P. O. Box 2443
Questions Linger About Proposed Habersham Street
The Glynn Environmental Coalition (GEC) reviewed the proposed Glynn County Habersham Street School Site Report of Phase I Environmental Site Assessment and Hazard Analysis Assessment (Report) by Geotechnical and Environmental Consultants, dated August 23, 2001. We identified additional information and data that were either not evaluated or unavailable at the time the Report was written.
The assessment and hazard analysis report concluded: “The 1993, 1988, and 1974 aerial photographs shows the target property essentially as it appears today (undeveloped, forested land). The reviewed aerial photographs strongly suggest a similar condition prior to the oldest photo taken in 1974. The aerial photographs reviewed did not indicate obvious environmental impacts to the site”.
We reviewed historical photographs from 1942 to 1968 to evaluate potential contamination on the proposed school site from past operations at the LCP Chemicals Superfund Site. The aerial photographs indicated that there was activity in the area under consideration for a school site during the 1940s, including suspected waste dumping from operations at the LCP Chemicals Superfund Site. Nearby Harbison Walker Refactory – Calsilite was listed on the Georgia Environmental Protection Division Hazardous Site Inventory (Site Number 10279). Historical photographs show roads leading from LCP Chemicals into the area under consideration for a school site.
Like the consultants that produced the environmental assessment for the Glynn County Board of Education, the GEC used “A Guide to School Site Selection, August 1999”, by the Georgia Department of Education Facilities Service Unit as the guidance document for evaluating the proposed Habersham Street School Site. The five evaluation categories are used to determine the suitability of a property for a school site.
I. Size: Five Acres Plus One Acre for Each 100 Children. The site meets size criteria based upon the 19-acre site size and estimated 700 elementary school children.
II. Utilities: Telephone, Electric, Water and Sewer. The site meets criteria for the availability of utilities
III. Safety Hazards: The proposed site fails 7 (in bold) of the 13 safety hazard criteria for selection.
1. Electrical transmission lines rated at 115 KV or higher
2. Oil or petroleum transmission lines and storage facilities
3. Hazardous chemical pipelines
4. Natural Gas transmission and distribution lines larger than ten inches in diameter with a pressure of 200 psi or more
5. * Propane storage facilities
7. Major highways
8. Airport approach or departure paths
9. Industrial/manufacturing facilities:
(a) Using or storing hazardous substances as defined under Title 40 CFR 262
(b) Emitting hazardous air pollutants as defined under the “Clean Air Act” and/or
(c) 1990 “Clean Air Act Amendment” – Risk Management Plan Sec. 112(r)
10. Lakes, rivers, dams, reservoirs, or other bodies of water
11. Potential flooding because the property is located within the 100-year flood plain or dam breach zone
12. Nuclear waste storage facilities
13. Munitions or explosives storage or manufacturing
(* Amerigas and Ferrellgas propane storage facilities not identified in Report)
The Report identified industrial and manufacturing facilities storing hazardous waste or emitting hazardous air pollutants (Safety Hazards #9), but did not evaluate air quality in the proposed school site area. The nearby Georgia Environmental Protection Division Air Monitoring Station at the Coastal Georgia Community College on Altama Avenue identified five hazardous air pollutants that exceed health-based standards.
IV. Environmental Factors: A. Zoned for commercial or industrial development should be avoided. B. Insulated from business and industrial development. C. Acceptable to the school patronage community.
The school site failed criteria for zoning next to commercial and industrial development, and insulation from businesses and industrial development. Acceptable to the school patronage community is a determination that is made by the Glynn County Board of Education and was not evaluated by the GEC.
V. Geographical Related Factors: Appropriately located with respect to other schools and the population to be served. Geographical related factors were not evaluated by the Glynn Environmental Coalition.
Conditions near the proposed school site have changed since the Report was prepared in August 2001. An asphalt plant has been permitted 1800 feet from the proposed school site (The Glynn County Commission and Board of Education wrote letters to the Georgia Environmental Protection Division requesting the plant not be permitted, but an air permit was issued). Emissions from the asphalt plant will increase levels of hazardous air pollutants that exceed health-based standards. In addition, increased noise should be expected from the rail car shakers used during unloading, and increased particulate matter from operations.