Case Study- Growing Toward Tomorrow, Together: Integrating Remedy And .
Growing Toward Tomorrow, Together: Integrating Remedy and ReuseT H E C AMIL L A W OOD P RE SE RV I N G SU P E RFU N D SI T E I N CA M I L L A , G E O RG IAwww.epa.govIntroductionThe small town of Camilla, Georgia, was wrestling with asignificant challenge. A 40-acre area close to downtown wascontaminated and had been vacant for almost a decade. EPAhad listed the former Camilla Wood Preserving Company woodtreating facility on the Superfund National Priorities List in 1998.While site investigations were ongoing, the fenced area remainedan eyesore and health concern.Through the early and sustained engagement of the community,local and state governments, and EPA, the one-time liability hasbeen replaced with productive reuses addressing communitypriorities. The City of Camilla and Mitchell County have builtrecreational facilities, including several soccer fields, on thewestern, 25-acre portion of the site. Plans are also in place toreuse the remainder of the site following cleanup.Since the early 2000s, EPA, the Georgia Environmental ProtectionDivision (EPD), the City of Camilla, and Mitchell County havebeen working together in support of a coordinated approach tothe cleanup of the Camilla Wood Preserving Superfund site. Theapproach has linked cleanup and redevelopment, with a protectiveremedy and land revitalization as overarching goals. In 2002,EPA selected the site as a Superfund Redevelopment Initiativepilot project, which led to the development of the community’sreuse plan for the site in 2003. Updated in 2007, the plan laid thefoundation for returning the site to recreational use.Today, hundreds of area youth and adults participate in soccerand football leagues on site, addressing a surging need in theregion for recreational fields. Integration of remedy and reusealso streamlined the Superfund process and provided substantialcost savings. Original cleanup costs were estimated at over 100million; they are now 14.4 million. The remedy’s componentsallow for the community’s reuse goals and have enabled cleanupto take place more rapidly and efficiently and at less cost.In April 2012, EPA recognized the community’s efforts with theAgency’s Excellence in Site Reuse Award. “The City of Camillaand Mitchell County worked collectively to establish soccerThe Camilla Wood Preserving site is located in Camilla, a small town (pop.5,360) in southwestern Georgia, about 60 miles north of Tallahassee.fields and recreational centers on the site to benefit all the citizensof Camilla and enhance long-term maintenance of the remedy,”noted Region 4 Superfund Director Franklin E. Hill at the awardceremony. In 2010, the community was also recognized by theAssociation County Commissioners of Georgia and GeorgiaTrend magazine for “improving services for county residents andenhancing quality of life in Georgia communities.”This case study explores the strategies and working relationshipsthat led to the successful cleanup and reuse of the Camilla WoodPreserving site. The following pages trace the evolution ofcleanup and reuse efforts, highlighting local planning efforts andcoordination with site agencies in the 2000s and ongoing cleanupand reuse activities through 2012. The case study providesinformation and lessons learned to parties interested in therecreational reuse of Superfund sites and how to address remedyand reuse considerations throughout the Superfund process.Use of the site’s two sports fields has increased steadily since 2007. Site reuses also include an aerobics classroom and office space for Mitchell County’sParks & Recreation Department, a concession stand, lights and parking.1U.S. Environmental Protection AgencySuperfund Redevelopment Initiative
Site History, Contamination and RemediationWood preserving activities at the site between 1947 and 1991resulted in the contamination of site soils and ground waterwith dioxin, pentachlorophenol, creosote and polyaromatichydrocarbons. As these pre-cleanup photographs illustrate,site facilities included treatment cylinders, also called retorts(bottom), and pole barns where pressure-treated wood wasplaced for drying and storage (right). There were also twosmall office buildings on site. Prior to its development, thearea had been a cypress swamp.EPA performed investigations and short-term cleanups calledremoval actions at the site from 1991 through 1997. Activitiesincluded treatment or disposal of on-site surface water,gathering and storage of drums with spent chemicals from thetreatment process, and removal of equipment and debris offsite. EPA placed the site on the Superfund program’s NationalPriorities List (NPL) in July 1998.In 2006, EPA Region 4 identified an opportunity to moveforward with the cleanup of the western portion of the site asa removal action. In total, 10,000 cubic yards of contaminatedsoils were excavated and stockpiled on the eastern portion ofthe site for later cleanup; an additional 10,000 cubic yards weredisposed of off site. Excavated areas were then backfilled withclean soil, meeting EPA’s recreational use criteria. Remainingpole barns and contaminated soils lining the drainage ditchzone on the western half of the site were also removed, withthe ditch backfilled with clean soil, graded and revegetated.Fencing was installed between the two halves of the site.Aerial view of the site prior to cleanup.In 2009, EPA issued a Record of Decision (ROD) selecting a final, comprehensive remedy for the site, addressingsoil contamination on the eastern portion of the site and site ground water. Components of the remedy included: On-site stabilization and solidification of contaminated soils. Installation of a below-ground barrier wall to contain ground water contamination. Ground water treatment and monitoring to ensure contamination degrades over time. Land use controls to limit future uses to non-residential uses only, prohibit ground water use for drinking waterpurposes, and prohibit soil removal or digging near treated material.Throughout planning and cleanup activities, EPA and Georgia EPD staffmet regularly with local stakeholders to share information and updates andto incorporate community feedback into the Superfund process. The selectedremedy was consistent with the community’s future land use plans, enablingthe western portion of the site to be reused for recreational purposes. Finalcleanup activities for the western portion of the site began in November 2006;construction of the remedy was completed in January 2008. Cleanup of theeastern portion of the site began in May 2012 and is scheduled for completionin mid-2014.2
Project History2002 – 2003Recognizing Opportunities, Developing PlansBy 2002, EPA and Georgia EPD had been updating the Cityof Camilla and Mitchell County regarding site activities forseveral years. “We had good communication with the agencies,”recalled former Camilla City Manager Michael Scott. “Weunderstood that it was going to be a long-term process.”For EPA On-Scene Coordinator Leo Francendese, learningabout the community’s priorities for the site was also essential.“Without an understanding of how the site might be used in thefuture, initial cleanup plans called for digging up and haulingover 200,000 yards of contaminated soil to a landfill,” he said.“It would have been very expensive.” With limited federaldollars available for Superfund-lead site cleanups, it could alsohave been years before funding became available.The idea of reusing the site elicited a strong, positive reactionfrom the community. “Cleaning it up and then fencing it offand forgetting about it didn’t make any sense,” recalled formerCamilla Mayor Jay Powell. “Remember, this is a large arearight next to downtown. We saw an opportunity to turn a bignegative into a big plus.” Considering reuse offered significantbenefits for site agencies – EPA and Georgia EPD – and thecommunity. Understanding the site’s reasonably anticipatedfuture use meant EPA could better target site investigations,saving time and money while still ensuring the protectivenessof the remedy. For the community, a streamlined cleanupprocess meant that site reuses could happen safely and soonerrather than later.Detailed community map.county to apply for pilot project funding from the Agency’sSuperfund Redevelopment Initiative (SRI) to conduct acommunity-based reuse planning process. The funding,awarded in late 2002, enabled the localities to move forward.The City of Camilla established and worked with a communitybased Land Use Committee and a consultant team to develop aconceptual reuse framework plan.To ensure the plan would be feasible and compatible withthe site’s cleanup alternatives, the project team developeda detailed understanding of site conditions. As draft reusescenarios circulated, the project team evaluated how theymight work with different cleanup approaches. To do this, theproject team coordinated closely with EPA’s Leo Francendese.“We [site agencies] were at the table as resources,” he recalled.“The decision-making process belonged to the community.”During the six-month project, the Committee discussed anddefined reuse priorities for the site. Strong initial interest in aFirst, though, the community needed to explore local land useneeds and priorities. EPA site staff encouraged the city andReuse Planning in CamillaCamilla City Council formed a Land Use Committee torepresent community perspectives and guide the reuseplanning project. The Committee also provided a forum forthe community to learn about the site.The reuse planning process included diverse local interests.Committee members included a city councilor, a farmer,the city manager, the fire chief, the recreation director,neighborhood residents and a representative from MitchellCounty.In addition to committee meetings, the project also includeda public comment period and presentations to Camilla’s CityCouncil.Marked-up site map identifying key cleanup and reuse considerations.Close coordination with EPA and Georgia EPD site staff ensured theproject’s draft reuse scenarios accurately reflected site conditions andcleanup considerations.3
The community’s 2003 reuse plan for the site.fire and rescue training area expanded to include a communitypark and trails serving local residents and visitors. Otherpriorities included a small caravan/RV park and a stormwatermanagement area for parts of the site prone to flooding.Committee members also emphasized the importance ofreconnecting the site with the rest of Camilla and recognizingthe site’s history as part of the community’s heritage.The Committee presented the project’s final reuse planto Camilla City Council in June 2003, which approved itand submitted it to EPA in late 2003. “The process wasstraightforward and productive,” said Michael Scott, who alsoserved on the Committee. “The Committee identified publicsector land uses as a community priority, and the site was large4enough to be able to accommodate several of these uses.” EPAand Georgia EPD staff indicated that the reuse plan would becompatible with a range of likely cleanup approaches at thesite.2004 – 2007Making the Most of OpportunitiesBetween 2004 and 2006, targeted site investigations informedby the community’s reuse plans continued. Interim cleanupsteps included the removal of contaminated drums and thesolidification of a former wastewater pond on site. Next steps
for the site’s reuse were on hold, pending the selection ofthe site’s final remedy. In the community, several parks andrecreation departments in the area consolidated into a singledepartment operated by Mitchell County.In 2006, these activities were overshadowed by a suddenopportunity. EPA Region 4 identified a way to move forwardwith the cleanup of the western portion of the site as a removalaction. “We proposed cleaning up contaminated soils torecreational standards, in line with the community’s anticipateduses for the site,” said EPA’s current site Project Manager ScottMiller. “That meant replacing soils with clean fill and cleaningup sediments in several drainage ditches.”SRI provided additional resources so that the community couldwork with Region 4 to update the 2003 reuse plan. The reason –local conditions had changed. A fire and rescue training facilityhad been built in a nearby community. Meantime, a regionalneed for new soccer fields had grown rapidly. The Land UseCommittee determined that the site would be an ideal locationfor a soccer complex, given its close proximity to majoraccess roads, athletic fields, Mitchell-Baker High School andresidential neighborhoods.“In 2003, there were no soccer fields in the area,” recalledcurrent City Manager Bennett Adams, who was previouslyMitchell County’s long-time County Administrator. “Then,demand took off. Parents were driving their kids out of thecounty to play. We needed fields badly.” Following severalpublic meetings, the Committee also identified the needfor basketball courts and a flexible open space area. TheCommittee also retained the small RV park in the revised plan,and proposed the adaptive reuse of the remaining building onsite as office and storage space for Mitchell County’s Parks andRecreation Department.“The reuse implications of the removal action werestraightforward,” said EPA’s Scott Miller. “The cleanup actionwould place a foot of clean fill on the western part of thesite. That depth of fill would need to be maintained movingforward. The community could pave or grade the area or plantvegetation, as long as the fill remained 12 inches deep.”Other next steps, however were less clear. Proceeding withacquiring contaminated property, for example, was new groundfor the community. “The site property had been abandonedand both the city and county were owed back taxes that weregreater than the land’s market value,” said former city attorneyMichael Bankston. “It was unlikely that the bank holding a lienon the property or any other party was going to be interestedin it. But we also needed to make sure that acquiring the sitewould not expose the city to any liability.”To do this, the city coordinated closely with EPA Region’s4’s legal staff and hired an environmental law firm to reviewdifferent acquisition options. In fall 2006, the city determinedthat involuntary acquisition, covered under an explicit liabilityexemption under CERCLA, would provide the best liabilityprotection. “EPA was instrumental in advising us how to dothis,” recalled Michael Bankston. “We needed their guidanceto feel comfortable moving forward.”To foreclose on the property, the city selected an administrativeproceeding as the best approach. An administrative proceedingTimeline of Events1947 – 1991 Wood preserving activities contaminate sitesoils1991 – 1997 EPA conducts series of short-term cleanups(removal actions)EPA lists site on the NPLJuly 19982002 – 2003 City of Camilla requests SRI assistance;community-based reuse planning processunderwayCity of Camilla finalizes first site reuse planFall 2003County-wide Parks & Recreation2005Department createdEPA begins time-critical removal action toNov. 2006address contaminated soils on western halfof the siteFall 2006 – Community updates site reuse planSpring 2007Aug. 2007Sept. 2007Jan. 20082010May 2012201220142014 City of Camilla acquires site property andtransfers ownership to Mitchell CountyMitchell County Recreation Complex opensEPA completes time-critical removal actionCommunity receives Association CountyCommissioners of Georgia Award forexcellence in community planning/visioningEPA begins cleanup of eastern portion of thesiteCity of Camilla and Mitchell Countyawarded EPA Region 4’s Excellence in SiteReuse awardScheduled completion date for cleanup ofeastern portion of the sitePlanned recreational reuse of eastern portionof the site5
The community’s revised 2007 reuse plan for the western portion of the ation, and Liability Act (CERCLA) is the lawpassed by Congress on December 11, 1980, that is commonlyknown as Superfund.unhindered title to the property, but the lengthy legal processwould likely have meant delaying the planned opening of thepark – targeted for September 2007. Cooperation between thecity and Mitchell County was also critical to the foreclosureprocess. After surveys, subdivision and the 12-monthredemption period, the city would be able to take clear title tothe western 25 acres of the site in August 2007.would provide the city with title to the property immediately,but the property would be subject to redeemable interests for a12-month period prior to the planned opening of the communitypark. In contrast, judicial action would provide the city withIn the meantime, the community was completing the secondphase of the reuse planning process and EPA initiated theremoval action in late 2006. It was time to move from planningto implementation.CERCLA6
2007 – 2012Partnering to Get the Job Done The Bigger Picture: EPA and ReuseBeginning in 2007, the cleanup and reuse of the western portionof the site relied on close and extended collaboration amongEPA, the City of Camilla and Mitchell County.Efforts to address future land use considerations at theCamilla Wood Preserving site fit in well with emergingnationwide interest in the revitalization of contaminatedareas, including Superfund sites. With the creation of EPA’sSuperfund Redevelopment Initiative in 1999 and its LandRevitalization Agenda in 2003, EPA’s Office of Solid Wasteand Emergency Response launched a new EPA initiativefocusing on promoting land reuse and revitalization atcontaminated sites. The city and county agreed to be responsible for takingcare of the property – mowing and maintaining the grasscover – over the long term. EPA remains responsible forongoing cleanup activities such as ground water sampling. The city’s Electric Department coordinated with EPA toextend utilities on site. Utilities were placed in a trenchwith a protective barrier adjacent to the on-site roadbuilt during earlier cleanup activities. EPA’s contractorcompleted all digging and burial activities in accordancewith the remedy. Utilities included water, wastewater andelectric systems, sprinkler systems and lighting. Once the removal action was completed, EPA and MitchellCounty worked together to purchase and place sod overthe clean soil. Work crews also cleaned and refurbishedthe remaining building. Once the City of Camilla acquired the site propertyin August 2007, it transferred ownership to MitchellCounty, given the county’s responsibility for local publicrecreation resources. Both localities worked together topay for, build and install the site’s parking lot, concessionstand and lights. An in-state business also donated pipingfor the park’s irrigation system, saving the city and countyapproximately 9,000.“With everyone working together, it was like a turn key project,”said Mitchell County Parks & Recreation Department DirectorIke McCook. “There was a lot to do and it all got done.”As September 2007 approached, it became clear that theMitchell County Recreation Complex would open as planned.Even so, local officials were not entirely sure how thecommunity would respond. “I was a little skeptical,” recalledIn 2002, the Small Business Liability and BrownfieldsRevitalization Act also became law. The Act was designedto make the acquisition and redevelopment of contaminatedproperties like Superfund sites easier by addressing theliability concerns associated with these sites. EPA’s Officeof Site Remediation Enforcement has a team devoted tofacilitating and implementing these liability protections. Seethe Resources section for more information.City Manager Bennett Adams. “I thought some people mightstill be thinking about the past. I said to Ike McCook, ‘I hopewe have someone show up.’”In the end, there was no cause for concern. More than 400people attended the opening of the Mitchell County RecreationComplex. Since then, the use of the facility has steadilyincreased; it is now the area’s most heavily used publicrecreation resource. In 2011, 576 children and adults played insoccer and football leagues at the recreation complex, more thantripling initial usage of the fields in 2008. “In the beginning,you could hear people at soccer games talking about how [thecomplex] was built on a Superfund site,” said Ike McCook.“Now, you don’t hear anything. It’s part of daily life.” Looking Back, Looking ForwardThe cleanup and reuse of the Camilla Wood PreservingSuperfund site has provided sparkling results – a streamlinedcleanup process that has saved time and millions of dollars oftaxpayers’ money. “Early involvement from the city and countyCleanup activities on the western portion of the site in 2007.7
Recreation Statistics for the Mitchell County Recreation ComplexYear200820092010Fall YouthSoccer League95124148Number of Participants*Winter SoccerFall FootballLeague(flag and tackle)71NA93NA111215Adult Soccer League(year-round)NANA125*Data provided by Mitchell County Parks & Recreation Department in July 2012.was key,” said Georgia EPD Project Manager Penny Gaynor.“Without the community’s interest and feedback, the cleanupprobably wouldn’t have happened so fast. Knowing there is anend user [at a Superfund site] really helps EPA and the stateagencies.”Not all parts of the site’s reuse have gone according to plan.The seven-space RV park was partially built before work washalted; the area is needed for planned upgrades to the site’sstormwater retention basin. Resource limitations have delayedthe installation of planned trails. Overall, however, site agenciesand the community remain very pleased with how the site’scleanup and reuse has worked out.“In 2002, people were resigned to the fact that nothing wouldever be done with the site,” recalled former City ManagerMichael Scott. “Afterward, people were coming up to mesaying, ‘you really took care of an eyesore that we didn’t thinkwe ever would see anything done with in our lifetimes.’ I hopethe next phase is as successful for the community.”Looking forward, EPA kicked off cleanup for the easternportion of the site in May 2012. The city and county are onceagain collaborating with site agencies to integrate remedyand reuse considerations, including access points, utilityconnections and grading. “It continues to be a pleasure to workwith the community,” said EPA Project Manager Scott Miller.“I’m optimistic that the city and county will be able to optimizean appropriate mix of recreational uses on the eastern side ofthe site.”The city and county have drawn up initial plans toaccommodate remaining priority recreational uses identifiedby the community, including basketball courts, baseball fields,batting cages, a playground, picnic tables and a volleyballcourt. Walking and biking trails could also be extended acrossthe entire site and connect to downtown Camilla followingcleanup. “The second phase of the cleanup project is underwayand we’re hoping everything will work out as planned,”said City Manager Bennett Adams. “We’re taking a flexibleapproach in case any obstacles come up.”8At the end of the process in 2014, site agencies and thecommunity will work together on a final step – implementationof institutional controls in the form of a restrictive covenant toensure the long-term protectiveness of the entire site remedy.The covenant will limit future land use to nonresidential usesonly, prohibit ground water use on the property for drinking,and prohibit soil removal or digging within the boundary of thetreated material.Looking back, the project has been guided and spurred by aspirit of collaboration and innovation, coordination amonglocal, state and federal partners, and local government andcommunity leadership. The outcome is the successful cleanupand recreational reuse of the Camilla Wood PreservingSuperfund site.
The Camilla Wood Preserving Site:The Story in PicturesFrom Planning.To Cleanup.To Reuse.9
Lessons LearnedParticipants agree that a combination of significant factors havecontributed to the project’s successful outcomes. The site’s proximity to residential areas and downtownCamilla and the need for public recreation facilitiesmeant that cleanup and redevelopment were highpriorities. The City of Camilla and Mitchell County energeticallypursued the site’s cleanup and redevelopment over thelong term. EPA provided two phases of reuse planning assistancethat supported the community’s efforts to develop reuseplans and update them over time as local prioritieschanged. EPA and Georgia EPD understood the community’sredevelopment priorities in the context of the site’sremedy, enabling decision documents and a cleanup thatreflected remedy and reuse considerations. Coordination of utility and sod installation withcleanup activities saved time and money and helped thecommunity open the recreation complex on schedule inSeptember 2007. EPA had selected a remedy for the site that would beconsistent with the site’s reasonably anticipated futureland use. All parties involved were patient and flexible,recognizing that cleanup and redevelopment are complexprocesses reliant on available resources, multiple parties,site contamination and other factors.The Bigger PictureWhile these site-specific conditions created an ideal climatefor successful reuse outcomes, there are also a range ofbroader lessons learned that can help guide similar projects atcontaminated lands across the country.EPA works closely with communities, site owners and otherstakeholders to support reuse outcomes that are compatiblewith site cleanups.The Agency places a high priority on supporting the return ofcontaminated sites to productive and beneficial uses. In Camilla,the community was able to work with EPA and Georgia EPDto develop site reuse plans that reflected site conditions andcleanup plans. In turn, the community’s reuse plans were ableto inform EPA’s selected remedy for the site.10While EPA provides tools and resources to supportSuperfund reuse, communities and public- and privatesector organizations make it happen.EPA’s mission is to protect human health and the environment.EPA relies on engaged community stakeholders to bring theirfuture land use goals and priorities to the table so that thisinformation can be incorporated into the remedial process,linking cleanup and redevelopment. In Camilla, the city andcounty shepherded the site’s redevelopment from the outsetand acquired part of the site in 2007 to make it happen. Thecity and county’s coordinated long-term effort to transform thesite into a community asset was essential to the site’s successfulreuse.Local governments can play a unique leadership role incleanup and redevelopment projects.As the organizations responsible for their communities’ generalwelfare, local governments are particularly well positionedto host redevelopment projects, bring together diversestakeholders to discuss site cleanup and reuse opportunities,and use planning tools and incentives to foster positive siteoutcomes.Effective reuse planning projects are inclusive, informationbased and focused on targeted outcomes.Community-based reuse planning processes can be mosteffective when they engage diverse stakeholders, includingsite owners and prospective purchasers, are based on detailedsite and community information, and lead to implementablestrategies and next steps. Community engagement was a centralcomponent of the City of Camilla’s reuse planning process forthe site.The design of site remedies can reflect and incorporateplans for a site’s reasonably anticipated future land use.The community’s reuse plan and EPA’s remedial planning forthe site were able to directly inform each other in Camilla.EPA’s site information and remedial considerations guided thetypes and locations of land uses that would ensure the protectionof human health and the environment and the site’s long-termstewardship. In turn, the community’s reuse priorities informedEPA’s consideration of the site’s remedy components in the2006 removal action and the site’s 2009 Record of Decision.Reuse plans and cleanup approaches can both changeover time. Such changes provide further opportunities tointegrate remedy and reuse considerations.In Camilla, the community’s recreational needs changedsignificantly between 2003 and 2006. The second phase of SRIsupported reuse planning enabled the community to update andalign its plans with EPA’s removal action.
Build on past experience.Parties at the Camilla Wood Preserving site charted new territoryin addressing stigma and other site issues. Today, thanks to thechanges to CERCLA when the bona fide prospective purchase(BFPP) provisions of the 2002 Brownfields Revitalization Actwere added, the availability of environmental insurance, andEPA tools such as Ready for Reuse (RfR) Determinations,resources for redevelopment are more widely available.Prospective purchasers can contact EPA site teams to learnmore, or see the Resources section on the next page foradditional information.EPA and Reuse: Lessons LearnedSince the inception of the Superfund program, EPA has beenbuilding on its expertise in conducting site characterizationand remediation to ensure that contamination is not a barrierto the reuse of property. Today, consideration of future use isan integral part of EPA’s cleanup programs, from initial siteinvestigations and remedy selection through to the design,implementation, and operation and maintenance of a site’sremedy.ConclusionEvents at the Camilla Wood Preserving Superfund site illustratehow remedy and reuse can come together to provide significantbenefits – the protection of human health and the environmentand community revitalization. Integration of remedy and reusestreamlined the Superfund process and provided substantialcost savings. Without the discussion of reuse, the remedy beingconsidered at the site could have potentially compromisedthe community’s reuse goals. Once reuse came into play, theremedy was no longer the e
Use of the site's two sports fields has increased steadily since 2007. Site reuses also include an aerobics classroom and office space for Mitchell County's Parks & Recreation Department, a concession stand, lights and parking. The Camilla Wood Preserving site is located in Camilla, a small town (pop.
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