UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION4 -~ ­ Science and Ecosystem Support Division Field Services Branch ~ J 980 College Station Road Athens, Georgia 30605-2720

May 23 , 2018

4SESD-FSB

MEMORANDUM

SUBJECT: Southside Chattanooga Lead Site Remedial Investigation Work Plan Chattanooga, SESD Project Number 18-0271

FROM: Timothy Simpson, Life Scientist Superfund and Air Section

THRO: John Deatrick, Chief JD Field Services Branch .

TO: Robenson Joseph, Remedial Project Manager Superfund Sustainability and Restoration Branch Superfund Division

Attached is the Remedial Investigation Work Plan for the Southside Chattanooga Lead Site in

Chattanooga, Tennessee. Field work began the week of May 14, 2018. If you have any questions, please call me at (706) 355-8736.

Attachment Remedial Investigation Work Plan Southside Chattanooga Lead Site

United States Environmental Protection Agency Region 4

Remedial Investigation Work Plan

Southside Chattanooga Lead Site Chattanooga, Hamilton County, Tennessee May 23, 2018 SESD Project Number 18-0271

Prepared for: Prepared by: Robenson Joseph, Remedial Project Manager Timothy Simpson, Life Scientist US EPA Region 4 US EPA Region 4 Superfund Division Science and Ecosystem Support Division 61 Forsyth Street, SW 980 College Station Road Atlanta, Georgia 30303 Athens, Georgia 30605

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Approvals:

SESD Field Team Leader

o s/1'-If Z.ol ~ Timothy Simpson, ife Scientist Date Field Services Branch

Approving Official:

John Deatrick, Chief Date Field Services Branch

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Table of Contents

1.0 INTRODUCTION ...... 4 1.1 Scope of Work ...... 4 1.2 Site Background ...... 4 1.3 Previous Investigations ...... 5

2.0 PROJECT MANAGEMENT ...... 6 2.1 Project Organization ...... 6 Table 1: Project Personnel ...... 6 2.2 Technical Approach ...... 7 2.2.1 Evaluation of Existing Data ...... 7 2.2.2 Identification of Applicable or Relavant Appropriate Requirements ...... 7 2.2.3 Conceptual Site Model ...... 8 2.2.4 Remedial Action Objectives ...... 8 2.3 Environmental Setting ...... 8 2.3.1 Geology ...... 8 2.3.2 Hydrology ...... 9 2.4 Field Investigation and Data Acquisition ...... 10 2.4.1 Soil Sampling ...... 10 2.4.2 Groundwater Sampling ...... 11 2.4.3 Potable Well Survey ...... 11 2.4.4 Surface Water and Sediment Sampling ...... 11 2.4.5 Macro Invertebrate Sampling ...... 12 2.5 Data Review, Verification and Validation ...... 12 2.6 Data Management ...... 12 2.7 Risk Assessment ...... 13

3.0 FINAL REPORTS ...... 14

4.0 REMEDIAL INVESTIGATION SCHEDULE ...... 15 Table 2: Remedial Investigation Schedule ...... 15 5.0 QUALITY CONTROL ...... 15

CONCEPTUAL SITE MODELS AND SITE FIGURES ...... 17 Figure 1: Conceptual Site Model - Human Health Risk Assessment ...... 19 Figure 2: Conceptual Site Model - Ecological Risk Assessment ...... 20 Figure 3: Conceptual Site Model - Hydrogeology and Transport Pathways ...... 21 Figure 4: Southside Chattanooga Lead Site ...... 22 Figure 5: Soil Types ...... 23

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1.0 INTRODUCTION

The United States Environmental Protection Agency (EPA) will conduct a Remedial Investigation (RI) at the Southside Chattanooga Lead (SCL) Site in Chattanooga, Hamilton County, Tennessee. The Site consists of residential neighborhoods and communal areas (such as schools, parks, and daycare facilities) where lead-impacted foundry material has been used as fill material and topsoil. The investigation will focus on eight neighborhoods in the downtown Chattanooga area: Alton Park, Cowart Place, East Lake, Highland Park, Jefferson Heights, Oak Grove, Richmond, and Southside Gardens.

The investigation will be conducted to define the nature and extent of lead contamination at the site. The collected data will also be utilized to assess the potential human and ecological risks that may be resulted from exposure to the contaminated materials.

1.1 Scope of Work

This work plan describes EPA’s technical approach, schedule, and quality control requirements for completing the RI. Field activities will be in accordance with the Quality Assurance Plan (QAPP), Southside Chattanooga Lead Site, April 26, 2018. The QAPP describes procedures that will be followed for organizing, storing, and securing the data collected. The overall objective of the QAPP is to ensure that project objectives are met through the generation of high-quality, reliable data to characterize the extent of contamination at the SCL site. The QAPP conforms to the requirements of EPA’s Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final, EPA/540/G-89/004 (EPA, 1988). It addresses EPA requirements for preparing QAPPs in accordance with the EPA Requirements for Quality Assurance Project Plans (QA/R-5) March 2001, and supplemented by the EPA Guidance for Quality Assurance Project Plans (EPA QA/G-5), December 2002.

The QAPP is designed to be used in conjunction with project-specific Sample and Analysis Plans (SAPs) that document the investigative sampling and analysis tasks that will be performed to support decisions and EPA, Region 4, SESD Field Branches Quality System and Technical Procedures. The activities depicted in the QAPP are accredited under the EPA Region 4 Science and Ecosystem Support Division (SESD) ISO/IEC 17025 accreditation issued by the ANSI-ASQ National Accreditation Board.

1.2 Site Background

Since the late 19th century, approximately 60 foundries operated in Chattanooga. Most of the foundries specialized in melting and casting metal into desired shapes. Molds made of a sand mixture were used to create the shapes. After the desired shapes were made, the sand molds were broken and most of the sand mixture was reused. Some fine particles from the sand mixture could not be reused and were considered a by-product, or waste, called spent foundry sand.

Past foundry operations generated large quantities of waste byproduct, consisting of spent foundry sand, dust from collection systems, slag, coal, spent casting refractory material, off-spec products, and other miscellaneous wastes. Anecdotal information indicates that it was common practice in the early 20th century for foundries in Chattanooga to give residents their excess spent foundry sand and other byproducts to use as fill and topsoil. The spent foundry sand is dark-brown or black in color, and is

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usually found near the surface of a yard. The material may contain elevated concentrations of lead and other metals. In previous investigations, the EPA and Tennessee Department of Environment and Conservation (TDEC) have found elevated concentrations of lead in soil.

1.3 Previous Investigations

The following is a summary of past field investigations at the site. Additional detailed information can be found in section 4.2 of the QAPP.

In 2011, TDEC was contacted regarding a resident of Chattanooga with elevated blood lead levels. TDEC initiated soil assessment activities at the residence. Initial sampling activities indicated elevated concentrations of lead in surface soil at the property. TDEC requested assistance from the EPA Emergency Response and Removal Branch. EPA, in collaboration with TDEC, conducted an assessment of residential properties along Read Avenue and an adjoining public park located on Mitchell Avenue.

From May 2011 to April 2012, EPA conducted a removal assessment at the Read Avenue Lead Site to identify properties at which lead and arsenic concentrations in soil exceed their respective EPA Removal Management Levels (RMLs). Soil data were compared to EPA’s Regional Screening Level (RSL) for lead in residential soil (400 mg/kg) and EPA’s Removal Action Level (RAL) for arsenic in residential soil (39 mg/kg). A total of 126 soil samples were collected from 67 properties. Concentrations exceeding the lead RSL were detected at 49 locations (35 properties). Arsenic was detected but did not exceed the RAL. The EPA reports stated that highest lead concentrations appeared to be associated with locations where a dark gray-brown to black material resembling foundry sand was present in the samples.

From June to August 2012, EPA contractor Oneida Total Integrated Enterprises (OTIE) conducted a site reconnaissance of neighborhoods surrounding the Read Avenue Site. Screening locations were chosen based on visual observations of the reconnaissance. Soil samples were collected and screened with an X-Ray Fluorescence (XRF) for lead and arsenic. During the project, soil samples were collected from 17 neighborhoods. Of the 235 soil screening locations, 31 samples (collected from 24 locations) contained lead at concentrations above the EPA RAL, and eight samples (collected from six locations) contained arsenic above the EPA RAL.

From September 2012 to December 2013, EPA conducted a time-critical removal action at 84 properties at the Read Avenue Lead Removal site. Properties that contained lead or arsenic above EPA RMLs were excavated until native clay was observed or down to a maximum depth of approximately one foot. During the removal action, approximately 8,222 tons of contaminated soil was excavated and disposed of at a permitted landfill facility.

During September 2016, EPA TDEC, and Tetra Tech (EPA contractor) personnel conducted an urban background study of downtown Chattanooga. The primary goal of the study was to define urban background concentrations of certain contaminants, including lead. Surface soil samples were collected at a depth of 0-4 inches below ground surface at fifty randomly selected locations within the City limits of Chattanooga. Care was taken to avoid areas with known or suspected contamination.

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During 2016-2017, EPA conducted sampling activities, over two field events, as part of the site investigation activities. The purpose of the site investigation was to determine if foundry-related contamination was present in residential soils and to evaluate the results to assess whether the site had the potential to be included on the National Priorities List (NPL) and whether additional soil removal activities were warranted. During the field events, EPA contractor Tetra Tech collected samples from seven residential neighborhoods. Of the properties that were sampled, nineteen residential and two church properties contained lead concentrations above the 400 mg/kg RSL for residential soil.

During the week of August 21, 2017, EPA collected 50 surface soil samples from three residential neighborhoods (Oak Grove, Highland Park, East Lake) and East Lake Courts (Chattanooga Housing Authority property). All samples were analyzed for lead using a Niton® XL3t 955 Ultra XRF. Samples collected from ten residential properties exceeded the Site-Specific Screening Level of 360 mg/kg.

2.0 PROJECT MANAGEMENT

2.1 Project Organization

Project personnel will consist of EPA Region 4 and Tennessee Department of Environment and Conservation (TDEC) staff. The SESD Field Team Leader is responsible for developing the SAPs, implementing the field study, and for ensuring that data generated during field investigations meet the objectives of the project. Project personnel for the Remedial Investigation are listed in Table 1.

Table 1: Project Personnel

Team Members Organization Responsibilities Address/Email Remedial Project Robenson Joseph US EPA Region 4, Superfund Division [email protected] Manager Human Health Risk Sydney Chan US EPA Region 4, Superfund Division [email protected] Assessment Ecological Risk Brett Thomas US EPA Region 4, Superfund Division [email protected] Assessment

Katherine Schroer US EPA Region 4, Superfund Division Hydrologist [email protected]

Community Involvement Stephanie Y. Brown US EPA Region 4, Superfund Division [email protected] Coordinator Enforcement Project Leonardo Ceron US EPA Region 4, Superfund Division [email protected] Manager US EPA Region 4, Marshall Binford Site Attorney [email protected] Office of Regional Council US EPA Region 4, Science and SESD Field Team Timothy Simpson [email protected] Ecosystem Support Division Leader Tennessee Department of Environment State Lead and Primary Troy Keith [email protected] and Conservation Contact

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2.2 Technical Approach

The RI work plan is based on scoping/planning meetings conducted on September 7, 2017, January 30, 2018, and February 22, 2018. The work plan conforms to the requirements of EPA’s Guidance for Conducting RI and Feasibility Studies under CERCLA, Interim Final, EPA/540/G-89/004 (EPA, 1988).

2.2.1 Evaluation of Existing Data

Available information and data for the site were reviewed and used to develop human health and ecological risk Conceptual Site Models that identify known conditions and data gaps for the site. Data generated during previous field investigations conducted at the site by EPA, TDEC, and EPA contractor Tetra Tech, were evaluated. Specifically, the Region 4 Scientific Support Section (SSS) reviewed data from over 300 surface soil samples collected during the 2016 - 2017 site investigation and analyzed for metals. A subset of the site investigation samples was also analyzed for polycyclic aromatic hydrocarbons (PAHs). The PAH data, as well as data from the 2016 urban background study were included in the evaluation.

SSS performed a preliminary risk evaluation of the site investigation data to help identify chemicals of concern for the remedial investigation. Data from the SI were screened against the 2016 urban background concentrations and the residential soil values in the November 2017 Regional Screening Level (RSL) table to determine a list of Contaminants of Potential Concern (COPC). The refined list of COPCs were then used to estimate potential human health risks based on a residential exposure. Based on the results of the preliminary risk evaluation, SSS recommended that lead should be considered as the only risk driver for the site and can be the focus of the future sampling to support the remedial investigation.

2.2.2 Identification of Applicable or Relevant Appropriate Requirements

Section 121(d)(2) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, the 1986 Superfund Amendments and Reauthorization Act (SARA) and the National Contingency Plan of 1990 require the attainment (or waiver) of federal and more stringent state applicable or relevant and appropriate requirements (ARAR) during remedial actions. The site-specific screening level, selected by the risk manager for the site is 360 mg/kg. Additionally, EPA will use its emergency response authorities to cleanup a limited number of high priority areas above the Removal Action Level. The highest priority for removal actions are residential yards or communal areas with a lead concentration of 1,200 mg/kg or greater.

The following list summarizes these ARARs and comparison criteria to be used during the RI.

• Site-Specific Screening Level – 360 mg/kg or parts per million (ppm) • Removal Action Level – 1,200 mg/kg

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2.2.3 Conceptual Site Model

The purpose of the conceptual site model is to assist in the identification of additional sampling or data needs and to assist in the identification of potential remedial technologies. It includes known and suspected contamination sources, affected media, routes of migration and human and environmental receptors. Based on a review of existing data, the current Conceptual Site Models for human health (Figure 1), ecological receptors (Figure 2), and hydrogeology and transport pathways (Figure 3) were developed for the Remedial Investigation. Data for environmental samples collected at the site have documented the presence of elevated concentrations of lead in the soil.

Based on the current model, data gaps were identified and a sampling strategy was developed. Field investigation and data acquisition activities are described in Section 2.3 of this work plan and Section 4.0 of the QAPP.

2.2.4 Remedial Action Objectives

In accordance with the EPA Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA, Interim Final, EPA/540/G-89/004 (EPA, 1988), the following goals and preliminary remedial action objectives were established.

• Define the vertical extent of the lead impacted soil at residential properties and communal areas within the site boundary. • Determine whether lead is present in the groundwater within the site boundary at concentrations above levels that are protective of human health. • Determine whether lead is present in the surface water and sediment from drainage ditches located within the site boundaries at concentrations above levels that are protective of human and ecological receptors.

2.3 Environmental Setting

2.3.1 Geology

Chattanooga lies near the boundary of the Valley and Ridge and Appalachian Plateau Physiographic Provinces. The city is within the Valley and Ridge Province and is characterized by topography resulting from differential erosion of folded rock strata. Near Chattanooga, the southern section of the province is dominated by slightly larger valley floors, less relief, and southeast dipping beds that result from thrust faulting of most folds. At the site, along the valley floor, surface elevations range from 660 to 640 feet above mean sea level. The site is shown on Figure 4.

---Soils Soil types are presented on Figure 5. Based on a Natural Resources Conservation Service (NRCS) Custom Soil Report for the site, soils near the downtown area (including Cowart Place, Jefferson Heights and Southside Gardens) consist of highly disturbed and/or filled urban land. In the Alton Park area, soils are classified as Tupelo silt loam and Newark silt loam. Both are poorly drained, nearly level soils commonly found in flood plains and depressions. The surface layer of the Tupelo silt loam is a yellowish-brown silty loam approximately eight inches thick. The subsoil generally extends to a depth

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of approximately 48 inches. The upper part of the subsoil is also a yellowish-brown silty loam with mottled brownish-gray clay. Beneath that is gray clay to a depth of five feet. Permeability is low. The Newark silt loam surface layer is typically a dark grayish brown silt loam about six inches thick. The subsoil is approximately 2.5 feet thick and in the upper part is a mottled brown to grayish-brown silty loam. The lower part of the subsoil is a gray silty loam.

Near the confluence between Chattanooga Creek and Dobbs Branch, NRCS classifies the soils into the Colbert-Urban land complex series. This unit consists of deep, loamy soil that has five feet of clayey subsoil over limestone. The Colbert-Urban land series also dominates west of the National Cemetery, in the Highland Park neighborhood.

Site Geology Soil and alluvial deposits are Cambrian and Ordovician limestones and dolomites. A thrust fault called the Chattanooga Fault runs roughly parallel to Chattanooga Creek from the state line to the confluence with Dobbs Branch. The up-thrown dolomites on the east side of this thrust fault are of the Knox Group (Cambrian and Ordovician). This is primarily a siliceous dolomite which is light to dark gray, fine- to coarse-grained and thin- to very thick-bedded. It weathers to a cherty rubble. A gray, fine-grained limestone is occasionally found in the upper part of the unit. Limestones of the Chickamauga Super Group (Ordovician) lie on the west side of the Chattanooga Fault. Most site neighborhoods are underlain by dolomites and limestones of the Knox and Chickamauga groups.

2.3.2 Hydrology

Surface Water The site is within the basin, which is regulated by a series of dams along the river. In addition, much of the site is in the watershed of Chattanooga Creek. The creek flows north from Georgia and merges into Dobbs Branch, which flows westward from Missionary Ridge. Downstream of this confluence, Chattanooga Creek flows approximately 2.5 miles west and southwest before flowing into the Tennessee River, just down-river of downtown Chattanooga and above Reservoir. Nickajack Lake is the result of the Tennessee Valley Authority (TVA) constructing a hydroelectric dam at river mile 425.

The topography upstream of the site area is mountainous, promoting the susceptibility of streams such as Chattanooga Creek to overflow due to heavy, short duration, spring and summer storms. A floodplain has developed in the Chattanooga Creek basin, and backwater from severe Tennessee River floods could extend up the entire length of Chattanooga Creek. In the past, Tennessee River backwater has caused flood damage to the highly developed floodplain. Parts of the city are drained by a network of shallow man-made ditches constructed in the late 1930s as part of the Works Projects Administration (WPA) program.

Groundwater Groundwater in the region occurs within both the unconsolidated and consolidated materials. The unconsolidated materials include the alluvial deposits and soil residuum described above. There materials generally have a low water yield and are thus not considered an important groundwater source.

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The consolidated materials consist of limestone, dolomite, shale, and sandstone that form the bedrock. Water in limestone typically occurs in secondary fractures such as fractures and bedding planes, particularly those that have been enlarged by solution of calcareous material. These features occur erratically and cause hydraulic conductivities to be extremely variable throughout the region. This property explains why one well may be dry and another nearby well at the same depth in the same bedrock produces water.

Typically, most of the water encountered in limestone is near the top of the rock where weathering has increased the number of secondary features. Shales generally have low yields. Sandstones, particularly those on Lookout Mountain, may yield large quantities of water. Limestones and dolomites produce variable amounts of water depending on the number and size of fractures and solution cavities encountered. Groundwater is recharged primarily by the percolation of rainwater through the soils. Generally, groundwater discharges locally to ponds, streams (such as Chattanooga Creek) and springs. Previous investigations (e.g. Tennessee Products Superfund Site), have established that Chattanooga Creek is a “gaining stream” (e.g., groundwater flows toward and into the creek).

2.4 Field Investigations and Data Acquisition

Data will be collected to assess the nature and extent of lead contamination and will be used by EPA to determine where further action is required. Based on the concentrations of lead in the soil, groundwater, surface water or sediment, relative to the site ARARs, EPA will determine where site remediation activities are required.

The QAPP is the overarching quality assurance planning document for environmental data collection and field activities conducted by SESD at the site. It is applicable to all field activities and technical assistance projects conducted by SESD personnel and addresses aspects of project planning and data collection activities including sampling design, sample handling and custody, analytical methodologies, records management, quality control requirements, and data management procedures. It ensures that data collected by SESD is of known and documented quality and can support environmental decision making. Data Quality Objectives have been developed and appear in Section 4.3 of the QAPP.

SAPs will be developed prior to each field sampling event. Each SAP will include a description of the project objectives, field schedule, and description of the sampling design, including the number of environmental and quality control samples to be collected. Additional information including the project personnel and their responsibilities, applicable regulatory or action levels and specific decisions to be resolved will be included in the SAP, as well as, requested laboratory turn-around times, analytical methods, and the projected final report completion date.

2.4.1 Soil Sampling

All soil samples will be collected in accordance to the SESD Operating Procedure for Soil Sampling, SESDPROC-300. Sampling activities will be scheduled in coordination with the RPM as property access is acquired. Property access will be the responsibility of the RPM. Past site data and field observations indicate foundry material is generally found within the top 12-18 inches of soil in residential areas. Surface soil samples will be collected using incremental sampling methodology (30- point composite samples) from a depth of 0-4 inches below ground surface.

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To define the vertical extent of the lead-impacted soil, soil cores will be collected in residential neighborhoods within the site using a track-mounted Geoprobe® Direct Push Technology (DPT) rig. Soil cores will be co-located with temporary monitor well locations and will be collected at locations where lead concentrations in the surface soil exceeded the site-specific screening level. Existing soil data will be evaluated to select the sample locations. Cores will be collected and evaluated for the presence of foundry sand material. Subsurface soil samples will be collected within the 1-foot layer immediately below the observed foundry sand material. Additional samples may be collected from each soil core, as needed.

Soil samples will be analyzed using a Niton XL3t 955 Ultra XRF in accordance with EPA Method 6200, the SESD Operating Procedure for Field X-Ray Fluorescence Measurement, SESDPROC-107 and the EPA Region 4, Superfund Division, Superfund X-Ray Fluorescence Field Operations Guide. A detailed description of the surface soil sampling methodology and XRF measurements and sieving process is provided in Section 4.4.1 of the QAPP. Confirmation soil samples will be collected (five percent of the total number of soil samples collected). Samples will be sent to the SESD laboratory for lead analysis. The total number of confirmation samples will be listed in the project-specific SAP.

2.4.2 Groundwater Sampling

Groundwater within the site boundary will be evaluated for the presence or absence of lead. Temporary monitor wells will be installed and sampled for lead in residential neighborhoods within the site boundary. As previously stated, wells will be co-located with subsurface sample locations. Depth to groundwater is anticipated to be between 15-20 feet below ground surface. Given the fine-grained, clay- rich soils and unconsolidated sediments underlying site neighborhoods, the likelihood that metals are leaching from site foundry fill to groundwater is thought to be low.

Temporary monitor wells will be installed by SESD using a Geoprobe® DPT rig in accordance with the SESD guidance document, Design and Installation of Monitoring Wells, SESDGUID-101. All sampling activities will be in accordance with the SESD Operating Procedure for Groundwater Sampling, SESDPROC-301 and will be scheduled in coordination with the RPM. If elevated concentrations of lead are observed (above the lead MCL), permanent monitoring wells will be installed.

2.4.3 Potable Well Survey

Groundwater in site neighborhoods is not used as a source of drinking water and is not actively monitored. The public drinking water intake is in the Tennessee River, upstream of the city, and there are no known private wells in the site area. If elevated concentrations of lead are found in the groundwater, EPA will conduct a survey to determine if potable wells are present within the affected residential neighborhoods. If wells are present, they will be accurately identified and located so impacts and potential impacts from soil or groundwater contamination can be identified.

2.4.4 Surface Water and Sediment Sampling

During a Site visit on March 6, 2018, SSS and the RPM evaluated the potential human health exposure route of sediment and surface water within the site boundary. All surface water conveyances (WPA

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drainage ditches) seen within the boundary of the site were concrete lined with limited visible sediment. Based on the site visit, it was determined that human health exposure to surface water and sediments is an incomplete exposure pathway and does not need to be further evaluated. This is reflected as an incomplete pathway for human exposure in the conceptual site model.

SESD will collect surface water and sediment samples to assess the presence or absence of lead and to provide data for use in the ecological risk assessment. Samples will generally be collected from the WPA drainage ditches located within the site boundary. Samples will be collected in accordance with the SESD Operating Procedure for Sediment Sampling, SESDPROC-200 and the SESD Operating Procedure for Surface Water Sampling, SESDPROC-201, and will be scheduled in coordination with the RPM.

2.4.5 Macro Invertebrate Sampling

Macroinvertebrates may be used as indicator organisms to determine if a stream supports aquatic life. Due to their limited mobility and relatively long life-span, benthic macroinvertebrates integrate and reflect water quality effects over time, thus allowing the investigator to detect stress within a stream or between streams. Specific methods and equipment may vary, depending upon the objectives of the study and stream type.

If macroinvertebrate sampling is deemed necessary, sample activities will be coordinated with ecological risk assessment personnel and the RPM. Sampling activities will be conducted in accordance with the Tennessee Department of Environment & Conservation, Division of Water Resources’ Quality System Standard Operating Procedure for Macroinvertebrate Stream Surveys, Revision 6, August 2017 (Control Number: DWR-PAS-011-QSSOP-08117). The methodology, equipment and sample handling procedures described in the operating procedure will be used to assess the health of flowing freshwater ecosystems located within the site boundary.

2.5 Data Review, Verification and Validation

Analytical data provided by the SESD Analytical Services Branch will be reviewed, verified and peer reviewed in accordance with the SESD Analytical Services Branch Laboratory Operations and Quality Assurance Manual, most recent version. Data review will determine the quality of the data set. Data results will be either be accepted, rejected, or qualified and flagged accordingly.

All data derived from SESD field measurements will be reviewed, verified, and peer reviewed in accordance with the SESD Operating Procedure for Report Preparation and Distribution, SESDPROC- 003. The usability of all data derived from SESD field sampling and measurements conducted during this field investigation will be evaluated. Any limitation of the data use and/or reporting will be documented in the final report to the project manager.

2.6 Data Management

Records will be created to adequately document activities for which field investigators are responsible. All sample collection and measurement activities will be traceable through field records to the person collecting the sample or making field measurements. The Field Team Leader will be responsible for

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ensuring that all requirements for data management are met. Various types of field measurement data will be collected during the RI. Examples include global positioning system coordinates, water quality measurements, and XRF analytical results. GPS and field measurement data will be imported into the EarthSoft (Environmental Quality Information System (EQuIS™) database for reference and mapping purposes.

All field observations, measurements and sampling activities supporting the RI will be recorded, stored and managed according to the SESD procedures outlined in Section 4.12 of the QAPP.

2.7 Risk Assessment

EPA will conduct a risk assessment to determine whether lead poses a current or future risk to human health and the environment in the absence of any remedial action. The risk assessment will be conducted in accordance with EPA Risk Assessment Guidance for Superfund, Volume 1: Human Health Evaluation Manual (Part A), Interim Final, EPA/540/1-89/002, December 1989 and the Ecological Risk Assessment Guidance for Superfund: Process for Designing and Conducting Ecological Risk Assessments, Interim Final, EPA 540-R-97-006, June 1997.

EPA will identify contaminant(s), assess exposure and toxicity, and characterize risk. EPA will prepare a Baseline Risk Assessment that will be used to determine whether remediation will be necessary at the site, provide justification for performing remedial action, and determine what exposure pathways must be remediated. The risk assessment will include a human health risk assessment and an ecological risk assessment component.

As defined in the EPA Risk Assessment Guidance for Superfund Part A (EPA 1989), the elements required to form a complete exposure pathway include a source, transport mechanism, point of receptor contact, and exposure route. The following sections discuss the source and transport mechanisms, land use, potential receptors and exposure points, and potential exposure routes for the site.

Source and Transport Mechanisms At the site, potential impacts to soil, surface water, sediment and groundwater resulted from lead- impacted foundry material that was used as fill and topsoil. Contaminated soils may have moved to adjacent properties and to the surface water and sediment of off-site locations via surface water runoff and erosion in WPA drainage ditches.

Land Use Future land use may affect the types and the frequency of potential exposures from any residual contamination at the site, which may affect the remedies considered and chosen. Alternate future uses of land must be considered in the risk assessment process and to determine appropriate remediation techniques. Further, alternate future land uses selected for consideration should be chosen based on logical, reasoned judgment after an evaluation of all available information. For the site, current and future land use is primarily residential.

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Potential Human Receptors and Exposure Points Current and future receptors that are reasonably anticipated to be exposed to lead in environmental media were identified based on the information presented in Sections 1.2 and 1.3. These receptors are described below:

• Current and Future Resident: Current and future residents could be exposed to lead in soil or groundwater under current conditions. • Current and Future Recreationalist: Recreationalists could be exposed to lead in soil under at parks or other communal areas used for recreational purposes located within the site area. • Current and Future Utility and Construction Worker: Current and future utility workers could be exposed to lead in soil while performing low-frequency installation and maintenance activities at the site residential areas. The future on-site construction worker could be exposed to site-related contaminants in environmental media while performing short-duration construction related to possible site redevelopment. Therefore, the future on-site construction worker could be exposed to site-related constituents in soil.

Potential Human Exposure Routes The exposure routes that will be considered either quantitatively or qualitatively in the human health risk assessment for the various exposure scenarios include the following:

• Current and Future Resident: Ingestion of soil or groundwater, dermal contact with, and inhalation of particulates from soil. • Current and Future Recreationalist: Incidental ingestion of, dermal contact with, and inhalation of particulates from soil. • Current and Future Utility and Construction Worker: Incidental ingestion of, dermal contact with, and inhalation of particulates from soil at the site.

Potential Ecological Receptors and Exposure Points The ecological habitats that have been identified for the SCL site include the residential/communal areas and WPA drainage ditches located within the site boundary. The ecological receptors to be evaluated as part of this risk assessment will be those receptors that could be exposed to lead in soil, surface water and sediment under current conditions.

Potential Ecological Exposure Routes The ecological habitats of the residential/communal areas and WPA drainage ditches are potential exposure point for releases from the SCL site. Exposures include direct contact with soil, sediment and surface water, and ingestion of prey.

3.0 FINAL REPORTS

The Remedial Investigation report will conform to the Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, October 1988. The report will include a summary of sampling activities and findings, updated Conceptual Site Model, human health risk assessment summary, and ecological risk assessment summary.

The SESD Field Team Leader will prepare a field investigation report after each sampling event. Field investigation report preparation will be in accordance with the SESD Operating Procedure for Report

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Preparation and Distribution (SESDPROC-003). Field investigation reports will describe the results of associated observations, sampling and measurement results and/or scientific interpretation.

EPA will prepare a human health risk assessment report that addresses the following: hazard identification sources, dose-response assessment, conceptual exposure/pathway analysis, characterization of site and potential receptors, exposure assessment, risk characterization, identification of limitations/uncertainties, and updated Conceptual Site Models. Additionally, EPA will prepare an ecological risk assessment report that addresses the following: screening level problem formulation, screening level ecological effects evaluation, screening exposure estimate and risk calculation, scientific/management decision point, and identification of limitations/uncertainties.

4.0 REMEDIAL INVESTIGATION SCHEDULE

The Remedial Investigation will be conducted in multiple phases and may be contingent on the results of prior field investigations. Field sampling activities will begin in May 2018. All sampling activities will be scheduled in coordination with the RPM as property access is acquired.

Table 2: Remedial Investigation Schedule

RI Schedule Date Submittal of Quality Assurance Project Plan 04/26/2018 Submittal of Sample and Analysis Plan 05/07/2018 Field Sampling Event (18-0271): Surface Soil 05/14-18/2018 Laboratory Completion Date (Projected) 06/18/2018 Field Report Completion Date (Projected) 07/06/2018 Field Sampling Event (18-0356): Subsurface Soil & Groundwater 07/09-20/2018 Projected Laboratory Completion Date (Projected) 08/24/2018 Field Report Completion Date (Projected) 09/21/2018 Additional Field Sampling Events To be determined Remedial Investigation Draft Report 60-90 Days after field work Human Health and Ecological Risk Assessment Draft Report 60-90 Days after field work Feasibility Study (FS) Report 90 Days after final RI Report Proposed Plan Draft proposed 30 days after final FS report

5.0 QUALITY CONTROL

Specific quality control requirements for the RI are detailed in Section 4.7 the QAPP. Field quality control measures will be in accordance with the SESD Operating Procedure for Field Sampling Quality Control, SESDPROC-011, and/or 40 CFR Part 136.3, Table II-Required Containers, Preservation Techniques, and Holding Times, as applicable.

The specific number and type of quality assurance samples will be listed in each SAP. The SESD Field Team Leader is responsible for ensuring that all field quality assurance and quality control activities are

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being implemented according to the SAP.

Specific XRF quality control samples will include a silica blank, medium standard, and high standard. Laboratory quality control measures for samples analyzed by the SESD laboratory are specified in the SESD Analytical Services Branch Laboratory Operations and Quality Assurance Manual, most recent version.

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Conceptual Site Models and Site Figures

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Page Intentionally Left Blank

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Current Current and Future

Primary Primary Secondary Tertiary Adult and Utility and Adult/Child Adult/Youth/Child Contaminant Contaminant Primary Contaminant Secondary Contaminant Tertiary Exposure Adult/Child Construction School Attendees Youth Resident (2) Recreationalist (4) Sources R/T Mechanisms Affected Media R/T Mechanisms Affected Media R/T Mechanisms Affected Media Routes Trespassers Workers (2) and Staff (3) Inhalation • • • • •

Fugitive Dust (1)

Uptake into Homegrown Ingestion ------Erosion Produce • I Historical Use of Foundry Waste Material Runoff as Fill and Top Soil(1) Ingestion (5) Deposition Surface Soil (7) Dermal Contact • • • • • (5) Leaching Subsurface Leaching by Ingestion •-- •-- • •-- •-- by Percolation Soil Percolation Dermal Contact -- -- • -- -- Erosion Surface • Water

Runoff Sediment Ingestion ------Groundwater Dermal Contact ------

Inhalation ------I

Ingestion (6) -- -- (6) Sediment Dermal Contact • • (6) -- -- • (6) Biotic Uptake Ingestion •-- • (6) -- -- (6) Biota (fish tissue) • Surface Water I • •

Notes: = Potentially complete exposure pathway -- retained for quantitative analysis. R/T = Release/Transport -- = Incomplete exposure pathway -- will not be retained for quantitative analysis. • United States 1. As shown under primary contaminant R/T mechanisms. Environmental Protection Agency 2. Exposures assumed to occur in existing residential area and furture new construction for residential use. 3. Exposures assumed to occur on the current school yard while school is in session. Southside Chattanooga Lead Site Chattanooga 4. It is assumed these recreationalists are from other areas and not residents at the site. Hamilton County, 5. Exposures assumed to occur in school playground when school is not in session. Tennessee TDD No. TT-05-024 6. Potential exposures through incidental ingestion and dermal contact with nearby FIGURE 1 surface water and sediment and ingestion of aquatic life (fish tissue). REMEDIAL INVESTIGATION 7. Secondary R/T mechanisms originating from surface soil also apply to subsurface soil HUMAN HEALTH RISK ASSESSMENT that is brought to the surface as the result of excavation and landscaping activities in the future. CONCEPTUAL SITE MODEL 8. Potential exposures through ingestion of aquatic life (fish tissue). [11;] TETRA TECH 1/8/2018 X:\G\2017\05\024A\FH10\Figure1.FH10 TTEMI-KC clayton.hayes 1/8/2018 X:\G\2017\05\024A\FH10\Figure1.FH10

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Primary Primary Secondary Tertiary Contaminant Contaminant Primary Contaminant Secondary Contaminant Tertiary Sources R/T Mechanisms Affected Media R/T Mechanisms Affected Media R/T Mechanisms Affected Media Potentially Exposed Ecological Receptors

Herbivore Mammal Deposition Upland Plants Ingestion Herbivores of Dust Herbivore Bird

Fugitive Dust Omnivore Mammal Omnivore Bird Omnivores and Soil Ingestion Direct Contact Invertebrates Insectivores Insectivore Mammal Erosion Insectivore Bird

Historical Use of Foundry Herbivores Ingestion Carnivores Waste Material as Fill Runoff Ingestion and Top Soil Carnivore Mammal Omnivores and Carnivore Bird Insectivores

Deposition Surface Soil Birds Leaching by Percolation Groundwater Carnivorous Erosion Surface Water Birds Herbivorous Runoff Sediment and Reptiles (2) Omnivorous Mammals

Herbivorous and Omnivorous Birds

Sediment Aquatic Ingestion Fish Invertebrates Piscivorous Mammals Amphibians (1) Surface Water Direct Contact Piscivorous Plants Ingestion Birds

Plankton Ingestion Fish Fish Fish Ingestion

United States Environmental Protection Agency

Southside Chattanooga Lead Site Chattanooga, Hamilton County, Tennessee TDD No. TT-05-024 Notes: FIGURE 2 1. Due to a lack of toxicity data, amphibians may be represented by fish in the risk assessment. REMEDIAL INVESTIGATION ECOLOGICAL RISK ASSESSMENT 2. Due to a lack of toxicity data, reptiles may be represented by birds and mammals in the risk assessment. CONCEPTUAL SITE MODEL

[11;] TETRA TECH 1/8/2018 X:\G\2017\05\024A\FH10\Figure2.FH10 TTEMI-KC clayton.hayes 1/8/2018 X:\G\2017\05\024A\FH10\Figure2.FH10

Page 20 of 23 Remedial Investigation Work Plan Southside Chattanooga Lead Site II Historical Foundries

9 5 6

4 1 3 5,6 ? Spent Foundry Sand

2 Urban Soils •· -:-:-:-:-:-:-:-:-:-:-:-:-.-. ? 7 8 Water Table______(approximately 10‐20 ft bgs) "5[ ___ _ Exposure ------\-: -,------"'io,1'~,l'~•I ------Floodplain Deposits Future .·.·.-.• :-·-·.•, • .· . ·-: clay rich, low permeability with local -.• . · . ·.· . -: . . . ·. :: -:• . •. · .·. . -:-:-:-· -·.· .. layers of higher permeability Potential

Bedrock mostly limestone and dolomite

Main Transport Pathways Main Potential Exposure Routes 1 Runoff / Deposition 0 Human Ecological 02 Leaching to groundwater (?) 04 Inhalation 07 Soil ‐ worms, insects 03 Wind 05 Dermal contact – soils, future groundwater (?) 08 Aquatic ‐ fish, mayflies United States 6 Ingestion – soils, produce, future groundwater (?) 9 Avian ‐ songbirds Environmental Protection Agency 0 0

Southside Chattanooga Lead Site Chattanooga, Hamilton County, Tennessee TDD No. TT‐05‐024 Figure 3 Remedial Investigation Hydrogeology and Transport Pathways Conceptual Site Model

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Figure 4: Southside Chattanooga Lead Site

Southside Chattanooga Lead Site Chattanooga, Tennessee

Na-lbf\'II (!',~ ~t,ory~t,, Jefferson Heights ? ¼ -!? J I Blu6' Bla.m, .. H1 I-One ira1I .f Southside Gardens ~ I Oak Grove

Alton Park :/:- /

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Figure 5: Soil Types

Custom Soil Resource Report Soil Map

MapScale:" 1:-1S,800lfpmradcnAl)Cftral:{8.S-'x 11/ ste'!:.

0 ,.,, .---=====------======,-};;' Mapl)'OJlm:)n: \~Merom" O:me'~V.a:i&1 Ed)etrs: utMZooe 16NV.a;&1

Legend: CdC – Colbert-Urban land complex; EdC – Enders silt loam; FwD – Fullerton-Urban land complex; Ne – Newark silt loam; SfB - Sequat-Urban land complex; Tu – tupelo silt loam; uEoB – Etowah silt loam; Ur – Urban land; W-Water

Source: United States Department of Agriculture, Natural Resources Conservation Service (2018). Custom Soil Resource Report for Hamilton County, Tennessee. Generated using tool at https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx

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