Waterworks building. Water was boosted from there to a reservoir on top of a nearby hill, and then flowed under gravity into the Town’s water system.

The Waterworks was disconnected from the Town’s water system after higher-capacity wells were developed in the 1940’s. Non-potable water could still be obtained from the Waterworks well until 2000, when the pumping system failed. Town employees lived in the residential portion of the building until 1967. Up until about 1984, the building was used as a maintenance shop for the Town’s Utilities Department. Since then, it has periodically used for storage, but is currently vacant except for a colony of bats and the occasional skunk or gopher snake.

The Waterworks building the National Register of Historic Places in 1984, and has been the subject of several studies and condition assessments. Several roof repairs were made, and the seriously dilapidated 1-story roof is being replaced this year. Much of the exterior stone masonry was repointed in 2011-2012 as a volunteer service-learning project funded with a grant from the Freeport McMoRan Foundation. However, the interior is in poor condition and the floor in the pump room over the 30-foot deep pit is collapsing. This is unfortunate, as the pump room is one of the most interesting rooms in the building, with Victorian-style balustrades and a skylight that was opened to install or remove pumping equipment. The boiler room and pumping pit have walls of exposed stone masonry, whereas walls and ceilings in other rooms have been plastered. Doors and windows are damaged and the paint and wallpaper in the residential section is peeling. A section of plaster fell from the ceiling in the entry area last year. The property is fenced with “No Trespassing” signs. It was boarded up in 1996, and in 2011-12, youth volunteers painted “faux” window and door panels to cover the boarded-up ones. Other actions taken to increase security include repairing the front gate, installing new gate locks, replacing and locking a door over the basement entry, and strapping down a cover over the outside well. The Utilities Department previously secured another access to the underground collection by setting a heavy concrete manhole section over it. A “Safe Routes to School” bridge was built across Silva Creek this year, with a fenced corridor through the Waterworks property. This new fence will help limit unauthorized entry to the site. Entry to the building itself is limited to authorized persons, and hard hats and dust masks are advised.

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In September of 2000, the Environmental Protection Agency approved the Town of Silver City’s application for a Brownfields Site Assessment Pilot Project grant and awarded the Town $200,000 plus an additional $50,000 for assessment and planning of greenspaces. A Phase I Environmental Site Assessment was completed for the Waterworks in February, 2002, by Engineers Inc. of Silver City, and a Phase II Site Assessment Report was completed in November, 2002 by INTERA of Albuquerque, NM. Lead-based paint was detected throughout the Waterworks building, and floor tile and mastic in the building were found to contain asbestos, although the pump room was not accessed for sampling because of safety concerns. A roosting colony of bats was recently discovered. Abatement of lead/asbestos/bat guano is needed. In 2011, the Town took action to dispose of transite (asbestos-cement) pipe stored on the Waterworks property, and to further characterize arsenic levels in soils at one location, as recommended in the Phase II report. A hazardous waste contractor removed and disposed of approximately 75 linear feet of transite pipe. An environmental consultant conducted additional soil sampling and analysis, and found arsenic levels at “native or background” levels13.

The EPA Brownfields Site Assessment Pilot Project also funded a 2003 reuse plan14 to explore future possibilities for renovation and adaptive use of the historic Waterworks property. Suggestions included redevelopment as a museum, interactive science/art center for children, or public library – although the library idea was abandoned. The 2003 plan was followed by a Master Plan in 2008 developed with funding from a National Park Service “Preserve America” grant15. At the time, a local non-profit, the Gila Conservation Education Center, was interested in using the Waterworks for a nature education center. This remains the current vision for the Waterworks, as well as interpretation of its own history and history of water in Silver City. It has potential to become a living museum, home to a caretaker as it was historically. The Town is committed to keeping the Waterworks as a Town-owned property because of its historic value.

ii) Proposed Cleanup Plan:

There are serious potential and real concerns about hazards at the Waterworks because of the building’s dilapidated condition and presence of lead-based paint (LBP), asbestos-containing materials (ACM), and bat guano. The building has some structural problems, including the collapsing floor in the pump room. Since the Waterworks property is zoned residential, and the building had both residential and industrial functions in the past, it is desirable to clean up and rehabilitate the two-story section to residential standards and the one-story section and pumping pit to standards compatible with future museum use.

Approximately 6000 square feet of wall, ceiling, windows and other surfaces in the residential section and some 40 square feet of windows and door moldings in the boiler room contain lead-based paint. The pump room could not be accessed for sampling during the Phase II assessment because the floor is collapsing, but would add approximately 550 square feet for the doors, beams and balustrades, if these surfaces have lead-based paint. The vinyl tile and mastic on floors in the former kitchen and bathroom (approx. 230 sq. ft.) were found to have “Category 1 non-friable” asbestos.

13 Azurite Consulting and Management, 2011, Town of Silver City Historic Waterworks Building Phase II Arsenic Investigation. 14 Mark Richard and Associates, 2003, Reuse and Open Space Plan for Old Waterworks Property. 15 University of New Mexico School of Architecture and Planning. 2008. Waterworks Building Master Plan Study.

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Abatement of LBP and ACM will require particular care to not adversely affect historic finishes. All work will need to be approved by the New Mexico Historic Preservation Division (NMHPD). The National Park Service guidelines for rehabilitation are applicable16. These call for salvage and repair of deteriorated features, and if features are missing, replacement “in kind.”

Rehabilitation was addressed in the architectural building condition assessment funded with the Freeport grant17. For the ceilings, the architect recommended removing plaster and replacing it

with sheet rock, finished to match the original surface. The same treatment was recommended for the walls, although removing the peeling paint and crumbling wallpaper, and then re-plastering may be a less destructive approach. Finishing must not interfere with the stone masonry’s ability to “breathe.” Windows and doors with LBP and ACM will need to be refinished, reglazed and in some cases, rebuilt. Wood moldings will be cleaned and then repainted to encapsulate any remaining LBP. Removal of the ACM-containing vinyl tile is preferred if it will not harm the wood floors; otherwise encapsulation may be possible. [this section will be revised based on NMED consultant’s rehabilitation plan] Additional engineering study and stabilization of the floor in the pump room is needed, as it has been extensively damaged from water and fire. Debris in the pumping pit will require additional assessment. Any debris without historic value will be removed from the pumping pit, sampled, and appropriately

disposed of. Historic features will be stabilized and preserved, to allow interpretation of their original function.

Abatement of bat guano will be performed prior to LBP/ACM abatement, and will need to occur during the winter when the bats have out-migrated. Placement of netting and steel wool will be required to exclude bats from the building. Cleanup will consist of misting guano with a 10% bleach solution with hand sprayers, then sweeping it up with non-metallic brushes. Cleanup personnel will need to wear HEPA masks and protective clothing18. If the guano is found to be non-hazardous, it may be reused as fertilizer in planted areas.

EPA Region 6 notified the Town by email on May 6, 2011, that the Waterworks property was eligible for a Brownfields cleanup grant. The New Mexico Environment Department is currently providing Targeted Brownfields Assistance to the Town of Silver City for additional assessment. This will include sampling and analysis of materials missed during the Phase II investigation, an updated Phase I specifically for the historic Waterworks building, and development of a remediation plan which includes input on an Analysis of Brownfields Cleanup Alternatives (ABCA), a work plan and cost estimates. The Town will continue to evaluate and mitigate hazards at the Waterworks property, and will work to prevent hazardous materials from being stored or used on-site in the future. If the EPA Brownfields Cleanup Grant is awarded, the Town will comply with all regulations, provide legally required notices, cooperate with contractors performing cleanup actions, make sure that quality assurance requirements are met, and assure that work is done in a timely manner.

16 see: www.nps.gov/history/hps/tps/standguide/ 17 Barbara Zook, architect, September 2011, Silver City Waterworks Building Condition Assessment. 18 USAEHA TB No. 142, December 1992. at: https://safety.army.mil/

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b. Budget for EPA Funding, Tracking and Measuring Progress, and Leveraging

i) Budget Table (all amounts include gross receipts tax if applicable): [Note: these are preliminary estimates, to be refined based on NMED consultant’s assessment]

Task 1 Task 2(3) Task 3 Task 4 Task 5(5) Task 6 Total

Personnel Fringe Travel (1)3,000 3,000 Supplies (6)5,000 5,000 Equipment Contractual 9,000 3,000 20,000 5,000 (7)120,000 157,000 Construction 35,000 35,000 Other Cost-share (2)15,000 8,000 2,000 (8)15,000 (9)40,000

Total 18,000 17,000 5,000 20,000 40,000 140,000 240,000 (1) Travel to Brownfields conference by one Town staff (2) Town staff: $2,000 fiscal management and legal ads, $10,000 for 3-mo. full-time eq. program manager. $3,000 for

at least 120 hrs. assistance from volunteer project manager. (3) Lead paint renovation training $4,000, training on use of historic plaster $5,000 based on Sept. 2011 repointing

training workshop cost; Health and safety training by OHSB (see letters of support), $8,000 cost-share. (4) $2,500 for development and 3-yr. maintenance of website, $500 for informational flyer, $2,000 included from

GCEC’s in-kind contribution of publicity and educational outreach (see letters of support). (5) Estimated from Structural Condition Assessment by Caspersen Engineering, Nov. 30, 2011. (6) $5,000 for cleanup supplies for volunteers, including 1 HEPA vacuum ($--), 5 HEPA masks ($--), protective clothing,

paint, plaster, and other supplies. (7) Contractual cleanup costs for lead/asbestos/bat guano abatement estimated by NMED consultant Oct. 2012;

includes $40,000 for historical renovation of up to 4 doors, 5 transom windows, 15 double-hung windows. (8) Includes $12,000 cash match by Town, and $3,000 for at least 175 hours of volunteer labor at $17.44/hr19 (9) The Town is applying for a waiver of the cost-share amount (see attachments). Task 1 – Programmatic Oversight: Town of Silver City personnel costs for general oversight, procurement, accounting, bid administration, agency coordination, regulatory compliance, and project documentation and reporting required by EPA, with assistance from volunteer project manager. The Town will also provide space for public meetings, copying services, and cover the cost of legal notices.

Task 2 – Training: Workshops for Town staff, volunteers and the general public in health and safety, lead paint renovation, and re-plastering with historically-compatible materials.

Task 3 – Community Outreach: Development and maintenance of website. Assistance with public meetings, publicity and other outreach by volunteers and local non-profit organizations.

Task 4 – Environmental Health Consultant(s): Consultant(s) with technical expertise in lead/asbestos abatement and health/safety regulations, to prepare the QAPP, develop specifications for cleanup, provide oversight of cleanup activities and conduct confirmation sampling to ensure cleanup is protective of human health and the environment.

19 2010 value of volunteer hour for New Mexico is $17.44, from www.independentsector.org.

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Task 5 – Structural Stabilization: Structural engineering design and construction costs for pump room floor stabilization and reconstruction.

Task 6 – Cleanup Implementation: Abatement of lead, asbestos, and bat guano. Volunteers will assist with cleanup of guano and repainting and/or re-plastering. Cost includes historic rehabilitation of doors and windows by removing hazardous materials and replacing “in-kind” as necessary to restore functionality. ii) Tracking and Measuring Progress: The Town of Silver City’s Finance Department will maintain records of expenditures for this project. Progress reports will be prepared by the Town and its consultants and submitted to EPA as required for grant administration, and the Town will keep records on project outcomes. Progress will be measured by achievement of short-term and long-term project outcomes and outputs such as: hiring consultants, conducting public meetings, completing engineering design and structural work, preparation of QAPP, implementing cleanup activities, and closing out the project. NMED will update the ACRES data base for the Town. iii) Leveraging: The proposed project will complete the lead/asbestos/bat guano abatement in the Waterworks building; not additional funds. The New Mexico Environment Department is currently assisting the Town by funding additional materials sampling and preparation of a remediation plan through its Targeted Brownfields Assistance (TBA) program, as well as input on the ABCA. Value of the TBA service is $25,000.

The Town will continue to look for additional funding to not only support this project but the long-term goal of rehabilitation and reuse of the Waterworks building. For example, repair of the deteriorated one-story roof is being funded in part by the Town and in part by a private donation. Funding from the Freeport McMoRan Foundation paid for several assessments, volunteer service projects and repairs in 2011-2012, and additional funding will be sought from this source. The New Mexico Historic Preservation Division provides small grants for planning and design, which the Town will apply for. Other potential sources of funding from private and public sources will be investigated, including foundation grants, Department of Transportation grants, Community Development Block Grants, legislative allocations, and loans from the New Mexico Finance Authority, EPA and others.

Town staff will participate in this project. Budgeted cost-share amounts are as shown in in the Budget Table above. The Facilities Maintenance, Utilities and Public Works Departments will also assist with cleanup and disposal of non-hazardous materials including landfill fees. The Community Development Department will assist with community outreach, copying, and can provide office space, phone and computer for personnel involved with this project. The Office of Sustainability will contribute and estimated $2,000 of technical assistance.

Volunteer work and partnerships with community-based organizations and other non-profit and governmental organizations will continue to be a critical part of the Waterworks Project. A Town of Silver City volunteer, Nancy Gordon, has acted as project manager and advocate for rehabilitation activities during the past two years. She has offered to donate 200 hours to this project with a value of $5,32820, of which $3,000 is included as cost-share in the Budget Table.

20 Ms. Gordon uses her background in hydrology/engineering for outreach and research; however the quoted value

for volunteer service is based on NM Statewide average wage for construction supervision of $26.64/hr.

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Volunteers provided over 1300 hours of masonry repair and other work on the building in 2011-2012, and many are keen to begin work on the interior. They can perform some of the repainting and re-plastering for abatement, and clean up the bat guano if it is determined to be non-hazardous. 400 hours of volunteer labor are estimated for this project (5 volunteers, 1 month of 6-hour days), valued at $6,976, of which $3,000 is included as cost-share. Other leveraged support includes training from the New Mexico Occupational Health and Safety Bureau, valued at $8,360 ($8,000 included as cost-share), educational outreach by the Gila Conservation Education Center valued at $5,000, and assistance with data gathering, and publicity from several other community-based organizations (see Letters of Support). c. Programmatic Capability and Past Performance

i) Programmatic Capability:

The Town of Silver City’s government consists of a Mayor and four Town Councilors. It has been involved with decisions on planning, assessment, construction, and other activities at the Waterworks since the Town took ownership in 1925. The Town Manager, Alex Brown, is responsible for the day-to-day operations of the Town and for supervision of various Departments, including approval of grant applications. The Town’s Assistant Engineer will direct activities under this grant. Personnel in the Finance and Purchasing Departments will provide fiscal management. If employee turnover occurs, the Town has sufficient resources to continue funding these staff positions, and in the interim, the Town Manager can assign other qualified Town staff to take over their responsibilities. The Town supports training of its employees, although it is anticipated that no additional expertise or resources will be needed for management of the proposed project; the budget includes amounts for training in specific cleanup practices. Charles (Bud) Melaney has worked as the Assistant Engineer for the Town for eight years. With degrees in Civil Engineering and Aviation Technology and previous experience with the Indian Health Service of the U.S. Public Health Service, he is well qualified to manage the proposed cleanup project. His current responsibilities include environmental compliance at the Town’s wastewater treatment plant and old landfill, as well as serving as the FEMA floodplain manager and reviewing drainage plans submitted by developers. The Town managed a previous brownfield cleanup project for the old Hillcrest Hospital in 2006. The building was a dilapidated eyesore on the Town’s horizon, and public pressure led to its acquisition by the Town. Cleanup of hazardous materials including asbestos, lead based paint and pigeon droppings was supported by the Brownfields Cleanup Revolving Loan Fund and funding from the state legislature. This project was successful and the structure was subsequently demolished. Mr. Melaney had a role in reviewing drainage containment work. Nancy Gordon, a Town volunteer, has been involved with rehabilitation of the Waterworks since 2011, and will continue to assist with the proposed cleanup project. She was Assistant Engineer for the Town in 2000 when the successful application for an EPA Brownfields Site Assessment Pilot Project was submitted. She has given numerous presentations on the Waterworks, applied for grants, and managed various community-based projects at the site. A large cadre of volunteers is now available for continued work on the Waterworks project. Qualified contractors will be hired to perform engineering services, develop the QAPP, conduct environmental oversight of the cleanup, and carry out cleanup activities. The program manager

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and volunteer project assistant will coordinate with the Town’s Purchasing Department, NMED, and EPA to procure qualified contractors. The Purchasing Department will oversee contract procurement, following the Town’s Procurement Code and meeting EPA requirements. ii) Adverse Audits: [please fact-check] The Town’s budget for FY12 is over $29 million. It administered over $5.8 million in state and federal grants during FY11, from funding sources that included the EPA, New Mexico Environment Department, U.S. Highway Department, U.S. Department of Housing and Urban Development (including CDBG grants), and New Mexico Finance Authority. There were no adverse audit findings. The Town’s audits have been clean for six years. iii) Past Performance:

In 2000, the EPA approved the Town of Silver City’s application for a Brownfields Site Assessment Pilot Project grant and awarded the Town $200,000 plus an additional $50,000 for assessment and planning of greenspaces. The Town used the grant money to perform numerous environmental assessments at brownfields that included the Town’s old landfill, mill and mining sites, the old hospital, and the Waterworks. The grant was successfully managed with all phases of work under the grant performed and substantial compliance with the work plan and reporting requirements achieved. Only four brownfields sites were initially targeted, but by the end of 2003, 10 Phase I and three Phase II Assessments had been performed and four reuse plans developed for brownfields. Grant funds were totally drawn down over a period of three years and three months. Other funds and assistance from non-profits and volunteers were obtained to redevelop brownfield properties including a historic mining site, Boston Hill, now a popular recreation area; the reconstruction of a historic chapel on another brownfield property; and the clean up of a large illegal dumping site and the clearing of titles in area of confusing property deeds along San Vicente Arroyo that lead to development of a riparian nature trail with interpretive signs. 3. COMMUNITY ENGAGEMENT AND PARTNERSHIPS a. Plan for Involving Community

The community has been extensively involved in the Waterworks Project since its 1984 listing on the National Register, participating in past reuse planning and more recent rehabilitation and landscaping projects. In fact, this year the Town of Silver City and a Town volunteer were honored with Community Preservation Planning awards from the State of New Mexico’s Historic Preservation Division because of the involvement of youth, nonprofits, government and businesses in preservation efforts at the Waterworks.

In 2011-12, eight presentations on the Silver City Waterworks were given to local community-based organizations and the Town Council, reaching over 150 people. A local non-profit, the Gila Conservation Education Center (GCEC), provided “inquiry-based” lessons on the Waterworks to some 140 fifth-grade students. Two videos were developed on activities at the Waterworks and its history, and were run continuously for several months on a local community-access “CATS” TV channel.

Funding from the Freeport McMoRan Foundation supported a volunteer service-learning project in masonry repair at the Waterworks, with training provided by Cornerstones, a non-profit out of

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Santa Fe that assists with historic preservation projects. Over 80 volunteers contributed over 1300 hours of work in 2011-2012 to “repoint” the stone walls with traditional lime-based mortar. The Volunteer Center and The Wellness Coalition, local non-profits, assisted with volunteer management and with the repointing, and 16 teachers and students from Aldo Leopold High School contributed a service day. Projects funded by the Freeport grant are continuing, and will include reconstruction of the historic front porch. Local businesses also donated or gave discounts on materials and food for volunteers, and engineers and other contractors donated services during the same time period.

Youth Volunteer Corps (YVC) members from The Wellness Coalition have now contributed a week of service at the Waterworks each summer for three years to remove non-native vegetation and paint “faux” door and window coverings. During the fall of 2010 and spring of 2012, Youth Conservation Corps (YCC) crews from Aldo Leopold High School established native plant gardens, improved drainage around the building, and did other projects. This fall, a YCC crew will be working on rainwater harvesting projects around town, including at the Waterworks.

Activities have been covered by local newspapers, including an article in Desert Exposure21. The new “Safe Routes to School” bridge and improvements to the building and landscaping have increased the visibility of the Waterworks. Motorists passing by on Little Walnut road slow down to look or wave at volunteers. Tourists stop to take photos and to peer into the windows before realizing they’re “faux.” During the repointing project, local builders stopped by and asked for the lime mortar recipe.

Outreach activities include a Facebook page, “Silver City Waterworks,” set up by one of the “repointing” volunteers; a December 2011 exhibit at the Silver City Library; and plans by GCEC for additional presentations to area schools. A bi-monthly progress report has been e-mailed to Town staff, non-profits, and community members since April, 2010. The e-mail address list now has over 100 entries, and is forwarded to at least 100 more by the local Department of Health office. Updates will continue to be sent out during the proposed project.

Three public meetings are planned:

• Pre-application meeting to discuss draft grant proposal: October 22, 2012.

• Pre-cleanup meeting: At least two weeks before actual cleanup work, to notify the public of what will occur and solicit comments on the final ABCA. A Community Relations Plan will also be developed prior to this meeting.

• Post-cleanup meeting: Within two months after cleanup work is finalized and approved, a meeting will be held to report on cleanup activities. The meeting will also be a forum for discussion of reuse possibilities and future directions for the project. If funding is obtained for a “charrette,” it would be scheduled close to this time.

Meetings will be held in an ADA-accessible meeting room at the City Hall Annex, located less than a mile from the Waterworks property. Notices of public meetings will be posted in local newspapers, on the Town’s website, and in e-mail “blasts” at least two weeks before each meeting. All legal notices of public meetings must include language about contacting the Town Clerk if an interpreter, reader, amplifier or other aid or service is needed to participate. A flyer

21 “Rock House Rescue,” by Richard Mahler, Desert Exposure, January 2011. http://www.desertexposure.com/201101/201101_waterworks.php

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with information on the project will also be developed and distributed around town before the pre-cleanup meeting. A special effort will be made to notify Town staff, the neighboring Jose Barrios School and Royal Scepter properties, and local council of the League of United Latin American Citizens (LULAC).

Grant funds will be used to develop and maintain a separate website for the Waterworks, tied to the Town’s website. Progress will also be reported in email newsletters to the ever-expanding mailing list, through newspaper articles, and word of mouth. Training in health and safety and cleanup practices will be provided for Town staff, Waterworks volunteers, and the community. The proposed cleanup project will help educate the local population on potential lead and asbestos hazards in older homes, and remediation methods used in historic structures.

b. Current Efforts and Plans to Develop Partnerships

i) Local/State Environmental and Health Agencies: Letters of support were obtained from the New Mexico Environment Department’s Groundwater Quality Bureau and Occupational Safety and Health Bureau, NM Historic Preservation Division, and Grant County Health Promotion Team (NMDOH). The Town will cooperate with regulators on site remediation, and with other partners on future reuse planning.

ii) Other Federal/State Agencies: Support letters were also requested from the NM Dept. of Transportation, NM Dept. of Labor, NM Economic Development Dept., USDA-Rural Development and HUD, mainly to investigate potential future funding sources.

iii) Any Local Environmental Job Training Program, e.g. Brownfields Job Training Grantee: Santa Fe Community College (SFCC) has an environmental job training program, located about a 6-hour drive from Silver City. It has conducted workshops on lead paint renovation in Silver City, and will be scheduled to conduct another during this project. Contractors conducting environmental oversight and abatement for this project would be encouraged to contact SFCC for a list of potential students or graduates of their program, to give them an opportunity to participate. A letter from SFCC is attached.

c. Role of Key Community-Based Organizations Community engagement is essential to ensure success of the cleanup project. Letters of support are attached from several community-based and other organizations that have previously participated or plan to participate in rehabilitation and other activities at the Waterworks. Organizations have offered to assist with publicity, educational outreach, data collection, volunteer and other assistance. A summary table follows.

CBO/Ind iv idua l Contact Person/ Contact In fo .

Miss ion/Role in Pro ject

Commitment to Proposed Pro ject

Silver City Waterworks volunteers

Nancy Gordon (575)538-3969 [email protected]

Assistance with project management and cleanup activities

120 hrs. project mgmt., 40 hrs. cleanup

Jose Barrios Elem. School

Royal Scepter GCEC ALHS (YCC)

TO BE COMPLETED AFTER LETTERS ARE RECEIVED

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TWC (YVC/Americorps) SWNM Council of Govts. Arts & Cultural Dist. SC Museum Soc. Main Street Project GRIP Freeport McMoRan Foundation

Cornerstones 4. PROJECT BENEFITS

a. Welfare and/or Public Health The Waterworks is specifically mentioned in Silver City’s Comprehensive Plan22 in a section on economic development and heritage tourism. Key principles of the Comprehensive Plan include:

• developing a diverse and sustainable regional economy, • protecting the town’s distinctive architecture, • preserving quality of the natural environment, open space, water and other resources, • providing parks, open space and other recreational opportunities, • protecting Silver City’s “small town” feel and character, and • promoting walkable, livable neighborhoods.

Brownfields redevelopment at the Waterworks will meet these goals and increase livability of the community by removing safety and health hazards, stimulating investment in the

neighborhood, preserving greenspace, and increasing recreational opportunities.

Cleanup of the Waterworks building is an essential step in its rehabilitation. Abatement of lead-based paint (LBP), asbestos-containing materials (ACM) and bat guano, and stabilizing the pump room floor to allow cleanup of debris in the pumping pit, will prepare the building for future rehabilitation work and prevent possible health threats from migration of contamination. The Town of Silver City will work with environmental professionals, the New Mexico Environment Department and EPA to ensure that remediation work is carried out efficiently, safely, and effectively. Contaminants and dust

will be contained inside the building during cleanup to ensure protection of the nearby “Safe Routes to School” walking/bicycling corridor and bridge, Jose Barrios Elementary School, Royal Scepter rock shop, and Silva Creek riparian area.

22 Silver City Comprehensive Plan, March 2004.

TO BE COMPLETED AFTER LETTERS ARE RECEIVED

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Ranking – page 15

The proposed cleanup project will not displace residents often affected by brownfields, and will contribute to greener, healthier buildings and neighborhoods. Community participation during the project will help ensure equitable development. Silver City is renowned for its historic architecture; in fact some 73% of its housing units were built before 198023, and many older buildings undoubtedly contain LBP and ACM. The Waterworks project can serve as an example of how historic properties can be successfully remediated. Training workshops conducted during the project will be open to the public. The current vision for reuse of the Waterworks, described in its 2008 Master Plan24, is similar to that of the Gertrude B. Fox Environmental Center in Bethlehem, PA25, to protect historic and natural treasures and foster environmental education. It can become a field trip destination for students from schools in Southwest New Mexico, and a venue for educational events like the annual Children’s Water Festival26. Visitors will learn about sustainability, local ecosystems, and the role of water in the community. By also restoring the 2-story residential section to its historic use as a caretaker’s residence, the Waterworks can be a “living museum,” providing housing for one family and complimenting the Royal Scepter shop where owners live on-site. A nature center promotes health and well-being by encouraging people to appreciate nature and live active outdoor lives, complimenting goals of Grant County’s Healthy Kids, Healthy Communities initiative27. A Greenways Master Plan is currently being developed which includes the new “Safe Routes to School” bridge by the Waterworks, and sidewalk and bike lanes along Little Walnut Road (which also accesses the Continental Divide Trail). This will contribute to community walkability and bicycle access, and promote exercise for school children and adults, helping to reduce rates of obesity, diabetes and other chronic illnesses.

b. Economic Benefits and/or Greenspace i) Economic: The proposed brownfields cleanup project will have direct economic benefits through employment of environmental, engineering, construction and cleanup personnel, and purchases of supplies. Local businesses benefit from the “domino effect,” increasing gross receipts tax revenue to municipal governments to support necessary services to the elderly, handicapped, and youth. The project will revitalize a previously blighted property, generating civic pride and investment in the area and increasing property values.

Total rehabilitation of the Waterworks building has been estimated at $1 million28. EPA funding for cleanup will save the Town this expense and allow it to leverage additional grants, loans, and “in kind” contributions. Ongoing volunteer assistance will also help reduce the total cost. Cleanup, stabilization and rehabilitation activities provide opportunities for job training. There is potential for collaboration with Western New Mexico University (WNMU), which offers classes in electrical technology, welding, solar and wind energy, and industrial maintenance. WNMU’s president advocates community service by students. Adults qualifying for TANF (welfare) benefits are often required to do community service, and some people convicted of petty 23 as of 2004 Comprehensive Plan. 24 Waterworks Building Master Plan Study, University of New Mexico, 2008. 25 http://www.illicksmill.org 26 http://www.gcecnm.org/waterfest.html 27 http://www.healthykidshealthycommunities.org/communities/grant-county-nm 28 Zook, Barbara, Silver City Waterworks Building Condition Assessment, September 23, 2011.

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Ranking – page 16

misdemeanors are given this option. The Waterworks can be a place where these and others – like the YCC, YVC crews and volunteers that have already participated – can learn valuable occupational, leadership, “green building,” and historic preservation skills. Silver City is not on an Interstate and does not have a major airport, and its remoteness from major markets hinders business expansion and attraction. Recent wildfires in the Gila Wilderness have also impacted hunting, fishing, backpacking and other forest-related activities. To improve its economy, the Town needs to build on existing businesses, promote tourism, and attract retirees and self-employed professionals based on its quality of life,29 enhanced by brownfields cleanup. ii) Non-economic: The 2008 Master Plan for the Waterworks24 was funded by a National Park Service Preserve America grant after Silver City was designated a Preserve America community “in recognition of its continuing commitment to preserving and using its cultural and natural resources for the benefit and enjoyment of the public.”

Outcomes of the Waterworks project include cleanup and reuse of the 3,300 square foot historic building and approximately three acres for a heritage park that would include the botanical garden. Creation of a new nature center and preservation of the Silva Creek greenspace contribute to health and welfare benefits summarized in section (a) above. It is anticipated that a non-profit group such as the Gila Conservation Education Center, Silver City Museum Society, or a new “Friends” group will operate a gift shop and organize activities and exhibits at the proposed Waterworks nature center. Income from admission fees, special events and the gift shop will help support staffing and maintenance.

Festivals and events, typically organized by non-profits, are held almost monthly in Silver City. They include a Gem and Mineral Show, Fiber Arts and Clay Festivals, Blues and Bluegrass Festivals, the Gila River Festival, and a seasonal Farmer’s Market. The Waterworks can become a venue for workshops and other activities held in conjunction with local events. The Silver City Arts and Cultural District (ACD) promotes these events, and currently partners with the Southwest New Mexico Green Chamber of Commerce to manage the Visitor’s Center. A Cultural Plan for the ACD specifically recommended stabilization of the Waterworks30. c. Environmental Benefits from Infrastructure Reuse/Sustainable Reuse In addition to remediation of contaminants at the Waterworks, the EPA brownfields cleanup project will lead to other environmental, sustainable development, and livability benefits as the site is redeveloped, including those in section (b)(ii) above. Cleanup of brownfields is recommended in the regional economic plan31. Avenues of communication developed with NMED, EPA, Town staff and the public during this project will facilitate redevelopment of other properties in accordance with environmental regulations. Existing infrastructure such as water, sewer, electricity and natural gas, will be utilized when the property is redeveloped. Electricity is now being used for a yard light and outdoor power supply, 29 see http://www.silvercity.org/ 30 Silver City Arts and Cultural District Cultural Plan, June 2009, New Mexico Main Street, Santa Fe. Also see http://silvercitytourism.org/ and http://nmgreenchamber.com/southwest/ 31 2010-2015 Comprehensive Economic Development Strategy, prepared by Southwest New Mexico Council of Governments. www.swnmcog.org

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Ranking – page 17

and there is a yard hydrant for landscape watering and various construction projects. Because the Waterworks building is listed on the National Register of Historic Places, salvage and reuse of existing features like doors, windows, and lumber, is mandated. Possible reuse of the historic plaster removed during cleanup will be investigated. Other materials, like old plumbing and wiring, will be recycled to the extent possible. The regional landfill has single-stream recycling, and items are taken to a recycling facility in El Paso, Texas – except for glass, which is crushed for cover material at the landfill. Hazardous waste must be taken to an approved facility. Listing on the National Register makes it more difficult to achieve energy efficiency because features like single-paned windows and doors must be renovated or replaced “in kind,” although storm windows and insulating film may be allowed. Insulation can be added in the attic of the two-story section of the Waterworks building; however, the one-story section with its exposed rough-sawn rafters may have to remain un-insulated and used only during warmer seasons.

Water supplies are limited in the semi-arid Southwest, and this problem will be exacerbated by climate change and population growth. The Waterworks can become a demonstration site for water-conserving fixtures, rainwater harvesting, groundwater recharge, xeriscaping, and other “green skills.” Native plant gardens have already been established at the Waterworks and the botanical gardens by Aldo Leopold High School YCC crews. Work by the YCC and YVC to remove non-native plants and create features to trap sediment and infiltrate stormwater will be continued, guided by a grading/drainage plan for the property32 and the Town’s Drainage Policy. The Waterworks has 18 acre-feet of water rights, some of which are currently leased to the nearby Townside Farm that grows organic vegetables to sell at the Farmer’s Market. One potential outcome is to again use non-potable water from the Waterworks well, preferably using a solar pump. The Town’s Office of Sustainability was instrumental in installing a 32-panel solar system on a new covered downtown parking structure, and will assist with this project. Vegetable gardens can be developed on the Waterworks property to demonstrate how to raise fresh, healthy food and possibly heritage corn, squash and beans like prehistoric cultures might have raised. The non-potable water could also be piped over to the botanical gardens. Understanding the history of water shortages at the Waterworks and the legacy of Silver City’s “Big Ditch,” and how they relate to the health of the watershed will help inform future land management decisions.

32 Netz, Ken, Drainage Report and Grading Plan for Town of Silver City Rock House Water Works Building, August 2011.

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Attachments

LIST OF ATTACHMENTS [the Threshold Criteria section is considered an Attachment] Letter of support from state authority: New Mexico Environment Department [to be added]

Draft Analysis of Brownfields Cleanup Alternatives (ABCA) [attached] Letters of Support [letters were requested from the following entities; to be added]:

Local/State Environmental and Health Agencies: New Mexico Environment Department (NMED) Groundwater Quality Bureau, Santa Fe. NMED Occupational Safety and Health Bureau, Santa Fe. NMED Surface Water Quality Bureau, Silver City Field Office Grant County Health Promotion Team, with New Mexico Department of Health

Other Federal/State Agencies: New Mexico Historic Preservation Division New Mexico Department of Transportation New Mexico Department of Labor New Mexico Economic Development Department US HUD – Albuquerque field office USDA – Rural Development

Job Training Program: Santa Fe Community College

Community-Based and Other Organizations or Individuals: Southwest New Mexico Council of Governments Jose Barrios Elementary School Royal Scepter Gems and Minerals Gila Conservation Education Center Gila Resources Information Project Aldo Leopold High School – YCC program The Wellness Coalition – YVC/Americorps programs The Volunteer Center of Grant County Arts and Cultural District Silver City Museum Society Grant County Trails Group Main Street Project Freeport McMoRan Foundation Cornerstones

Documentation of community notification [to be added]

Hardship Waiver Request [attached]

Special Considerations Checklist [attached]

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant ABCA – page 1

ANALYSIS OF BROWNFIELD CLEANUP ALTERNATIVES Silver City Waterworks

EPA Brownfields Cleanup Grant, FY13 Draft – October, 2012

Introduction and Background

The Silver City Waterworks, built in 1887, provided the Town’s first municipal water supply. Located on Little Walnut Road next to the Jose Barrios Elementary School, the building is sometimes called the “Rock House,” because it was constructed of local sandstone. It has a 1-story section that once housed steam-powered pumps and boilers, and a 2-story section that was a residence for the engineer and his family. Water was collected from subsurface streams in a 500-foot long tunnel or “collection gallery.” Pumps in a 30-foot deep pit within the building boosted the water up to reservoirs on an adjacent hill, from which it flowed down into the Town’s water system.

After deeper, more reliable wells were developed in the 1940’s, the Waterworks was disconnected from the Town’s water system. Non-potable water continued to be available until 2000. The building was used as a residence for city employees until 1967, and then used as a maintenance shop for the Utilities Department until about 1984. It is currently vacant and in a dilapidated condition, although recent activities have greatly improved its outward appearance and stability of masonry walls.

As a result of the Town being awarded an EPA Brownfields Site Assessment Pilot Project Grant in 2000, Phase I and II assessments were conducted at the Waterworks property. Lead-based paint was detected throughout the building, and floor tile and mastic were found to contain asbestos. Deposits of bat guano were discovered more recently, and probably date back to when the building was vacated.

The Town now proposes to apply for up to $200,000 in funding from EPA Brownfields Cleanup Grant to address lead/asbestos/bat guano abatement at the Waterworks. A nature center/water museum, possibly a “living museum” with a resident caretaker, is the current vision for reuse.

A grant from the Freeport McMoRan Copper and Gold Foundation in 2011 paid for updated engineering and architectural assessments, educational outreach, and a highly successful volunteer service-learning project in masonry repair. Youth volunteers and others have spent many additional hours on removing non-native vegetation, drainage projects, painting historic-looking panels to cover boarded-up doors and windows, and other improvements. These recent activities have greatly increased awareness and visibility of the Waterworks property.

The Analysis of Brownfields Cleanup Alternatives (ABCA) is a screening tool to document selection of the appropriate type of cleanup for the Waterworks building. The preferred remedial action takes into account past studies and rehabilitation activities, the surrounding environment, potential reuse, and the fact that the building is listed on the National Register of Historic Places.

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant ABCA – page 2

Applicable Regulations and Cleanup Standards

The Town proposes to conduct general project oversight with assistance from the New Mexico Environment Department (NMED) and US Environmental Protection Agency (EPA). The NMED recently funded additional assessment work and a remediation plan for the Waterworks, including a work plan and cost estimates. These will be incorporated into the final ABCA.

An environmental health consultant will be hired with grant funds to develop specifications for cleanup of lead-based paint, asbestos and bat guano, and to oversee and monitor cleanup activities. Cleanup will be carried out by a qualified contractor with certifications in lead and asbestos abatement. Volunteers may assist with cleanup of bat guano, and with painting and re-plastering to encapsulate lead-based paint as appropriate, and will receive appropriate training.

Cleanup must be protective of human health and the environment, and must follow state and federal regulations. Cleanup must also be protective of historical features in the Waterworks, requiring consultation with the New Mexico Historic Preservation Division. State remediation standards for residential use will be followed because of potential reuse as a “living museum.”

A licensed asbestos abatement contractor must remove asbestos-containing materials (ACM) containing more than 1% asbestos. NMED Solid Waste Bureau regulations require that waste ACM must be disposed of at an asbestos-approved landfill. Paint with lead content of over 0.5% is considered lead-based paint (LBP) and must be renovated by a certified contractor. EPA implemented regulations in 2010 that apply to properties built pre-1978 and require contractors to follow specific work practices to prevent lead contamination. LBP must be disposed as hazardous waste if ≥5.0 ppm of lead can be leached from the material using TCLP.

OSHA and other regulations apply to protection of workers exposed to LBP and ACM, and a confined space entry permit may be required for removal of debris from the 30-foot deep pumping pit. Air monitoring may or may not be required during abatement of asbestos since the vinyl floor tile and mastic were identified as containing non-friable ACM. Evaluation of Cleanup Alternatives

Three alternatives were developed to address the lead/asbestos/bat guano contamination at the Waterworks building. The “No Action” alternative is used as a baseline against which others can be compared. Evaluation criteria considered in developing alternatives included:

• Short-term and long-term protection of public health and the environment • Feasibility of the alternative, including ability of grantee to implement it • Compatibility with future reuse of the property • Cost (estimates are preliminary, for relative comparison).

Alternative 1: No Action The Waterworks building is currently boarded up and the property is fenced with “No Trespassing” signs. Under the “No Action” alternative, the property would remain closed up and inaccessible except to authorized personnel. Without lead/asbestos/bat guano abatement, further rehabilitation efforts would be limited to mothballing the structure. Volunteers, Town personnel and funding agencies would be unlikely to contribute additional funding and energy to the building, and it would deteriorate, creating urban blight rather than renewal.

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant ABCA – page 3

This alternative is not desirable because it does not meet reuse goals recommended in planning studies done for the property. It would certainly disappoint private and public donors and volunteers who have substantially contributed to rehabilitation planning and activities. “No Action” may eventually result in collapse of the building and release of hazardous materials. With an elementary school adjoining to the south, and a riparian area behind the property, the potential risk to human health and the environment with this alternative is high. Alternative 2: Cleanup of Hazardous Materials followed by Demolition Under this alternative, materials with lead paint and asbestos including vinyl tile, paint on walls and ceilings, and windows and doors, would be removed and taken to a landfill authorized to accept hazardous waste. Containment would be required to keep hazardous materials from migrating off-site. The building would be demolished, the pumping pit filled with dirt and the land reclaimed. Sandstone from the building could be salvaged or used as fill material. Although listing on the National Register of Historic Places does not totally protect a building from demolition, it affords some protection if federal funds are used. For the proposed EPA funding, consultation with the New Mexico Historic Preservation Division would be required to obtain approval. It is unlikely that NMHPD would approve demolition of this historic structure, especially since NMHPD has supported rehabilitation of the Waterworks with grants and other assistance since its listing on the Register in 1984. Therefore with this alternative, the Town would likely have to pay for the abatement and disposal of hazardous materials. For comparison, the cost of remediation of lead paint, asbestos, and pigeon droppings for the old Hillcrest Hospital was about $340,000. Demolition and redevelopment costs for the Waterworks property would depend on the type of structure to be built. The beautiful historic building would be destroyed and the story of craftsmanship written in its walls would be lost. Alternative 3: Cleanup of Hazardous Materials followed by Continued Rehabilitation Under this alternative, the EPA Brownfields Cleanup Grant would cover abatement of lead-based paint, asbestos-containing materials and cleanup of bat guano in the Waterworks building. Historic features would be preserved. The asbestos-containing vinyl tile and mastic would preferably be removed; however, encapsulation with another layer of tile may be an option if the underlying wood floors would be severely damaged by removal of the tile. Windows and doors with lead-based paint and/or asbestos will be salvaged, treated to remove hazardous materials, and rebuilt with “in-kind” materials as required. Plaster on ceilings will be removed and tested for appropriate disposal. Lead-based paint on the plastered walls in the residential section and pump room will be removed with care, and a new layer of plaster applied. Surface finishes applied to walls must be able to “breathe” because of the stone masonry; therefore, latex or oil-based paint can’t be used to encapsulate walls. Encapsulation with paint could be performed on the wood moldings.

The floor in the pump room, over the 30-foot deep pit, is collapsing. To access debris in the pumping pit for confirmatory sampling and removal, and abatement of any lead-based paint or asbestos in the pump room, the floor will be rebuilt and stabilized. Recommended Cleanup Alternative: Alternative 3, as a critical step towards rehabilitation and reuse of the building.

Silver City Waterworks FY13 EPA Brownfields Cleanup Grant Hardship Waiver

HARDSHIP WAIVER REQUEST

The Town of Silver City requests a hardship waiver of the 20% cost share for this Brownfields Cleanup Grant. The Town suffers from problems common to frontier rural communities with high poverty rates and an aging population as young people seek employment elsewhere. From 2000 to 2010, the Town’s population dropped from 10,545 to 10,315, and decreased even further to 10,269 in 2011, according to the U.S. Census33. Its percentage of elderly over age 65, 19%, is higher than state or national levels. Freeport McMoRan Copper and Gold is a major employer in the area, and the area’s economy is sensitive to swings in the price of copper. When operations at the mines were curtailed in 2008-2009, unemployment in the county skyrocketed to 13% in June-July, 2009. Copper prices have since rebounded, and unemployment decreased to 7.3% as of July, 2012, although the area’s economy remains sluggish. This summer’s Whitewater-Baldy wildfire in the neighboring Gila National Forest was the largest in New Mexico’s recorded history, and impacted recreational activities and tourism in the region. Silver City’s per-capita income is lower than that of the county, state or nation, and its poverty rate is 17.9%, exceeding the national level of 13.8%34. The Town’s isolation translates to higher prices for gasoline and food, and a high percentage of the area’s population depends on public support. The Town of Silver City relies on gross receipts taxes as the foundation of its income, and its GRT revenues plunged during the recent recession. It has been successful at obtaining grants for infrastructure development, managing over $5.8 million in grants in FY11. Infrastructure and site preparation for a new affordable housing development, Vistas de Plata, was financed with over two million dollars in federal (HUD) and state grants. The EPA Brownfields Cleanup Grant would help achieve the Town’s vision of rehabilitating the historic Silver City Waterworks into a nature center/water museum to improve educational and recreational opportunities for the Town and add to its quality of life. The cost waiver will allow the Town to use those funds for other critical needs.

33 US Census Bureau “Quickfacts” at http://quickfacts.census.gov/qfd/states/, and 34 2006-2010 data from U.S. Census Bureau “Quickfacts.”