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 1900’s and prior to the development of damming and flood control measures by the Tennessee Valley Authority (TVA). Several of the 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 from TDEC, the EPA Region 4 ERRB with assistance from SESD Athens, conducted two follow up assessments of the Read and Mitchell Avenue area in January and April 2012.  Of the 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 from 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 addition, 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 fluorescence spectroscopy (XRF). No significant lead contamination was found and all lead levels were below 55 ppm.

 Lead is a hazardous substances as defined by CERCLA 101 (14) and listed in Title 40 of the Code of Federal Regulations (CFR), Section 302.4. The EPA's Technical Services Section has reviewed the results of the removal site evaluation and determined there is a threat to public health and the environment resulting from 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) of the National Oil and Hazardous Substances Pollution Contingency 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 investigation 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 from 400 to 4500 ppm. EPA Region 4 Technical Services Section (TSS) recommends a Removal Management Level (RML) of 400 ppm for residential lead exposure scenarios. Concentrations exceeding these levels at the Site were confirmed through on-site XRF analysis. The maximum lead concentration detected in surface soils through XRF readings exceeded 10,000 ppm.

The source of lead contamination appears to be lead contaminated bag-house dust andparticulate waste from stack emissions collected at foundries in the immediate vicinity of the Site. Children, as well as adults, are at risk to come in contact with the contaminants via windborne 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 (b)(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 potential 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.