U. S. ENVIRONMENTAL PROTECTION AGENCY
                                REGION 4
                  ENVIRONMENTAL JUSTICE UPDATE
EPA
904/
2000.1
    Environmental Accountability Division
Environmental Justice/Community Liasion Program
            March 31,2000
                                            US EPA Headquarters. Library
                                                 Mail code 3201
                                            1200 Pennsylvania Avenue NW
                                              Washington  DC 20460

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K.QGO, / .
                                          REPORT TO THE
                  NATIONAL ENVIRONMENTAL JUSTICE ADVISORY COUNCIL
                                 U.S. Environmental Protection Agency
                                             REGION 4
                                            March 31,2000
         DEMOGRAPHICS

         The Environmental Protection Agency (EPA), Region 4, consists of eight (8) southeastern states.
         These states are: (1) Alabama, (2) Florida, (3) Georgia, (4) Kentucky, (5) Mississippi, (6)
         North Carolina, (7) South Carolina, and (8) Tennessee. The eight states of Region 4 represent the
         largest and most diverse Region within the Agency. Region 4 states are growing faster than any
         other region in the United States, excluding the desert southwest. The population of Region 4
         states is projected to increase to 52 million individuals by the year 2000.

         ENVIRONMENTAL JUSTICE PROGRAM/COMMUNITY LIAISON PROGRAM
         Contact Person: Connie Raines, (404) 562-9671

         Region 4 established the Environmental Justice/Community Liaison Program (EJ/CLP) in July
         1993 to develop a regional program to address any environmental issues that have
         disproportionate and adverse impacts on minority and/or socioeconomically disadvantaged
         communities. The regional environmental justice program has continued to evolve in the last five
         years.

         In 1996, EPA, Region 4 underwent a major reorganization. A new division was established, the
         Environmental Accountability Division (EAD), Director, Phyllis Harris.  As a result of the
         reorganization, the EJ/CLP was strategically moved to the new division to ensure that the overall
         mission of the EJ/CLP was accomplished and resources within EAD were designated
         accordingly.  EAD is responsible for the overall direction, administration, and evaluation of
         regional integration of environmental justice into the Agency's daily activities.
                                                            U.S. EPA Headquarters Library
                                                                  Mail code 3201
                                                            1200 Pennsylvania Avenue NW
                                                              Washington DC 20460

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                    DIVISIONAL PROGRAMS AND INITIATIVES

                                    AIR DIVISION

Toxic SUBSTANCES CONTROL ACT LEAD-BASED PAINT PROGRAM
By its nature, the Toxic Substances Control Act (TSCA) Lead-Based Paint Program addresses
environmental justice issues on an ongoing basis.  The EPA Lead-Based Paint Program was
developed to help reduce childhood lead poisoning, with the knowledge that the children at
highest risk for lead poisoning are children residing in older homes, in low-income, urban
settings.  Minority children are at a much higher risk for lead poisoning that non-minority
children. The children at highest risk for lead poisoning, therefore, are the children found in
environmental j ustice communities.

In setting priorities for the Region's Lead-Based Paint Program, the Region targets high risk
communities/environmental justice communities when conducting inspections, when conducting
outreach and when undertaking compliance assistance initiatives.  The Lead-Based Paint Rules
being targeted in these areas include a real estate information disclosure rule, an information
disclosure rule for renovators and remodelers, and a certification rule for individuals conducting
paint inspections, risk assessments, and paint removal. The Region uses data based on age of
housing, income level, and age of children present in housing to identify areas with the greatest
probability of hazard from lead-based paint in housing when conducting the program activities.
The Region also works with county health departments to assist in further identifying high risk
areas and areas where children have been found with elevated blood lead levels.

CHATTANOOGA AIR Toxics STUDY

For updates and more information, see:
htip:/A\Av\v.epa.aov/region4/programs/cbep/Droiects2.html
EPA Region:  Region 4

Area Description: Chattanooga, Hamilton County, Tennessee. Chattanooga has a history of
heavy industry. During the time when highway construction took place in downtown
Chattanooga, inexpensive property was used to construct several public housing projects for
minority communities whose homes were demolished. According to 1990 census data, 98% of
the residents of the southern portion of Chattanooga are African American, and more than 60%
of the residents live below poverty level. The Alton Park/Piney Woods neighborhoods in
southern Chattanooga are the primary focus of the Chattanooga Air Toxics Study. This area
includes approximately 6,500 residents, is heavily concentrated with various industries, and is in
close proximity to the Chattanooga Creek Superfund Site, which is of particular concern  to the
citizens.

Describe Environmental Problems:  The southern portion of Chattanooga has been the focus of
a number of environmental studies and remediation activities.  There are numerous Superfund
sites located in the area.  The Chattanooga-Hamilton County Air Pollution Control Bureau
(CHCAPCB), in conjunction with the Tennessee Valley Authority, conducted a two-year (1985-

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86) ambient air monitoring study in the Piney Woods area. The data collected did not indicate an
air quality problem, however, no final report was issued for this study. As a result of public
petitions, the Agency for Toxic Substances and Disease Registry (ATSDR) finalized a Public
Health Assessment for the Chattanooga Creek Coal Tar Deposits in southern Chattanooga. The
ATSDR Health Assessment indicated possible health problems in the local population, although
no conclusions regarding cause could be drawn.  One of the recommendations of ATSDR's
Public Health Assessment was that an ambient air toxics monitoring study be conducted in South
Chattanooga.  Subsequently, the U.S. Environmental Protection Agency (EPA) Urban Air Toxics
Monitoring Program (UATMP) was used to provide recommendations on where ambient air
toxics monitors should be placed to detect maximum population exposures. In November 1998.
EPA Region 4 and the local air agency began a one-year air toxic monitoring  study.

Describe how/what vour RGI projects) is impacting the environmental problems that
otherwise would not be reachable/doable/possible through our Program work: The overall
goal of the Chattanooga Initiative is to mobilize the community, assess the public health and
ecological risks associated with environmental problems, and collectively identify solutions to
unacceptable risks in order to improve the environment and protect the health and welfare of the
public. The Initiative is primarily focused on the low-income and minority populations located
adjacent to industrial areas.

While the Clean Air Act and Amendments will eventually address air quality  problems in urban
areas, such as Chattanooga (e.g., through Maximum Achievable Control Technology (MACT)
standards and residual risk analyses), the stakeholders believe there is sufficient cause to evaluate
and address potential air related risks ahead of statutory deadlines.  The objective of the
Chattanooga Air Toxics Study is to identify air toxics posing unacceptable risks, if any, and to
institute measures to reduce those risks (e.g., pollution prevention initiatives) ahead of Clean Air
Act requirements. Depending on the nature of the risk management planning  process instituted
by the stakeholders, it is possible the actions taken could be more stringent than those required
under existing State and Federal authorities.

Describe the expected results for this Fiscal Year; Monitoring data collection began at six
sites in Chattanooga in November 1998. Air toxics samples were collected every 12 days
through November 1,1999, yielding a total of 30 samples/site.  The air toxics sampling
equipment monitored volatile organic compounds (VOC), semi-volatile organic compounds
(SVOC), aldehydes, and metals in suspended particulate. A contractor was selected in
September 1999 to develop an inhalation risk assessment for the Chattanooga Air Toxics Study,
based on the data collected, and to assist with presenting the risk assessment results to local
residents and other stakeholders.

During fiscal year (FY) 2000, data collected over last year will be interpreted and evaluated. A
risk assessment workplan has been drafted.  The  risk assessment report will be available by
September 2000.  The first of a series of stakeholders' meeting to inform and update the citizen
regarding the Chattanooga Air Toxics Study has  been conducted.  A Stakeholders' Advisory
Committee was established to work closely with Federal, State and local officials in utilizing the
data collected to better understand air quality conditions in Chattanooga.  A Risk Management
Plan will be developed in FY 2000 to respond to the results of the risk assessment.  Modeling

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will be necessary, subsequent to the monitoring risk evaluation, to assess the sources responsible
for unacceptable levels of hazardous air pollutants. Risk management goals cannot be achieved
without the ability to identify the sources of the pollutants responsible for unacceptable risk.
This modeling effort will continue into FY2001.

Stakeholder Participation - Internal and External: EPA - Region 4; Chattanooga-Hamilton
County Air Pollution Control Bureau; Agency for Toxic Substances and Disease Registry; State
of Tennessee; Stop TOxic Pollution (STOP); University of Tennessee; community groups; local
industries; and local elected officials.

National Strategic Plan Link; (Goal(s)/Objective(s)/Sub-Objective that this project supports
http://intranet.epa.gOv/budgpage/l 999sub/subobj-htm - sub-objective descriptions)

Goal 1 - Clean Air, Obj. 2, Subobj. 2.2 - Air Toxics Characterization;
Goal 7 - Expansion of American's Right-to-Know About Their Environment, Obj.l, Subobj.  1.7

JRegionaJ Priority:  Environmental Justice

The population of the southern portion of the Chattanooga area is 98 % African American and
more than 60% of the residents live below poverty level. The study area where most
environmental concerns exists, clearly meets the criteria for environmental justice (EJ). The
lessons learned from this pilot can be used to develop programs that can be incorporated into  the
Region's urban air toxics and Brownfield initiatives,  as well as other EJ communities.
Regional Contact:
Van Shrieves
EPA Region 4, 61 Forsyth St., SW, Atlanta, GA 30303
Phone: (404)562-9089
E-mail:  shrieves.van@.epa.gov
WEST LOUISVILLE COMMUNITY-BASED ENVIRONMENTAL PROTECTION (CBEP) PROJECT

For updates and more information, see:
http://\v:\vvv.epa.goy/region4/programs/cbep/proiects2.html
http://members.aol.com/Ecotopic/Rubbertown.html

EPA Region: Region 4

Area Description: The project targets the most densely concentrated area of industry within the
State and the surrounding communities. Bounded by the Ohio River and downtown Louisville,
the initiative encompasses portions of both the City of Louisville and Jefferson County and
includes the "Rubbertown" industrial complex, a four-square mile area with large industries.

Describe Environmental Problems;  The Rubbertown industrial facilities have been emitting a
wide variety of pollutants  into the environment for approximately 50 years. Consequently, there
are considerable multi-faceted environmental concerns in the area for both the community and
regulators. Citizens are concerned with adverse impacts to air and surface water quality due to
ongoing industrial practices and the cumulative environmental and health effects from local

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industries. They are also concerned that improper waste disposal practices, which were routine
prior to the 1970s, have contaminated the land and groundwater. Community representatives rated
air (64%), water (41%) and land (31%) quality as poor. A Task Force, including representatives
from the neighborhood associations and other community members, industry, environmental
groups and local government, identified six environmental concerns of highest priority, and
generated  15 recommendations and 38 action items. The top priorities of the community include:
industrial odors in the area; air pollution; surface water quality; community "right-to-
know'Vaccess to environmental information; need for health assessments; and access to quality
affordable health care.

Based on available data, the Region 4 West Louisville CBEP Work Group identified hazardous
air pollutants, Toxic Release Inventory (TRI) emissions, ozone, and indoor air quality (combined
effects of cigarette smoke, radon and volatile organic compounds (VOCs)) as posing a potentially
high risk to the community. Additional information is needed on lead Levels in soil, houses and
blood, as it appears that lead may potentially pose a high risk to the community.  Further
information is also needed to determine the impact of solid waste landfills on Ohio River water
quality and the risks posed by soil contamination, water pollution and contaminated groundwater
discharging into the Ohio River.

Describe how/what your RGI pro ject(s) is impacting the environmental problems that
otherwise would not be reachable/doable/possible through our Program work; The West
Louisville CBEP area is a geographic region that has both a high population density and a long
history of heavy industrial land uses in close proximity to residential areas.  Existing statutes and
funding generally are focused on controlling individual sources of pollutants with little direct
attention on the cumulative, long-term impacts of multiple sources on a nearby residential
populations  This project seeks to support environmental protection that is more efficient and
responsive to the concerns of the people of this community.

This project  involves a comprehensive, multi-media investigation, necessitating the involvement
of nearly all  EPA program offices. The overall initiative is an expensive undertaking that
requires the collaboration of numerous entities and funding from several sources.  The
Commonwealth of Kentucky and the local community have come forward with significant
funding and  in-kind contributions, but it is unlikely the project will be successfully completed
without the continued support from the EPA through traditional mechanisms and RGI funding.

RGI funds are needed to conduct soil sampling in this community, analysis of the samples, and
interpretation of results.  Superfund and RCRA statutes provide funding and/or authority for
these types of soil studies at the location of known or suspected contaminant sources, but not on
an area wide basis, as planned here. Available Commonwealth and local resources for this CBEP
project are directed at the air monitoring study, so it is unlikely that the  soils characterization
work will be conducted without EPA funding.

There are no other current sources of funds for conducting a risk assessment using the air toxics
data being collected.  The risk assessment is necessary to evaluate the impact of hazardous air
pollutants on the community.

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While air monitoring and soil samples data are being collected and analyzed, Regional staff will
work with Commonwealth and local agencies to provide community outreach on environmental
issues. Citizens of the West Louisville area want to know if the environment they live in is one
that threatens their health and the health of their children. The West County communities have
expressed a desire to focus on children's health issues. Among other activities, the Region will
provide the community with children's health tools, Tools for Schools (focusing on indoor air
quality issues), and Energy Star Schools materials.

These funds will help the community generate additional resources and focus on priority issues.
This community has proven to be very astute at generating positive media attention and local  and
state support in furthering their efforts.

Describe the expected results for this Fiscal Year;
There have been several outcomes as a result of EPA's involvement in the Rubbertown
community. A Steering Committee of stakeholders was formed to develop a work plan
delineating the project mission, objectives, time lines and roles and responsibilities of
participating organizations. Funding was secured to conduct  an air toxics monitoring study
during FY 2000, and to provide training and information to community members on air toxics,
geographic information systems for environmental data and other environmental issues. The
Region 4 Waste Management Division has tasked a contractor, using existing site assessment
contract funds, to screen potential hazardous substance release sites within the project area to
recommend where further action should be considered. The Community Task Force Coordinator
received "train the trainer" training on the Superfund Jobs Training Initiative (JTI). The City  of
Louisville volunteered assistance in geographic information systems mapping, and the University
of Louisville volunteered the time of graduate students to assist in the effort. This will
complement the air toxics monitoring that will be conducted during FYOO and part of FY01.

In addition to EPA's involvement, the community stakeholders have made progress on
addressing the identified community issues of concern, utilizing grant money from a variety of
sources, including various community grants offered by EPA. The community developed, with
University of Louisville assistance, a set of geographic information system (GIS) maps of the area
depicting health, census, and environmental data. The County hired a'Community Coordinator for
the Park DuValle neighborhood under a Sustainable Development Challenge Grant awarded last
year. The Coordinator will participate in the CBEP effort and champion numerous action items.
The Jefferson County Air Pollution Control District established a computer  work station
dedicated to performing air quality modeling that was used in siting the air toxics monitors. The
Jefferson County Air Pollution Control District presented the CBEP project at an event attended
by 125 citizens.  This public/private event informed citizens about the Clean Air Act §112(r) -
Emergency Release program and requirements. Additional outreach on this topic is also planned
for the Park DuValle neighborhood.  The Metropolitan Sewer District is currently conducting an
odor survey for residents.

The ultimate goal of this project is to facilitate the improvement of public health and
environmental conditions in the area using sound environmental data and decisions.  This  goal is
essentially identical to the goal of the West County Community Involvement Task Force,  a
coalition of community, industry, and local government, and  is aligned with the objectives of the

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"Environmental Justice through Pollution Prevention" grant awarded to the University of
Louisville.  This goal will be met by undertaking many types of activities to promote sustainable
development for the study area. The stakeholders are in the process of finalizing a workplan to
delineate the activities that will be undertaken over an period of approximately two years.
Specific results expected from FYOO funds being requested include:

Land Quality
•      A report will be produced from a study already underway to identify and screen potential
       hazardous substance release sites within the project area. This study is aimed at
       identifying sites not already being addressed under state or federal authorities (Superfund,
       RCRA etc.), or overlooked priorities amongst sites already identified.
•      This work will be supplemented with soil sampling and risk characterization designed to
       augment hazardous air pollutant risk characterization. Approximately 50 soil samples
       will be collected in and around the residential portions of the project area. The samples
       will be analyzed for TAL/TCL parameters. Evaluation of the resulting data will begin
       this fiscal year (FY), but will not be completed until FY2001. Together, the soil and air
       monitoring data will provide a more complete picture of the environmental risks the
       community faces.
Air Quality
•      Air toxics monitoring will begin by April 2000, and continue for one year,
•      To complete the risk characterization, a detailed evaluation of the air monitoring data will
       be required.  Additional funds  are needed to supplement the approximately $20,000
       provided 1999, to assess the data collected. This task would require approximately six
       months of work beyond the end of monitoring data collection.
•      Additional risk training will be provided during FY 2000 to the community, prior to
       delivering the results of the study, in order to improve the community's understanding of
       the issues, and ability to act on the information.

Outreach
•      Conduct risk training in the community (at least two training sessions), and ensure that
       one or more key local community representatives attend an upcoming risk assessment
       workshop to be held in Ashland, KY (TriState Geographic Initiative).

•      Develop a community and government partnership plan to address environmental health
       hazards (i.e., pesticides, PCBs, asbestos, lead, second hand smoke and radon)  faced by
       children at home, school and play through education of parents, children, educators and
       decision-makers.
•      Conduct an assessment of West Louisville (i.e., parts of Louisville and Jefferson County)
       and provide limited support to  begin implementing the Pesticides, Asbestos, Lead (PAL)
       project in Louisville. The program will utilize resources in the community and
       government to help empower families and neighborhoods to take better care of their
       children's environment. Emphasis will be placed on building upon the lessons and
       successes of the Children's  PAL Initiative in Baldwin County and the eleven existing
       Children Health Champion (CHC) Campaigns. This project will also incorporate many
       ongoing agency voluntary initiatives including the Tools for Schools, Integrated Pest
       Management in Schools, and other programs (asbestos, PCB's, asthma, radon, Energy

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       Star Schools) which address children's environmental health hazards.
•      Provide environmental health outreach materials for the PAL program (utilizing success
       of PAL tested tools from other areas)
•      Perform some interventions. The extent of the interventions implemented will be
       dependent upon the availability of other local, state and federal resources.
•      Provide a catalyst and work with the community and city/county governments and EPA's
       Energy Star Program to promote Energy Star Schools. Facilitate opportunities for the
       County School System to talk with other school systems (e.g., Fulton County) regarding
       "lessons learned" from their attempts to improve the efficiency of their schools.
•      Identify mechanisms and help secure EPA internship opportunities for up to two West
       County residents, focusing on the environmental issues being addressed in their
       community.
•      Provide outreach focusing on pollution prevention (P2) during P2 week in September
       2000.  Work with the stakeholders to design and implement an appropriate and effective
       outreach event.

Stakeholder Participation - Internal and External; The following entities are actively
involved in the project area at this time:

West County Community Task Force - comprising twelve neighborhood associations, including
religious leaders, non-profit environmental groups (e.g.-Paddle Wheel Alliance), industrial
facilities within the project area (through the Rubbertown Community Advisory Council), local
government (City of Louisville, City of Louisville Housing Authority, Jefferson County
Department of Planning and Environmental Management, Jefferson County Health Department,
Jefferson County Air Pollution Control District), the University of Louisville, the Kentucky
Pollution Prevention Center, the Environmental Protection Agency, Agency  for Toxic Substances
and Disease Registry, Louisville Police Department, Municipal Sewer District, the Kentucky
Division for Environmental Protection, and Jefferson County Schools.

National Strategic Plan Link: (Goal(s)/Objective(s)/Sub-Objective that this project supports
http://intranet.epa.gov/budgpage/1999sub/subobi.htm - sub-objective descriptions)

Goal 1 - Clean Air; Obj. 2, Sub obj. 2.2; Goal 5 -  Better Waste Management, Restoration of
Contaminated Waste Sites, and Emergency Response, Goal 7 - Expansion of American's Right-
to-Know About Their Environment, Obj.l, Subobj.  1.7

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Regional Priority; EnvironmentalJustice
The West Louisville area is populated by approximately 70,000 residents of which the majority
are minorities (78%).  Approximately 40 percent of the residents are living below the poverty
level. The study area clearly meets the criteria for environmental justice (EJ) concerns.  The
lessons learned from this pilot can be used to develop programs that can be incorporated into the
Region's urban and Brownfields initiatives in other EJ communities.
Regional Contact;
Leslie Cox Montgomery
EPA Region 4, APTMD
61 Forsyth Street, SW
Atlanta, GA 30303
(404) 562-9088
montgomery.leslie@epa.gov
Richard Campbell
EPA Region 4, WMD
61 Forsyth, Street, SW
Atlanta, GA 30303
(404) 562-8825
Campbell.richardfa/epa.gov
CHILDREN'S PESTICIDE, ASBESTOS AND LEAD (PAL) INITIATIVE
The Children's Pesticide, Asbestos, and Lead (PAL) initiative is a community-based program
designed to minimize children's exposures to environmental health hazards which include lead-
based paint, pesticides, secondhand smoke, radon, polychlorinated biphenyls (PCBs), and
asbestos. The EPA Region 4 Pesticides and Toxic Substances Branch has conducted the
Children's PAL initiative in Baldwin County, GA and is ready to move ahead and implement this
initiative in Birmingham, AL, a community which has significant concerns with children's
environmental hazards.

The inner city area of Birmingham, Alabama is an environmental justice area with high
percentages of housing with lead-based paint and asbestos.  There are also significant Toxic
Release Inventory (TRI) emissions in the area.  The high percentage of minority population and
poverty in this area are consistent with the environmental and demographic factors associated
with high incidences of childhood lead poisoning, asthma, and other environmental health
concerns.  The project will also address an environmental justice area in the community with
longstanding environmental health concerns including asthma, radon, lead poisoning, and
asbestos poisoning which have been exasperated by repeated floods.

The objective of the Children's PAL Initiative is to develop a joint coordinated community and
government partnership to address environmental health hazards (i.e., pesticides, PCBs,
asbestos, lead, second hand smoke, and radon) faced by children at home, school, and play. The
program includes implementation of community-based educational programs for parents,
children, educators, and decision-makers. Opportunities will be explored to implement
interventions that will address several children's health issues and address the needs and interests
of the community (i.e., childhood lead poisoning, asthma, pesticide poisoning).  The program
will utilize resources in the community and government to help empower families and
neighborhoods to take better care of their children's environment. Emphasis will be placed on
building upon the lessons and successes of the Children's PAL Initiative in Baldwin County and
the eleven existing Children Health Champion (CMC) Campaigns. This project will also
incorporate many ongoing agency voluntary initiatives including  the Tools  for Schools,
Integrated Pest Management in Schools,
and other programs (asbestos, PCB's, asthma, radon) which address children's environmental

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health hazards.

These childhood environmental issues have a major impact on the quality of life in the
community. For example, lead poisoning results in decreased intelligence, learning disabilities,
hyperactivity, attention deficit disorders, impaired hearing, decreased growth and muscle
coordination, and antisocial behavior.  The detriment of life associated with these issues has a
major impact on both the short and long term welfare of the community.

Through our efforts to support ongoing activities to address the flooding concerns in the
community, opportunities will be explored to implement open space, water quality and pollution
prevention measures. Potential exists for an opportunity to develop appropriate outreach material
addressing environmental issues such as asthma triggers, asbestos, lead paint and other indoor
hazards from floods.

WORKER PROTECTION STANDARD ISSUES
Oversight and implementation of the Worker Protection Standard (WPS) has been at the
forefront of environmental justice concerns of farm workers since it's inception and is expected
to increase in focus after the release of the final Government Accounting Office report in March,
2000.

Since 1996, Region 4 has been actively soliciting feedback from farm worker advocacy groups in
order to improve EPA's oversight and improve consistency of enforcement across the
southeastern United States. In 1996 and again in 1998, Region 4 held public meetings with
growers and farm workers, in particular the Florida Association of Farmworkers, to address
concerns over perceived lack of enforcement of the regulation by state agencies and failure of the
medical community to properly diagnose pesticide illnesses. In order to address both these
concerns, Region 4 in collaboration with the Office of Pesticide Programs and Florida
Department of Agriculture and Consumer Services, participated in planning for a national
program to educate primary care givers in proper diagnosis of pesticide injury. At a state level,
the Florida Department of Health implemented a Pesticide Incident Monitoring  System to more
adequately address consistent diagnosis and reporting of pesticide illnesses for treatment and
investigation.
In addition, there are a number of studies currently ongoing at t national level to develop
information regarding the impact of pesticides of farm workers and their families.

Region 4 is completing an audit of the 8 state WPS programs in the region in order to evaluate
state and regional implementation of the WPS.  In addition, since 1999, Region 4 has required
States to commit to specific WPS activities above and beyond national guidance
recommendations in response to perceived inconsistencies among the WPS enforcement
programs in the southeast.

REGION 4 CHILD HEALTH CHAMPION COMMUNITY
Prichard, Alabama was selected to be the Region 4 Child Health Champion (CHC) Pilot
Community. Prichard has a population of 35,000, of which 80% are minority and 40% below the
poverty level. The community is surrounded by paper mills and chemical manufacturing plants.
most of which are just outside the city limits, in MobileCounty.. The Toxic Release Inventory
(TRI) emissions in Mobile County is ranked as the 16th highest in the nation. The incidence of
childhood lead poisoning  in Prichard is very high, over 20% of the children under 6 years old that

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were tested had elevated blood lead levels.
A Community Team was formed which developed and implemented an Action Plan focusing on
the reduction of childhood exposure to environmental hazards resulting in lead poisoning and
asthma. The planned interventions consisted of a series of outreach and education activities
aimed at parents and kids over the course of the year.  For example, a CHC Christmas Parade
was held on December, 1999, following outreach activities at the three satellite learning centers.
Sixty-one units featuring, in part, the Prichard Boys & Girls Club, children from the Alabama
Village, Local elected officials, County elected officials, the U.S. Attorney, area students, four
bands, and last but not least, Santa Clause.  Training for parents, asthma and lead screening for
kids, and the establishment of an Information Hot line and Repository all have been
implemented.  The public schools and many of the private schools are beginning to implement
the Tools for Schools program with special emphasis on Integrated Pest Management.

Data is regularly being gathered in some of the elementary schools in Prichard on absences due to
asthma. Data on the incidences of asthma and lead poisoning is also being collected by the local
health center. This data will be compared with baseline data taken in similar communities. The
comparison of the baseline data with those collected during the project may help identify trends
associated with the effectiveness of the interventions.  Reductions of these environmental health
threats is anticipated to improve the urban livability for the children of Prichard. We also
anticipate that other communities can benefit from the project's successes by developing similar
ones tailored to their particular needs.

                      OFFICE OF PERSONNEL MANAGEMENT
                          POLICY AND ANALYSIS BRANCH
ENVIRONMENTAL JUSTICE ACCOMPLISHMENTS
The Planning and Analysis Branch (PAB) is developing foundations for two public health-based
approaches to be implemented within the Agency's environmental compliance framework.  This
includes: 1) the development of an approach that allow the Agency to identify chemicals of
concern based on chronic disease outcomes and; 2) the development of a Toxicological screening
method that identifies chemicals of concern based on the inherent toxicity of released chemicals.

Since the Agency has not previously included chronic disease outcomes in its day to day
operations, a senior level Epidemiologist has been added to PAB.  The public healthoutcomes
that are currently being assessed include Asthma, Cancer, Lung Cancer, and Childhood
Anomalies (birth defects). PAB has developed a Chronic Disease  Assessment Method to be
used as a tool in determining where to focus resources based on potential Public Health threats.
The steps in the method include: 1) Identifying the Health Condition or Disease; 2) Identifying
EPA Addressable and non-Addressable Causes of the Disease; 3) Identifying the Populations of
Interest; 4) Defining the Disease's Occurrence in the Population of Interest; 5) Defining
Associations Methods (e.g.,  identify methods to examine potential links between the disease and
addressable environmental causes); and 6) Use the Disease's Occurrence as Indicators to Foster
Pollution Reduction.

This process-has been applied successfully to Asthma which is clearly associated with all

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minorities partly due to genetics (out of the 11 chromosomal alleles associated with asthma
susceptibility, all but one is unique to minorities). Its prevalence is higher in Blacks (almost 3
times) than in Whites. One primary Asthma exacerbator is ozone. Using a published Atlanta
study as a basis, PAB developed an analysis that identified counties in Georgia where African
American populations might potentially experience a 37% increases in Asthma incidence based
on ozone levels reaching measured concentrations of 110 ppb. The results are currently in peer
review. Programmatic use of the analysis is similarly under review. In a recent Regional project
entitled the "Mississippi Assessment Project", Asthma incidence, Asthma trends, and Asthma
cost analysis data were used for the first time by the Agency as the massive study sought to
define programmatically-driven focus areas in Mississippi. Cancer mortality data from the
state's cancer registry were also brought into this study.

Toxicological screening has always been used by the Agency and thus the PAB approach draws
from the standard risk paradigm of the National Academy of Science. In short, it compares the
concentration and inherent toxicity of chemicals released in a given study area to predict which
chemicals (and their associated sectors) pose the most hazard. The process also can provide
summaries respective to the target organ that might be effected by exposure to the chemical(s) of
concern. Although there are several toxicity-based approaches that can be applied in this
manner, PAB has developed its own method to be used in comparison to and in conjunction with
methods of Region 3 and the Office of Pollution Prevention and Toxic Substances.  The methods
differ based on the toxicity data employed in each.  PAB uses IRIS toxicity data for greatest
defensibility. During the Mississippi Assessment Project, this approach was used to indicate
areas where the most toxic air and water releases were located based on data from the Toxic
Release Inventory (TRI).  In working with the Environmental Accountability Division during the
Mississippi Project, EJ data were co-mapped with a toxicity-screened TRI data and served to
demonstrate areas where facilities with compliance issues overlapped EJ areas. This TRI-based
approach was also applied in Oakridge Tennessee where a Target Organ summary was requested.
In that project however, EJ demographic data were not compared to areas where the most toxic
substances were released.

These methods are currently being presented and refined through presentations in various
national and Regional functions.  Both assessment methods were presented at the national
Community Assessment conference in Washington DC.

                      WASTE MANAGEMENT DIVISION

The Waste Management  Division (WD) has over 300 employees working on administration,
removal, remedial, compliance and enforcement  issues with the Resource Conservation  and
Recovery Act (RCRA), the Comprehensive Environmental Response and Liability Act (CERCLA,
also known as Superfund), as well as Federal Facilities (Department of Energy and Department of
Defense).  The  following are some highlights from recent WD activities as they pertain to
environmental justice (EJ).

AIKEN, SOUTH CAROLINA
  For the Department of Energy's (DOE) Savannah River Site, a "Savannah River Subsistence Fish
Consumption and SRS Environmental Justice Outreach program" is being conducted. This is a
multi-agency collaborative [DOE, EPA, SC DHEC, Georgia DNR, and the  Consortium for Risk

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Evaluation with Stakeholder Participation (CRESP)].   DOE (upon a request from EPA WD and
Region 4 management) are reinitiating efforts to develop an outreach plan addressing subsistence
fishers in the immediate vicinity of the Savannah River Site. Some species of Savannah River fish
exhibit strontium and cesium contamination from SRS at levels posing a potential cancer health risk
(10-3) to subsistence fishers.   A CRESP follow-up field survey  (October  1999) with the joint
EPA/SCDHEC/GA DNR Savannah River Fish Fact Sheet (issued in summer 1998) revealed the
following about fishers on the river between the Augusta Lock and Dam (north of SRS) to the
Highway 301 Bridge (south of SRS):
      99% of the fishers approached along the river agreed to participate in the survey;
      Only 6.5% of the fishers interviewed had seen the Fish Fact Sheet;
      Only 17% of the fishers indicated that who issued the Fish Fact Sheet made a difference in
      the relevance of the message;
•     After reading the Fish Fact Sheet, 92% of the fishers understood that certain groups of people
      should limit fish intake from the Savannah River.

ANNISTON, ALABAMA
    The former Monsanto (now Solutia) facility was formerly one of only two  facilities that
manufactured polychlorinated biphenyls (PCBs). It is situated on the west side of Anniston (AL)
with a high proportion of low-income African Americans and whites (about 8,000 people).  Recent
evidence amassed by a lawyer and the citizen group, Citizens Against Pollution (CAP), show that
the local population exhibits PCBs in blood and fat tissue. Using this health data and environmental
sampling, ATSDR made the following statements at a recent public meeting (over 600 attended) in
its "Health Consultation":  (1) PCBs in soils present a "public  health hazard,"  and (2) PCB
"exposures may still be occurring"  (due  to elevated levels in young children).  EPA Region 4's
RCRA, as well as CERCLA (Superfund) removal and remedial programs are involved in a number
of efforts that include community  involvement activities.  The opening of a local Community
Relations Office has greatly added value to EPA/community dialogue. Other collaborating agencies
are the Alabama Department  of Public Health and the Alabama  Department of Environmental
Management.  EPA's Office of Technical Services is working with ATSDR on conducting an
"Exposure Investigation" with a focus on local children to assess how current exposures may be
occurring. Another active local citizen group is Sweet Valley/Cobbtown Environmental Justice Task
Force (SVCEJTF), which was instrumental in attaining a permanent relocation for about a dozen
homes in the mid-1990's.

ARKWRIGHT COMMUNITY, SPARTANBURG, SOUTH CAROLINA
 For this EJ community, the Agency's Superfund program continues to work closely with multiple
stakeholders at the IMC Fertilizer Plant  (58 acres) and Arkwright Dump (30 acres).  Remedial
program efforts have included environmental assessments on both sites, leading to a remedial
investigation/feasibility study at the Arkwright Dump site which is now ongoing. While assessment
activities are continuing at the IMC  Fertilizer Plant, EPA worked closely with the state to monitor
extensive building de-construction and limited de-contamination activities (about $1M voluntary
action).  The community-based group, Re-Genesis,  has worked closely  with  EPA to ensure
community involvement during the environmental assessment phase. With the cooperation of Re-
Genesis, former workers of the abandoned fertilizer facility furnished a wealth of information on
disposal practices to civil investigators and remedial staff.  A special local "Superfund Process"
training added value to the community knowledge.  EPA has provided guidance on applying for the
EJ grant (awarded), the Brownfields Pilot grant and the Superfund Redevelopment Initiative grant.
Most recent.collaborative activities include a "Responsive Revitalization" forum, held  with 60

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diverse stakeholders (e.g. City, County, landowners, banks, developers, and EPA).
CLEARWATER, FLORIDA
  The city of Clearwater has identified environmental justice as a priority of its Brownfields Pilot
Grant Program ($200,000). An Environmental Justice Plan was developed and has included many
community and stakeholder forums and public meetings to:  1) provide information about the
Clearwater Brownfields Area; 2) receive public input on EJ issues, strategies and efforts; and 3)
listen to the needs of the community. A Planning Action Team was formed of residents and city staff
to shepherd the Environmental Justice Plan. Further, 43 interviews with community members were
conducted to ascertain perceptions and desired outcomes of the Clearwater Brownfields Program.
The International City/County Management Association funded the implementation of this Plan in
coordination with the University of South Florida's Environmental Policy Program and Florida
A&M  University's Environmental  Justice  Center.   The  EJ Strategic Plan for  Brownfields
Redevelopment identified restoration and cleanup of a downtown creek as a priority.  The City, in
response, entered into a partnership with the US Army Corps of Engineers, Florida Department of
Environmental Protection, Southwest Florida Water Management District, and EPA to implement
the Stevenson Creek Ecosystem Restoration Project.

COLUMBIA, MISSISSIPPI
 Under an EPA Brownfields Pilot Grant ($200,000), the City is working with a  local environmental
justice group, Jesus People Against Pollution, to ensure meaningful community involvement.
Recently one Charrette was conducted with federal (e.g. EPA, HUD, EDA) and local partners.  A
second Charrette is being planned with emphasis on community input as it pertains to their vision
for revitalization and relocation. Federal, state and local partners will be participating.

COMMUNITY INVOLVEMENT IN RISK ASSESSMENT VIDEO
    Waste Division staff from our EJ program and Office  of Technical Services worked with
Headquarters OERR  on finalizing a video to accompany the latest guidance on "Community
Involvement in Risk Assessment." EJ staff assembled a local EJ focus group to view the two draft
videos. This focus group provided constructive comments, which were incorporated into the final
films.

FORT VALLEY, GEORGIA
The Woolfolk Chemical Works Superfund site is a former pesticides production facility within
  an EJ area.  Presently, the EPA is conducting  remedial design sampling  activities (e.g. soils
sediments, groundwater and commercial dust wipes). Community involvement activities have been
conducted throughout the remedial process.  An Alliance Group has been formed at the site to
provide a forum for all involved to discuss and address cleanup issues, on behalf of public health,
protection of the environment, and the local economy. The Alliance Group meets monthly at the
Peach County Courthouse  and consists of diverse representatives  [City, County, Utilities
Commission, Woolfolk Citizens Response Group, citizens, businesses, and state  and federal agencies
(EPA, ATSDR, GA DPH, GA EPD)].

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 JACKSONVILLE, FLORIDA
 The Brown's Dump Site and the Jacksonville Ash Site are comprised of former incinerators
and incinerator ash dumps that are located in current residential areas, parks and schools.  The
 incinerator ash is mixed with surface soils and characteristically contains high levels of lead.  EPA
 has  entered into an Administrative Order with the City of Jacksonville to perform Remedial
 Investigations and Feasibility Studies at each Site. Community interest and concern is high in the
 mainly minority neighborhoods, especially regarding the safety of the children attending the schools
 and living in the area. ATSDR (on EPA request) has performed Health Consultations at both of the
 sites and is closely involved with the sites to address public health concerns and recommend EPA
 action.  EPA is also coordinating  with the Duval County Health Department's blood lead level
 testing and residential soil testing programs. As part of the Administrative Order, the City is funding
 $50,000 to each community so they can hire Technical  Advisors to relate and help  disseminate
 technical information.  EPA has included each Technical Advisor as members of the EPA Peer
 Review Teams. Each Site has identified a community group to help reach the affected communities:
 Brown's Dump - Citizens Organized for Environmental Justice, Inc.; Jacksonville Ash Site - North
 Riverside Community  Association.   EPA has conducted 4 weeks  of one-on-one  community
 interviews to  gather and  understand community concerns.  In efforts to have community and
 stakeholder input and support during the Superfund process, EPA has initiated this early involvement
 with the affected communities, and is coordinating closely with the City of Jacksonville, ATSDR
 and the Duval County Health Department.

 LAKELAND, FLORIDA
 The Landia  Superfund Site is in a predominately low-income area, with a high percentage
of retirees.  Failed negotiations and an extensive time lapse (since the site originated with the State
 of Florida in the early 1980's) have caused an entire neighborhood to become outraged and frustrated.
 Once this situation was brought to EPA's attention, the Remedial Branch immediately began efforts
 on potential NPL listing.  In fall, 1999, ERRB conducted an extensive sampling of the residential
 area (including yards and ditches) and the Landia and Florida Favorite Superfund facilities. Results
 eased community concerns and ultimately showed very low levels of pesticides and metals on
 residential property. However, the results from the facility proved there was a problem that mainly
 involved toxaphene, arsenic, and lead, and subsequently,  needed to be addressed as a time-critical
 action.  In addition, recent air data shows concern from long-term affects. While PRP negotiations
 continue, Florida Department of Health will be proposing medical monitoring for the community.
 EPA's Emergency Response and Remedial programs, Florida Department of Health,  and Florida
 Department of Environmental Protection have improved community  involvement activities.
 Beneficial outreach efforts have included availability sessions involving smaller groups. The main
 public voice of concern has been the length of time it has  taken to determine that there should be a
 time-critical action taken at this site. Community Involvement activities at the site include: 1) an
 open house; 2) four community briefings that included a  question and answer period; 3) in-depth
 community interviews; 4) community relations plan; and 5) numerous fact sheets and other literature
 placed in an information repository.

 LOUISVILLE, MISSISSIPPI
 The American Creosote Removal Action is within a predominately low-income, minority
 community. There was a removal  action at the site in the 1980s.  A hazard ranking package was
 prepared to propose the site to the NPL. However, the site did not rank. In 1999, the Emergency
 Response and Removal Branch (ERRB) began a removal action.  As a result of intensive
 community  relations and valuable  input from the community, the site was easily ranked. The

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primary concern at the site is creosote. Children from the nearby housing project had played in a
creosote contaminated pond on the site.  The ponds on the site had also been used in the past by a
church for baptism. Citizens have voiced concerns because creosote is apparent in the creek that
runs next to the site. The creek can no longer be used by the community for fishing or
swimming. A door-to-door campaign was launched to"inform the community because the
majority of the residents near the site do not receive the newspaper.  The residents are pleased
that a superfund removal action is taking place to clean up the site and that there will be a
remedial action to clean up the groundwater at the site.

MEMPHIS, TENNESSEE
  DOD Defense Depot:  The Defense Depot Memphis Tennessee (DDMT) Federal  Facilities Site,
was placed on the NPL by EPA based on the Depot's Hazard Ranking System score. The site is
located in a predominately low-income community within Memphis.  The primary issues of concern
have been groundwater contamination and health impacts from the Depot's past and present
hazardous substances handling and disposal practices.  Other concerns involve the establishment of
more open communications and easier access to information about the process and the future reuse
of the Depot. The Depot, EPA. other agencies, and the community participates on a Restoration
Advisory Board monthly to address community's concerns and ensure effective public participation.
 Currently, the Depot is conducting a public comment period on the Chemical Warfare Material
(CWM) Removal Action Plan.  The Depot will have a informational session in March 2000 to
discuss the CWM removal project and the engineering controls that will be used to protect the
community.
 Perma-Fix: During an August 1999 public hearing, the Agencies received significant opposition
to renewing a  RCRA/HSWA (drum storage) Permit at Perma-Fix of Memphis. The locality in
Shelby County is considered an EJ area. All comments revolved around shutting the facility down
and having them relocate. Representatives from the Mayors office and Congressman Ford requested
permit denial.  TDEC and Perma-Fix have negotiated a compromise which drastically reduces the
hazardous waste operations at the site and demands operational closure in 5 years. TDEC's Director
is setting up another public [informational] meeting in Spring 2000, to allow the State and EPA
Region 4 to explain RCRA/HSWA permit decisions at Perma-Fix of Memphis before they are
finalized.  WD EJ staff have been requested to become involved.

NATIONAL CITIZENS NETWORK ON FEDERAL FACILITY HEALTH ISSUES
Waste Division EJ staff have been engaged (1998-present) with a federal agency coalition (EPA,
DOE, ATSDR,  CDC,  NIOSH) working closely with the People of Color/Disenfranchised
Environmental Health Network. The primary issues are related to improved health interventions for
communities and workers near Department of Energy (DOE) and Department of Defense (DOD)
facilities.  EJ staff organized a national meeting  in Arlington, with over 16 impacted EJ groups
attending (12/99).

PEDIATRIC ENVIRONMENTAL  HEALTH SPECIALITY UNIT (PEHSU)
A PEHSU has been established in Region 4 through a partnership between EPA and ATSDR at
Emory University.  This PEHSU links the  Department of Pediatrics  in the School of Medicine,
the Department of Environmental and Occupational Health in the School of Public Health, and
the associated clinical facilities. The goals of the Emory PEHSU are to reduce environmental
health threats to children, improve access to expertise  in pediatric environmental medicine.
improve the ability to evaluate the effects of toxic substances on children's health, and to
strengthen public health prevention capability by creating new linkages and improving

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 coordination services. Emory's PEHSU will implement five specific objectives to: 1) develop
 educational materials on children's environmental health; 2) carry out health education activities
 within Emory's medical center and regionally; 3) provide clinical consultation to agencies and
 health care providers in our region (e.g. toll-free number, documentation and outcome analysis of
 calls); 4) create an infrastructure for delivering pediatric environmental health care within
 Emory's medical center; and 5) provide clinical pediatric environmental health services.  The
 Unit will serve as a resource for pediatricians, other health care providers, parents, teachers, the
 public, and EPA and ATSDR staff nationwide.

 PENSACOLA, FLORIDA
 The Escambia Treating Company Superfund Site is part of a National Relocation Pilot.  To date,
 EPA has relocated over 90% of single family housing residents. EPA has reimbursed
 homeowners for the fair market value of their homes plus a differential amount to help them buy
 a new home of their choice. Additionally, EPA has reimbursed residents for the actual costs of
 their move.  As for the Escambia Arms Apartments (a HUD subsidized apartment complex with
 200 two and three bedroom units), EPA has provided relocation assistance to approximately  14%
 of the residents, as negotiations continue with the owner of the complex.  EPA's relocation
 assistance has taken the form of down-payment assistance for several residents who elected to
 move away from the complex on their own, and were found to be eligible for relocation
 assistance under provisions of the Uniform Relocation Act. To ensure that whatever remedial
 options proposed are consistent with the beneficial future redevelopment of the area
 (revitalization and reuse plans are currently being developed by the Escambia County
 Community Redevelopment Agency through an EPA grant), EPA postponed issuing a proposed
 plan for the remedial action for Operable Unit 1 (former facility, the residential neighborhood).

 PRICHARD, ALABAMA
   This EJ community was selected for a Region 4 "Child Health Champion Campaign Pilot" by
 all our Divisions. This community is surrounded by paper mills and chemical manufacturing
 plants, most of which are just outside the city limits, in Mobile County. The community formed
 a team and received a Cooperative Agreement with a financial assistance award of $135,000.
 These funds are to reduce the exposure of children to environmental hazards that result in lead
 poisoning and asthma. An Action Plan was designed and elements are being implemented.
 Partnerships were developed with all elementary schools to gather absenteeism statistics for
 research. An outreach campaign provided health and educational materials to the residents.
 Blood tests conducted confirmed a very high incidence of elevated lead levels in children under
 six years of age. EPA also performed short term air sampling of the volatile organic compounds
 (VOCs) in the Prichard area and found many compounds exceeding conservative health-based
 screening benchmarks.

SCARBORO COMMUNITY, OAK RIDGE, TENNESSEE
 This community is situated near the Y-12 nuclear weapons plant and is the closest African-
 American residential community to any DOE facility in the country.  In terms of historical
 significance, the community was created by the U.S. Army as an African-American
 neighborhood during the Manhattan Project era.  The Federal Facilities program, along with EJ
 staff, continue to provide EJ support to the community in the following capacities: 1) provided
 assistance on grant-writing to fund the local EJ group's (SCORE) activities; 2) engaged in public
 meetings to ensure broad outreach: 3) agreed to oversight sampling of previous DOE
 investigations at community request; 4) participated in public meetings whereby EPA presented

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                                          -19-

 EPA's draft Sampling Plan of Scarboro to the local SSAB (advisory board to DOE) and the
 Scarboro Community; and 5) participated in dialogues with local public interest groups to
 discuss various issues that impact neighboring Oak Ridge communities. The primary issues
 voiced recently are: 1) requests for an expanded scope of sampling study (including radioactive
 elements) for other communities near Y-12; 2) evaluation of contamination and likelihood of
 adverse health effects; and 3) information on environmental hazards in terms that are easily
 understood.
 UNIONTOWN, ALABAMA
 The Uniontown Redevelopment Cooperation [the task force working on the Brownfields Pilot
 Grant Project ($200,000)] has expanded from five to eleven members to stimulate more
 community involvement in this small Alabama town.  In addition to this, the City has partnered
 with Auburn University through its Vision 20/20 Program to create the following focus groups:
 1) Administration and Organization of City Government; 2) Quality of Life; 3) Economic
 Development and Infrastructure; and 4) Workforce and Education.

 Editor: Brian Holtzclaw
 Contributors:  Randa Chichakli; Katrina Jones; Rose Jackson; Ken Lucas; Julie Corkran; Sherryl
 Carbonaro; David Derokey; Charles King, Jr.; Dee Rodgers-Smith; Barbara Dick; Tiki Whitfield;
 Nicole Bates; Camilla Warren; Cheryl Walker Smith; Mike Norman
                                  WATER DIVISION
 REGION 4 ENFORCEMENT PROGRAM
The Region 4 Safe Drinking Water Enforcement program continues to make significant effort in
low income and/or minority communities.  Under Safe Drinking Water Act (SDWA) 1431,42
U.S.C. Section 300(i), EPA Administrator is granted authority to take appropriate enforcement
action if he or she receives information that 1.) a contaminant is present or likely to enter a Public
Water Supply (PWS) or Underground Source of Drinking Water (USDW),  2.) the contaminant may
present an "imminent and substantial endanger" to human health, and 3.) the appropriate State and
local authorities have not acted to protect public health. Region 4 Enforcement program have
conducted SDWA  1431 inspections in the following North Carolina counties due to the impact of
concentrated animal feeding operations (CAFOs): Robeson County; Duplin County; Sampson
County; and Johnston County.

A recent North Carolina study revealed a large number of private wells being impacted by nearby
CAFOs. This study initiated EPA Region 4's involvement in this area. The Enforcement program is
continuing its study and investigation of this issue.

Source Water Assessment and Protection Efforts
Region 4's Source Water Assessment and Protection (SWAP) Program provided grants to the
following dbadvantaged communities to support their efforts to protect their drinking water sources.

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                                        -20-

Hurtsboro. AL
The Town of Hurtsboro, Alabama is a small, disadvantaged community in Alabama.  EPA
Region 4 awarded a grant to the Town in FY 1999 to close an abandoned drinking water well
located within their wellhead protection area. This Town also received an EPA Wellhead
Protection grant in 1995 which established protection measures for their public ground water
supply system.

Cherokee and Choctaw Tribes
Each tribe has received a Source Water Protection grant from EPA Region 4 to develop and
implement a SWAP program.  Although EPA and the Tribes are not required to develop or
implement SWAPs, both believe in the public health and environmental benefits of the
program.

Region 4's Tribal Underground  Injection Control (UIC) Program
The Water Management Division, Ground Water and Drinking Water Branch,  Ground Water
and UIC Section began direct implementation of the Tribal UIC program during FY 1999-2000.
Under the Safe Drinking Water Act (SDWA) of 1996, EPA was charged with establishing a
program whereby  the number and  type of UIC wells are to be identified, inventoried, and
monitored.  The goal of the UIC program is to protect the health of persons when a contaminant
which is present in or may enter a  public water system (PWS) or underground source of
drinking water (USDW) may present an imminent and substantial endangerment to the health
of persons.

There is a concern because more than 89 percent of U.S. public water supply systems draw
some  or all of their drinking water from sources found underground in  rock, sand, and gravel.
Most ground water used for drinking is located near the earth's surface and is easily
contaminated. Of major concern is potential contamination of USDW  by any of the hundreds
of thousands of injection wells nationwide. Injection wells may threaten ground water
resources if the injection fluids do not stay within the well and the intended injection zone.

The Regional Tribal program consists of the following six Tribes:
      Catawba Indian Nation, located in Rock Hill, SC;
      Eastern Band of Cherokee  Indians, located in Cherokee NC;
      Miccosukee Tribe of Indians of Florida, located in Dade County;
      Mississippi Band of Choctaw Indians, located in Philadelphia, MS and  in TN;
      Poarch Band of Creek Indians, located in Atmore, AL; and the
      Seminole Tribe of Florida, located in Southern Florida.

The six reservations cover over 259,692 acres of land in Region 4 and represent a population of
-12,000 individuals.

The UIC program  teamed with members from EPA's Drinking Water Section,  Source Water
Protection, Ground Water Protection program, and other pertinent federal agencies to perform
the initial inventorying and cataloging of the wells located on the six reservations. Under a
strategy developed b;.  the workgroup, two of the six reservations have had an initial inventory
with the remaining four to be inventoried by the end of this fiscal year. Thus far, over 70 wells

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                                        -21-

have been identified and have been provided technical and compliance assistance.

The workgroup developed an effective approach to allocating funds to the Tribes for the
implementation of their reservation specific programs for ensuring the requirements of the
SDWA, in particular performing their SWAP assessments and their Class V implementation
efforts.  At this time, the Branch's workgroup is ahead of its Government Performance Results
Act (GPRA) commitments for the Tribes for FY 2000 and is performing impending
commitments for FY 2001.
EPA Region 4 Class V Inventory Initiative
The Environmental Protection Agency (EPA) Region 4 is actively inventorying Class V
injection wells in Kentucky and Tennessee. The other six Region 4 states (Alabama, Florida,
Georgia, Mississippi, North Carolina, and South Carolina) have primacy for impiementing the
program.

Class V shallow injection wells are used to drain or dispose of fluids underground and include
drain fields, improved sinkholes, and large capacity septic systems. Cesspools, industrial wells,
and automotive fluid disposal wells are of particular concern to EPA. These wells are being
inventoried, and in rare cases, permitted to protect ground water resources from unsafe waste
fluid disposal.
A majority of inventoried Class V wells are large capacity septic tank systems that serve more
than 20 people a day. These systems are commonly found at churches, schools, markets, and
other similar locations in unsewered areas. Waste fluids from bathrooms and kitchen facilities
are the most common fluids disposed from these facilities.

EPA is conducting the inventory in Tennessee. However in Kentucky, local officials from the
Department for Public Health are educating Class V well owners on State and federal ground
water programs and are inventorying the Class V wells.

Environmental Justice Issues Associated with the Proposed Daniel Island
Marine Cargo Terminal-Charleston, South Carolina
The South Carolina State Ports Authority has proposed to construct a marine cargo terminal on
Daniel Island which is located at the confluence of the Cooper and Wando rivers in Charleston
Harbor. A portion of Daniel Island has been utilized as a confined disposal facility for dredged
material, but has remained undeveloped until recently. The current proposal would result in the
elimination of 67 acres of intertidal wetlands, 70 acres of estuarine waters, and 20 acres of
freshwater wetlands.  In addition to the direct wetland impacts, there are important indirect
environmental impacts. These include increased storm water runoff, changes in harbor

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                                          -22-

 hydrology due to dredging, environmental justice/societal issues associated with displacement
 of current residents along the proposed transportation corridor, increased dredging and disposal
 of dredged material, increased ship traffic and conflicts with recreational boaters, habitat
 fragmentation, and increased bilge water discharge.

 With respect to environmental justice, a number of involved minority community members
 have voiced concerns regarding the impacts of the applicant's proposed access corridors. The
 proposed access corridors to the new port facilities appear to be inferior to other seemingly
 feasible alignments. Selection of the proposed corridor through these communities would
 result in either resident relocation or dissection of the community. This issue, in conjunction
 with the other potential impacts of the proposed  project, raise significant concerns about the
 overall viability of the proposed project.  Issues pertaining to state and federal laws and
 regulations as well as federal executive orders will be addressed in the final EIS to be
 completed after consideration of comments on the draft EIS. The Corps of Engineers,
 Charleston District is the federal agency responsible for the Daniel Island Environmental
 Impact Statement.

 The draft EIS and the Clean Water Act Section 404 (wetlands) permit application public notice
  were both released in September 1999 by the  Charleston District Corps of Engineers.  The
 initial comment period was to expire in January 2000, but overwhelming concerns voiced by
 both citizens and politicians resulted in the Charleston District extending the comment period
 until April 14, 2000. EPA has provided comments on the draft EIS and comments on the
 Section 404 permit application will be submitted prior to the April deadline.

MISSISSIPPI DELTA
EPA has been involved in the development of a report and conference that will highlight the
Region of Mississippi Delta, including the states of Missouri, Arkansas, Kentucky, Tennessee.
Mississippi, and Louisiana. This multi-federal agency effort is a continuation of work started a
decade ago by the Lower Mississippi Delta Development commission, chaired by then governor,
Bill Clinton.

The overriding goals of this Delta Initiative are to  revitalize the regional economy, improve the
quality of life, protect and enhance the region's  natural resources, environment and tourism, and
to develop and implement regional planning. EPA's role in this work has been to identify the
major natural resource and environment issues facing the Delta, including wetlands protection
       and
restoration, air and water quality protection, wildlife and natural resource conservation,
and water and sewer infrastructure needs.

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                                          -23-

A final report is development for this imitative and will be titled "Delta Vision, delta Voices:
The Mississippi Delta Beyond 200." The report will be released at conference being hosted
by Secretary Rodney Slater, of the Department of Transportation, to be held in Washington, D.C.
on May 10-11, 2000. President Bill Clinton and Vice President Al gore will participate in this
conference as will community leaders from throughout the Delta Region.  For more information
on this Delta Initiative, please contact Jennifer Derby, U.S. Environmental Protection Agency,
404-562-9401.
                                                         U.S. EPA Headquarters Library
                                                                Mail code 3201
                                                         1200 Pennsylvania Avenue NW
                                                            Washington  DC 20460

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