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Havertown PCP

COMMUNITY RELATIONS PLAN

HAVERFORD TOWNSHIP, DELAWARE COUNTY, PENNSYLVANIA

Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Hazardous Waste Management Division
Philadelphia, PA 19107

Work Assignment No. : ESS-018
Date Prepared : June 10, 1998
Contract No. : 68-W4-0010
WA Project Manager : Kara Udicious
Telephone No. : 215-928-7906
EPA WA Manager : Harold Yates
Telephone No. : 215-597-4081

TABLE OF CONTENT

  1. INTRODUCTION
  2. OVERVIEW OF THE SUPERFUND PROGRAM
  3. SITE BACKGROUND
    1. SITE LOCATION AND DESCRIPTION
    2. SITE HISTORY AND CURRENT ACTIVITIES
  4. COMMUNITY INVOLVEMENT
    1. HISTORY OF COMMUNITY CONCERNS
    2. COMMUNITY CONCERNS
  5. COMMUNITY RELATIONS OBJECTIVES
  6. COMMUNITY RELATIONS ACTIVITIES 

APPENDICES

  1. INTERESTED PARTIES
  2. COMMUNITY DISTRIBUTION LOCATIONS FOR FACT SHEETS
  3. SUGGESTED LOCATIONS FOR INFORMATION REPOSITORY, ADMINISTRATIVE RECORD REPOSITORY, PUBLIC MEETINGS

SECTION 1.0: INTRODUCTION

This community relations plan describes issues of community interest and concern related to the Havertown PCP Superfund Site located in Haverford Township, Delaware County, Pennsylvania. The 1980 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), more commonly known as Superfund, requires that the U.S. Environmental Protection Agency (EPA) prepare a community relations plan for involving local citizens in the decisions related to hazardous waste sites in their area. This plan outlines the community relations activities that EPA will conduct during the clean-up process at the Havertown PCP Site.

The major goals of this plan are to provide ways to establish and maintain open communication between the public; local, state, and Federal officials; and other parties interested in the Havertown PCP Site and to disseminate information to residents and other interested parties in a timely manner. This community relations plan describes the site and its history; summarizes current site activities; outlines past community involvement and the community's current concerns; and describes the community relations activities EPA proposes to conduct during the continuing clean-up process at the site. EPA uses the community relations activities outlined in this plan to inform the local community, area civic and environmental groups, and other officials about the Superfund process and on-going site activities and developments.

EPA obtained the information used to develop this plan from its files, a January 1991 Community Relations Plan, and information meetings with community members.

SECTION 2.0: OVERVIEW OF THE SUPERFUND PROGRAM

Superfund is a program managed by EPA and dedicated to cleaning up uncontrolled or abandoned hazardous waste sites across the United States. The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) guides EPA in implementing the Superfund program. The program was initiated in 1980 under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and amended in 1986 by the Superfund Amendments and Reauthorization Act (SARA). Superfund gives EPA the authority to stop on-going releases and prevent potential releases of hazardous substances which may cause harm to human health or the environment; enables EPA to make the parties responsible for contaminating a site pay for its cleanup; and provides funding for the cleanup when money from responsible parties is not available.

Identifying Sites for Cleanup

Under the Superfund program, EPA investigates hazardous waste sites throughout the United States. EPA conducts an initial review of each site to determine whether further action is necessary. EPA then evaluates the site using the hazard ranking system, a measurement tool which assigns each site a score based on the possibility that contamination will spread through ground water, surface water, or air. The hazard ranking system also takes into account other factors, such as the location of nearby residences. EPA places the most serious sites on the National Priorities List (NPL), a list of sites targeted for long-term or remedial action under the authority of CERCLA.

Superfund's Removal and Remedial Branches

The Superfund program allows EPA to conduct removal actions to address immediate threats and remedial actions to address long-term threats to human health and the environment. At many sites, including the Havertown PCP Site, EPA conducts both removal and remedial actions. Removal actions are usually conducted over a period of months while remedial actions usually take years to complete. The steps involved in a remedial action are outlined below.

Selecting and Implementing a Clean-up Plan

After EPA places a site on the NPL, the Agency conducts a remedial investigation/feasibility study (RI/FS). The remedial investigation identifies the nature, amount, extent, and effects of the site contamination. The feasibility study reviews the available methods for cleaning up the site contamination and determines the most effective clean-up method for the site. EPA presents this selected clean-up method, along with the other possibilities, to the site community in the proposed remedial action plan (PRAP). EPA's release of the PRAP opens a 30-day public comment period during which community members are invited to comment on the PRAP. EPA holds a public meeting during this public comment period to solicit input. EPA takes all comments into account and may amend its recommended clean-up method based on these comments. EPA then presents the selected clean-up method in the record of decision (ROD). In addition to the clean-up method, the ROD contains a summary of the public's comments on the PRAP and EPA's responses.

After EPA selects the clean-up method, the Agency begins its design and implementation, called the remedial design/remedial action. When necessary, EPA can modify the ROD to reflect minor changes to the clean-up plan. After EPA has determined that all appropriate clean-up actions have been completed at a site, the Agency will delete the site from the NPL. EPA continues to monitor delisted Superfund sites every five years to ensure that proper clean-up levels are being maintained.

SECTION 3.0: SITE BACKGROUND

This section provides a brief description of the site, a short site history, including past EPA involvement, and a summary of current site activities.

3.1 SITE LOCATION AND DESCRIPTION

The Havertown PCP Site covers about 12 acres in Havertown, Haverford Township, Delaware County, in the southeastern portion of Pennsylvania. The site, pictured in the map below, consists of a wood treatment facility operated by the National Wood Preserver (NWP), adjacent properties, including portions of the Continental Auto Parts (CAP) and Lobb Lumber facilities and the Philadelphia Chewing Gum Company, and neighboring residential and commercial areas adjacent to Naylor's Run.

Havertown PCP Site MapThe NWP property appears to be the source of contamination at the site. Specifically, the company used pentachlorophenol (PCP) as a preservative to treat telephone poles, railroad ties, and wood for boardwalks. Reportedly, waste containing the PCP flowed from treatment units into the ground. These chemicals contaminated the area soil and ground water.

The land surrounding the site consists of commercial establishments, industries, parks, schools, and residential homes. Approximately 26,000 people live within one mile of the site. Four or five residences in the area have private wells, but all area residents have access to municipal water for drinking purposes.

3.2 SITE HISTORY AND CURRENT ACTIVITIES

The NWP facility has undergone a series of state and Federal enforcement-related activities since contamination in Naylor's Run was first discovered in 1962. In 1981, EPA conducted a Superfund emergency response action to address areas of imminent concern. In 1987, the Pennsylvania Department of Environmental Resources (PADER) initiated a remedial investigation/feasibility study (RI/FS) to identify long-term environmental concerns. The RI/FS determines the nature and extent of any contaminants at a site and evaluates cleanup alternatives.

EPA's September 29, 1989 record of decision (ROD) for operable unit one responds to findings from PADER's study. A ROD is an official EPA document which formally presents EPA's selected clean-up method for a Superfund site. The ROD stated that EPA's initial response to site contamination should include designing and installing an oil/water separator, removing staged on-site contaminated waste, and performing "no action" on on-site soils. While completing the actions from the 1989 ROD, EPA conducted an additional RI/FS to address shallow ground water contamination. In 1991, EPA signed a ROD which authorized the installation of two oil extraction wells, a ground water collection trench, and a treatment plant. Presently, EPA is completing the design of these projects, and also is examining the condition of deeper ground water in the area.

In addition to these completed and planned remedial actions, EPA has conducted several removal projects at the site. In August 1993, EPA cleaned 30 tanks and removed 97,004 gallons of liquid hazardous waste, 60 tons of hazardous waste sludge, and 55 gallons of solid hazardous wastes from the site. Next, EPA removed all above ground structures, including the cleaned tanks, from the NWP property. EPA also removed an underground storage tank, leveled the surface of the site, and constructed a barrier to prevent contaminated water and soil from moving off the site. Presently, EPA is planning another removal action which will include building a protective cap over the former NWP property and portions of the Lobb Lumber and the CAP properties. The cap is EPA's response to wide spread soil contamination at the site and will be used to prevent contact with contaminated soil, prevent rain water from trickling through the soils and moving additional contamination into the ground water, and prevent contaminated soil from blowing off site. EPA estimates that construction of the cap will begin in the spring of 1996.

SECTION 4.0: COMMUNITY INVOLVEMENT

This section of the community relations plan summarizes the history of community involvement for the Havertown PCP Site and the major concerns expressed during a recent community meeting.

4.1 HISTORY OF COMMUNITY CONCERNS

Residential complaints initially alerted local officials to the problems posed by the site in 1972. The public has been actively involved in the Havertown PCP Site since then. Some residents have reported that their complaints about an oily substance with a foul odor go back more than 25 years. Prior to initial corrective efforts in 1976, the residents were concerned because they felt that nothing was being done to correct the problem. However according to officials involved in the clean-up activity in 1976, public interest at the point was relatively low, as was media and congressional interest.

A community relations program was first implemented during EPA's sampling and monitoring activities in 1981-1982. As part of this program, EPA officials met regularly with township officials and local residents to update them on site progress. Additionally, EPA asked one local resident to help monitor the stream containment efforts. On March 24, 1982, EPA and PADER held a public meeting at the Lynnwood School to discuss their efforts to address hazards posed by the release of wood-treatment chemicals in the vicinity of Naylor's Run. At the meeting it was reported that an EPA Technical Assistance Team (TAT) was tasked to investigate citizens' reports of oil and PCP deposits downstream and reports of PCP vapors in local basements. Residents were given a 24-hour number to report any further incidents of downstream contamination or off-site vapors. EPA sent a follow-up letter to citizens who had attended the meeting to keep them informed of site progress. The letter summarized the results of field studies conducted in April, 1982, and informed residents that air monitoring and other environmental review processes would continue. In the letter, EPA cautioned residents to keep away from the stream and promised to erect warning signs. Finally, residents were given the name, address, and telephone number of a EPA public affairs representative to contact if they had any questions.

As a result of the successful community relations work in 1982, the level of interest on the part of residents and the media continued in a positive and progressive manner. On January 25, 1985, PADER issued a regional press release announcing that a public meeting would be held on February 26, 1985, to discuss community relations activities for the planned remedial action at the site. At the meeting, PADER officials briefed the residents on investigative and clean-up efforts and answered questions. On February 26, 1987, PADER mailed letters to area residents providing notice of another public meeting to be held on March 12, 1987. PADER discussed access agreements with area residents at the meeting and later distributed simplified right-of-entry consent forms.

EPA and PADER held an on-site press conference on December 19, 1987, and guided participants on a tour of Naylor's Run Creek. Following the press conference, PADER and EPA obtained permission from area residents to collect soil samples from residential properties near the site for PCP analysis. PCP was not detected in the samples collected from residential properties, although contamination was found in the drainage ditch.

In September, 1988, PADER completed its remedial investigation and issued the results. Based on the results, and following a public comment period, EPA issued a ROD for the site, which required the following actions:

In consideration of the decision to perform additional studies and clean-up efforts, EPA conducted community interviews on April 25 and 26, 1990, to discuss the concerns or interests of local residents and officials. EPA informed all interviewees of the investigation and remedial actions about to take place.

In general, all interviewees were interested in EPA activity at the site and wanted to be kept involved. Residents and township officials stated that they would like to be better informed of EPA activities in the future. According to township officials, communication efforts had been irregular.

EPA held another public meeting on July 30, 1991, to discuss its plan to address the contaminated shallow ground water at the site. The proposed plan included collecting water east of the site, before it reaches Naylor's Run, and building a water treatment plant on the NWP property to treat the collected site water. To advertise the event, EPA distributed a news release and published a public notice in local papers. Many area residents attended this meeting to get more information and to express their concerns. Overall, a majority of the community agreed that EPA's proposed plan was protective. At the close of the public comment period, EPA signed the ROD which selected its proposed plan as the remedy for the shallow ground water at the site. The ROD announcement was printed in area papers on November 13, 1991.

On December 6, 1993 EPA organized and facilitated an information meeting at the Lynnwood School to announce the removal of 96,000 gallons of wood treating chemicals from tanks and drums on site. A second removal announcement was made in May 1994. In a public notice published in local papers, EPA advised citizens that recent sampling results at the site indicated that contaminated soil posed a potential long-term threat to human health and the environment. EPA previously did not plan to address the site soil, but the recent tests determined that some type of action was necessary. EPA listed five removal alternatives in the public notice. The comment period began on June 1 and ended June 30, 1994. Based on EPA's analysis and community input, the Agency decided to cap the affected soil. This decision was announced in an October, 1994, fact sheet. EPA held meetings with the Havertown community to discuss the cap design and construction schedule on July 31, 1995, and February 8, 1996. On both occasions, EPA distributed fact sheets addressing EPA plans and community questions to meeting attendees and to residents on the site mailing list.

Although the level of clean-up activity has varied over the years, the community remains concerned and wants to be kept well informed throughout the project. According to those interviewed, a majority of community members rely on direct correspondence from EPA for information about site developments. In the future, community involvement and cooperation will be an important and essential element for the successful implementation of removal and remedial action at the site.

4.2 COMMUNITY CONCERNS

Community concern about the Havertown PCP Site began in the early 1960's, although state officials were not made aware of a problem until a number of complaints were made in 1972. Local residents and officials showed a low level of interest in the site for about a ten year period dating from 1972 to 1982.

Community involvement increased in 1982 as a result of PADER efforts to get the community to communicate their concerns. The community has maintained a moderate interest level throughout the investigative and clean-up efforts of EPA and PADER. With the expected arrival of removal teams and the planned cap construction, community members will probably become more engaged as participants. Therefore, it is important to solicit involvement and address concerns now. Following is a summary of the major concerns expressed at an EPA information meeting on July 31, 1995.

SECTION 5.0:COMMUNITY RELATIONS OBJECTIVES

EPA designed this community relations plan to facilitate interaction between the Agency and the public. EPA recommends the following objectives to support the community relations program for the Havertown PCP Site.

Maintain Effective Avenues of Communication among Local, State, and Federal Officials

In order to meet the needs of the community effectively, EPA will maintain regular contact through telephone conversations or correspondence with local, state, and other Federal officials. EPA will provide these officials with information about site activities on a regular basis so that they may respond accurately and in a timely manner to concerned residents.

Provide Site-Related Information to Interested Parties

EPA will provide information to local residents, businesses, and other interested parties regarding site-related activities and developments to increase their knowledge and understanding of site activities. EPA will provide these parties with information on scheduling, technical, program, and community relations documents related to the site.

Provide Information on the Superfund Process and How It Relates to the Site to Interested Parties

EPA will provide information to all interested parties on the Superfund process and how it relates to the Havertown PCP Site. EPA will provide these parties with information about Superfund and inform them of any new developments or changes to the Superfund program. This information will help clarify EPA's involvement at the site, educate the public about the site's inclusion in the Superfund program, and explain how the entire Superfund process works.

SECTION 6.0: COMMUNITY RELATIONS ACTIVITIES

To achieve and maintain the community relations objectives effectively and efficiently, EPA recommends the community relations activities described below for the Havertown PCP Site. EPA will conduct these activities throughout the Superfund process at the site to ensure that the public is well informed of site activities and developments and to ensure that the public has sufficient time to express its concerns. EPA is required to complete these activities under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA).

Provide a Community Involvement Facilitator

To provide accurate and timely responses to residents, state and local officials, citizen's groups, and the local media, EPA will designate a Community Involvement Coordinator (CIC) to handle inquiries and concerns regarding the site. The CIC will be responsible for maintaining open communication between EPA and parties interested in the site and for coordinating community relations activities, such as public meetings. EPA encourages the public to contact the CIC with any questions or comments about the Havertown PCP Site. The address and telephone number of the site CIC, Harold Yates, are in Appendix A of this community relations plan.

Establish and Maintain an Information Repository

EPA will establish an information repository to ensure that accurate and easily-understood information is available to the public. EPA will update the repository with site-related documents and fact sheets as they become available, so that the community is aware of on-going site activities and developments. The repository also will house the administrative record for the site. The administrative record is EPA's official compilation of documents, data, reports, and other information that support the selection of a clean-up action. The information repository will have photocopying capabilities. The repository for the Havertown PCP Site is the Haverford Township Building. The address, telephone number, and business hours are listed in Appendix C of this community relations plan.

Prepare Fact Sheets

To provide the community with information about the Superfund Program and site-related activities and developments, EPA will prepare informational fact sheets. Fact sheets are an effective means of establishing and maintaining communication with the public. The fact sheets will inform the public of current site status, future site activities, and developments in the Superfund process. EPA will prepare fact sheets two to four times a year, as site events warrant.

Maintain a Site Mailing List

To disseminate information easily and effectively to interested parties, EPA will maintain an up-to-date mailing list of those individuals, businesses, or organizations interested in the Havertown PCP Site. The list will include the names, addresses, and telephone numbers of area residents and businesses; local, state, and Federal officials; and other interested groups. EPA uses this mailing list most often for the mailing of site-related documents, such as fact sheets. EPA maintains this listing in its Region III Office in Philadelphia, PA. To protect the privacy of the listed persons, EPA will not release the list to the press or general public.

Provide News Releases to the Local Media

To ensure that the public receives accurate and timely information on site-related activities and developments at the Havertown PCP Site, EPA will contact the local news media. As site events progress and EPA reaches developmental milestones, EPA will provide information to the local news media about the purpose, location, and time of public meetings and about the availability of site-related information at the site repository. EPA will send notices announcing these events to the newspapers and television and radio stations that serve the local community.

Hold Public Meetings or Availability Sessions for Residents and Local Officials

EPA will hold meetings or availability sessions for both the public and local officials to inform the community of site activities. Public meetings offer a forum for the public to express their concerns and ask questions related to the site and site activities. They also give EPA an opportunity to meet the public. Suggested locations for public meetings are listed in Appendix C of this plan. Availability sessions offer interested citizens an opportunity to meet with EPA near the site area. These sessions are beneficial because the public can get a first hand look at site activities. EPA will hold public meetings or availability sessions for the site when significant milestones are reached during the site's progress or at the request of the community.

Additional Local Speaking Engagements

EPA is willing to attend meetings of area groups and organizations, such as the Rotary Club or League of Women Voters, to serve as a guest speaker. As a guest speaker, an EPA staff member can address concerns of the members of these organizations and maintain contact with area residents. This also provides an opportunity for members of these groups to learn more about the site and EPA's work.

Maintain Contact with Local Officials

EPA will maintain regular contact with local officials to inform them of the schedule of activities and major findings at the site. By maintaining regular contact with local officials, EPA can effectively address any public concerns that arise. As site events develop, EPA will contact local officials to keep them informed.

APPENDIX A: INTERESTED PARTIES

1. Federal Agency Officials

Harold Yates
(215) 597-4081
Community Involvement Coordinator
U.S. Environmental Protection Agency
Region III (3EA30)
1650 Arch Street
Philadelphia, PA 19103-2029

Gregory Ham
(215) 597-4750
Remedial Project Manager
U.S. Environmental Protection Agency
Region III (3HW22)
1650 Arch Street
Philadelphia, PA 19103-2029

2. State Agency Officials

Dave Kennedy
(610) 832-6199
Pennsylvania Department of Environmental Protection
Suite 6010, Lee Park
555 North Lane
Conshohoken, PA 19428

3. Federal Elected Officials

Senator Rick Santorum
(202) 224-6324
Russell Senate Building
Suite 120
Washington, DC 20510
Widener Building
(215) 864-6900
1 Penn Square, Suite 960
Philadelphia, PA 19107

Senator Arlen Specter
(202) 224-6324 530
Hart Senate Office Building
Washington, DC 20510
(215) 597-7200
600 Arch Street
Suite 9400
Philadelphia, PA 19106

Representative Curt Weldon
(202) 225-2011 2452
Rayburn House Office Building
Washington, DC 20515
(610) 259-0700
1554 Garret Road 
Upper Darby, PA 19082

4. State Elected Officials

Governor Thomas Ridge
(800) 932-0784
Office of the Governor
Main Capitol Building
Harrisburg, PA 17120

Senator Richard A. Tilghman
(610) 525-7674
406 Gatcombe Lane
Bryn Mawr, PA 19010

Representative Greg Vitali
(610) 789-3900
1001 East Darby Road
Havertown, PA 19083

5. Local Officials

Haverford Township Board of Commissioners
(610) 446-1001
Township Administration Building
2325 Darby Road
Havertown, PA 19083

Fred C. Moran, President
John D. McDonald, Vice-President
Joan F. Genthert-GianGiulio, Member
Joseph F. Kelly, Member
Ben Kapustin, Member
Joe Cirillo, Member
Carolyn Parker, Member
Anthony M. Ercole, Member
James McGarrity, Member

Thomas J. Bannar, Township Manager
(610) 446-9403
Haverford Township
Township Administration Building
2325 Darby Road
Havertown, PA 19083

Lori Hanlon-Widdop, Director/Codes Enforcement
(610) 446-1002
Haverford Township
Township Administration Building
2325 Darby Road
Havertown, PA 19083

Paul J. Winterhalter, Township Solicitor
(610) 446-1001
Haverford Township
Township Administration Building
2325 Darby Road
Havertown, PA 19083

6. Local Media

Radio and Television

WCAU Radio and Television
(215) 639-7836
City Line & Monument Avenue
Philadelphia, PA 19131

WDAS Radio
(215) 581-2100
Belmont Avenue
Philadelphia, PA 19131

WHYY Radio and Television
(215) 351-9200
Independence Mall West
Philadelphia, PA 19106

KYW Radio and Television
(215) 238-4700
Independence Mall East
Philadelphia, PA 19106

Newspapers

PHILADELPHIA INQUIRER
(215) 854-5463 440
North Broad Street, 3rd Fl.
Philadelphia, PA 19130
Advertising Contact: Ms. Joan Burak

Main Line Neighborhood Section
$19.05 per column inch (Thursday and Friday)
$22.83 per column inch (Sunday)
Deadline:
Make reservation by the week prior to publication/Send copy three days prior to publication
Circulation:
38,700 (Thursday and Friday)
71,000 (Sunday)

Pennsylvania West Section (Delaware and Chester Counties)
Rate: $15.05 per column inch
Deadline:
Make reservation by the week prior to publication/Send copy three days prior to publication
Circulation: 113,000 (Monday and Tuesday)

DELAWARE COUNTY DAILY TIMES
(610) 622-8864
500 Mildred Avenue 
Primos, PA 19018
Advertising Contact: Ms. Carol Sandone

Rate: $ 38.20 per column inch
Deadline:
Make reservation by the week prior to publication/Send copy two days prior to publication
Circulation:
60,000 (Daily - excluding Saturday)

APPENDIX B: COMMUNITY DISTRIBUTION LOCATIONS FOR FACT SHEETS

Haverford Township Building
(610) 446-1001
2325 Darby Road
Havertown, PA 19083

Haverford Township Free Library
(610) 446-3082
1601 Darby Road
Havertown, PA 19083

Havertown Post Office
(610) 789-4020
444 Township Line
Havertown, PA 19083

APPENDIX C: SUGGESTED LOCATIONS FOR INFORMATION REPOSITORY, ADMINISTRATIVE RECORD REPOSITORY, AND PUBLIC MEETINGS

1. Information and Administrative Record Repository

Haverford Township Building
(610) 446-1001
c/o Lori Hanlon-Widdop
2325 Darby Road
Havertown, PA 19083

U.S. EPA, Region III
(215) 597-3037
c/o Anna Butch
841 Chestnut Building, 9th floor
Philadelphia, PA 19107

Haverford Township Free Library
(610) 446-3082
1601 Darby Road
Havertown, PA 19083

2. Public Meeting Locations

*Lynnwood Elementary School
(610) 853-1487
Lawrence Road
Havertown, PA 19083

*Oakmont School
(610) 853-5950
Eagle Road and Hathaway Lane
Havertown, PA 19083

Haverford Township Building
(610) 446-1001
2325 Darby Road
Havertown, PA 19083

*NOTE: All arrangements for schools in Haverford Township must be made through:

Mr. Gilbert S. Countryman
(610) 853-5917
Administrative Assistant
Haverford Township School District
1801 Darby Road
Havertown, PA 19083

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