Brownfields Response Program...

The Natural Resources Department and the Salish Kootenai Housing Authority are currently in the final stages of the Brownsfield Clean-up of the former Elmo Cash Store.  This cooperative endeavor completes over five years of planning and with the help of an US Environmental Protection Agency clean-up grant ensures this site has the potential to be redeveloped for future use.

In 1995, the United States Environmental Protection Agency (EPA) established the Brownfields Tribal Response Program and has since then, grown into a principal nationwide plan of environmental restoration. In 2003, the Confederated Salish and Kootenai Tribes began a Tribal Brownfields Response Program funded by grant monies provided by the EPA.

As you read this, you might say to yourself "we do not have such Brownfields here on the Flathead Indian Reservation" but in fact we may. Brownfields can be almost anywhere and any thing that includes underground storage tanks, Methamphetamine labs, abandoned or under used buildings, and opens dumps.

According to the United States Environmental Protection Agency State and tribal response programs play a significant role in cleaning up Brownfields. As Congress recognized in the legislative history of the Brownfields Law, "The vast majority of contaminated sites across the nation will not be cleaned up by the Superfund program. Instead, most sites will be cleaned up under State authority." Prior to the passage of the Brownfields Law, EPA developed a framework for negotiations between EPA regions and states regarding State Voluntary Cleanup Programs. This preliminary framework was the precursor to how EPA works with states and tribes today.

The EPA also states that the continued demand for Brownfields cleanup and redevelopment in communities throughout the country, coupled with increasingly limited state and tribal resources, makes access to federal funding critical. The law authorizes EPA to provide up to $50 million in grants to states and tribes to establish or enhance their response programs. Generally, these response programs address the assessment, cleanup, and redevelopment of Brownfields. In 2003, EPA distributed almost $50 million among all 50 states, 30 tribes, the District of Columbia, and the Virgin Islands. This funding will enable states and tribes to develop or enhance their response program's infrastructure and capabilities. For some recipients, the funding will provide an opportunity to create new response programs to address contaminated properties. States and tribes also can use the new funding to capitalize a revolving fund for cleanup, purchase environmental insurance, or develop other insurance mechanisms to provide financing for cleanup activities. In addition, the funds can be used to establish or maintain the statutorily required public record, to oversee cleanups, and to conduct site-specific activities.

The EPA provides financial assistance to states and tribes, which increases their capacity to meet the Brownfields cleanup and redevelopment challenges. It will also help to ensure that properties are cleaned up safely, according to state and tribal standards to protect Human Health and the Environment. In the start of the Tribal Response Program in 2003, the Program received grant funds in the amount of $99,000. In 2011/12, the Program received grant funds in the amount of $155,000.  These funds were used to perform program management activities that include but not limited to;

Administer and implement the TRP Four Elements.
	Timely Survey and Inventory of Brownfield Sites.
	Oversight and enforcement Authorities or Other mechanisms and Resources.
	Mechanisms and Resources to Provide Meaningful Opportunities for Public Participation.
	Mechanisms for Approval of a Cleanup Plan and Verification and Certification that Clean-up are Complete
Develop and approve RFPs.
Develop/Manage/oversee contracts.
Manage/oversee Brownfield/Solid Waste Aid(s)
Prepare Property Profile Forms.
Obtain Training as needed and available.
Inspect sites within the exterior boundaries of the Flathead Indian Reservation.
Resolve issues, concerns, and complaints.
Administer and implement the CSKT Solid Waste Ordinance NO 106A.
Assists and provide technical assistance when necessary to EPA, Lake County Environmental Health, Tribal Law Enforcement, Tribal Programs, and Tribal Council.
Write quarterly, mid & end year reports due to EPA.
Write quarterly, mid & end year reports due to CSKT.
Maintaining Public Record for the Tribal Response Program.
Prepare Site Eligibility Forms due to EPA R8 before any Brownfield Site can be considered for an ESA or Cleanup.
Assist DES and Tribal Environmental Health in any/all disaster and emergencies under 24/7 basis.

Fiscal Year 2010/11
During the past year the Brownfield TRP performed two (2) Phase I Environmental Site Assessments and one (1)  Phase II Environmental Site Assessments at the Tribal Trust property that may have been contaminated by the adjacent Old Ronan Dump.  An RFP was developed and contracted out to AMEC to conduct the ESA. 

The Elmo Cash Store cleanup Project has been completed with contaminants still existing on the adjacent Former Joseph Allotment which the TRP was not able to capture due to EPA’s designating Elmo Cash Store and the Joseph allotment as 2 separate sites also a lack of funding, therefore is required to request additional competitive cleanup funds to complete cleanup and Awarded Cleanup Grant Funds.  Currently the TRP Program has awarded AMEC Geomatrix Environmental Consulting to conduct clean-up design engineering/oversight that will include:

• Final negotiated work plan preparation
• Public Involvement
• Preparation of Cleanup Plan
• Prepare Bid Specifications
• Conduct Oversight of the Site Remediation and/or Cleanup: The Over-site contractor shall prepare cleanup methods for the contractors chosen by CSKT
• Conduct Confirmation Sampling and Report
• Final Cleanup Verification Report
• Progress Reports/Invoice Submittals
• Quality Assurance/Quality Control Requirements for Sampling and Analysis
• Health and Safety Requirements
• Indian Preference
• Disadvantaged Business Enterprise (DBE) Utilization Requirements
• Deliverables
• Schedule and Costs

The Tribal Response Program will be conducting an additional assessment at the Tribal Trust property site located in Ronan for FY11 2012 utilizing Tribal Response Program 128(a) grant funds.   

To view any of these sites you can click on site assessments, you can also view the Public Record on this site(s), which I recommend

Highlights (FY10 thru FY11, 2011/12)

The Brownfield TRP Program has attended numerous training sessions on Brownfield, solid waste, and hazardous waste issues that will assist the TRP in keeping the reservation in its pristine environment and to ensure the protection of the Confederated Salish and Kootenai Tribes natural resources.  The tribes also completed a reservation wide Brownfield inventory with the aid from Portage Environmental, Inc. an Indian owned environmental consulting firm based out of Idaho Falls, Idaho in October of 2004. Sites are still being added to the Brownfield Inventory as new potential Brownfield sites are recognized, as of today the Tribal Response Program has an estimated 139 potential Brownfield Sites on the reservation with two sites cleaned utilizing Brownfield Competitive Cleanup grant funds and Tribal Program assistance, one other smaller site was cleaned utilizing Brownfield Tribal Response grant funds.  The Tribal Response Program anticipates at least 1 or 2 site cleanups in the next 2 years.

As of today the Brownfield Tribal Response Program has conducted the following:

• Phase I ESA- 15
• Phase II ESA- 14
• Phase III ESA- 3
• Phase IV ESA- 2
• Cleanup- 3 with 1 in progress (Joseph Allotment)

The Brownfield Tribal Response Program ensures the protection of the Confederated Salish and Kootenai Tribes natural resources by inspecting the exterior boundaries of the reservation for illegal or abandoned sites that might comprise of solid and/or hazardous substance such as Illegal dumping that consists of waste materials that are unknown until investigated, these materials may have the probability to contaminate the natural resources of the reservation, and may cause severe health risks to the public and our water resources.

The Brownfield’s TRP Program conducts inspections through methodology that consist of; sample collection, laboratory and chemical analysis, field investigation, research, Photos’, observations, documenting, interviews, and inquiries. This assists the program to ensure that the safety of the tribes’ pristine natural resources is met.

If you have a complaint, you have 2 options available to get your complaint into the Tribal Response Program’s office:

1. Come into the office and fill out a TRP Complaint Form, or
2. Find the Complaint Form on-line at www.cskt.org Tribal Response Program web page

If you need to report a potential Brownfield site or would like an environmental site assessment done at a potential Brownfield site or would like information available in the public record please provide the site location and contact information to Marlene McDanal, the Tribal Response/Solid/Hazardous Waste Program Manager at mmcdanal@cskt.org  , or P.O. Box 278, Pablo, MT 59855.
The Brownfield Tribal Response/Solid/Hazardous Waste Program Manager can also be reached at (406) 675-2700 ext 7215. The Natural Resources Department offices are located at 301 Main Street in Polson, Montana. Normal office hours are from 7:00 a.m. to 5:30 p.m. Monday thru Thursday. Closed most holidays.