COMMUNITY INVOLVEMENT PLAN WESTSIDE LEAD ATLANTA, GEORGIA January 2021 U. S. ENVIRONMENTAL PROTECTION AGENCY REGION 4 Digitally signed by ABENA ABENA MOORE MOORE APPROVED:_______________________________Date: 2021.01.26 13:04:37 -05'00' DATE: January 26, 2021 THE U. S. ENVIRONMENTAL PROTECTION AGENCY’S (EPA) SUPERFUND COMMUNITY INVOLVEMENT PROGRAM IS COMMITTED TO PROMOTING COMMUNICATION BETWEEN CITIZENS AND THE AGENCY. ACTIVE PUBLIC INVOLVEMENT IS CRUCIAL TO THE SUCCESS OF ANY PUBLIC PROJECT. EPA’S COMMUNITY INVOLVEMENT ACTIVITIES AT WESTSIDE LEAD STUDY AREA AND SITE ARE DESIGNED TO INFORM THE PUBLIC OF THE NATURE OF THE ENVIRONMENTAL ISSUES ASSOCIATED WITH THE STUDY AREA AND SITE, INVOLVE THE PUBLIC IN THE DECISION- MAKING PROCESS THAT WILL AFFECT THEM, INVOLVE THE PUBLIC IN THE RESPONSES UNDER CONSIDERATION TO REMEDY THESE ISSUES, AND INFORM THE PUBLIC OF THE PROGRESS BEING MADE TO IMPLEMENT A REMOVAL ACTION, AS NEEDED. Westside Lead Community Involvement Plan Table of Contents Section Page 1.0 Overview of the Community Involvement Plan .................................................. 1 2.0 Background and Description of Study Area and Site .......................................... 1 2.1 Background ................................................................................................. 1 2.2 Westside Lead Location .............................................................................. 2 2.3 Sampling and Cleanup Activities ................................................................. 4 3.0 Community Background .................................................................................... 5 3.1 Community Profile ...................................................................................... 5 3.2 History of Community Involvement ............................................................ 7 3.3 Key Community Concerns .......................................................................... 9 3.4 Response to Community Concerns ............................................................ 10 3.5 Summary of Communication Needs .......................................................... 10 4.0 EPA’s Community Involvement Program ........................................................ 10 4.1 The Plan .................................................................................................... 11 4.2 Time Frame Summary for Community Involvement Activities .................. 14 Appendices: A EPA Regional Contacts .................................................................................. A-1 B Local Officials ............................................................................................... B-1 C State Elected Officials.................................................................................... C-1 D Federal Elected Officials ................................................................................ D-1 E Environmental and Active Citizens Groups .................................................... E-1 F Media Contacts .............................................................................................. F-1 G Meeting Locations ......................................................................................... G-1 H Repository Locations ..................................................................................... H-1 I Glossary ......................................................................................................... I-1 Atlanta, Georgia January 2021 i Westside Lead Community Involvement Plan Section 1.0 Overview of the Community Involvement Plan The United States Environmental Protection Agency developed this Community Involvement Plan (CIP) to facilitate two-way communication between the community surrounding the Westside Lead Study Area (Study Area) and the Removal Site (Site) and the EPA and to encourage community involvement in EPA’s activities. The EPA will use the community involvement activities outlined in this plan to ensure that residents are continuously informed and provided opportunities to be involved. The Study Area is the area where the EPA is collecting soil samples to determine the extent of the lead contamination. Within the Study Area is the Site, which is where the EPA has found lead contamination in soil at levels that require a cleanup to be conducted. The objective of the EPA's Community Involvement Program is to involve the public in activities and decisions related to the cleanup of sites. The EPA actively solicits comments and information from the community in its decision-making process. Public input can be useful in two ways: • Communities provide valuable information on local history, citizen involvement, and site conditions. • Communities assist the EPA in recognizing the unique characteristics of each site community and in developing responses that effectively addresses specific community needs. This CIP addresses the Study Area and Site in relationship to the community and the EPA; Section 2.0 provides a background and description of the Study Area and Site; Section 3.0 provides background information about the community; and Section 4.0 provides the overall goal of the EPA community involvement program and a listing of resources available (Appendices). The EPA drew upon several information sources to develop this plan, including community interviews and Site files. The EPA’s Regional Office will oversee the implementation of the community involvement activities outlined in this Plan. *Words appearing in boldface type are defined in Appendix I, Glossary. Section 2.0 Background and Description of Study Area and Site 2.1 Background In July 2018, an Emory University student collected data on heavy metal concentrations in Atlanta-area garden soil as part of their doctoral dissertation research. Samples were collected at locations throughout western Atlanta and surrounding suburban areas, focusing on community gardens. Elevated lead levels in soil were found at several locations in west Atlanta, including on Elm Street in the English Avenue area. This finding was not unexpected as many urban areas exhibit Atlanta, Georgia January 2021 1 Westside Lead Community Involvement Plan lead concentrations higher than natural background due to a variety of factors, most commonly lead-based paint and historical use of leaded gasoline. Urban lead contamination is a well- researched issue, and the presence of lead above natural background would not normally result in a Superfund investigation. However, Emory’s discussions with one of the community members resulted in the identification of industrial slag on residential lots near one of the gardens in the English Avenue neighborhood. Emory found the surrounding soil to have lead concentrations greater than 4,000 milligrams per kilogram (mg/kg), ten times the EPA’s Removal Management Level (RML) of 400 mg/kg. RMLs are values the EPA uses to help determine if any future actions may be needed. It is important to note that an exceedance of an RML by itself does not imply that adverse health effects will occur. It was believed at the time that the slag was confined to a series of piles dumped on a single vacant lot on Elm Street. While the industrial source of the slag remains unknown, there were foundries located in Atlanta going back to the late 1800s and several were located near the English Avenue area. The EPA has since learned that two of the foundries have documented evidence of lead-contaminated slag on-site and required post-closure remedial actions after the facilities shut down. One of the Emory student’s instructors, also an EPA Region 4 toxicologist, reported the finding to the EPA and the Georgia Department of Natural Resources’ Environmental Protection Division (GA EPD). On November 15, 2018, GA EPD requested that the EPA perform a Removal Site Evaluation (RSE) on the property. The EPA performed a Site observation in December 2018. At that time, the On-Scene Coordinator (OSC) noted slag visible in lawns at several properties along both sides of Elm Street. Combined with the elevated lead data Emory collected from other properties along Elm Street, this observation indicated a potentially more widespread extent of contamination. Though slag may be a possible source of lead contamination, the presence of slag material does not automatically equate to high levels of lead in soil. Sampling is required to determine the specific risk at properties. The OSC initiated an investigation to determine whether contamination on Elm Street was confined to the soil piles at the single vacant lot, as previously thought, or was more widespread. To define a manageable investigation area, the OSC selected, as a starting point, the two city blocks surrounding 395 Elm Street. These blocks encompassed 60 tax parcels and were referred to as the “Study Area.” The soil samples EPA collected on the 60 parcels indicated lead contamination greater than the RML on some parcels and that the lead contamination in the soil likely extended beyond the boundaries of the 60-parcel Study Area. Properties with lead concentrations greater than 400 mg/kg are referred for remediation as part of the Westside Lead Site Removal Action. Based on data collected, the EPA determined that the Study Area needed to be expanded, which would require collecting soil samples on additional parcels within a larger area. 2.2 Westside Lead Location The EPA has established a Study Area which currently encompasses portions of the Vine City and English Avenue neighborhoods where the EPA is collecting soil