PUBLIC MEETING

Inside you will find:

 Background Information

 Summary of the Site Investigation

 Summary of the Feasibility Study

 The site's health risks

 EPA’s proposed cleanup remedy

August 2002

EPA SUPERFUND UPDATE

PROPOSED PLAN FACT SHEET

CLEANUP OF

CHATTANOOGA CREEK

TENNESSEE PRODUCTS SUPERFUND SITE

CHATTANOOGA, HAMILTON COUNTY, TENNESSEE

REGION 4

EPA COMPLETES INVESTIGATION OF CHATTANOOGA

CREEK, RECOMMENDS FINAL REMEDY FOR THE SITE

The U.S. Environmental Protection Agency (EPA), in

partnership with the Tennessee Department of

Environment and Conservation(TDEC), have completed

the Federal Superfund investigation of Chattanooga

Creek, also known asthe TennesseeProductsSuperfund

Site. The site is located in the Alton Park and Piney

Woods neighborhood in south Chattanooga, Hamilton

County, Tennessee. This Fact Sheet willbriefly describe

the results of the Remedial Investigation (RI) and

Feasibility Study (including a summary of all the cleanup

alternativesevaluated),andwillpresent the proposedfinal

decision concerning the cleanup of the site.

August 22, 2002

7:00 p.m.

Calvin Donaldson Elementary School

EPA will host a public meeting on August 22, 2002 at

the Calvin Donaldson Elementary School at 7:00 p.m.

The meeting will provide an opportunity for the

community to discuss the investigation, the cleanup

alternatives considered, and the preferred remedy

with EPA and State representatives. The public is

encouraged to review and comment on the cleanup

alternatives considered and on the proposed remedy

presented in this plan. EPA is accepting public

commentsfromAugust12 to September10,2002.

EPA is issuing this Proposed Plan as part of its public

participation responsibilities under Section

300.430(f)(2) of the National Oil and Hazardous

Substances Pollution Contingency Plan (NCP). This

proposed plan summarizes information that can be

found in greater detail in the RI/FS report and other

documents contained in the Administrative Record file

for the site.
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Tennessee Products Superfund Site Proposed Plan Factsheet August 2002

2

Site Accomplishments

The initial cleanup of coal-tar inChattanooga Creek was

completed in November 1998 (under EPA’s removal

authority). The cleanup which began in June 1997, by the

EPA, was the first phase of the cleanup plan for the

Chattanooga Creek.

This first phase ofthe cleanup consisted of the following:

165 cubic yards were removed from a pit of coal-tar

constituents, located just north of Hamill Road near

Wilson Road; 250 cubic yards of coal-tar constituents

were removed from a disposal pit located in the creek’s

flood plain; two waste mounds of coal-tar constituents

located behind the former plant site and next to the

railroad tracks (near Wilson Road) were removed --

about 2,000 cubic yards of material; and, 4,236 linear

feet of Chattanooga Creek were cleaned up. A total of

25,350 cubic yards ofwaste wasexcavatedfromthe site.

The wastes were recycled at a municipal electric power

plant in Baldwin, Illinois, and at a cement manufacturing

plant in SouthCarolina. These facilities used the coal-tar

constituent wastes for fuel in their processes.

Along with the contaminated sediment, all of the

discarded debris found in the creek was removed.

Specifically, hundreds of car and truck tires were taken

out. The tires were sent to a Chattanooga facility which

burned the tires for fuel. The materials which could not

be recycled were sent to a local landfill. The cost of the

first phase of the cleanup was approximately $12 million

(actual physical cost of the cleanup).

Site Background and History

The Tennessee Products Superfund Site islocated in the

Alton Park/Piney Woods neighborhood in south

Chattanooga, Tennessee. The Site consists of two

distinct source areas of contamination:

1. Certain areas in the flood plain containing

uncontrolled coal-tar constituents; and

2. Sediments along approximately 2.5 miles of

Chattanooga Creek that were contaminated with

coal-tar constituents.

The approximate locations of these areas are shown

on Figure 1 (attached).

Contamination in the creek was caused, in part, by

the former coal carbonization facility (coke plant),

located at 4800 Central Avenue. This facility was

operated from approximately 1918 until 1987.

Various companies operatedthe facilitythroughout it’s

history. The Tennessee Products Corporation

operated it the longest, from 1926 to 1964.

In 1994, all of the buildings on the plant property,

except for the foundations and some underground

tanks, were removed. However, several areas

contaminatedwithcoal-tarconstituentsstill exist onthe

plant property.

The 24 acre propertywas once listed on the National

Priorities List (NPL) for Superfund sites, as a part of

the Tennessee Products Site listing. However, in

1996, the Mead Corporation, a Potentially

Responsible Party (PRP) which owned the facility

from 1964 to 1974, challenged EPA’s decision to

include the plant property on the NPL, and was

successful in Federal Court of removing the plant

property from the list. The plant property is now

being addressed by Mead under Tennessee

Department of Environment and Conservation

(TDEC) oversight. The remainder of the site, which

includes Chattanooga Creek, stayed on the NPL.

Waste water fromthe facilitywasroutinely discharged

into Chattanooga Creek through an old pipe and

through a ditch that empties into the creek. EPA

believes the discharges from the facility began at the

start of plant operations and continued into the late
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Tennessee Products Superfund Site Proposed Plan Factsheet August 2002

3

70's. The discharges were oily wastewater containing

particlesof coal-tar. Two other sources of contamination

at the site are: a coal-tar processing plant whichoperated

next to the former coke plant until1976; and the chemical

manufacturing plant, currently owned by Velsicol

Chemical.

Throughout the 1980's and early 1990's EPAand TDEC

studied and monitored the water quality in Chattanooga

Creek. In the summer 1992 EPA concluded a formal

study of the contaminated sediments in the Creek. The

results of that study are outlined in a report titled

Chattanooga Creek Sediment Profile Study. High

levels of coal-tar contaminationwere detected in most of

the creek’s sediment.

Based on the results of the sediment study and other

information known about the site, the Agency of Toxic

Substances and Disease Registry (ATSDR) issued a

Health Advisory for the site. They identified health

hazards associated with direct contact of sediments

contaminated with coal-tar. In response to this finding,

ATSDR conducted health education classes about the

creek at local schools; a health assessment was

performed to identify potential waste exposure to the

community; and many information meetings and written

updates were provided to the community.

In 1993, EPAplaced a fence between the creek and the

Alton Park Middle School to prevent children from

playing in the creek.

EPA used the ATSDR HealthAdvisoryto place the site

on the National Priorities List (NPL) in September of

1995. The Remedial Investigation and Feasibility Study

began shortly before the formal listing of the site. 

In June 1997, EPA began removing the contaminated

sediment from the most accessible section of the creek,

specifically, between Hamill Road and the section of

creek next totheAltonPark Middle School(northof38th

Street). This cleanup action is described in the previous

Site Accomplishments section of this Fact Sheet.

The cleanup strategy established for the site was to

remove the contamination in the creek which

presented the highest risk to the community first, then

remove the rest ofthe contaminationthrough a longerterm cleanup action. As mentioned before, the first

phase of the cleanup was accomplished by the 1997-

1998 removaldescribed earlier. The second phase of

the cleanup will remove all of the contaminated

sediment remaining from those areas of the creek

which are less accessible, and which present a lesser

exposure risk to the community. The second phase of

the cleanup strategy is the subject of this Fact Sheet

and proposed plan.

Remedial Investigation and Feasibility

Study

The purpose of a remedialinvestigationisto determine

the nature and extent of contamination at the site and

determine the threat to public health and the

environment from a release or potential release of

hazardous substances from the site. The remedial

investigationincluded reviewing historical information,

and collecting samples from the air, water, soil,

sediment and waste. The remedial investigation

focused on the plant site, although a number of

samples were collected from areas surrounding the

creek and the plant site. EPA decided not to collect

many creek sediment samples for this investigation

becauseEPAconducted a more comprehensive study

ofthe creek in 1992 (Chattanooga Creek Sediment

Profile Study).

The purpose ofthe FeasibilityStudywas to determine

the best cleanup remedy. For this site, EPA

conducted a Feasibility Study focused on cleanup

alternatives for the creek sediment only, since this is

the largest waste area requiring remediation. Other

much smaller areas in the flood plain that are

contaminated with coal-tar and its related chemicals

will be addressed along with the creek sediments.
Cleanup of Chattanooga Creek

Tennessee Products Superfund Site Proposed Plan Factsheet August 2002

4

The former plant property was not considered in the

development of the cleanup strategy because the

property was removed from the NPL listing by the

FederalCourts. Therefore, no remedy will be proposed

for the plant property as part of this remedy selection

process. However, it will be addressed through the State

Superfund authority, and the State is currently

coordinating a cleanup with the Mead Corporation.

Site Characteristics and Study

Results

Chattanooga Creek is located in the Tennessee River

Basin, and occupies the northern portion of the

Chattanooga Valley between Lookout Mountain and

Missionary Ridge. The creek originates from the slopes

of Lookout Mountain, flows approximately 26 miles

northward into Tennessee and eventually into the

Tennessee River. The creek has a watershed of nearly

75 square miles, of which approximately 22% is in

Tennessee.

The portionofthe creek that is known to contain coal-tar

contaminated sediment is a segment 2.5 miles long,

beginning from approximately Hamill Road and ending at

Dobbs Branch (see Figure 1, attached).

Soil, sediment, groundwater and air samples were

collected from the site and surrounding targeted areas.

Some of the targeted areasincluded:the Coke Plant site;

Chattanooga Creek tar deposit in the flood plain;

SchwermanTrucking site;ChattanoogaCreek sediments

and groundwater; Residentialareas; the Early Childhood

Family Education Center playground; and the Northeast

and Northwest tributary areas. Please note that the

Remedial Investigation covered many areas, including

areas that were cleaned up during the 1998 removal

action. The focus of the proposed Phase 2 clean up are

areas containing the most contamination.

A summary of the Remedial Investigationresultsrelevant

to the areas containing contaminationassociated withthe

Tennessee Products Site is presented below:

Air: Air samples were collected to find out if any

contaminants from the site were in the air. A few

samples showed the presence of the type of

contaminantsfound inthe creek, but the levels did not

present an unacceptable risk. Also, during the first

phase of the cleanup, while the contaminated creek

sediments were being removed, EPA monitored the

air continuously and did not detect any unsafe levels of

contaminants in the air.

Groundwater: Shallow groundwater samples were

collected near the creek to determine if contaminants

from the creek were being released into the

groundwater. Deeper groundwater samples were also

collected in certain areas, but no contaminants were

detected. Results show that a few of the organic

chemicals found in the sediment are present in the

shallow groundwater near the creek. The following

chemicals were detected at very low concentrations:

Volatile Organics: Chlorobenzene

Semi-Volitile Organics: 1,3-Dichlorobenzene, 1,4-

Dichlorobenzene, Naphthalene, Acenaphthalene,

Phenanthrene, and 2-Methylnaphthalene

Pesticides: Alpha-BHC, Beta-BHC, Gama-BHC and

Dieldrin

Metals: Iron (found to be above background

concentrations)

The groundwater contamination found to be

associated with the creek is limited to a narrow band

along the creek. During most of the year groundwater

flows into the creek, preventing the chemicals in the

creek from escaping. Only during high flood events

does water flow from the creek into the groundwater.

Soil: Soil samples were collected from the Northeast

Tributaryarea and the Chattanooga Creek tar deposit

located in the flood plain. Results from each area are

as follows:
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Tennessee Products Superfund Site Proposed Plan Factsheet August 2002

5

Northeast TributaryArea:soilsamplescollectedfrom

the banks of the Northeast Tributarycontained some

Volatile Organic compounds (benzene, toluene,

ethylbenzene and xylenes); high concentrations of

Polynuclear Aromatic Hydrocarbons (PAHs); and

low concentrations of pesticides. The PAH

compounds are the type of chemicals associated with

the creek and plant site. There is no apparent

pattern in the distribution of the chemicals in the soil.

It is believed that the soil next to the Northeast

Tributary is material that was removed from the

tributary channel and dumped along its bank. It has

been documented that the wastewater discharged

from the rear of the former coke plant flowed into

theNortheastTributaryand intoChattanooga Creek.

Chattanooga Creek Tar Deposit: This is an area in

the flood plain of the creek that contained a large

amount ofcoal-tar constituentsina pit approximately

90 feet square. Prior to Chattanooga Creek being

straightened under 38th Street, it meandered along a

pathnext to the pit. EPAcollected soilsamplesfrom

the area surrounding this pit to determine ifchemicals

from the pit were spread out. A total of 18 soil

samples were taken from locations which were

approximately 200 feet apart. Results show that

PAH contamination is present at varying

concentrations and inno distinguishable pattern. Also

foundweresome metals that wereabove background

concentrations in at least one sample. These metals

were: cadmium, chromium, nickel, antimony, zinc,

mercury and sodium.

Sediment: EPA conducted a comprehensive sediment

study in Chattanooga Creek which identified significant

PAH (coal-tar constituents) contamination. Most of the

contamination is between Hamill Road and Dobbs

Branch (see Figure 1 attached)

Summary of Site Risks

As part of the RI/FS, EPA conducted a baseline risk

assessment to determine the current and future effects

of contaminants onhumanhealthand the environment.

Risk assessment is a process which makes many

assumptions about how people and the environment

are exposed to the site’s contaminants. Sampling

results are usedwithotherinformationto determine the

risks caused by the contaminants of concern based

on conservative exposure assumptions.

Contaminants of Concern

The main contaminants of concern (COCs) being

addressed by this remedy are polynuclear aromatic

hydrocarbons (PAHs). PAHs present in the creek

bed are at concentrations that would present an

unacceptable risk should chronic human exposure

occur. In the current specific environmental setting,

PAHs at the surface and at depthin certain sediments

present significant risks, according to the humanhealth

and ecological risk assessments.

Human Health Risks

The human health risks for this site were estimated

basedonanassumptionthat people would visit the site

currently and in the future, and on an assumption that

the site would be developed for commercial use and

future site workers would be exposed to

contamination in the creek. The exposure pathways

examined in the Risk Assessment were:

• ingestion of soil

• dermal contact with soil

• ingestion of sediment (in Chattanooga Creek)

• dermal contact with sediment (in Chattanooga Creek)

• ingestion of groundwater

• inhalation of volatile organic compounds (VOCs)

released from ground water, and

• inhalation of dust.
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Tennessee Products Superfund Site Proposed Plan Factsheet August 2002

6

The risks associated with these exposure scenarios are

calculated for cancer causing chemicals (carcinogenic

risks) and for other chemicals whichdo not cause cancer,

but that have the potential to cause other ill effects (noncarcinogenic risks). The estimated risks for the areas

investigatedlinked toChattanoogaCreekare summarized

below and in Table 1 and Table 2 attached.

Groundwater near the creek: The excess lifetime

cancer risk estimated for ingestion of contaminated

groundwater near the creek is within EPA’s

acceptable target range for adults and children.

Ingestion of groundwater does not pose an

unacceptable risk.

Chattanooga Creek Tar Deposit: The excess lifetime

cancer risk estimated for exposure to contaminated

soil in the area of the tar deposit is within EPA’s

acceptable risk range. Exposure to soil in this area

does not pose an unacceptable risk . This risk

assessment wasperformedonthe soilsurrounding the

tar pit. All of the heavily contaminated material was

removed during the 1997 removal action.

Northeast TributaryArea: The excess lifetime cancer

risk estimated for exposure to contaminated soil next

to the Northeast Tributary is above EPA’s

acceptable target range. Exposure to contaminated

soil near the Northeast Tributary does present an

unacceptable risk to adults and children, mainly from

direct contact and inadvertent ingestion.

Chattanooga Creek Sediment: The excess lifetime

cancer risk is estimated to be above EPA’s

acceptable risk range for adults and children who

visit the creek and who are exposed to contaminated

sediment (between 38th Street and Dobbs Branch).

Inadvertent ingestion of contaminated sediment and

direct dermal contact does present an unacceptable

risk. The creek segment between Hamill Road and

38th Street was cleaned up during the 1997 removal

action.

Ecological Risks

A complete ecological assessment was performed as

part of the RI/FS. EPA conducted flood plain soil,

surface water, sediment, and freshwater clam tissue

sampling at the site. Sediment and soil toxicity tests

were also conducted using samples of sediment

contaminated withcoal-tar constituents collectedfrom

the creek. An earthworm bioaccumulation studywas

conducted using Site soil samples.

The ecological risk assessment generally concluded

that plants and animals in the flood plain of the creek

have not been adversely impacted. However, the

ecologicalassessment also indicatesthat aquatic life in

Chattanooga Creek are at risk from exposure to

contaminated sediment. The sediment toxicity tests

show that PAH contamination in the sediment

significantly affects the survival, growth and

reproduction of aquatic life in the creek.

Remedial Action Objectives

Based on the remedial investigation and the risk

assessment, EPA determined that the objectives of

the remedy will be to:

• prevent human exposure to contaminated soil

along the Northeast Tributary and contaminated

sediment in Chattanooga Creek; and,

• eliminate risks to aquatic life in Chattanooga

Creek from exposure to contaminated sediment.

Scope and Role of the Remedy

As mentioned before, the overall cleanup strategy for

the site was first, to address the contaminated

sediment in Chattanooga Creek that was easily

accessible and posed the highest health risk to people.

This was accomplished through the 1997-98 sediment

removalaction. The second phase ofthe cleanup isto

address the remaining contaminated portion of the

creek, and the Northeast Tributary Area.
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Tennessee Products Superfund Site Proposed Plan Factsheet August 2002

7

The law requires EPA to use treatment to address the

principal threats posed by a site (NCP Section

300.430(a)(1)(iii)(A)). The principal threat is a source

waste material at a site that is considered to be highly

toxic or highly mobile, which would present a significant

threat to human health or the environment should

exposure occur. The coal-tar/PAH contaminated

sediment at this site does not meet the definition of

“principalthreat,” and therefore, the requirement to treat

the principal threat does not apply.

Coal-tar/PAH contamination from the site and the risks

associated with its exposure will be addressed through

the proposed cleanup action presented in this plan.

Summary of Remedial Alternatives

Six remedial action alternatives were considered for

evaluationinthe Focused FeasibilityStudyReport. They

are described as follows:

Alternative 1: No Action. The law requires that the “no

action” alternative be evaluated generally to establish a

baseline for comparison. Under this alternative EPA

would take no action at the site to prevent exposure to

the contaminated sediment and soil.

Alternative 2: Re-routing the Chattanooga Creek and

encapsulating (solidifying) the coal-tar constituents and

contaminated sediment left behind;

Alternative 3: Creating an on-site landfill for the

contaminated material;

Alternative 4: On-site ThermalDesorption–heatingthe

material at low temperatures to evaporate the chemicals;

Alternative 5: On-site incineration – burn the

contaminatedmaterialat the siteto destroythe chemicals;

Alternative 6: Off-site disposal and recycling –

removing the contaminated material and sending it to a

recycling facility.

Evaluation of Alternatives

The six remedial alternatives, including the no-action

alternative were evaluated using nine criteria

established by EPA. The nine criteria are defined in

a box on the next page. A summary of the evaluation

follows:

Overall Protection of Public Health and

Environment: All the remedies meet this criteria,

except Alternative 2, which keeps the contaminated

material on-site and may potentially pose a future

risk if the treatment fails long-term. The no-action

alternative does not meet this criteria.

Compliance with State and Federal

Requirements: Alternative 2 and 3 would not

comply with State and Federal regulations, unless

the contaminated material is treated first. All the

other Alternatives meet this criteria, except the noaction alternative.

Short-term Effectiveness: All the alternatives

considered (except the no-action alternative) will 

involve engineering controls to protect workers and

residents during construction. It is not expected that

any of these remedies will pose short-term health or

environmental risks. However, the no-action

alternative will continue to pose an unacceptable risk

without treatment.

Long-term Effectiveness: Alternatives 4, 5, and 6 

meets this standard because the waste is removed or

permanently treated. Alternatives 2 and 3 do not

provide the same level of protection because of

uncertainties with long-term reliability of the remedy. 

 The no-action alternative does not meet this criteria.
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Tennessee Products Superfund Site Proposed Plan Factsheet August 2002

8

Reduction of Mobility, Toxicity and Volume:

Alternatives 2, 3, 4, and 5 reduce the mobility and

toxicity of the waste, but no significant volume

reduction is achieved. Alternative 6 meets this criteria

completely by eliminating the waste. The no-action

alternative does not meet this criteria.

Implementability: All the alternatives can be

reasonably implemented. This criteria is not a

consideration for the no-action alternative.

Cost: The estimated costs to implement each

remedy is as follows:

Alternative 1: $0

Alternative 2: $6,707,900

Alternative 3: $6,321,600 (without pre-treatment)

Alternative 4: $8,662,200 to $12,574,500 (depending on

whether the thermal unit is direct-fired or

indirect-fired)

Alternative 5: $12,151,000

Alternative 6: $7,479,400

State Acceptance: TDEC has assisted EPA in

reviewing all technical reports produced during this

investigation and has evaluated the remedial

alternatives considered for this site. TDEC agrees

with the proposed remedy for the site.

Community Acceptance: Community acceptance

of the preferred alternative will be evaluated during

the public comment period. Comments received

from the community will be addressed in the

Responsiveness Summary section of the Record of

Decision Document.

Summary of the Preferred Alternative

Based on the results of the Remedial Investigation

and Feasibility Study, EPA has determined that

excavation and off-site disposal and recycling

(Alternative 6) is the preferred alternative for the

site. The preferred alternative provides the best

balance of tradeoffs among the nine evaluation

criteria, and meets the remedial goals by preventing

future human contact with the coal-tar constituents

and contaminated sediment in Chattanooga Creek. 

This remedy was used during the first phase of the

cleanup and was proven to be effective and efficient. 

Also, this was also the only alternative considered to

completely remove the waste material from the site.

The preferred alternative will involve excavating the

coal-tar constituent waste and contaminated

sediment from the location where the Phase 1

Nine Criteria for Evaluating

Remedial Alternatives

1. Overall Protection of Public Health and

Environment: Degree to which the remedy eliminates,

reduces, or controls health and environmental threats

through treatment, engineering methods or institutional

controls.

2. Compliance with State and Federal

Requirements: Degree to which each alternative meets

environmental regulations determined to be applicable or

relevant and appropriate.

3. Short-term Effectiveness: Length of construction

period and the risks posed to workers and nearby

residents during construction.

4. Long-term Effectiveness: Ability of a remedy to

maintain protection of health and environment after the

remedy is completed.

5. Reduction of Mobility, Toxicity and Volume:

Degree to which the remedy reduces: the ability of

contaminants to move through the environment; harmful

nature of the contaminants; and, amount of contamination

removed.

6. Implementability: Refers to the technical feasibility and

administrative ease of implementing a remedy.

7. Cost: Benefits of a remedy are weighed against its cost.

8. State Acceptance: Consideration of the State’s

comments and acceptance of the preferred remedy.

9. Community Acceptance: Consideration of the public’s

comments and acceptance of the preferred remedy.
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Tennessee Products Superfund Site Proposed Plan Factsheet August 2002

9

Cleanup ended to the confluence of Dobbs Branch. 

During the Phase 1 Cleanup the following

circumstances were encountered:

• all of the contaminated sediment was removed

because bedrock was near the bottom of the creek bed

and all of the sediment was completely contaminated;

and,

• the coal-tar contamination is easily identified by visual

inspection.

These conditions are expected to be encountered in the

remaining portion of the creek. Therefore, it is

unnecessary to establish cleanup standards for the

cleanup in the creek, since all of the contaminated

sediment is proposed to be removed.

The law requires that if a remedy is selected that results

in contamination remaining at the site above levels that

allow for unrestricted use and unrestricted exposure,

then EPA shall evaluate the remedy every five years to

determine if it continues to protect human health and the

environment. If the preferred alternative is selected

then the five-year review will not be required.

COMMUNITY PARTICIPATION

The Comprehensive Environmental Response,

Compensation and Liability Act (commonly referred to

as CERCLA or the "Superfund Law") requires that

EPA publish this Proposed Plan (Section 117(a)). 

Other public involvement activities undertaken at

Superfund sites consist of: interviews with local

residents and elected officials, development of a

community relations plan, fact sheets, information

availability sessions, public meetings, public comment

periods, newspaper advertisements, site visits,

Technical Assistance Grants, and any other activities

needed to keep the community informed about the site

and involved in the clean-up process.

To promote public involvement at the Tennessee

Products site, EPA is conducting a 30-day public

comment period from August 12 to September

10, 2002. Public input on the remedial

investigation, on all the alternatives considered, and

on the preferred alternative is an important

contribution to the remedy selection process. 

During this comment period, the public is invited to

attend a public meeting on August 22, 2002, at

the Calvin Donaldson Elementary School,

located at 927 West 37th Street, Chattanooga, 

beginning at 7:00 p.m. At the public meeting,

EPA will answer questions, present the Remedial

Investigation results and discuss the preferred

alternative for the Tennessee Products Site. 

Because this Proposed Plan Fact Sheet provides

only a summary description of the investigation and

preferred alternative being considered, the public is

encouraged to refer to the Administrative Record

located in the information repository for a more

detailed explanation.

The public is invited to review all site-related

documents housed at the information repository

located at the Sallie Crenshaw Bethlehem Center,

200 West 39th Street, Chattanooga (423-266-

1384). The public is also invited to offer comments

to EPA, either verbally at the public meeting, which

will be recorded by a court reporter, or in written

form during the 30-day comment period. The final

remedy selected for the site could be different from

the proposed remedy, described in this Proposed

Plan Fact Sheet, depending upon new information or

statements EPA may receive as a result of public

comments. 

Public input is an

important piece of the

Superfund puzzle!

Please mail written comments, postmarked no later
Cleanup of Chattanooga Creek

Tennessee Products Superfund Site Proposed Plan Factsheet August 2002

10

QUICK COMMENTS

Please let us know what you think about the Tennessee Products Super

needed so that we can be responsive to the needs of the community. P

and mail it to:

Mr. Nestor Young

North Site Management Branch

U.S. EPA, Region 4

61 Forsyth Street, SW

Atlanta, Georgia 30303

Name: Phone: 

Address: 

Comments: 

than midnight September 10, 2002 to:

Nestor Young

Remedial Project Manager

U.S. Environmental Protection Agency, Region 4

North Site Management Branch

61 Forsyth Street, SW

Atlanta, GA 30303

If you have any questions about the site, you may

contact Linda Starks, Community Involvement 

Coordinator, or Nestor Young, Remedial Project

Manager, at the address above or phone 1-800-435-

9233. EPA's final cleanup decision will be recorded in

a document called a Record of Decision (ROD). 

Public comments received by EPA will be reviewed.

Response to comments will be included in a section

of the ROD called the Responsiveness Summary. 

Once the ROD is signed by EPA's Regional

Administrator, it will become part of the

Administrative Record. The Administrative Record,

located in the information repository, contains all

documents used by EPA in making a final

determination of the most appropriate action for the

site.

The Administrative Record can be found at:

Sallie Crenshaw Bethlehem Center

200 West 39th Street

Chattanooga, TN 37409

(423-266-1384)
U.S. Environmental Protection Agency

61 Forsyth Street, SW.

Atlanta, Georgia 30303

 Region 4 Nestor Young, NSMB

Official Business

Penalty for Private Use $300

Inside: Chattanooga Creek Proposed Clean Up Plan

Table 1:

Summary of Cancer and Non-Cancer Risks by Exposure Route

Current Use Scenario for Chattanooga Creek Sediments

Location Exposure Route

Child Resident Adult Resident Lifetime

Resident

Cancer4 HI5 Cancer HI Cancer HI

Upper Reach1

Inadvertent

Ingestion

Dermal Contact

4E-07

1E-07

0.02

0.004

3E-07

3E-07

0.005

0.002

7E-07

4E-07

0.01

0.003

Total Risk 5E-07 0.03 6E-07 0.01 1E-06 0.01

Middle Reach2

Inadvertent

Ingestion

Dermal Contact

3E-04

3E-04

0.3

0.2

3E-04

5E-04

0.1

0.1

6E-04

7E-04

0.1

0.1

Total Risk 6E-04 0.5 8E-04 0.2 1E-03 0.2

Lower Reach3

Inadvertent

Ingestion

Dermal Contact

1E-06

1E-06

0.01

0.01

1E-06

2E-06

0.01

0.01

3E-06

3E-06

0.02

0.01

Total Risk 3E-06 0.03 4E-06 0.02 6E-06 0.03

Notes: 1. The Upper Reach is the area from Burnt Mill Bridge to the RR bridge between Hooker and Hamil Roads.

2. The Middle Reach is the area between the RR bridge (between Hooker and Hamil Roads) and Dobbs Branch.

3. The Lower Reach is the area between Dobbs Branch and the Tennessee River.

4. Cancer: The cancer risk level is a probability of getting cancer over a lifetime as a result of exposure to a chemical

at the particular level of exposure. The numbers mean the following: 1E-04 is one chance in 10,000; 1E-05 is one

chance in 100,000; and 1E-06 one chance in a million. EPA determined that estimated cancer risks between 1E04 (0.0001) and 1E-06 (0.000001) is acceptable, and do not necessarily indicate that a cleanup is needed.

3. HI: The Hazard Index (HI) is the sum of the Hazard Quotient for each exposure route. An HI is calculated for

non-carcinogens to assess whether health problems, other than cancer, might be associated with a Superfund site. 

If the number is greater than 1.0 then the chemical may pose some risk to human health.
Table 2: Summary of Cancer and Non-cancer Risks by Exposure Route

for the Northeast Tributary Area1

Exposure Route

Estimated Risk

Current Use Scenario for a Site

Visitor

Future Use Scenario for a Site

Visitor (property developed for

commercial use)

Future Use Scenario 

for a Site Worker

(property developed for

commercial use)

Cancer2 HI3 Cancer HI Cancer HI

Inadvertent Ingestion of Soil

Dermal Contact with Soil

Inhalation of Dust 

Inadvertent Ingestion of Surface Water

Dermal Contact of Surface Water

Inadvertent Ingestion of Sediment

Dermal Contact with Sediment

1E-04

2E-04

2E-08

2E-06

5E-04

4E-05

7E-05

0.03

0.04

0.000001

0.1

0.5

0.1

0.03

1E-04

2E-04

2E-08

2E-06

5E-04

4E-05

7E-05

0.03

0.04

0.000001

0.1

0.5

0.1

0.03

2E-03

1E-03

6E-07

NA

NA

NA

NA

0.2

0.1

0.00002

NA

NA

NA

NA

TOTAL RISK 9E-04 0.7 9E-04 0.7 3E-03 0.4

Notes:

1. The Northeast Tributary Area consists of a mound of contaminated soil next to the Northeast Tributary of Chattanooga Creek.

2. Cancer: The cancer risk level is a probability of getting cancer over a lifetime as a result of exposure to a chemical at the particular level of exposure. 

The numbers mean the following: 1E-04 is one chance in 10,000; 1E-05 is one chance in 100,000; and 1E-06 one chance in a million. EPA determined

that estimated cancer risks between 1E-04 (0.0001) and 1E-06 (0.000001) is acceptable, and do not necessarily indicate that a cleanup is needed.

3 HI: The Hazard Index (HI) is the sum of the Hazard Quotients for each exposure route. An HI is calculated for non-carcinogens to assess whether

health problems, other than cancer, might be associated with the site. If the number is greater than 1.0, then the chemical may pose some risk to human

health.