-^ - ^ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ^ ^ 2 ^ REGION 4 ^ ^ " K Z ^ ATLANTA FEDERAL CENTER V * * * * ^ * ? 61 FORSYTH STREET

' ' I PHO-^^^^ ATLANTA, GEORGIA 30303-8960

SEP 0 7 2012 Mr. Andy Binford Department of Environment & Conservation 401 Church Street 4 * F l o o r - L & C Annex Nashville, TN 37243-1538

Subject: Soulhside Chattanooga Lead Site 1700 Read Avenue Chattanooga, Tennessee —

Dear Mr. Binford:

The U.S. Environmental Protection Agency's Emergency Response and Removal Branch (ERRB) conducted a Removal Site Evaluation (RSE) at the above referenced site for potential removal action eligibility under the National Contingency Plan (NCP).

Based on the information collected during the RSE, the On-Scene Coordinator (OSC) recommends this site be given priority for removal eligibility under EPA's Superfund Removal Program (see enclosed RSE memo). Concurrent with this recommendation, EPA may also begin its enforcement activities to determine potentially responsible parties for this Site.

A final determination of removal eligibility will be made by the OSC assigned to the site. A decision to conduct a removal action will be documented in an Action Memorandum and a copy will be forwarded to the State. Should the OSC make a final determination that a removal action is not warranted you will be subsequently notified of this determination.

Should you have any questions concerning ERRB's determination, please contact Perry Gaughan, OSC at (404) 562-8817, or Matt Taylor, Chief of Removal Operations Section, at (404) 562-8759.

Sincerely

A. Shane Hitchcock. Chief Emergency Response & Removal Branch

Enclosure

cc: Dawn Taylor. Tony Moore, Debbie Jourdan, Kerri Sanders, Terry Stilman, Alyssa Hughes, Perry Gaughan, Matt Taylor

l i i teniel Address (URL) • http://Aww.epa.gov Hecycled/nBcyclabte • Printed Afth Vegul-ibie Oil Based Ifiks on Rtjcycled p:iper (MIrtmirrn 30% Poslconsumer)

U.S. ENVIRONMENTAL PROTECTION AGENCY POLLUTION/SITUATION REPORT

Southside Chattanooga Lead Removal Site Evaluation POLREP

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region IV

Subject: POLREP # I Removal Site Evaluation Southside Chattanooga Lead 1700 Read Avenue Chattanooga, Hamilton County, Tennessee

Latitude: 35.0456 °N Longitude: -85.3097 ^ W

To: Matt Taylor, USEPA R4 ERRB From: Perry Gaughan, On-Scene Coordinator Date: August 13,2012 Reporting Period: 10/01/̂ 2011 - 06/30/12

1. Introduction Site Number: B4J4 Response Authority: CERCLA Response Type: Time-Critical Response Lead: EPA Incident Category: Removal Assessment NPL Status: Non NPL

1.1 Site Description

The Tennessee Department of Environmental Conservation (TDEC) requested the EPA Region 4 Emergency Response and Removal Branch's (ERRB's) assistance after discovering that the lawns of one residence and potentially several more were contaminated with lead along Read Avenue near downtown Chattanooga. Initially, one resident along Read Avenue presented to the emergency room with severe fatigue and abdominal pain. Emergency room blood work indicated lead levels approaching 20 micrograms per deciliter (ug/dl) which alerted TDEC to conduct follow up assessments. TDEC requested assistance from ERRB to characterize the soil around the home and an initial assessment was conducted with SESD (Science and Ecosystem Support Division) Athens in which three homes were assessed as well as a public park and playground area at 1700 Mitchell Avenue. Ten samples were collected and two samples showed elevated lead levels exceeding 400 ppm.

1.2 Site Location

The Southside Chattanooga Lead Site is located along Read, Mitchell and Carr Avenues south of Main Street in Chattanooga, Hamilton County, Tennessee (Latitude: 35.0456, Longitude: -85.3097). The area is a blend of young, middle income couples who are renovating older constructed homes and low to middle income retired couples who have resided in the area for 20 plus years. The vast majority of homes were built in the early 1900's.

The Southside Chattanooga area is immediately adjacent to downtown Chattanooga and was prone to flooding during the early I900's and prior to the development of damming and flood control measures by the Tennessee Valley Authority (TVA). Several ofthe homes along Read and Mitchell Avenues appear to have been built on 4-5 feet of clay fill.

2.0 Removal Site Evaluation

In response to a request fi-om TDEC, the EPA Region 4 ERRB with assistance fi'om SESD Athens, conducted two follow up assessments ofthe Read and Mitchell Avenue area in January and April 2012. Ofthe 81 homes (162 front and back yards) assessed near downtown Chattanooga, 68 lawns (42 %) have lead levels exceeding 400 ppm. Lead levels range from 400 - 4000 ppm. The 4000 ppm sample was collected fi'om a lawn along the 1600 block of Read Ave and the sample contained very dark fine material, most likely a high concentration of bag-house dust.

In addifion, the Battle Academy Elementary School which neighbors the site was sampled in mid June 2012. A 20' by 20' grid was laid over the school property and 140 grids were screened using X-ray tluorescence spectroscopy (XRF). No significant lead contamination was found and all lead levels were below 55 ppm.

3.0 Threats to Public Health or Welfare

Lead is a hazardous substances as defined by CERCLA 101 (14) and listed in Tide 40 of the Code of Federal Regulations (CFR), Section 302.4. The EPA's Technical Services Section has reviewed the results ofthe removal site evaluation and determined there is a threat to public health and the environment resulting txom the elevated lead contaminated soil on the Site.

Lead present in on-site surface and subsurface soils pose the following threats to public health or welfare as listed in Section 300.415 (b)(2) ofthe National Oil and Hazardous Substances Pollution Confingency Plan (NCP):

Section 300.415 (b)(2)(i) Actual or potential exposure to nearby human populations^ or the food chain from hazardous substances pollutants or contaminants', TDEC's initial investigafion revealed that there is significant lead contamination present in surface soils exceeding 1,000 ppm. Further sampling conducted by EPA confirmed elevated lead levels at several residential lots ranging fi-om 400 to 4500 ppm. EPA Region 4 Technical Services Section (TSS) recommends a Removal Management Level (RML) of 400 ppm tor residential lead exposure scenarios. Concentrations exceeding these levels at the Site were contlrmed through

on-site XRF analysis. The maximum lead concentrafion detected in surface soils tlirough XRF readings exceeded 10,000 ppm.

The source of lead contamination appears to be lead contaminated bag-house dust and particulate waste from stack emissions collected at foundries in the immediate vicinity ofthe Site. Children, as well as adults, are at risk to come in contact with the contaminants via windbome dust, inadvertent ingestion of contaminated soil, and direct contact with the contaminated surface soils. EPA recently became aware of one family in which three children have reported blood lead levels approaching 5 ug/dl.

Section 300.415 (h)(2)(iv) High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface that may migrate; XRF levels and laboratory data reveal that elevated lead levels are present at or near the surface in several lawns throughout the Site -creating a potenfial for migration to off-site locations.

Section 300.415 (b)(2)(v) Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released; If a removal action is not implemented, there is a potential for weather conditions, such as heavy rain events, to cause off-site migration of lead contamination.

Section 300.415 (b)(2)(vii) The availability of other appropriate federal or state response mechanisms to respond to the release; At the request of TDEC, EPA has collected sufficient data to proceed with a removal action. It is not anticipated that TDEC or any other state or local agency will be able to carry out the necessary removal action at the Site,

The removal site investigation has identified lead concentrations exceeding the RML for residential land use that pose a threat to human health and the environment. Based on the criteria listed above, the EPA Region 4 Emergency Response and Removal Branch has determined that initiating a time-critical removal action at the Site is appropriate.

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