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RCRA Community Engagement Initiative (CEI) Case Study
The following case study demonstrates beneficial CE principles and techniques. A common theme between each of the
case studies is that EPA and the facilities worked together to coordinate a cohesive plan to keep the community informed
and provide a forum for its participation.
Facility Name and Location: Walter Coke, Inc. (fka Sloss Industries), North Birmingham, AL
Background
Walter Coke, Inc. is a 90-year old facility that manufactures coke from raw coal for the blast furnace and steel industry.
Located in North Birmingham Alabama, the facility is adjacent to three environmental justice (EJ) communities: the
Harriman Park, Collegeville, and Fairmont neighborhoods.
Since 1989, the facility has been operating
under an EPA-issued enforcement order
[Administrative Order on Consent, 3008(h)]
for RCRA Corrective Action. In 2009, EPA
requested that the facility investigate
neighboring properties for contaminants of
concern in surface soils. Over 70 locations
were sampled by the facility in 2009.
Results showed levels above EPA short-term
screening levels for arsenic and benzo(a)
pyrene at nearby schools and residences
above cleanup levels. Several CE activities
were initiated in conjunction with the
residential soil sampling and cleanup activities.
Fairmont
Harriman Park
Collegeville
Leoend
¦ Whiter Coke Facility Boundary
Neighborhood
3 Coilegeville
Himmin Park
Fairmont
2.000
a ¦
FIGURE 1-1
Walter Coke Facility and
Surrounding Neighborhoods
Residential Remedial Action
\Afelter Coke I ne
Birmingham, Alabama
•
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RCRA Community Engagement Initiative (CEI) Case Study

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Below is the timeline of CE efforts at Walter Coke and descriptions of the CE activities. Detailed descriptions of the CE
Tools are presented in the CE Tools section of this Guidebook.
Trigger Event	CETool	CE Activity Description
2009
EPA RCRA conducted outside-the-
fenceline investigations in 2005 and
2009 to follow the nature and extent of
contamination from Walter Coke
Public Meetings
EPA RCRA corrective action technical staff did outreach during a
Walter Coke sponsored "community barbeque" to announce the
upcoming 2009 community soil sampling event for the 3 adjacent
neighborhoods and promote signing of+70 property access
agreements.
Local technical meeting to discuss 2009
community-based sampling results.
Discussed adverse soil findings for local
schools and residences.
Community Profile
Partnering
•	Demographic EJ maps and a situational analysis were created
to better understand the community. EJ GIS maps were
'ground-truthed.'
•	Community reconnaissance was conducted of the school and
residences found with high PAH levels.
•	EPA provided a CE presentation at an EPA technical meeting held
with the Agency for Toxic Substances and Disease Registry (ATSDR),
the Alabama Department of Environmental Management (ADEM),
and Walter Coke officials.
Technical findings released to School
District
Fact Sheet
Letters *
•	Communications with Birmingham School District Superintendent
and officials began re: adverse soil findings.
•	Conducted verbal and written notifications of 2009 soil sampling
findings to School District and composed a parent and faculty Fact
Sheet on findings.
Technical findings; sharing information
with residents
Letters*
Canvassing*
FAQs*
Fact Sheets
Feedback
Public Meetings
Information/ Data
Availability
Sessions *
GIS Maps*
•	EPA RCRA staff coordinated and released 2009 Community Soil
Sampling Results Letters to +70 property owners/renters.
•	Canvassed door-to-door and sent invitations for Information
Sessions
•	Held Community Leader Meeting and listening session for
Collegeville, Fairmont, Harriman Park Neighborhoods.
•	Included Walter Coke participation.
2011
Pollution community complaints
from residents, and facility
recommendations to take a leadership
role in CE
Consultations *
•	Consultations with Walter Coke Communication Director and public
relations consultant to encourage direct communications with the
impacted communities especially on air pollution issues (active
Clean Air Act permit at facility).
•	Challenged Walter Coke to start a community dialogue process, and
provided the EPA Community Advisory Group guidance. As a result,
the facility launched a monthly Community Advisory Panel (CAP)
meeting process with assistance of a local PR consultant.
* = CE Tool not covered in current CE Toolkit
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Trigger Event
CE Tool
CE Activity Description
Community complaints about lack
of technical assistance & unsecured
contaminated areass
Grants *
Consultations *
•	EPA coordinated Technical Assistance Services for Communities
(TASC) involvement.
•	CE staff created a proposal, technical directive and TASC guidance.
•	CE and technical staff coordinated communications with City of
Birmingham (Planning, Engineering and Permits Dept.) to secure
the abandoned Carver High School Property fencing and add
warning postings to reflect the property was contaminated.
Community pollution complaints
continue
Feedback
Public Meetings
•	Meetings and calls with Community Leaders and active citizenry to
generate internal environmental justice concerns summaries.
•	Air concerns were the majority of community complaints.
•	Shared summaries with internal EPA Air and OEJ programs.
Need to share overall risk
management strategy
Public Meetings
Partnering
• Special CE, technical and EPA Management meetings held with
Community Leaders to outline RCRA next steps of soil cleanup/
replacement at locations above cleanup levels.
Growing need for internal EPA
programs to collaborate; requested
Air program to perform air model on
Walter Coke sources (using AERMOD)
Partnering
Consultation *
•	RCRA CE advocated a One-EPA approach between RCRA and Air
Division, sharing serious citizen-based EJ air complaints/concerns
and coordinated an internal meeting.
•	Staff encouraged Air Division to take a stronger position on Walter
Coke issues due to air pollution deposition-to- soils and health
exposure concerns.
Facility-sponsored public meetings
Public Meetings
Feedback
•	RCRA CE attendance at various monthly Walter Coke sponsored
Community Advisory Panel (CAP) meetings.
•	Community offered critical feedback to the facility, EPA, and other
regulatory programs.
Risk Management: Two schools
received soil cleanup and replacement
Flyers/Letters *
•	Composed Parent flyers re: risk management interventions at both
Riggins and Hudson K-8 Schools.
•	Collaborative effort of RCRA staff to facilitate outreach with the
North Birmingham School District, ATSDR and Southeast Pediatric
Environmental Health Specialty Unit (SE PEHSU).
Transparency in EPA actions
Information
Repository
•	Launch of EPA RCRA CE outreach website for Walter Coke host
communitv at FOIA Reading Room. tDs://www.eDa.gov/foia/
outreach-information-erD-comDliant-coke-llc
•	Maintained a limited library information repository at N.
Birmingham Library since 2007.
Broadcast of Soil Sampling results
Public Meetings
Feedback
• Two RCRA staff (CE and technical) coordinated two EPA/ATSDR
Community Forums, held to broadcast community soil sampling
results, about 30% of properties and % schools were above cleanup
levels. About 300 attended; large news media coverage. Citizens
expressed concerns. CE Tools included updated maps, Fact Sheets,
FAQs. Mayor's office briefing also held.
* = CE Tool not covered in current CE Toolkit
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RCRA Public Participation Manual - Tools
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Trigger Event
CE Tool
CE Activity Description
Community-capacity building
Technical
Assistance*
Workshops
Feedback
• CE staff helped direct work under Technical Assistance Services for
Communities contractor (the "TASC" contract is with EPA HQ):
a.	Technical Assistance Needs Assessment (TANA) completed by
interviewing ~5 residents (May 2011)
b.	Held Environmental Basics and Community Empowerment
Workshop (July 2011) and Community Workbook (about 100
attended on Saturday) conducted by TASC and RCRA staff.
Heard current citizen concerns.
Gathering Citizen Concerns
Feedback
Listening Session *
• EJ Listening Multi-Agency Session (US Attorney, DOJ, EPA senior
management) held in B'ham with Regional Administrator in
attendance. CE efforts were about assisting with invitations for N.
B'ham representatives.
Risk Management: Residential
Property cleanup
Canvassing*
• CE and technical staff provided support with the Site Access
Agreement process for the 23 targeted residential properties
for soil cleanup to be conducted by Walter Coke. Sixteen homes
agreed to have cleanup and soil replacement performed.
Growing need to address community
capacity
Partnering
Technical
Assistance *
• Awarded $20,000 of special funding from Headquarters for
technical assistance. The approved collaborative project is called,
"Assessing and Addressing Environmental Justice ("EJ") and
Children's Health ("CH") Living near Industry in North Birmingham,
AL." CE staff also helped compose (with other programs) a
successful HQ proposal forTRI and pollution prevention special
project funding to assist this EJ impacted community.
2012
Coordinated approach recognized by
EPA Senior Management
Partnering
•	RCRA, Air, Superfund, Water, and Office of Environmental
Accountability (OEA) Division discussions began as to how to take
a stronger comprehensive "One-EPA" approach to our EPA mission
there.
•	Superfund announced their involvement in the "outside-the-
fenceline" contamination issues in the community, with Walter
Coke as 'ground zero;' Superfund Removal Program Administrative
Order on Consent (AOC) negotiations were initiated.
The RCRA Corrective Action Section
continues to negotiate a new "Round
#2" AOC talks with Walter Coke to
address mostly "inside-the-fenceline"
cleanup issues
Public
Participation Plans
• RCRA agreed for need for the AOC to contain a condition that the
facility is to construct a meaningful Community Involvement Plan
for EPA approval.
One-EPA effort moving forward
Communications
Strategy
• The North Birmingham Environmental Collaboration Project
developed an internal Outreach/Communications Strategy.
* = CE Tool not covered in current CE Toolkit
RCRA Public Participation Manual - Tools
RCRA Community Engagement Initiative (CEI) Case Study

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