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Stanley Kessler

Community Relations Plan

for the Stanley Kessler Superfund Site
King of Prussia, Montgomery County, Pennsylvania

Prepared for
U.S. Environmental Protection Agency
Region III
1650 Arch St.
Philadelphia, Pennsylvania 19103-2029

On July 10, 1996
Under ESS Region III

Work Assignment No. ESS-008

For additional information, contact
Community Involvement Coordinator
William Hudson
hudson.william@epa.gov
800-553-2509
215-814-5532

Table of Contents

Section Page

Preface iii

  1. Overview of the Community Relations Plan
  2. EPA Background
    1. Superfund
    2. Relevant EPA Groups
    3. State Role
  3. Site Description and History
    1. Site Description
    2. Site History
  4. Community Background
    1. Community Profile
    2. History of Community Involvement and Concerns
  5. Goals of the Community Relations Plan
  6. Community Relations Activities

APPENDICES

  1. Interested Party and Contact List (excluding local residents for privacy protection)
  2. Public Meeting Location and Stenographic Information
  3. Information Repository
  4. Glossary of Technical Terms
  5. Technical Assistance Grant Information
  6. Sample Fact Sheet

FIGURES

  1. Site Location Map
  2. Site Layout Map

TABLE

  1. Community Relations Activities and Timing

Preface

This Community Relations Plan was developed for the Stanley Kessler Superfund Site (the site) under Contract Number 68-W4-0010 with the U.S. Environmental Protection Agency (EPA), Region III. EPA Region III is conducting activities at the site under the guidelines of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), a federal law passed in 1980 and commonly known as "Superfund"; the Superfund Amendments and Reauthorization Act (SARA), enacted in 1986; and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), revised in 1990.

EPA is the agency with primary responsibility for all Superfund activities at the site. The Pennsylvania Department of Environmental Protection (PADEP) acts as a support agency at the site, assisting EPA where necessary.

This Community Relations Plan is designed to enhance community involvement and facilitate two-way communication between EPA and community members. It reflects EPA's commitment to acknowledging and addressing the site-related concerns of local residents, public officials, media representatives, and other stakeholders in the long-term site cleanup. Currently, community interest in the site is minimal. The history of community involvement is discussed in Section 4.2, pages 12-14.

Section 1: Overview of the Community Relations Plan

This Community Relations Plan will be used by EPA in conducting community relations activities as part of the Superfund process at the site. EPA has a basic obligation to keep community members informed about the progress of the long-term site cleanup. In addition, EPA has an obligation to provide adequate opportunity for public input.

The Community Relations Plan comprises the six sections, plus appendices, listed below.

  1. Overview of the Community Relations Plan.
  2. EPA Background: This section provides an overview of Superfund and briefly profiles relevant EPA sections, divisions, branches, and offices. It also explains the role played by the Pennsylvania Department of Environmental Protection (PADEP).
  3. Site Description and History: This section briefly describes the site and summarizes its history from 1960 through 1994.
  4. Community Background: This section includes a profile of the community in the site area and a history of community relations at the site.
  5. Goals of the Community Relations Plan: This section lists four goals involving EPA, residents, public officials, and local news media.
  6. Community Relations Activities: This section describes the activities that EPA will conduct to achieve its community relations goals at the site.
  7. Appendices: Appendix A provides names, addresses, and telephone numbers of federal, State, and local officials; local media outlets; and other interested parties. Appendix B lists a location for public meetings and stenographic information. Appendix C provides information about the local information repository established for the site. Appendix D is a glossary of relevant technical terms. Appendix E provides Technical Assistance Grant information. Appendix F is a sample site fact sheet.

This Community Relations Plan draws on information from many sources, including EPA site files, public meetings and community interviews conducted by EPA, and input from public officials. The EPA Region III office has lead responsibility for Superfund activities at the site, and will oversee the implementation of all activities outlined in this Plan. PADEP is the support agency at the site. (See Section 2, pages 3-5, for more information about Superfund, EPA, and PADEP.)

Section 2: EPA Background

2.1 Superfund

Superfund is the nation's program to clean up uncontrolled and abandoned hazardous waste sites. The federal regulation that guides the Superfund program is the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), which was revised in 1990. The Superfund law, officially known as the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), was passed by Congress in 1980 and amended in 1986 by the Superfund Amendments and Reauthorization Act (SARA). Superfund:

Identifying Sites for Cleanup

Under the Superfund program, EPA investigates hazardous waste sites throughout America. EPA conducts an initial review of each site and, if further action is warranted, evaluates the site using the Hazard Ranking System. This is a statistical tool which assigns each site a score based mainly on the potential spread of contaminants through groundwater, surface water, or air. It also takes into account other factors, such as the location of nearby residents. EPA places the most serious sites on the National Priorities List (NPL), its roster of sites identified for possible cleanup using Superfund money. (At any point in this process--either before, during, or after EPA uses the Hazard Ranking System--EPA can take immediate action to prevent a hazardous substance release.)

Selecting and Implementing the Cleanup Plan

After EPA places a site on the National Priorities List, it supervises a Remedial Investigation and Feasibility Study. This investigation and study provide a detailed picture of site contamination and assess ways to permanently reduce or eliminate it. Next, EPA reviews the cleanup alternatives and selects a preferred alternative. EPA announces this preliminary selection in a document called the Proposed Remedial Action Plan (Proposed Plan). Following a public comment period, during which it solicits input from local residents, public officials, and other parties, EPA makes its final selection of a cleanup method. EPA announces this selection in the Record of Decision.

The next steps are Remedial Design and Remedial Action, during which EPA supervises the design and implementation of the cleanup plan outlined in the Record of Decision. When necessary, EPA can release a new Proposed Plan and amend the Record of Decision to reflect significant changes in the cleanup plan. Only after EPA has determined that all appropriate cleanup actions have been completed at a site does it delete that site from the National Priorities List.

2.2 Relevant EPA Groups

EPA manages and enforces the nation's environmental laws. Based in Washington, D.C., it includes 10 regional offices, each of which includes community relations and technical staff involved in Superfund site cleanups. EPA Region III covers Pennsylvania, Delaware, Maryland, Virginia, West Virginia, and Washington, D.C. The EPA Region III regional office, located in Philadelphia, Pennsylvania, includes several offices, divisions, branches, and sections.

Superfund Community Involvement Branch (Region III)

This section, part of EPA's Office of External Affairs, oversees communication between EPA and all residents, public officials, media representatives, and community groups associated with Superfund sites. The Superfund community involvement program for each site involves the planning, coordination, and implementation of activities designed to facilitate communication and enhance community involvement. Each site has a Community Involvement Coordinator who works closely with EPA technical staff to keep the local community informed and involved. (See Appendix A for the name, address, and telephone number of the EPA Region III Community Involvement Coordinator for the Stanley Kessler Superfund Site.)

Hazardous Waste Management Division (Region III)

This division oversees the development and implementation of Superfund program activities, as well as Resource Conservation and Recovery Act (RCRA) activities. It includes the Office of Superfund Programs, the Superfund Removal Branch, the Superfund General Remedial Branch, and the Office of RCRA Programs.

Superfund Removal Branch (Region III)

Part of EPA's Hazardous Waste Management Division, the Superfund Removal Branch manages short-term actions and emergency responses. These actions include responses to accidental releases of hazardous substances, as well as short-term work at sites on EPA's National Priorities List. Removal actions are supervised by EPA On-Scene Coordinators (OSCs).

Superfund Pennsylvania Remedial Branch (Region III)

This branch is responsible for all long-term technical work at Superfund sites in Pennsylvania, including site assessments, remedial investigations and feasibility studies, treatability tests, and remedial (cleanup) design and action. (Long-term work at Superfund sites in Virginia, West Virginia, Delaware, and Maryland is handled by the Superfund General Remedial Branch.) Each site has a Remedial Project Manager, who supervises the work done by other EPA technical staff, private contractors, and other parties involved in site study and cleanup. (See Appendix A for the name, address, and telephone number of the EPA Region III Remedial Project Manager for the Stanley Kessler Superfund Site.)

2.3 State Role

Pennsylvania Department of Environmental Protection

The Pennsylvania Department of Environmental Protection (PADEP) acts as the support agency during EPA-led study and cleanup at federal Superfund sites in Pennsylvania. PADEP staff involved in activities at the Stanley Kessler Superfund Site include the PADEP Project Officer and Public Affairs Officer assigned to the site. (See Appendix A for the name, address, and telephone number of these PADEP contact persons.) PADEP's involvement in the site cleanup includes reviewing and commenting on site work plans and studies, participating in community relations activities, and providing technical assistance to EPA.

Section 3: Site Description and History

3.1 Site Description

The Stanley Kessler site is a 3.21-acre property located in an industrialized area of King of Prussia, Upper Merion Township, Montgomery County, Pennsylvania. (See Figure 1, page 9.) The site property contains a one-story masonry building where wire is degreased and respooled. (See Figure 2, page 10.) Materials used for current operations are stored on a level, paved area south of the building. This paved area is enclosed by an eight-foot-high chain link fence. Since approximately 1963, solvents have been used for degreasing; prior to 1963, workers used acids and bases to clean metals. During the period when acids were used, wastes were washed down a series of floor drains to an on-site acid waste neutralization system. This neutralization system involved a septic tank (Tank 1) and a cesspool (Tank 2). Tank 1 consisted of a concrete vessel, containing crushed limestone to neutralize the acid, with a baffled overflow to Tank 2. Tank 2 was a cinder-block vessel which had no structural bottom.

3.2 Site History

Since 1960, the Stanley Kessler Company has operated a welding wire respooling facility on the site. From the 1960s to the early 1980s, workers recycled metal wire in one building on the site. During that time, workers handled volatile organic compounds (VOCs) including trichloroethylene (TCE) and 1,1,1 trichloroethane (TCA). VOCs, commonly used as solvents and degreasers, are hazardous, carbon-based chemicals that easily evaporate in the open air. VOCs can also seep into the soil and pollute underground water supplies (ground water).

From 1963 to 1978, facility practices resulted in the spilling of solvent degreasers into floor drains that fed into the on-site septic tank/cesspool system. This resulted in the contamination of soil and groundwater at the site. The floor drains were closed in 1978.

In April 1979, TCE was detected in the Upper Merion Reservoir located one-half mile north of the site. This reservoir is a major source of drinking water for the Philadelphia Suburban Water Supply, which serves about 800,000 people. Water from this reservoir is treated prior to distribution. In September 1979, the Pennsylvania Department of Environmental Protection (PADEP) directed the Stanley Kessler Company to install monitoring wells to define the extent of groundwater contamination, develop a recovery plan, eliminate all sources of groundwater pollution, and prepare a Pollution Incident Prevention Plan for the facility. A contractor hired by the Stanley Kessler Company installed on-site monitoring wells. Analysis of samples from the wells revealed the presence of several contaminants in site soil and groundwater. In 1980, EPA filed suit against the company, citing violations of environmental laws governing waste disposal and drinking water.

In 1981, the septic tank and cesspool system were dug up and disposed of off-site, along with a quantity of contaminated soil and sludge. The hole left by the excavated septic tank, cesspool, and soil was filled with gravel and covered with topsoil. Subsequent sampling by EPA determined that contamination present in site soil and groundwater posed a potential threat to human health and the environment. In September 1982, EPA finalized the Stanley Kessler site on the National Priorities List, its roster of abandoned or uncontrolled hazardous waste sites targeted for potential cleanup under the Superfund program.

In 1984, the Stanley Kessler Company installed a small on-site treatment system to address groundwater contamination. The pumped groundwater was passed through a high-pressure air stripper, which removed the contaminants and allowed them to evaporate. The treated water was then discharged back into the earth's surface via an infiltration gallery located in the area of the former septic tank and cesspool system. This system operated until 1990.

In January 1991, a Consent Order signed by EPA and the Stanley Kessler Company was filed with the court. Under the terms of the Consent Order, the Stanley Kessler Company agreed to complete a Remedial Investigation and Feasibility Study (RI/FS). The Remedial Investigation determined the nature and extent of contamination; the Feasibility Study outlined various methods to clean it up. As part of the RI/FS, a Risk Assessment was conducted to evaluate the risks to public health and the environment posed by site contamination.

Following its approval of the final Remedial Investigation and Feasibility Study reports, EPA developed a Proposed Plan. The Proposed Plan, issued by EPA on June 20, 1994, highlighted EPA's Preferred Remedial Alternative, its preferred remedy for site contamination. This alternative (Alternative 4) involved extraction of contaminated groundwater, treatment with granular activated carbon, and discharge of the treated water to an on-site intermittent stream.

June 20, 1994 also marked the start of a 30-day public comment period on the Proposed Plan and previous site studies. As part of the public comment period, EPA held a public meeting on June 30. After extending the public comment period an additional 30 days and after reviewing community and state input, EPA made its final selection of Alternative 4 to address Site contamination. EPA announced this selection in a Record of Decision document, issued on September 30, 1994.

Figure 1

Site Location Map

[Site location map to go here.]

Figure 2

Site Layout Map

[Site layout map to go here.]

Section 4: Community Background

4.1 Community Profile

The Stanley Kessler Superfund site is located in King of Prussia, one of four communities that make up Upper Merion Township in Montgomery County, Pennsylvania. Established in 1713, Upper Merion Township originally was a rural community consisting of farmlands and large estates. However, the post-World War II development of major throughways such as the Pennsylvania Turnpike and the Schuylkill Expressway helped transform the King of Prussia area into a center of economic activity.

Presently, Upper Merion Township is one of the Philadelphia area's premiere office and retail communities. It employs more people than any other municipality in Montgomery County. The township boasts a diverse community, with approximately 26,000 residents and more than 50,000 daily workers. Although the King of Prussia area has experienced a slight decline in population over the past ten years, industry in the community has flourished with such attractions as the Court and Plaza Mall, and the Valley Forge Plaza & Convention Center. Since 1980, over 1.5 million square feet of office and light industrial space have been developed in the township, a large portion of which is located in King of Prussia. Primary employers in the area include Martin Marietta, SmithKline Beecham, and Philadelphia Gear Corporation.

Upper Merion Township is governed by a township manager and an elected board of five supervisors which oversee all township activities. An appointed Environmental Advisory Council keeps township officials notified of all relevant environmental happenings in the community. The entire township is serviced by public water and sewer facilities. Emergencies are handled by a full-time police force and volunteer fire companies. Medical facilities include Montgomery Hospital and Suburban General Hospital, both of which are located in Norristown.

The immediate site community includes an industrial park, apartment and townhouse complexes, single-family dwellings, local businesses, and a day care center. Although the site cleanup is a priority for local officials, interest by local residents appears to be minimal.

4.2 History of Community Involvement and Concerns

Information used in the development of this Community Relations Plan does not include any reference to site-related comments or questions from residents or local officials prior to January 1993. That month, concurrent with investigations and studies at the site, the EPA Community Involvement Coordinator and EPA Remedial Project Manager assigned to the site attended a meeting of the Upper Merion Township supervisors to update them on the progress of site cleanup activities and gauge community interest in the site.

In June 1994, EPA held a public meeting to discuss the results of the completed Remedial Investigation/Feasibility Study and to present the Proposed Remedial Action Plan, which highlighted EPA's preferred cleanup method. EPA wrote a public notice announcing its release of the Proposed Plan, soliciting public comment on the Proposed Plan, and announcing the June 30 public meeting, and placed the notice in three local newspapers. Only nine persons attended the public meeting: three reporters, three Upper Merion Township officials, two representatives from the Pennsylvania Department of Environmental Protection (PADEP), and one citizen. The reporters present represented the following newspapers: The Times Herald, The King of Prussia Courier, and The Philadelphia Inquirer "Neighbors" section. EPA also opened a 30-day public comment period to allow community members to comment on and ask questions about the cleanup methods outlined in the Proposed Plan. In response to a timely request, EPA extended the comment period an additional thirty days.

EPA produced informational fact sheets in January 1993 and October 1994 to provide updates on site activities. EPA placed copies of both fact sheets in the local EPA information repository and made copies available to local officials. The October 1994 fact sheet was mailed to elected officials, media representatives, and other interested parties, as well as a small number of homeowners in the immediate site area.

In fall 1994, the EPA Community Involvement Coordinator for the site traveled to King of Prussia to conduct community interviews and document site-related concerns. Members of the Environmental Advisory Council, interviewed by EPA in October 1994, were unable to recall any instances in which local residents had contacted the Council for information about the site. One possible reason for this apparent lack of interest is the absence of any currently identified, immediate public health threat associated with site contamination. All residences and local businesses in the site area are connected to the public water supply, which is not affected by site groundwater contamination.

Comments and questions received by EPA during the fall 1994 community interviews in King of Prussia, follow-up telephone interviews, and the June 30, 1994 public meeting illuminated the issues summarized below.

Duration of the Site Cleanup

Some individuals expressed concern about what they perceive as the slow progress of site studies and cleanup actions. Some individuals stated that community involvement is low because residents in the area are not aware of ongoing activities and do not understand the Superfund remedial process. In addition, some community members believe that an extended amount of time has already been spent on the cleanup, and that any additional delays might have a negative impact on future land development in the area.

Reduced Property Values

Some of the individuals interviewed by EPA feel that the ongoing site cleanup can have or has had a negative impact on property values in the site area. One individual stated that there is a stigma associated with Superfund sites and suggested that EPA provide information about the site property and its beneficial use following the site cleanup.

Communication Between EPA and Community Members

Some of the individuals contacted by EPA referred to a general lack of awareness of the site history and site cleanup. Some of these individuals suggested that EPA distribute site updates more often. Suggested topics for EPA site updates include the cleanup schedule, the progress of cleanup work, completion dates, and potential emergency situations.

Some community members stated that changes in EPA site personnel have had or can have a negative impact on two-way communication between EPA and the community. Input provided during EPA community interviews indicates that many community members do not fully understand the Superfund process and the Technical Assistance Grant (TAG) program. Several community members have suggested that EPA utilize local newspapers, the township newsletter, and local Government Access Channel 8 to disseminate information to the site community.

One member of the Environmental Advisory Council interviewed by EPA stated that residents who know about the Council generally see it as a "watchdog" on local environmental issues and feel that the Council is a good point-of-contact for site activities.

Impact of Site Contamination

Input received by EPA to date indicates that community concern about site contamination is minimal. None of the individuals contacted by EPA expressed any major health and safety concerns about current site conditions. In response to questions from EPA, some individuals expressed concern about the possible future impact of site contamination on the community. Although residents and businesses are connected to the public water supply, some community members are concerned about potential migration of site contaminants.

Section 5: Goals of the Community Relations Plan

The Community Relations Plan for the Stanley Kessler Superfund Site has four goals involving effective two-way communication between EPA and community members. The goals listed below involve the cooperative efforts of the EPA Community Involvement Coordinator and Remedial Project Manager for the site, as well as other EPA staff as needed.

  1. Provide community members with useful information about the Superfund process.
    • EPA will use printed materials, public meetings, and other means to explain the Superfund process and indicate how site Remedial Design and Remedial Action activities fit into the general Superfund process.
  2. Provide timely, site-specific information to community members.
    • EPA will update residents, local officials, the Environmental Advisory Council, and other interested parties on the progress of the site cleanup. In addition, EPA will make site documents available to the public.
  3. Provide opportunities for community input.
    • EPA staff will listen to and address site-related comments and questions voiced by community members.
  4. Enhance communication between EPA, local officials, and the media.
    • EPA will provide Upper Merion Township officials and the Environmental Advisory Council with timely information about site activities, and will invite and address questions from them. Information will also be disseminated to the local media outlets to provide community members with the information needed to play an informed role in the site cleanup.

Section 6: Community Relations Activities

Listed and described below are 16 community relations activities for the Stanley Kessler Superfund Site designed to achieve the goals summarized in Section 5. Please note that the sequential numbers which accompany the 16 community relations activities are for reference only, and do not necessarily indicate their relative importance. The anticipated time frame for these activities is indicated in the table on pages 22-23. Comments in [bracketed italics] identify those activities which EPA has conducted and will conduct as required by the Superfund Amendments and Reauthorization Act (SARA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).

Notify residents of upcoming site activities on a regular basis.

Purpose
EPA will provide residents with dates and times of upcoming site activities in order to minimize any disruptions to their normal schedules, enhance their participation in the site cleanup, and enable them to provide informed input to EPA.
Contents
Printed announcements, telephone calls, and availability sessions will focus on current and upcoming site cleanup work; announce the release of key documents and other milestones; and publicize the time, place, and purpose of public meetings.
Timing
EPA will notify residents as needed.

Notify local media of upcoming site activities on a regular basis.

Purpose
EPA will take a proactive approach and disseminate information about site activities before they occur. This proactive approach involves issuing press releases, telephoning media representatives, and holding news briefings to provide the media with timely information. In addition, EPA will provide information to Township Lines,the Upper Merion Township newsletter. Also important is coordination between EPA and PADER: to the extent practicable, EPA will confer with PADER and strive to coordinate its media briefings and updates with relevant PADER activities.
Contents
News releases, telephone calls, and briefings will focus on current and upcoming site activities; announce the release of key documents and other milestones; and publicize the time, place, and purpose of public meetings.
Timing: EPA will update local media as needed.

Designate an EPA primary contact person to handle site inquiries.

Purpose
EPA has designated a primary contact person to ensure that EPA statements about the site are coordinated and consistent.
Contact
The EPA Community Involvement Coordinator assigned to the site is the primary contact person. The Community Involvement Coordinator will work closely with EPA's Remedial Project Manager for the site.

Respond promptly and accurately to inquiries from residents, public officials, the Environmental Advisory Council, government agencies, and the media.

Purpose
Maintaining the two-way flow of information between EPA and other parties will strengthen community involvement and enhance cooperation between EPA and other agencies involved in the site cleanup, such as PADEP. Timely responses to media and Environmental Advisory Council inquiries will increase public awareness of site activities.
Timing
EPA will respond to inquiries as needed.

Write and distribute site fact sheets.

Purpose
Site fact sheets mailed to residents, members of the Environmental Advisory Council, public officials, and other interested parties will provide updates about site activities and indicate their relation to the Superfund process.
Contents
Fact sheets may include: information about past, current, and upcoming site activities; question and answer sections focusing on community concerns; overviews of remedial technologies; site maps; listings of EPA and PADEP contact persons; and tear-off forms so that residents can add their names to the EPA site mailing list.
Timing
EPA will issue fact sheets as needed to update the community.

Maintain contact with the Environmental Advisory Council.

Purpose
Good communication with this point of contact between EPA and community members will help keep local officials and residents informed of site activities. (See Appendix A for the names, addresses, and telephone numbers of Environmental Advisory Council members and township officials.)
Timing
EPA will maintain contact as needed to discuss site developments and community relations activities.

Maintain and update the local information repository.

Purpose
EPA will update the information repository's collection of site-specific EPA documents and information about the Superfund process so that citizens can follow the progress of EPA's site cleanup and provide informed comment. [EPA will conduct this activity as required by SARA and the NCP.]
Contents
The information repository includes the Administrative Record file, which comprises the Remedial Investigation and Feasibility Study reports, the Proposed Remedial Action Plan, and other documents used by EPA to make its selection of long-term cleanup methods. The repository also includes the Community Relations Plan, information about the Technical Assistance Grant program, and other information about the site and the general Superfund process.
Location
EPA has established a local information repository at the Upper Merion Township Library. (See Appendix C for the address and telephone number.)
Timing
EPA will include new site documents in the repository as they are released.

Provide Technical Assistance Grant information.

Purpose
EPA will provide information about the Technical Assistance Grant program and review grant applications from qualified groups. (See Appendix E)
Timing
EPA will provide information and process applications as needed.

Release a Proposed Plan and hold a public comment period on it.

Purpose
EPA released a Proposed Plan on June 20, 1994. As required, EPA reviewed all comments received during the public comment period before making its final selection of a cleanup alternative. This selection was announced in the Record of Decision. [EPA released the Proposed Plan as required by SARA and the NCP.]
Timing
EPA public comment periods on Proposed Plans last for a minimum of 30 days, and can be extended. The public comment period on the Proposed Plan for the Stanley Kessler Superfund Site began on June 20, 1994, was extended an additional thirty days, and ended on August 18, 1994.

Publish public notices.

Purpose
EPA will use public notices in local newspapers to inform the community of key site developments, public meetings, and the release of site documents. [EPA used public notices to announce the release of the the Proposed Plan and the Record of Decision, as required by SARA and the NCP.]
Contents
Notices include relevant dates, times, and locations, as well as the name, address, and phone number of the EPA primary contact person. Notices regarding site documents briefly summarize the documents.
Timing
EPA has placed public notices to announce the release of the Proposed Plan and the Record of Decision. In addition, EPA will continue to place public notices for other reasons as needed.

Conduct public meetings.

Purpose
Public meetings are an efficient means of updating the community on site developments and addressing community questions and comments. [EPA held a public meeting during the public comment period on the Proposed Plan, and will hold a public meeting following the completion of the final engineering design for the site cleanup, as required by SARA and the NCP.]
Participants
The EPA Community Involvement Coordinator, the EPA Remedial Project Manager, and other EPA staff as needed will participate in the meetings. EPA welcomes the participation of staff from PADEP.
Timing
On June 30, 1994, EPA held a public meeting on the Proposed Plan. EPA will hold a public meeting following the completion of the final engineering design for the Site cleanup. In addition, EPA will hold other meetings as needed. If appropriate, and as needed, EPA will investigate the possibility of having EPA public meetings videotaped and shown on Government Access Channel 8.

Obtain a transcript of the public meeting on the Proposed Plan.

Purpose
EPA obtained an official transcript of the public meeting on the Proposed Plan, and subsequently made the transcript available to the public in order to document all information presented at the public meeting. [EPA conducted these activities as required by SARA and the NCP.]
Contents
The transcript is a verbatim record of the public meeting.
Timing
The transcript was placed in the local information repository after the public meeting on the Proposed Plan.

Prepare a Responsiveness Summary.

Purpose
The Responsiveness Summary summarizes input received by EPA during the public comment period on the Proposed Plan. [EPA prepared a Responsiveness Summary as required by SARA and the NCP.]
Contents
The Responsiveness Summary summarizes public comments and questions regarding the cleanup alternatives described in the Proposed Plan, as well as EPA responses.
Timing
EPA released the Responsiveness Summary as an attachment to the new Record of Decision.

Conduct informal meetings and workshops.

Purpose
Informal meetings and workshops on site issues will enable EPA to share information and solicit input from the community.
Participants
The EPA Community Involvement Coordinator, the EPA Remedial Project Manager, other EPA staff, and other individuals as needed will participate in the meetings and workshops.
Timing
EPA will schedule informal meetings and workshops as needed, based on community interest.

Maintain and update site mailing lists.

Purpose
EPA maintains an up-to-date listing of federal, state, and local officials; local media; Environmental Advisory Council members; and other interested parties. EPA also maintains a separate, confidential list of residents in the site area. EPA uses both lists in mailing site fact sheets, providing telephone updates, and conducting other community involvement activities as needed.
Contents
See Appendix A for the names, addresses, and telephone numbers of federal, state, and local officials; local media; and other interested parties.
Timing
EPA will update the lists as needed to reflect new information.

Revise the Community Relations Plan.

Purpose
EPA will revise the Community Relations Plan, if necessary, to address community needs and concerns regarding the design and implementation of the site remedy which are not currently addressed in the Community Relations Plan. [EPA will conduct this activity, if necessary, as required by SARA and the NCP.]
Contents
The Revised Community Relations Plan will update the information presented in the previous version of the Community Relations Plan.
Timing
EPA will revise the Community Relations Plan as needed.

Table 1:Community Relations Activities and Timing

Activity Timing

Notify residents of upcoming site activities.

As needed.

Designate an EPA primary contact person.

Person has been designated.

Respond promptly and accurately to inquiries.

As needed.

Write and distribute site fact sheets.

As needed.

Maintain contact with the Environmental Advisory Council.

As needed.

Maintain and update the local information repository.

As new site documents are released.

Provide Technical Assistance Grant information

As needed.

Release a Proposed Plan and hold a public comment period on it.

Minimum 30-day public comment period.

Publish public notices to announce the release of the Proposed Plan and the Record of Decision, and for other reasons.

As needed.

Conduct public meetings to discuss the Proposed Plan and the final engineering design, and for other reasons.

As needed.

Obtain a transcript of the public meeting on the Proposed Plan.

Obtained and placed in the local information repository after the public meeting.

Prepare a Responsiveness Summary.

Released as an attachment to the Record of Decision.

Conduct informal meetings and workshops.

As needed, based on community interest.

Maintain and update site mailing lists.

Lists have been established; update as needed.

Revise the Community Relations Plan.

As needed.

APPENDIX A: Interested Party and Contact List

A. Federal Elected Officials

Representative Curt Weldon
2452 Rayburn House Office Building
Washington, DC 20515
(202) 225-2011
Brian Taylor
Legislative Assistant

1554 Garrett Road
Upper Darby, PA 19082
(610) 259-0700

Senator Arlen Specter
303 Hart Senate Office Building
Washington, DC 20514
(202) 224-4254
Daniel Renberg
Legislative Assistant

9400 Federal Building
600 Arch Street
Philadelphia, PA 19106
(215) 597-7200

Senator Rick Santorum
120 Russell Senate Office Building
Washington, DC 20510
(202) 224-6324
David French
Legislative Assistant

Widener Building
1 South Penn Square, Suite 960
Philadelphia, PA 19107
(215) 864-6900

B. State Elected Officials

Representative Colleen Sheehan
House P.O. Box 202020
Main Capitol Building
Harrisburg, PA 17120
(717) 783-3038

295 South Gulph Road
King of Prussia, PA 19406
(610) 962-9950

Senator Richard Tilghman
Room 281
Main Capitol Building
Harrisburg, PA 17120
(717) 787-5544

406 Gatcombe Lane
Bryn Mawr, PA 19010
(610) 834-7234

C. Local Officials

Mario Mele, Chairman
Montgomery County Courthouse
P.O. Box 311
Swede and Airy Streets
Norristown, PA 19404
(610) 278-3020

Richard Buckman
Montgomery County Courthouse
P.O. Box 311
Swede and Airy Streets
Norristown, PA 19404
(610) 278-3020

Joseph Hoeffel
Montgomery County Courthouse
P.O. Box 311
Swede and Airy Streets
Norristown, PA 19404
(610) 277-9500

Ronald G. Wagenmann
Township Manager
Upper Merion Township
175 West Valley Forge Road
King of Prussia, PA 19406
(610) 265-8722

Donna Williams
Public Information Officer
Upper Merion Township
175 West Valley Forge Road
King of Prussia, PA 19406
(610) 265-2600

John Waters
Fire Marshall/Director of Safety and Code Enforcement
Upper Merion Township
175 West Valley Forge Road
King of Prussia, PA 19406
(610) 265-2600

Anthony Volpi
Chairman
Upper Merion Township Supervisors
175 West Valley Forge Road
King of Prussia, PA 19406
(610) 337-8364

Barbara Fraley
Supervisor
Upper Merion Township Supervisors
175 West Valley Forge Road
King of Prussia, PA 19406
(610) 265-2600

William Wall
Supervisor
Upper Merion Township
1288 Suplee Lane
Conshohocken, PA 19428
(610) 828-8687

Robert Clifton
Supervisor
Upper Merion Township
175 West Valley Forge Road
King of Prussia, PA 19406
(610) 265-2761

Ralph Volpe
Supervisor
Upper Merion Township
175 West Valley Forge Road
King of Prussia, PA 19406
(610) 265-8266

D. Environmental Advisory Council

Francis Schultz, Jr.
Chairman
Environmental Advisory Council
460 Timber Circle
Wayne, PA 19087
610-687-6851
610-687-6852

Lewis Luchie, Jr.
Member
Environmental Advisory Council
971 Steven Lane
Wayne, PA 19087
610-688-7051

William F. Dunn
Member
Environmental Advisory Council
Upper Merion Township
175 West Valley Forge Road
King of Prussia, PA 19406
610-265-2606

E. EPA Region III Officials

William Hudson (3EA30)
Community Involvement Coordinator
U.S. Environmental Protection Agency
Region III
1650 Arch St.
Philadelphia, PA 19103-2029
215-814-5532 or (800)
800-553-2509
hudson.william@epa.gov

Ruth Scharr (3HW21)
Remedial Project Manager
U.S. Environmental Protection Agency
Region III
1650 Arch St
Philadelphia, PA 19103-2029
215-814-3191
scharr.ruth@epa.gov

F. Pennsylvania Department of Environmental Protection

Pennsylvania Department of Environmental Protection
Southeast Regional Office
Lee Park, Suite 6010
555 North Lane
Conshohocken, PA 19428
610-832-6000

G. Media

Newspapers

Times Herald
410 Markley Street, P.O. Box 591
Norristown, PA 19404
610272-3820
610-272-9515 (FAX)

Montgomery County Observer
1050 DeKalb Pike
Blue Bell, PA 19422
610-277-8787
610-277-8788 (FAX)

Today's Post
160 Gulph Road
King of Prussia, PA 19406
610-337-1700
610-337-9850 (FAX)

King of Prussia Courier
134 North Wayne Avenue
Wayne, PA 19087
610-688-3000
610-254-8522 (FAX)

Philadelphia Inquirer
Montgomery County Neighbors Section
400 North Broad Street
Philadelphia, PA 19131
215-854-5454
215-854-4788 (FAX)

Radio Stations

KYW
Independence Mall East
Philadelphia, PA 19106
215-238-4700
215-238-4545 (FAX)

WHYY
150 North 6th Street
Philadelphia, PA 19106
215-351-9200
215-351-0398 (FAX)

WWDB
166 East Levering Mill Road
Bala Cynwyd, PA 19001
215-668-4400
215-668-4468 (FAX)

Television Stations

WCAU-TV 10 (NBC)
City Line Avenue and Monument Road
Philadelphia, PA 19131
215-668-5700
215-668-5533 (FAX)

WPVI-TV 6 (ABC)
4100 City Line Avenue
Philadelphia, PA 19131
215-878-9800
215-878-8920 (FAX)

KYW-TV 3 (CBS)
Independence Mall East
Philadelphia, PA 19106
215-238-4991
215-238-4657 (FAX)

WTXF-TV 29 (FOX)
330 Market Street
Philadelphia, PA 19106
215-925-2929
215-592-1535 (FAX)

Suburban Cable
251 West DeKalb Pike, Suite EG2
King of Prussia, PA 19406
610-265-4233
610-265-2376 (FAX)
(Note: Upper Merion Township hearings are shown on Channel 8.)

H. Other Interested Parties

Chris Mattern
Lord, Bissell, and Brook
115 South La Salle Street
Chicago, IL 60603

Appendix B: Public Meeting Location and Stenographic Information

Public Meeting Location

Upper Merion Township Building
175 West Valley Forge Road
King of Prussia, PA 19406

Contact:
Ms. Linda Rubin, Township Secretary
610-265-2600

Resources:
Overhead projector, overhead screen, tables, chairs, air
conditioning, public address system, podium. The building is
accessible to the handicapped.

Stenographic Information

All Points Reporting
723 Erlen Road
Norristown, PA 19404

Contact:
Carol Skipper
610-564-5380

Has experience with EPA meetings.

Court Reporting Associates
4 Penn Center Plaza
Suite 520
Philadelphia, PA 19107

Contact:
Margarite
(215) 564-0466

Has experience with environmental hearings.

Karasch and Associates
301 West Market Street
West Chester, PA 19382

Contact:
Rita Walsh
(610) 696-8010

Has experience with EPA meetings.

Information Repository

Upper Merion Township Library
175 West Valley Forge Road
King of Prussia, PA 19406

Contact:
Mr. Karl Helicher, Director
(610) 265-4805

Hours:
Monday to Thursday, 9:00 a.m. to 9:00 p.m.
Friday, 9:00 a.m. to 5:00 p.m.
Saturday, 10:00 a.m. to 5:00 p.m. (10:00 a.m. to 12:00 p.m.
during July & August)
Sunday, 1:00 p.m. to 4:30 p.m. (closed Sundays during July &
August)

Resources:
Photocopiers, small meeting rooms

Appendix D: Glossary of Technical Terms

Administrative Record
The official file containing the Remedial Investigation report, Risk Assessment, Feasibility Study report, and other documents which provide the basis for EPA's selection of a remedial (long-term cleanup) alternative at a Superfund site.
Cleanup
An action taken to deal with a release or threatened release of hazardous substances that could adversely affect public health and or the environment. The word "cleanup" is used to refer to both short-term (removal) actions and long-term (remedial response) actions at Superfund sites.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
A federal law (commonly known as "Superfund") passed in 1980 and modified in 1986 by the Superfund Amendments and Reauthorization Act (SARA). The law gave EPA the authority to investigate sites where there is a suspected threat to public health or the environment caused by the release or potential release of hazardous substances. The law also created a special tax on the chemical and petroleum industries. Monies collected under the tax are deposited into a trust fund to be used to clean up abandoned or uncontrolled waste sites. Under the law, EPA can: pay for site cleanup when the parties responsible for site contamination cannot be located or are unwilling or unable to perform the cleanup; or take legal action to force parties responsible for site contamination to clean up the site or pay back the federal government for the cost of the cleanup.
Feasibility Study (FS)
A study which identifies and screens site cleanup alternatives, and analyzes the technologies and costs associated with these alternatives.
Groundwater
Fresh water usually located in geological formations beneath the earth's surface (aquifers) containing fresh water. Groundwater can be a major source of drinking water.
Information Repository
A collection of documents about a specific Superfund site and the general Superfund process. EPA usually places the information repository in a public building that is conveniently located, is accessible to the handicapped, and contains a photocopying machine.
National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
The federal regulation that guides the Superfund program. The NCP was revised in 1990.
National Priorities List (NPL)
EPA's list of the nation's most serious uncontrolled or abandoned hazardous waste sites identified for possible long-term cleanup using Superfund money. EPA updates the NPL at least once a year.
Proposed Remedial Action Plan (Proposed Plan)
A Superfund site document which reviews the cleanup alternatives presented in the site Feasibility Study and identifies EPA's Preferred Alternative. EPA must actively solicit public review of and comment on all the alternatives under consideration.
Public Comment Period
A period during which the public can review and comment on various documents and EPA actions. For example, EPA holds a public comment period when it proposes to add sites to the National Priorities List. EPA also holds a minimum 30-day public comment period to enable community members to review and comment on a Proposed Plan.
Record of Decision (ROD)
A public document that announces and explains the cleanup method(s) EPA will use at a National Priorities List site. The ROD is based on information and technical analysis generated during the Remedial Investigation and Feasibility Study and on EPA's consideration of comments received during the public comment period.
Remedial Action
The actual construction or implementation phase that follows the Remedial Design of the selected cleanup alternative at a National Priorities List site.
Remedial Design
An engineering phase that follows the Record of Decision in which technical drawings and specifications are developed for the remedial action at a site.
Remedial Investigation (RI)
A study which identifies the nature and extent of site contamination and determines the threat this contamination poses to human health and the environment.
Removal Action
An immediate, short-term cleanup action that addresses a release or threatened release of hazardous substances that does, or potentially could, pose an immediate threat to public health and/or the environment.
Resource Conservation and Recovery Act (RCRA)
A federal law that established a regulatory system to track hazardous substances from the time of generation to disposal. The law requires that safe and secure procedures be used in treating, transporting, storing, and disposing hazardous substances. RCRA is intended to prevent the creation of new, uncontrolled hazardous waste sites.
Responsiveness Summary
A summary of oral and written comments (and EPA responses to those comments) which EPA receives during the public comment period. The Responsiveness Summary is part of the Record of Decision.
Superfund
The name commonly used to refer to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
Superfund Amendments and Reauthorization Act (SARA)
Modifications to CERCLA enacted on October 17, 1986.
Surface Water
Ponds, lakes, rivers, and other bodies of water naturally open to the atmosphere.
Technical Assistance Grant (TAG)
An EPA grant of up to $50,000 which can be awarded to a bona fide citizens group in a Superfund site area. The grant enables that group to hire a technical expert to review and interpret site reports issued by EPA or other parties.

APPENDIX E: Technical Assistance Grant Information

EPA provides Technical Assistance Grants (TAGs) of up to $50,000 as part of its Superfund community relations program. The Technical Assistance Grant program enables citizens in a site area to hire a technical expert to review and interpret site reports generated by EPA or other parties. Complete information on Technical Assistance Grants is contained in an EPA document titled The Citizens' Guidance Manual for the Technical Assistance Grant Program, which is made available with all site information at the local information repository designated in Appendix C of this Community Relations Plan. For additional information on how to apply for a Technical Assistance Grant, contact:

William Hudson (3EA30)
Community Involvement Coordinator
U. S. EPA Region III
1650 Arch St.
Philadelphia, PA 19103-202
215-814-5532

EPA accepts applications for Technical Assistance Grants as mandated by the Comprehensive Environmental Response, Compensation, and Liability Act, as amended by the Superfund Amendments and Reauthorization Act. Only one group per site can receive a Technical Assistance Grant, so EPA urges local groups to join together to apply.

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