COMMUNITY INVOLVEMENT PLAN

LCP Chemicals Superfund Site
Brunswick, Glynn County, Georgia

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U.S. Environmental Protection Agency
Region 4

May 2015

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Community Involvement Plan

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Project Title:
Document Title:

Prepared by:
Date Prepared:
Principal author:
EPA RPM:

Title Page

LCP Chemical Superfund Site

Community Involvement Plan for LCP Chemicals Site
Brunswick, Glynn County, Georgia

U. S. Environmental Protection Agency

May 2015

Angela Miller, Community Involvement Coordinator
Galo Jackson, Remedial Project Manager

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* ACTIVE PUBLIC INVOLVEMENT IS CRUCIAL TO THE SUCCESS OF ANY PUBLIC PROJECT*

The United States Environmental Protection Agency's (U.S. EPA) Superfund Community
Involvement Program is committed to promoting communication between citizens and the
agency. EPA's community involvement activities at the LCP Chemicals Site are to:

¦	Inform the public of the nature of the environmental issues associated with the site.

¦	Involve the public in the decision-making process that will affect them.

¦	Involve the public in the responses under consideration to remedy these issues.

¦	Inform the public of the progress being made to implement the remedy.

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Table of Contents

Section	Page

1.0	Overview of the Community Involvement Plan	5

2.0	Community Background	7

2.1	Community Profile	7

2.2	History of Community Involvement	9

2.3	Community Concerns	9

2.4	Response to Community Concerns	10

2.5	Summary of Communication Needs	11

3.0	Community Involvement Goals and Activities	11

4.0	What is Superfund?	16

5.0	Site Description	17

5.1	Site Background	20

5.2	Site Investigations and Cleanup Activities	20

Appendices:

A	EPA Regional Contacts	22

B	Local Officials	23

C	Federal and State Elected Officials	24

D	Affiliated Agency Contacts	25

E	Environmental and Active Citizens Groups	26

F	Media Contacts	27

G	Meeting Locations	28

H	Information repository Location & Administrative Record File	29

I	Seven Cardinal Rules for Risk Communication	30

J	List of Abbreviations	31

K	Glossary	32

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Section 1.0

Overview of the Community Involvement Plan

One of the steps required under the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) or simply, Superfund, for sites listed on the National Priorities List
(NPL) is to prepare a Community Involvement Plan (CIP).

EPA developed this Community Involvement Plan to facilitate two-way communication between
the community surrounding the LCP Chemicals Superfund Site and EPA and to encourage
community involvement in site activities. EPA will utilize the community involvement activities
outlined in this plan to ensure that residents are continuously informed and provided
opportunities to be involved.

This Community Involvement Plan provides a background of the community (Section 2.0),
presents EPA's community involvement program (Section 3.0), outlines the Superfund program
(Section 4.0), addresses LCP Chemicals relationship to the community and EPA (Section 5.0)
and provides a listing of resources available (Appendices). EPA drew upon several information
sources to develop this plan, including community interviews, internet research and site files.
EPA's Regional Office will oversee the implementation of the community involvement activities
outlined in this Plan.

The CIP will be revised as community concern warrants or at minimum, every three years until
the Site is removed from the NPL. The revision process includes conducting additional
community interviews, updating mailing lists, updating the files at the designated at the
information repository and updating the contacts and resources provided in the appendices of the
CIP as necessary.

If you are interested in submitting comments or have questions or suggestions concerning the
CIP, please contact:

Angela Miller
Community Involvement Coordinator
(404) 562-8561 or 1 (877) 718-3752
miller.angela@epa.gov

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Section 2.0
Community Background

This section describes the composition of Brunswick, Glynn County, Georgia, and the history of
community involvement with the Site.

2.1 Community Profile

Glynn County, on the Atlantic coast south of the Altamaha River, is one of Georgia's
original eight counties. The county was created February 5, 1777 from 423 square miles
of land formerly held by Creek Indians. Glynn County is named for John Glynn, a
member of the British Parliament and a friend of the colonies who once held the position
of Sergeant of London.

Brunswick is the County's only municipality and serves as the county seat. The City of
Brunswick was named in honor of England's King George 111, who was of the House of
Brunswick.

The 2010 Census reported Glynn County's population at 79,626. The 2000 Census
reported 67,568. Demographics

Glynn County's coastal location is a recreational haven for residents and visitors alike.
The county features award-winning golf courses, some of the besting fishing on the East
Coast, as well as beautiful beaches on the four coastal islands. The five islands of Glynn
County, Jekyll Island. St. Simons Island. Sea Island. Little St. Simons Island, and Btythe
Island, make up the Golden Isles, so named because of their vast marshes that turn a
beautiful golden color in the fall. The islands' beaches, resorts, shops, and historic sites
annually attract visitors from around the world. President George W. Bush hosted the G8
Summit in 2004 on Sea Island.

Glynn County is home to many historical sites such as the Hofwvl-Broadfield Plantation.
This state-run park is a classic example of a working rice plantation from around 1807.

Fort Frederica, now Fort Frederica National Monument, was the military headquarters of
the Province of Georgia during the early colonial period and served as a buffer against the
Spanish incursion from Florida. Nearby is the site of the Battle of Gully Hole Creek and
Battle of Bloody Marsh, where on July 7, 1742, the British ambushed Spanish troops
marching single file through the marsh and routed them from the island, which marked
the end of the Spanish efforts to invade Georgia during the War of Jenkins' Ear.

Glynn County's historic Altamaha Canal was constructed as a transportation canal
between the harbor of Brunswick and the Altamaha River 12 miles to the north.
Construction began in 1836.

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In 1804, a St. Simons Island plantation owner dedicated 4 acres to the federal government
for the construction of a lighthouse. The first keeper, James Gould, was appointed by
President Madison in 1810. The lighthouse was destroyed during the Civil War so federal
forces could not use it as a navigational aid. Then, in 1872, the St. Simons Lighthouse
was constructed. The 104-foot tower has a 129-step cast spiral staircase and was designed
by one of Georgia's most noted architects, Charles Cluskey.

In 1915, the first president of AT&T, Theodore Vail, the founder of Standard Oil
Company, William Rockefeller, and financier J. P. Morgan, Jr participated in the very
first transcontinental telephone call at the Jekyll Island Club Hotel. It consisted of a four-
way call between Jekyll Island, Washington D.C., New York City, and San Francisco.

Glynn County's Port of Brunswick forms a vital part of the county" s economy. It is
recognized as one of the most productive ports on the East Coast and is the sixth-busiest
automobile port in the United States. It is the primary export facility for two of the three
United States traditional automotive manufacturers: Ford and General Motors.

The Federal Law Enforcement Training Center (FLETC), a large agency of the United
States Department of Homeland Security, is headquartered in Glynco. in Glynn County.
FLETC sits on 1,600 acres in Glynn County and serves as an interagency law
enforcement training organization for 90 US government federal law enforcement
agencies.

Glynn County is the center of Georgia's shrimping industry. It was once called The
Shrimp Capital of the World, but in recent times, production has been far below average.
The area is also the center of Georgia's crab and oyster industries.

The Sidney Lanier Bridge is a cable-stayed bridge that spans the Brunswick River in
Glynn County and is the longest spanning bridge in Georgia and is 480 feet tall. It is the
82nd largest cable-stayed bridge in the world. Named for poet Sidney Lanier, the bridge
hosts an annual "Bridge Run" sponsored by the local hospital.

In 1878, poet Sidney Lanier wrote "The Marshes of Glynn", which describes the vast,
open salt marshes of Glynn County. Several other famous individuals are from Glynn
County including Bill Diehl, the author of Sharky's Machine and Primal Fear, tobacco
magnate R. J. Reynolds, noted architect William Portman, and PGA golfer Davis Love,
IE. The Board of County Commissioners is composed of seven members elected by the
voters for staggered four-year terms. Five members represent specific districts and two
members serve at -large. The Chairman is chosen by the Board on a yearly basis. The
Board, as the county's governing authority, is responsible for establishing policy for
county operations, enacting ordinances and resolutions to promote the county's health,
safety, and welfare, and approving the annual budget which funds the operations of the

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constitutional officers as well as the departments under the Board's jurisdiction. The
County Commission meetings are held the first and third Thursday of each month at 6:00
p.m. in the Historic Courthouse, 701 G Street in Brunswick. Monthly work sessions are
held the third Tuesday of each month at 3:00 p.m. in the W. Harold Pate Building, 1725
Reynolds Street on the 2nd floor. Agendas for all meetings are posted in the calendar
section of this website. The Board appoints the County Manager, County Attorney, and
Chief of Police. The County Manager hires the department directors for the departments
under the Board's jurisdiction. Those departments include Administration, Community
Development, Public Works, Recreation & Parks Department, Fire and Emergency
Medical Services, Information Technology, Human Resources, and Finance.

2.2 History of Community Involvement

EPA Region 4 has established community involvement activities since the discovery of the Site,
which included the most recent public meetings and availability sessions:

¦	On December 4, 2014, EPA hosted a public meeting to approximately 130 citizens, local
stakeholders and city officials. The meeting's purpose was to provide information on the
history of the Site, removal actions and sampling that have previously been conducted at
the Site, presented detailed information on EPA's preferred alternative to clean up the
Site and explained the procedures for submitting written comments pertinent to the
preferred remedy, (see attached transcript of the public meeting)

¦	On February 26, 2015, EPA hosted an availability session to address questions and
concerns that were voiced at the public meeting. Representatives from EPA, GA EPD,
GA Public Health, Agency for Toxic Substance and Disease Registry (ATSDR) were
available to speak one-on-one with residents. There were approximately 80 people that
attended the session.

2.3 Key Community Concerns

¦	Concerns about PCB exposure

¦	Citizens would like blood testing

¦	Concerns about perceived uncontrolled releases and widespread health effects

¦	Concerns over protectiveness of remedy, related to BHHRA fish consumption
assumptions

¦	Concerns about cap stability and thin layer cover

¦	Concerns about the extent of contamination and how it lines up with the remedy

¦	Concerns and belief that little remediation has occurred and the time that it will
take to complete

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¦	Fish/shellfish consumption and when advisories will be removed

¦	Sapelo Island

¦	Institutional controls and fish consumption advisories

Most frequent concerns heard:

¦	Concerns over protectiveness of remedy, related to biological human health
risk assessment fish consumption assumptions - concern over protectiveness of
the remedy related to the human health risk assessment assumption of the number
of meals of local fish consumed, given the spread of contamination into
communities where local fish are perceived to be a larger portion of the diet.
Concern that EPA's Human Health Risk Assessment underestimated the fish
consumption rate for some fishers in the area.

¦	Concerns about cap stability and thin layer cover - concern over the stability
and effectiveness of a sediment cap, especially thin-layer capping; concern that
more contaminants are not being physically removed and the belief that removing
more will result in a better remedy; how can capping and thin cover work given the
tidal influence?

¦	Concerns about PCB Exposure - Aroclor 1268 is being found in people's blood;
how is this happening? What does this mean for human health? Why doesn't this
fact make the cleanup more urgent? Concerns for widespread health effects -
human and ecological.

¦	Concerns about the extent of contamination and how it lines up with the
remedy - concerns about the extent of contamination and remediating a much
smaller area. Complaints about timeliness/lack of lead time, too small a cleanup
footprint are manifestations of this; the community doesn't really trust us, and
doesn't believe that the cleanup proposed is sufficient. Why is the EPA actively
cleaning up a small part of the marsh? Why isn't there some interim containment
measure?

2.4 Response to Community Concerns

In response to community stakeholders' concerns, EPA's Community Involvement Coordinator
(CIC) and Remedial Project Manager (RPM) will address community's concerns in an effective
and efficient manner. EPA will maintain outreach in the community via fact sheets and public
meetings, availability sessions and meetings with individual community groups, as necessary.

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2.5 Summary of Communication Needs

Stakeholders have indicated a preference for EPA outreach efforts to include announcements in
printed mailings as well as electronic notifications. Citizens indicated that public meetings or
availability sessions are a viable option in providing updates to the community if they do not
pose conflict with standing meetings in the Brunswick area.

Section 3.0
EPA's Community Involvement Program

The overall goal of EPA's community involvement program is to promote two-way
communication between citizens and the EPA and to provide opportunities for meaningful and
active involvement by the community in the cleanup process. EPA will implement the
community involvement activities described below. The following plan is based on the results of
the community interviews described earlier; it addresses each issue that was identified as being
important to the community.

3.1 The Plan

Issue 1: Maintaining the Most Current Site Information for the Public

Activity 1A: Establish a Liaison for the Community and the EPA

Objective: To provide a primary liaison between the community and EPA and to
ensure prompt, accurate and consistent responses and information dissemination
about the Site. In those instances where EPA's Community Involvement
Coordinator (CIC) may be unable to provide adequate information (such as on
technical issues), inquiries will be directed to the appropriate EPA contact.

Method: EPA Region 4 has designated Angela Miller as the CIC to handle Site
inquiries and serve as point of contact for community members. She works closely
with Galo lackson, EPA's Remedial Project Manager. CIC Angela Miller can be
contacted at (877) 718-3752 and by email at miller.angela@epa.gov.

Timing: A CIC has been involved at the Site since 1998.

Activity IB: Prepare and Distribute Site Fact Sheets and Technical Summaries

Objective: To provide citizens with current, accurate, easy-to-read, easy-to-
understand information about the Site.

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Method: Fact sheets will be mailed to all parties on the Site mailing list. In
addition, copies will be available at the Site's Information Repository.

Timing: EPA will prepare and distribute fact sheets as needed.

Activity 1C: Provide a Toll-free "800 " Number the Community to Contact EPA

Objective: To enable citizens to obtain the latest site information available when
they want it, rather than having to wait for a meeting or a fact sheet mailing, and
without incurring any cost.

Method: EPA will activate the 800 number and publish it in all Site fact sheets.

Timing: The line is currently operational and manned during business hours. The
number is (877) 718-3752.

Activity ID: Develop a Mailing List for the Site.

Objective: To facilitate the distribution of Site-specific information to all parties
who would like to be kept informed about the Site.

Method: EPA will create a mailing list that includes all residences adjacent to the
Site. EPA will also solicit interested parties via fact sheets, newspaper articles and
public meetings.

Timing: EPA has developed a Site Mailing List, which includes email addresses
as well. Both will be updated as needed.

Activity IE: Establish and Maintain the Designated Information Repositories

Objective: To provide a convenient location where citizens can read and copy
official documents and other pertinent information about the Site and EPA
activities.

Method: The repository is a reference collection of Site information containing
the Administrative Record file, other Site-specific information, the Community
Involvement Plan (CIP), information on the general Superfund process and
relevant community information.

Timing: EPA has established the local Information Repository at the Brunswick
Glynn County Library. EPA Site staff will continue to place copies of additional
documents in the Information Repository as they become available.

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Activity IF: Provide Site and SuperfundInformation on the Internet

Objective: To provide key resources for searching and listing both general and
specific information pertaining to Superfund and hazardous waste issues.

Method: General information about EPA and the Superfund program can be
found at the following website URL addresses:

¦	EPA Headquarters: www.epa.gov.

¦	EPA Region 4: http://www.epa.gov/aboutepa/region4.html.

¦	Site status Summary: http://www.epa.gov/superfund/sites/npl

¦	Reading room:
http://epa.gov/region4/foiapgs/readingroom/lcp chemicals site/index.htm

Timing: EPA updates Site Status Summaries periodically.

Activity 1G: Establish and Maintain the Administrative Record.

Objective: To provide residents with an index of all documents generated and
referred by EPA during the Superfund process at the Site.

Method: EPA Region 4 will provide at least two sets of the Administrative
Record for the Site. One will be located at EPA Region 4's offices, in the EPA
Region 4 Library at 61 Forsyth Street SW, in Atlanta, Georgia 30303. The second
will be located at the local Information Repository - Brunswick Glynn County
Library located at 208 Gloucester Street in Brunswick. EPA opened the
Administrative Record during Site investigations and it will remain open during
the planning and implementation of the Site's cleanup.

Timing: EPA opens the Administrative Record at the beginning of Site
investigations. The Agency will continue to include additions to the
Administrative Record until the signing of the ROD. EPA confirmed the location
of the Administrative Record with the community in 1998. The Administrative
Record is housed at the following location within the community: Brunswick
Glynn County Library located at 208 Gloucester Street, Brunswick, Georgia.

Activity 1H: Develop the Community Involvement Plan

Objective: The Community Involvement Plan (CIP) is a living document, which
means that EPA can revise it, at or before the standard three-year term. The plan
provides a thorough discussion of the Site's history, cleanup progress, community
concerns, community participation/events and community contacts. The purpose
of the Community Involvement Plan is to serve as a document that represents the
community and its interests, concerns and priorities to EPA.

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Method: EPA will develop a draft of the CIP. The final CIP will be available in
the Site's local information Repository.

Timing: EPA developed the Community Involvement Plan during the Remedial
Investigation and Feasibility Study in May 2015.

Issue 2: Provide Effective Opportunities for Community Involvement

Activity 2A: Schedule Public Meetings.

Objective: To update the community on the most recent Site developments and
address community questions, concerns, ideas and comments.

Method: Refer to Appendix G for meeting locations. EPA will schedule, prepare
for and attend all announced meetings. EPA will provide at least two weeks'
notice of each scheduled meeting. The Site's Remedial Project Manager,
Community Involvement Coordinator and other appropriate EPA staff, as well as
other agencies involved, will attend.

Timing: EPA may schedule additional public meetings or availability sessions to
provide the community with regular updates regarding the progress of the Site's cleanup.

Activity 2B: Revise the Community Involvement Plan.

Objective: To identify and address community needs, issues and concerns
regarding the Site.

Method: The revised plan will update the information presented in the previous
version of the document.

Timing: EPA will revise the Site's Community Involvement Plan as community
concerns warrant or, at minimum, every three years until completion of all Site
activities.

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3.2 Time Frame Summary for Community Involvement Activities

ACTIVITY

Designate an EPA Community Involvement Coordinator
(CIC)

Prepare and distribute site fact sheets and technical
summaries

Involve students, parents, teachers through area schools

Provide a toll-free "800 number" for the community to
contact EPA

Maintain a mailing list for the Site

Establish and maintain Information Repositories

Provide Site and Superfund information on the Internet

Provide Technical Assistance Grant (TAG) information

Establish and maintain the Administrative Record

Conduct special events

Schedule and conduct public meetings

Encourage formation of a Community Advisory Group
(CAG)

Make informal visits to community

Solicit comments during a Public Comment Period

Prepare and issue a Responsiveness Summary

Revise the Community Involvement Plan (CIP)

TIME FRAME

Established
Angela Miller

As needed
As needed

Currently in operation
(877) 718-3752

Ongoing

Established

Brunswick Glynn County Library
208 Gloucester Street
Brunswick, GA

http://www.epa.gOv/superfund/sites/n
jjl and

http://epa.gov/region4/foiapgs/readin
groom/lcp chemicals site/index.htm

Ongoing

Established, update as needed
As needed or required
As needed or required
As warranted by the community

As needed

As needed or required
Following ROD

As needed or at least every 3 years

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Section 4.0
What Is Superfund?

Superfund is an environmental cleanup program enabled by a federal law enacted in 1980 known
as the Comprehensive Environmental Response, Compensation, and Liability Act, or CERCLA.
In 1986, another law, the Superfund Amendments and Reauthorization Act (SARA) reauthorized
CERCLA to continue Superfund cleanup activities. The CERCLA law gives EPA the authority
to require those parties responsible for creating hazardous waste sites to clean those sites up or to
reimburse the government if EPA cleans up the site. EPA requires responsible parties to clean up
hazardous waste sites through administrative orders, consent decrees, and other legal settlements.
EPA is authorized to enforce the Superfund laws in all 50 states and in U.S. territories.

Superfund site identification, monitoring, and response activities are coordinated with state,
tribal, and territorial environmental protection or waste management agencies.

The Superfund program encourages active dialogue between communities affected by the release
of hazardous substances and all of the agencies responsible for carrying out or overseeing
cleanup actions. EPA follows a step-by-step process to determine the best way to clean up a
polluted site and protect human health and the environment. EPA considers community
involvement to be an important part of the Superfund program and opportunities for community
involvement occur throughout the procedure. Figure 1 on the next page outlines the stages of the
Superfund process and highlights opportunities for community involvement at each step of the
process.

Visit these EPA websites for more information on the Superfund process.

Superfund: www.epa.gov/superfund/index.htm
Cleanup Process: www, epa. gov/ superfund/cleanup/index .htm
Community Involvement: www, epa. gov/ superfund/community/index .htm

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Section 5.0
Site Description

1.1 Site Description

Figure 1 illustrates the key features of the Site. The dominant physical feature of the Site is the
670+ acres of marsh, designated as OU1, that are located west of the formerly industrialized
upland portion of the Site (designated as OU3). The main feature of the LCP Chemicals marsh is
Purvis Creek, which divides the marshlands roughly in half - north to south. Purvis Creek flows
into the Turtle River. Some of the major features of the upland area are shown on Figure 2.

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Georgia Pacific Pulp Plant

Figure 1 - Features of the LCP Marsh

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5

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County Landfill

l\

County
Firing\
Range

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North API Separator

/

Cans

•way

Outfall
Pond

LCP Ditch (Main Canal)

Outfall Canal

Former Facility
Disposal Area

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Western Creek
Complex

Brine Mud
Impoundments

South API
Separator

Salt Dock

I		

Legend

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Figure 2 - Features of the upland portion of the LCP Chemicals Site

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5.1 Site Background

The Atlantic Refining Company (ARCO) operated the Site as a petroleum refinery from 1918 to
the early 1930s. The refinery ceased operations by 1935. Georgia Power Company purchased
portions of the Site between 1937 and 1950, and operated electric power generating facilities.
The Dixie Paint and Varnish Company operated a paint and varnish manufacturing facility at the
Site from 1946 to 1956. In 1956, the Allied Chemical and Dye Corporation (now Honeywell)
built and operated a chlor-alkali facility at the Site, principally for the production of chlorine gas,
hydrogen gas, and caustic solution. The plant operated using the mercury cell process, which
involves passing a concentrated brine solution between stationary graphite anodes and a flowing
mercury cathode to produce chlorine gas, sodium hydroxide (caustic) solution, and hydrogen gas.
Sodium hypochlorite (bleach) was also produced in a secondary reaction. For a time, the graphite
anodes were impregnated with the polychlorinated biphenyl (PCB) Aroclor 1268 to extend their
life. LCP Chemicals of Georgia, Inc. purchased the property and chlor-alkali plant in 1979.
Operations continued until 1994, when LCP Chemicals implemented a shutdown of the plant.

Since the early 1920s, the LCP Chemicals Site has been used by industry, initially for the
refinement of petroleum products, followed by electric power generation, then paint formulation.
From 1957 to 1994 the property was used as a chlor-alkali plant for the making of hydrogen gas,
chlorine gas and sodium hydroxide using the nearly obsolete mercury cell process. The industrial
uses of the Site resulted in contaminants either being placed in the marsh or pumped through
pipelines into the marsh. Although the twice daily tides have dispersed the contaminants, due to
the properties of the contaminants, the highest concentrations remain within the creeks and
channels closest to where the contaminants were placed or pumped. Wildlife, including finfish,
shellfish, birds and mammals live in or migrate through the LCP Chemicals marsh.

GAEPD and EPA organized the work for the LCP Chemicals Site into three Operable Units
(OUs): OU1 addresses the marsh; OU2 addresses the Site's groundwater, as well as the surface
and subsurface soil in the Cell Building Area; and OU3 addresses the remainder of the LCP
Chemicals Site's Uplands.

5.2 Site Inspections and Cleanup Activities

On June 17, 1996, the LCP Chemicals (Brunswick, GA) Site was added to the National Priorities
List (NPL). The NPL listing means that the Site ranks among the nation's highest priorities
among the known releases of hazardous substances, pollutants or contaminants for remedial
evaluation and response under the federal Superfund law, CERCLA.

The Potentially Responsible Party conducted an extensive RI from 1994 to 2012 to determine the
nature and extent of contamination in OU1 and assess the risks to human health and the

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environment posed by the contamination. More than 4,700 sediment samples were analyzed for
contaminants, including heavy metals, volatile organic compounds (VOCs), semi-volatile
organic compounds (SVOCs) and PCBs. A Baseline Human Health Risk Assessment (HHRA)
and Baseline Ecological Risk Assessment (BERA) were completed as part of the RI process.
These risk assessments are discussed in the Summary of Site Risks section of this Proposed Plan.
The RI, Baseline HHRA and BERA were approved by the EPA and GAEPD and are available
for review at the LCP Chemicals Electronic Reading Room, on the worldwide web at
www.epa.gov/Region04/LCP Chemical Reading Room. As a result of the RI studies and risk
assessments, a limited number of contaminants were identified as contaminants of concern
(COCs) that warranted further evaluation and remedial action under CERCLA.

In 1998-1999, there was a removal and proper disposal of 142,000 cubic yards
(CY) of waste and contaminated soil from the Uplands, and 25,000 CY from the marsh
sediments closest to the sources of historical facility discharge. The approximately 13 acres of
highly contaminated marsh sediments were excavated, backfilled with clean fill, and re-vegetated
with native marsh grasses. Dredging of primary source sediment was also performed along a
portion of Eastern Creek and in select portions of the LCP Ditch (2,650 linear ft). These actions
were conducted by the PRP group as Superfund removal actions and resulted in the removal of
39,000 tons of principal threat waste located in the marsh area. As a result of these removal
actions, the remaining contamination in OU1 is considered to be low-level threat waste to be
addressed by this Superfund remedial action.

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Appendix A
EPA Regional Contacts

Galo Jackson

Remedial Project Manager
U.S. EPA, Region 4
61 Forsyth Street, SW
Atlanta, GA 30303
(404) 562-8937
Jackson.galo@epa.gov

Angela Miller

Community Involvement Coordinator

U.S. EPA, Region 4

61 Forsyth Street, SW

Atlanta, GA 30303

(404) 562-8561

miller.angela@epa.gov

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Appendix B
Local Officials

City and State Elected Officials

Mayor

County Commissioners

Cornell Harvey

(912)267-5500
mayorcharvey@gmail.com

District 5
Allen Booker

(912)554-7111
ab ooker@glynncounty-ga. gov

City Commission

Felicia Harris Mayor Pro Tem

(912) 267-5500
felmharr@gmail.com

Johnny Cason

(912)267-5500
iohncasoniii@gmail.com

Julie R. Martin

(912)267-5500
iulie@GlynnHomeHunter.com

Vincent Williams

(912)267-5500
commvtwilliams@gmail.com

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Appendix C
Federal and State Elected Officials

Federal Elected Officials

U.S. Senate

U.S. House of Representatives

Washington, D.C. Office
John Isakson

131 Russell Senate Office Building
Washington, D.C., 20510
(202) 224-3643

Washington, D.C. Office
Buddy Carter

432 Cannon House Office Building
Washington, D.C., 20515
(202) 225-5831

District Office

One Overton Park

3625 /Cumberland Boulevard, Suite 970
Atlanta, GA 30339

District Office

1510 Newcastle Street, Suite 200
Brunswick, GA 31520
(912) 265-9010

(770) 661-0999

Washington, D.C. Office
David Perdue

383 Russell Senate Office Building
Washington, D.C., 20510
(202) 224-3521

District Office

191 Peachtree Street, NE, Suite 3250
Atlanta, GA 30303
(404)865-0087

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Appendix D
Affiliated Agency Contacts

ATSDR Region 4

Agency for Toxic Substances and Disease Registry

Atlanta Federal Center

61 Forsyth Street, SW

10th Floor

Atlanta, GA 30303

(800) 232-4636

www, atsdr. cdc. gov/

Georgia Environmental Protection Division

2 Martin Luther King Jr. Drive
Atlanta, Georgia 30334
(404) 656-4713
http ://epd. georgia. gov/

Georgia Department of Public Health

2 Peachtree Street, NW
15th Floor

Atlanta, Georgia 30303
(404) 657-2700
http ://dph. georgia. gov/

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Appendix E

Citizens Groups and Community Organizations

Glynn Environmental Coalition (GEC)

4472-C New Jessup Highway
Brunswick, Georgia
912-466-0934

http: //glynnenvironmental. org/

*GEC has been awarded the Technical Assistance Grant (TAG) through EPA

Rebuilding Together of Glynn County Georgia, Inc.

P.O. Box 1992
Brunswick, Georgia 31521

One Hundred Miles

1312 Newcastle Street, 2nd Floor
Brunswick, Georgia
912-264-4111

www, onehundredmiles. org/

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Appendix F
Media Contacts

Television Stations:

WJXX ABC 25
WTLV NBC 12

1070 East Adams Street
Jacksonville, FL 32202
(904)354-1212

Radio Stations:

The New Joy 100.3 Gospel Station

3028 Norwich Street
Brunswick, GA 31520
(912) 264-0783

Newspapers:

The Brunswick News

3011 Altama Avenue
Brunswick, GA 31520
(912) 265-8320

GA Times Union

3675 Community Road
Brunswick, GA 31520
(912) 466-9875

The Islander

3596 Darien HWY #6
Brunswick, GA 31525
(912) 265-9654

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Appendix G
Meeting Locations

Meeting locations are subject to availability and approval. To date, all meetings have been held at
the following location:

The Brunswick Glynn County Library

208 Gloucester Street
Brunswick, GA 31520
(912)267-1212

Brunswick Historic City Hall

1229 Newcastle Street
Brunswick, GA 31520
(912) 265-4032

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Appendix H

Information Repository Location & Administrative Record File

Information Repository:

EPA has established an information repository for the site at the following location:

Brunswick Glynn County Library
208 Gloucester Street
Brunswick, GA 31520
(912) 267-1212

Administrative Record File:

The Administrative Record file is housed at the same location, and a copy is also available at
EPA Region 4's offices in Atlanta, Georgia:

EPA Region 4 Library

9th Floor
61 Forsyth Street, SW
Atlanta, GA 30303

Hours of Operation: Monday through Friday, 8:00 a.m. to 4:00 p.m. Library is closed on all
federal holidays.

For more information, please contact:

Angela Miller

Community Involvement Coordinator
U.S. EPA Region 4
(404) 562-8561
Miller.angela@epa.gov

Galo Jackson

Remedial Project Manager
U.S. EPA Region 4
(404) 562-8937
Jackson. galo@epa. gov

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Appendix I

Seven Cardinal Rules for Risk Communication

Seven Cardinal Rules of Risk Communication

The "Seven Cardinal Rules of Risk Communication" were developed by Vince Covello and
Frederick W. Allen and published in an EPA pamphlet in 1988 (U.S. Environmental Protection
Agency, OPA-87-020, April 1988). The rules, which are appropriate for all Superfund site
communications follow:

1.	Accept and involve the public as a legitimate partner.

2.	Plan carefully and evaluate your efforts.

3.	Listen to the public's specific concerns.

4.	Be honest, frank, and open.

5.	Coordinate and collaborate with other credible sources.

6.	Meet the needs of the media.

7.	Speak clearly and with compassion.

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Appendix J
List of Abbreviation and Acronyms

This list of abbreviations and acronyms are commonly used within the agency. Please note that some of the items may not be included in this

Community Involvement Plan.

AT SDR

Agency for Toxic Substances and Disease Registry

CAG

Community Advisory Group

CERCLA

Comprehensive Environmental Response, Compensation and Liability Act

CIC

Community Involvement Coordinator

EPA

United States Environmental Protection Agency

FR

Federal Register

HQ

EPA Headquarters

HRS

Hazard Ranking System

mg/kg

Milligrams per Kilogram

NCP

National Oil and Hazardous Substances Pollution Contingency Plan

NPL

National Priorities List

osc

On-Scene Coordinator

OSHA

Occupation Safety and Health Administration

OSRTI

Office of Superfund Remediation and Technology Innovation

OSWER

Office of Solid Waste and Emergency Response

PCE

Perchloroethane

PRP

Potentially Responsible Party

RALs

Removal Action Levels

RI/FS

Remedial Investigation/Feasibility Study

ROD

Record of Decision

RPM

Remedial Project Manager

SF

Superfund

ssv

Sediment Screening Value

START

Superfund Technical Assistance & Response Team

TCA

1,1,1 -trichloroethane

TDEC

Tennessee Department of Environment and Conservation

VOCs

Volatile Organic Compounds

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Appendix K
Glossary

Administrative Record File

A file maintained for the public that contains information used to make a decision about a site
under CERCLA. The file is available for public review, and a copy is usually placed in the same
location as the site information repository. A duplicate file is held at a central location, such as
EPA's regional office.

Cleanup

Actions taken to deal with a release or threatened release of hazardous substances that could
affect public health or the environment. Cleanup is often used broadly to describe various
response actions or phases of remedial activities, such as remedial investigation/feasibility study.
The term "cleanup" is sometimes used interchangeably with the terms "remedial action,"
"remediation," "removal action," "response action" or "corrective action.

Community

An interacting population of various types of individuals in a common location; a neighborhood
or specific area where people live.

Community Involvement

The term used by EPA to identify its process for engaging in dialogue and collaboration with
communities affected by Superfund sites. EPA community involvement is founded on the belief
that people have a right to know what the Agency is doing in their community and to have a say
in it. Its purpose is to provide people with the opportunity to become involved in the Agency's
activities and to help shape the decisions that are made at Superfund sites.

Community Involvement Coordinator (CIC)

EPA official whose lead responsibility is to involve and inform the public about the Superfund
process and response actions in accordance with the interactive community involvement
requirements set forth in the National Contingency Plan.

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)

Commonly known as Superfund, the Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA) was enacted by Congress on December 11, 1980. CERCLA is
intended to protect human health and the environment by enabling the investigation and cleanup
of abandoned or uncontrolled hazardous waste sites. Under the program, EPA either can pay for
a site cleanup when parties responsible for the contamination cannot be located or are unwilling
or unable to perform the work, or take legal action to force parties responsible for site
contamination to clean up the site or repay the federal government for the cleanup cost.

Conveyance

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The transfer of title to property or a right of that property (i.e., an easement) from one person or
entity to another.

Contaminant

Any physical, chemical, biological or radiological substance or matter that has an adverse effect
on air, water or soil.

Contamination

Introduction into water, air and soil of microorganisms, chemicals, toxic substances, wastes or
wastewater in a concentration that makes the medium unfit for its next intended use. Also applies
to surfaces of objects, buildings and various household use products.

Environment

The sum of all external conditions affecting the life, development and survival of an organism.
Environmental Protection Agency (EPA)

Federal agency whose mission is to protect human health and safeguard the environment.
Environmental/Ecological Risk

The potential for adverse effects on living organisms associated with pollution of the
environment by effluents, emissions, wastes or accidental chemical releases, by energy use, or by
the depletion of natural resources.

Feasibility Study (FS)

The second part of a two-part study called an RI/FS. The feasibility study involves identifying
and evaluating the most appropriate technical approaches to addressing contamination problems
at a site. Alternatives are evaluated for their effectiveness in protecting human health and the
environment.

Ground Water

Water found underground that fills pores between materials such as sand, soil, or gravel. In
aquifers, ground water often occurs in quantities where it can be used for drinking water,
irrigation and other purposes.

Hazardous Substance

(1) Any material that poses a threat to human health and/or the environment. Typical hazardous
substances are toxic, corrosive, ignitable, explosive or chemically reactive. (2) Any substance
designated by EPA to be reported if a designated quantity of the substance is spilled in the waters
of the United States or is otherwise released into the environment.

Hazardous Waste

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Byproducts that can pose a substantial or potential hazard to human health or the environment
when improperly managed. Possesses at least one of four characteristics (ignitability, corrosivity,
reactivity or toxicity) or appears on special EPA lists.

Information Repository

A file containing current information, technical reports and reference documents regarding a
Superfund site. The information Repository is usually located in a public building, such as a
public school, city hall or library, which is conveniently located for community residents. EPA
may update the file at the Information Repository.

Lead Agency

An agency such as EPA or other federal agencies and state agencies that plan and implement
response actions under the NCP (e.g., the agency that has the primary responsibility for
coordinating a CERCLA response action).

Monitoring

Periodic or continuous surveillance or testing to determine the level of compliance with statutory
requirements and/or pollutant levels in various media or in humans, plants and animals.

National Priorities List (NPL)

The National Priorities List (NPL) is EPA's list of the most serious uncontrolled or abandoned
hazardous waste sites identified for possible long-term cleanup under Superfund. The list is
based primarily on the score a site receives from the Hazard Ranking System. EPA is required to
update the NPL, at least once a year.

Natural Resources

Land, fish, wildlife, air, water, ground water, drinking water supplies and other such resources
belonging to, managed by or controlled by the United States, a state or local government, any
foreign government, any Indian tribe or any member of an Indian tribe.

Pollutant

Generally, any substance introduced into the environment that adversely affects the usefulness of
a resource or the health of humans, animals or ecosystems.

Potentially Responsible Party (PRP)

An individual, company or other entity (such as owners, operators, transporters or generators of
hazardous waste) potentially responsible for, or contributing to, contamination at a Superfund
site. Whenever possible, EPA requires a PRP, through administrative and legal actions, to clean
up hazardous waste sites that it has contaminated.

Proposed Plan

A public participation requirement of CERCLA in which EPA and/or the PRP summarize for the
public the preferred cleanup strategy, rationale for the preference and alternatives presented in the

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detailed analysis of the RI/FS. The proposed plan may be prepared as a fact sheet or a separate
document. In either case, it must actively solicit public review and comment on all alternatives
under consideration.

Public

The community or people in general or a part or section of the community grouped because of a
common interest or activity.

Public Availability Session

Informal public sessions that often use poster displays and fact sheets and that include EPA
personnel and contractors who are available to discuss issues and answer questions. Public
availability sessions offer the public the opportunity to learn about project-related issues and to
interact with EPA on a one-to-one basis. Public availability sessions do not require the use of
court reporters and transcripts, although EPA may issue meeting summaries through newsletters
and progress reports.

Public Comment Period

A formal opportunity for community members to review and contribute written comments on
various EPA documents or actions.

Public Meeting

Formal public sessions characterized by a presentation to the public followed by a question-and-
answer session. Formal public meetings may involve the use of a court reporter and the issuance
of transcripts. Formal public meetings are required only for the Proposed Plan and ROD
amendments a site.

Record of Decision (ROD)

A public document that explains which cleanup alternatives will be used to clean up a Superfund
site.

Remedial Investigation (RI)

A study designed to collect the data necessary to determine the nature and extent of
contamination at a site.

Responsiveness Summary

A summary of oral and written comments received by EPA during a public comment period on
key site-related documents, with EPA's responses to those comments. The responsiveness
summary highlights community concerns to be taken into account by the group in making
decisions on a site and is a key part of the ROD.

Risk Assessment

An evaluation of the likelihood of exposure and potential magnitude of future health or
environmental effects that could occur if parties do not take any cleanup action at a site. Risk

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assessment may include both qualitative (non-numerical) evaluation and quantitative (numerical)
calculations based on specific assumptions about long-term exposure risks. Ecological risk
assessment applies to animals, fish, vegetation and other environmental receptors. Human health
risk assessment estimates the potential effects on people. Risk assessment results inform the
identification of site cleanup requirements.

Stakeholder

Any organization, governmental entity or individual that has a stake in or may be affected by the
Superfund program.

Superfund

The program operated under the legislative authority of CERCLA that funds and carries out EPA
solid waste emergency and long-term removal and remedial activities. These activities include
establishing the National Priorities List (NPL), investigating sites for inclusion on the list,
determining their priority, and conducting and/or supervising cleanup and other remedial actions.
Superfund is the common name for CERCLA and is often used as an adjective for hazardous
waste sites and the investigation and cleanup process directed by EPA.

Superfund Amendments and Reauthorization Act of1986 (SARA)

Established standards for cleanup activities and stipulates the conditions for off-site disposal of
wastes. The amendments also clarified many public participation questions and made federal
facilities accountable under the statute.

Technical Assistance Grant (TAG)

The purpose of the TAG is to increase the level of understanding and participation in the
Superfund process among community members and provide independent technical review of Site
documents.

Tennessee Department of Environment and Conservation (TDEC)

Environment and Conservation is committed to protecting and improving the quality of
Tennessee's air, land and water. Department programs and initiatives protect human health and
the environment and support economic development and quality of life through education,
outreach and effective enforcement of state and federal environmental laws.

Treatment

(1) Any method, technique or process designed to remove solids and/or pollutants from solid
waste, waste-streams, effluents and air emissions. (2) Methods used to change the biological
character or composition of any regulated medical waste so as to substantially reduce or
eliminate its potential for causing disease.

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