Maya M. Belka, South Chattanooga and Chattanooga Creek Floodplain: A Case Study
Faculty Chair: Dr. John Tucker
South Chattanooga, Tennessee, has been the object of numerous investigations due to its large minority population and industrial history. Utilizing the case study approach, the area was examined as both an environmental justice community and home to an active Superfund site. Through legal analysis, historical research, environmental sampling, and government agency assessment, patterns emerged. The patterns provided a means for comparison with other communities in similar situations. The comparisons allowed for the formulation of several recommendations.
The community's proximity to the heavily polluted Chattanooga Creek was a key component of the South Chattanooga case study. Chattanooga Creek flows through the heart of South Chattanooga and has been an industrial dumping ground for over 100 years. Decades of pollution and frequent flooding events gave rise to community concern regarding contact with the Creek. As a result, Chattanooga Creek was included on the National Priorities List (NPL) and a Superfund site investigation commenced.
After several site investigations and some Creek remediation, the United States Environmental Protection Agency (EPA) awarded the City of Chattanooga a Superfund Redevelopment Initiative (SRI) pilot grant. Portions of the grant were used to develop a detailed Superfund site reuse plan. The reuse plan proposed a greenway linking individual South Chattanooga communities to Chattanooga Creek and to one another. The greenway and park would offer recreational opportunities and would run through the floodplain along the entire length of the Chattanooga Creek Superfund site.
Due to persistent flooding of Chattanooga Creek and lingering questions about the adequacy of past and proposed removal actions. South Chattanooga citizens were not convinced that the floodplain was safe enough to accommodate public use without additional remediation. To address this concern, the Biological and Environmental Sciences Department at The University of Tennessee at Chattanooga (UTC), the Center for the Management, Utilization, and Protection of Water Resources at Tennessee Technological University (TTU), and the local environmental justice community organization Stop Toxic Pollution (S.T.O.P.), requested a grant from EPA's Region IV Office of Environmental Justice. EPA funded the Chattanooga Creek Hazardous Substances Monitoring Program grant, which allowed for environmental sampling of the Chattanooga Creek floodplain.
The results of the floodplain sampling showed soil polycyclic aromatic hydrocarbon (PAH) levels above several EPA Region IV remediation guidelines. Although guidelines are not legally enforceable, the remediation guidelines are the only guidance provided for this type of site assessment. As a result. South Chattanooga citizens indicated that the greenway, as proposed, should not be constructed without further remediation of floodplain soils. Despite EPA guideline exceedance and community concern, the Agency for Toxic Substances and Disease Registry (ATSDR) issued a Health Consultation that declared no apparent public health hazard existed from contact with soil PAH contamination. Because of the discrepancy between guideline exceedance and the ATSDR conclusion, other Superfund communities were investigated for comparison purposes.
Five Superfund communities from different EPA regions were analyzed. Major discrepancies between EPA Superfund remediation projects were discovered. The primary causes were a lack of guideline consistency, inconsistent interpretation of relevant environmental laws, and undeterminable risk associated with PAH mixtures. Although South Chattanooga's struggle was by no means unique, understanding the complexities associated with Superfund remediation and environmental justice communities were essential in order to provide recommendations for agency discrepancy and the risk assessment process. This thesis will identify the multiple factors that impede remediation of the Chattanooga Creek floodplain and hinder efforts by South Chattanooga residents to achieve environmental justice.