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Malvern TCE

Final Community Relations Plan: May 1996

U.S. Environmental Protection Agency
Office of External Affairs
Philadelphia, PA 19107

The U.S. Environmental Protection Agency's (EPA) Superfund Community Relations Program is committed to promoting communication between citizens and the Agency.

EPA's community relations activities at the Malvern TCE Site are designed to inform the public of the nature of the environmental issues associated with the site, the responses under consideration to remedy these issues, and the progress being made to implement the remedy.

Citizens are given the opportunity to comment on, and provide input to, decisions about clean-up actions at the Malvern TCE Site.

For information about EPA's Community Relations Program at the Malvern TCE Superfund Site contact Carolyn Szumal, Community Involvement Coordinator, at 1-800-553-2509.

TABLE OF CONTENTS

  1. Overview of the Community Relations Plan
  2. Chemclene Corporation, the Community, and EPA
    1. The Site From 1952 to 1993
    2. The Site From 1993 to Present
    3. Chemclene Corporation's Current Operations
  3. Community Background
    1. Summary of Community Concerns for the Site
    2. EPA's Response to Community Concerns
    3. Summary of Communication Needs
  4. EPA's Community Relations Program
    1. EPA's Immediate Community Relations Activities for the Site
    2. EPA's On-going Community Relations Activities for the Site
    3. EPA's Planned Community Relations Activities for the Site
  5. Profile of EPA's Efforts to Involve the Community
  1. About EPA
  2. Technical Assistance Grant (TAG) Information
  3. Interested Party and Contact List
  4. The World Wide Web
  5. Information Repository Locations
  6. Fact Sheets for the Malvern TCE Superfund Site
  7. Glossary of Technical Terms

ABOUT CHEMCLENE CORPORATION

1952-1992
Chemclene Corporation recycled industrial cleaning solvents and sold distilled solvents
1980-1981
Chemclene Corporation and PADER tested residential water wells and on-site wells, discovering TCE contamination
1981-1984
Chemclene Corporation removed drums of waste and soil from its property
1982-1992
Chemclene Corporation periodically tested residential wells and periodically replaced filters
1982
EPA placed the Site on the National Priorities List
1988
Chemclene Corporation agreed to conduct study
1992
Chemclene Corporation failed to meet EPA's hazardous waste facility permitting requirements
1993
EPA transferred Chemclene Corporation to the Superfund Site Program and took control of clean-up activities

Section 1.0: Overview of the Community Relations Plan

EPA developed this Community Relations Plan to encourage two-way communication between the community surrounding the Malvern TCE Superfund Site and EPA and to encourage community involvement in site activities. EPA will utilize the community relations activities outlined in this plan to increase communication and involvement.

This Community Relations Plan addresses Chemclene Corporation's relationship to the community and EPA (Section 2.0), provides a background of the community (Section 3.0), presents EPA's community relations program (Section 4.0), and provides a profile of EPA's efforts to involve the community (Section 5.0). EPA drew upon several information sources to develop this plan, including community interviews, site files, and an information meeting. The EPA Region III Office will oversee the implementation of the community relations activities outlined in this plan.

Section 2.0: Chemclene Corporation, the Community, and EPA

The Malvern TCE Superfund Site (the Site) is located at 258 N. Phoenixville Pike in East Whiteland Township, Chester County, Pennsylvania. The site is surrounded by wooded and residential property. The residential areas to the east and southeast have public water and sewer systems. The Hillbrook Circle residential development, southwest of the site, has domestic wells and septic systems. Catanach and Cedar Hollow quarries, two active limestone quarries, are east-northeast of the site.

FIGURE 2.1. MAP OF THE MALVERN TCE SITE

(Not available in on-line version of this document)

Section 2.1: The Site From 1952 to 1993

For nearly 25 years, Chemclene Corporation, owner of the site property, recycled industrial cleaning solvents and sold the distilled solvents, including trichloroethylene (TCE) 1 , 1,1,1-trichloroethane, tetrachloroethylene, and methylene chloride. Chemclene Corporation disposed of drummed waste that contained distillation residue from its recycling operation on the site property.

By the early 1980s, residents' familiarity and involvement with the Site increased when soil and groundwater contamination was discovered on Chemclene's property and groundwater contamination was discovered in nearby residential water wells. The soil and groundwater contained elevated concentrations of TCE and related volatile organic compounds.

(Italicized bold-face words or phrases are defined in Appendix H, Glossary of Technical Terms, the last page in this plan.)

Chemclene Corporation voluntarily initiated cleanup of its property, but soil and groundwater contamination persisted. Sampling by Chemclene Corporation and the Pennsylvania Department of Environmental Resources' sampling of the water wells on Phoenixville Pike and in the Hillbrook Circle development detected TCE contamination in nine of the residential water wells. Because the groundwater contamination was associated with the recycling operations at

the Chemclene Corporation, the company agreed to install water filters on these nine wells and to maintain and replace the filters. These filters were designed to remove the contaminants from the water, purifying the water supply.

From 1982 to 1992, residents on Phoenixville Pike and in the Hillbrook Circle development were involved with the Chemclene Corporation during its periodic sampling and testing of water wells, as well as its periodic replacement of filters on the wells with TCE contamination.

From 1980 to 1992, the Chemclene Corporation operated as a hazardous waste storage and treatment facility under the authority of the Resource Conservation and Recovery Act (RCRA), but failed to meet the storage permitting requirements. Therefore, Chemclene currently is not authorized to treat hazardous waste or store hazardous waste longer than 90 days.

In late 1982, EPA placed the Chemclene Corporation on the National Priorities List (NPL), referring to it as the Malvern TCE Site. Placing the site on the NPL triggered its eligibility for extensive, long-term cleanup under the Superfund Program. Because this site was already being addressed by Pennsylvania Department of Environmental Resources (PADER, which later changed its name to the Pennsylvania Department of Environmental Protection, PADEP), EPA did not take an active role in the cleanup. In the six years that followed, PADER continued to hold primary responsibility for clean-up activities at the site.

In 1988, EPA began to take a more active role in the clean-up activities at the site when the Chemclene Corporation entered into a consent decree with EPA, agreeing to complete a facility investigation and corrective measures study for the site. When the company failed to complete this study, EPA transferred the site to the Superfund Program.

Section 2.2: The Site From 1993 to Present

EPA transferred the Chemclene Corporation to the Superfund Program in November of 1993, allowing EPA to conduct extensive, long-term, clean-up efforts to protect the health of the community and to increase community involvement.

According to residents, their awareness of the Malvern TCE Site has increased over the past three years and can be attributed to EPA's presence at the site, specifically the combination of its remedial investigation activities and community relations activities. Some residents became more aware of the site and its associated contamination when their wells ran dry and they were required to redrill.

Overall, involvement with the affected community at the site remains minimal, and community knowledge of the site remains limited.

Since 1993, community awareness of the Malvern TCE Superfund Site has increased due to:

Section 2.3: Chemclene Corporation's Current Operations

From the early 1950s through 1993, Chemclene recycled and sold distilled solvents including trichloroethylene, 1,1,1-trichloroethane, tetrachloroethylene, and methylene chloride. In August 1993, Chemclene withdrew its application to EPA for a permit that would have allowed the company to treat and store hazardous waste. Chemclene currently accepts hazardous materials in bulk quantities and repackages the material for sale in smaller quantities. It currently has a Hazardous Materials Permit with the East Whiteland Township Fire Marshall's Office, which inspects the facility to ensure compliance with the Fire Prevention Code. This permit allows Chemclene to manufacture, use, store, or sell acetone, methanol, isopropanol, toluene, mineral spirits, methyl ethyl ketone, fuel oil, diesel fuel, trichloroethylene, methylene chloride, perchloroethylene, and hydrogen peroxide.

Section 3.0: Community Background

Section 3.1: Summary of Community Concerns for the Site

EPA conducted personal interviews with nine residents in the Hillbrook Circle and Aston Woods developments during February and March 1996. The interviews allowed EPA to update residents on clean-up activities at the site and to gather information on residents' concerns with the site. The community's major concerns and questions regarding the Malvern TCE Superfund Site include:

Through the interviewing process, EPA also was able to determine the types of information residents want to receive and how EPA can best provide the desired information. Following the interviews, EPA analyzed the information provided by the residents, reviewed supplemental site files, and designed the community relations plan for the Malvern TCE Superfund Site. Below is a summary of the major concerns and questions residents raised during the interviews with EPA; the community relations program EPA developed in response is presented in Section 4.0.

Health Effects of Long-Term Exposure to TCE

The most prevalent concern expressed during the community interviews regarded the health effects of exposure to TCE. All interviewed residents expressed concern about the long-term effects of exposure to TCE, particularly in light of the inconsistent water sampling and filter maintenance in the 1980s and early 1990s. Residents asked the EPA Community Involvement Coordinator for information about TCE, acceptable exposure levels, and the impacts of long-term exposure. Residents with children were particularly concerned about the impact of TCE on their children's health and well-being. Several residents emphasized the importance of immediate notification of any potential or imminent health threats associated with contamination from the site and expressed concern that the contamination was neither fully characterized nor contained, making the potential TCE exposure uncertain.

Lack of Public Information/Knowledge about the Site

Many of the residents expressed their concern with the lack of information and knowledge about the groundwater contamination prior to EPA taking control of clean-up activities at the site. Residents stated that when Chemclene Corporation was responsible for sampling well water in the Hillbrook Circle development and for maintaining water filters installed to purify well water, the company inconsistently and infrequently carried out the sampling and maintenance procedures. In fact, some residents stated that they were completely unaware that their water was on a filtration system. Several residents stated that prior to purchasing their house they were not informed by real estate agents about the groundwater contamination and water filtration system.

Well Water Sampling and Filtration

Many residents interviewed were concerned about Chemclene Corporation's inconsistent well water sampling and filter maintenance in the 1980s and early 1990s. They stated that Chemclene Corporation rarely, if ever, informed residents of scheduled samplings but did provide residents with a copy of their sampling results. They also stated that Chemclene Corporation infrequently replaced their water filters. These residents stated they are more confident in the safety and quality of their water supply since EPA has taken control of the testing and filter systems. Several residents did raise questions about the level of testing being conducted by EPA compared to that which had been done by Chemclene Corporation, noting that Chemclene's report contained a more extensive list of tested substances. Some residents found their sampling results, whether provided by Chemclene Corporation or EPA, difficult to interpret and understand.

Water Supply, Sink Holes, and Sedimentation

A number of residents in the Hillbrook Circle development have had problems with their wells, sink holes, or sedimentation. Over the last three to four years, a number of residential wells went dry, several at the same time. Some residents also mentioned problems with sink holes or excessive sedimentation in their yards. Residents were concerned that there was a correlation between EPA's clean-up activities at the site, particularly the drilling of on-site monitoring wells, and their dried-up water supply, growing sink holes, and/or excessive sedimentation.

Current Activities of the Chemclene Corporation

Community members requested information on the current operations and activities of the Chemclene Corporation. They expressed concern that Chemclene could be operating in ways that would contribute to additional groundwater and soil contamination. Several residents expressed their desire for Chemclene Corporation to cease operations.

Property Values

Although residents were most concerned about their health and safety, they were also concerned about the proximity of their properties to a Superfund site, and what effect the groundwater contamination and filter systems would have on potential purchasers. Residents stated that the contamination associated with the site deflated the value of their property. One resident suggested that the Hillbrook Circle development be placed on public water and sewer so that the contamination would not be an issue when placing a house on the market.

Section 3.2: EPA's Response to Community Concerns

EPA held an information session on Thursday, April 25, 1996, to respond to the concerns and questions raised by residents during the community interviews. EPA staff available to address community members' concerns included Linda Dietz, Remedial Project Manager, Jennifer Hubbard, Toxicologist, Barbara Rudnick, Hydrogeologist, and Carolyn Szumal, Community Involvement Coordinator. Ron Sloto, Hydrogeologist, U.S. Geological Services, also was available to answer questions. Throughout the information session, EPA staff responded to community concerns regarding the health effects of long-term exposure to TCE; well water sampling and filtration; water supply, sink holes, and sedimentation; and current activities of the Chemclene Corporation.

Responding to residents' concerns about receiving immediate notification of any potential or imminent threats associated with contamination from the site, EPA affirmed its commitment to protecting the health and safety of the community surrounding the site. Over the past three years, EPA staff immediately notified residents if soil and/or groundwater sampling indicated increased elevations of contaminants. EPA will continue to notify residents immediately if there are changes in the concentration of contaminants.

Some residents expressed concern that EPA's sampling and analysis was less thorough than Chemclene Corporation's since the sampling results listed more chemicals and substances that had been analyzed. EPA explained to residents its methods for collecting and analyzing samples, indicating that EPA's sampling method differs from the method employed by the Chemclene Corporation. EPA explained that despite these differences in methodology, its testing is as inclusive as Chemclene's.

Residents who had difficulty interpreting or understanding the sampling results from the well water testing were able to talk with EPA staff about the results. EPA explained to individual residents the significance of their sampling results. EPA also provided fact sheets on each of the contaminants identified in the residential groundwater. These fact sheets explained the chemical nature of the contaminant and the health effects associated with long-term exposure to the contaminant.

Over the past few years, many residents in the Hillbrook Circle development had experienced problems with their wells, sink holes, or sedimentation and expressed concern that there was a direct relationship between EPA's cleanup of the site and these problems. EPA explained to residents that the clean-up activities at the site included conducting soil and groundwater sampling, but have not included regrading of the soil. EPA explained that none of the clean-up activities conducted at the site impact water wells, filtration systems, septic systems, or public water supplies.

Responding to residents' concerns about the current operations of the Chemclene Corporation and the potential for additional groundwater and soil contamination, EPA explained that Chemclene Corporation has a Hazardous Materials Permit with the East Whiteland Township Fire Marshall's Office. East Whiteland Township, therefore, is responsible for inspecting the facility to ensure compliance with the Fire Prevention Code and for monitoring Chemclene's handling of hazardous materials.

Section 3.3: Summary of Communication Needs

During the interviews in February and March 1996, EPA and the residents also discussed the types of information residents want to receive about the site and the most effective ways for EPA to communicate that information. Residents indicated they want to be kept abreast of current and proposed clean-up activities at the site, the impact of these activities on the surrounding community, and any potential health effects of past or current activities at Chemclene Corporation. All interviewed residents stated that fact sheets or flyers mailed directly to their home is the most effective way for EPA to communicate with the community. Residents also indicated that periodic public meetings would be an effective forum for EPA to relay information to the community and to respond to community questions and concerns. Some residents stated that they would access information on the Internet.

Section 4.0: EPA's Community Relations Program

The overall goal of EPA's community relations program is to promote two-way communication between citizens and EPA. Soliciting and integrating comments and information from the affected community, local officials, and other interested parties is integral to achieving this goal. EPA recommends implementing the 13 community relations activities described in the following three sections to facilitate achieving its goal.

Section 4.1: EPA's Immediate Community Relations Activities for the Site

To ensure that the community is informed of site activities, to facilitate on-going public involvement with the site, and to respond to concerns and questions raised during the community interviews, EPA will implement the following five community involvement activities immediately:

Activity 1: Respond Promptly and Accurately to Inquiries from Residents, Public Officials, Community Groups, and the Media
Objective
To maintain two-way communication between EPA and the site community, addressing any site-related questions or concerns.
Method
EPA will utilize meetings and printed materials to respond to public concerns and inquiries and also will utilize the Community Involvement Coordinator to provide personal responses. The Coordinator will respond to all inquiries promptly and will be accessible to the public by telephone and e-mail.
Activity 2: Notify the Community and Public Officials of Site Activities on a Regular Basis
Objective
To provide the public with information about site activities, thereby minimizing concerns about activities and possible disruptions to the community and allowing public officials to respond to community concerns.
Method
EPA will disseminate information to the public through various tools, including fact sheets, activities updates, information sessions, public meetings, and public notices. EPA will place selected information about the site on the Internet (See Appendix D for EPA's Internet address.)
Activity 3: Prepare and Distribute Fact Sheets and Technical Summaries
Objective
To provide the public with information on the status and findings of clean-up activities in an effort to ensure that residents have up-to-date and easy-to-understand information on the issues associated with the cleanup.
Method
Fact sheets and activities updates will be mailed to all parties on the site mailing list. Copies will be placed at the East Whiteland Township Building, and a copy will be available at the information repository, located at the Chester County Library.
Activity 4: Conduct Public Meetings or Availability Sessions
Objective
To provide a forum for EPA to explain the Superfund process, describe clean-up technologies, share information on site-related activities, and request input from the community.
Method
EPA will hold informal meetings and workshops as warranted by site activities or requested by the community. These meetings and workshops will be held in the community and will be facilitated by the Community Involvement Coordinator, as well as attended by other EPA staff.
Activity 5: Conduct Community Interviews
Objective
To identify public issues and concerns with the site and to provide the public with information about the site.
Method
EPA conducted a series of interviews with community members to gather information on residents issues and concerns, the types of information residents want to receive, and how EPA can meet these information needs most effectively. The information gathered during the community interviews provides the foundation for this community relations plan.

Section 4.2: EPA's On-going Community Relations Activities for the Site

EPA will implement the following four on-going community involvement activities to provide the framework for supporting the immediate and planned activities and objectives described in sections 4.1 and 4.3.

Activity 1: Respond Promptly and Accurately to Inquiries from Residents, Public Officials, Community Groups, and the Media
Objective
To maintain two-way communication between EPA and the site community, addressing any site-related questions or concerns.
Method
EPA will utilize meetings and printed materials to respond to public concerns and inquiries, and also will utilize the Community Involvement Coordinator to provide personal responses. The coordinator will respond to all inquiries promptly and will be accessible to the public by telephone and e-mail.
Activity 2: Notify the Community and Public Officials of Site Activities on a Regular Basis
Objective
To provide the public with information about site activities, thereby minimizing concerns about activities and possible disruptions to the community and allowing public officials to respond to community concerns.
Method
EPA will disseminate information to the public through various tools, including fact sheets, activities updates, information sessions, public meetings, and public notices. EPA will place selected information about the site on the Internet (See Appendix E for EPA's Internet address.)
Activity 6: Designate an EPA Community Involvement Coordinator for the Site
Objective
To ensure prompt, accurate, and consistent information and responses about the Malvern TCE Superfund Site.
Method
Carolyn Szumal is the Community Involvement Coordinator for the Malvern TCE Site. Ms. Szumal will establish and maintain communications with concerned citizens and Federal, state, and local officials, implement EPA's community relations activities, and be available to the public via telephone or e-mail. She will work closely with Linda Dietz, EPA's Remedial Project Manager, and other government representatives working at the site. (See Appendix C for information on contacting Carolyn Szumal or Linda Dietz.)
Activity 7: Maintain and Update Site Mailing List
Objective
To mail fact sheets and other EPA materials to residents and to contact residents about other community involvement activities.
Method
EPA will maintain an up-to-date listing of Federal, state, and local officials; local media; community groups; and other interested parties, including residents. EPA obtains residential listings from local tax records, public meeting sign-in sheets, and other listings. EPA holds the residential mailing list confidential and does not release any address information.
Activity 8: Establish and Update Information Repository
Objective
To provide the public with easy access to information on the Malvern TCE Site.
Method
EPA established the Chester County Library as the information repository for the Malvern TCE Site. EPA will place site-related documents in the information repository as the documents are released. EPA also will explore placing documents housed in the information repository on the Internet.
Activity 9: Maintain a World Wide Web Site
Objective
To facilitate public access to information about the Malvern TCE Site.
Method
EPA will place copies of selected documents related to the site on the Internet. (See Appendix D for information on accessing the world wide web site.)

Section 4.3: EPA's Planned Community Relations Activities for the Site

As site-related clean-up activities progress toward the remediation phase, EPA will implement the following four community relations activities:

Activity 10: Publish Public Notices
Objective
To inform the community of key site developments, public meetings, and the release of site documents.
Method
EPA will publish notices in the Daily Local News and the Suburban Advertiser. These notices will include relevant dates, times, and locations of meetings or activities, as well as the name, address, and phone number of the primary contact person. Public notices regarding site-specific documents, such as the Record of Decision, will briefly summarize the document.
Activity 11: Hold a Public Comment Period Following Release of the Proposed Plan
Objective
To request public input on EPA's recommended course of proposed actions to remedy the contamination associated with the Malvern TCE Site.
Method
EPA will hold a public comment period for a minimum of 30 days following the release of the Proposed Plan, which will present the various clean-up options for the site. EPA will notify residents when the public comment period begins and ends.
Activity 12: Conduct a Public Meeting on the Proposed Plan
Objective
To explain EPA's recommended remedial action at the site and to respond to questions or concerns about EPA's recommendation.
Method
EPA will hold a public meeting on the Proposed Plan. This meeting will be held in the community and will be facilitated by the Community Involvement Coordinator, as well as attended by other EPA staff.
Activity 13: Prepare a Transcript of the Public Meeting on the Proposed Plan
Objective
To document and provide a public record of the proceedings of the public meeting.
Method
EPA will use a local stenographer to transcribe a word-for-word record of the public meeting on the Proposed Plan. EPA will place a copy of the transcript in the information repository.
Activity 14: Prepare a Responsiveness Summary
Objective
To document and summarize community input received by EPA during the public comment period.
Method
EPA will prepare a responsiveness summary that presents the comments and questions EPA receives on the Proposed Plan and presents EPA's responses. EPA will include the responsiveness summary as part of its Record of Decision, which presents EPA's final plan for clean-up activities.

Section 5.0: Profile of EPA's Efforts to Involve the Community

Historically, public concern and involvement with the Malvern TCE Superfund Site has been minimal. EPA initiated activities to increase community involvement with the site in July 1995. These activities have been designed to inform residents about the goals and activities of the Superfund Program, the nature of the environmental issues associated with the site, and the potential threat these issues may pose to the surrounding community. As work at the site progresses, EPA will communicate clean-up options under consideration and the progress being made in choosing and implementing the remedy. Interested citizens will have an opportunity to comment on, and provide input to, decisions about clean-up actions at the site. To date, EPA has:

EPA issued its first activities update fact sheet in July 1995, providing residents with a history of the Malvern TCE Superfund Site, an overview of EPA's activities at the site, and a description of the site's contamination. The activities update also announced EPA's first information session and public meeting. EPA distributed the update to residents surrounding the Site, and copies were placed at the East Whiteland Township Building.

EPA held its first public meeting, hosted by the East Whiteland Township Environmental Council, on July 31, 1995. The purpose of the meeting was for EPA to provide information about the Malvern TCE Superfund Site and EPA's activities at the site. Approximately 20 people attended the meeting, including concerned residents, the owner of the Chemclene Corporation, and members of the Environmental Advisory Council. EPA opened the session with an overview of the Superfund program, provided an overview of the contamination associated with the site, and then discussed the status of EPA's clean-up activities at the site. The meeting closed with a question and answer session. There was no media coverage of the meeting.

Additionally, in July 1995, EPA designated the information repository so that the public would have easy access to the information EPA utilizes to make its decisions about the clean-up activities at the site. The information repository is located at the Chester County Library and houses a copy of the reports, studies, plans, and fact sheets associated with the Site. EPA updates the information at the repository as new information on the site becomes available.

EPA issued its second activities update for the Malvern TCE Superfund Site in October 1995. The update provided background information on the site, as well as the status of groundwater and soils investigations and residential well sampling. EPA mailed the update to residents, placed copies at the East Whiteland Township Building, and placed a copy in the information repository.

In February 1996, EPA began developing this community relations plan by conducting interviews with residents of the Hillbrook Circle and Aston Woods areas. EPA talked with residents about their issues and concerns with the site, the types of information they want to receive, and how EPA can meet these information needs most effectively. Please refer to Section 3.1 for an overview of the comments and questions EPA received during the community interviews, Section 3.2 for a summary of EPA's responses to the community concerns, and Section 3.3 for a summary of the community's communication needs.

Issuing its third activities update in March 1996, EPA announced approval of the sampling plan for the Malvern TCE Site, discussed the scheduled soil sampling and its impact on the community, informed residents about the community relations plan preparations, and presented the residential water sampling schedule. EPA distributed the update to each residence in the Hillbrook Circle and Aston Woods residential developments and to affected residents on Phoenixville Pike. EPA also placed copies at the East Whiteland Township Building and placed a copy at the Information Repository at the Chester County Library. (Please refer to Section 3.2 for an overview of the information session held on April 25, 1996.)

Appendix A: About EPA

The Superfund Program

The Superfund Program is one of the nation's most ambitious and complex environmental programs. Congress created Superfund in 1980 when it passed the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and subsequently amended the Act in 1986 by the Superfund Amendments and Reauthorization Act (SARA). CERCLA arose out of the need to protect people and the environment from the dangers posed by abandoned or uncontrolled hazardous waste sites. CERCLA gave the Federal government the authority to respond to hazardous substance emergencies and to develop long-term solutions for the nation's most serious hazardous waste problems.

The term "Superfund" refers to a $1.6 billion trust fund established by Congress to pay for clean-up and enforcement activities at hazardous waste sites. A tax on petroleum and chemical industries finances Superfund. Superfund gives EPA the authority to stop on-going releases or prevent potential releases of hazardous substances; 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.

The National Oil and Hazardous Substances Pollution Contingency Plan, or National Contingency Plan (NCP), guides the Superfund program. This plan outlines the steps that EPA and other Federal agencies must follow when responding to releases of hazardous substances into the environment. There are two ways EPA can respond to hazardous substance releases - removal actions and remedial actions.

Identifying Sites for Cleanup

Under the Superfund Program, EPA investigates numerous hazardous waste sites throughout the United States. Upon discovery, EPA conducts an initial review of each site known as a preliminary assessment/site inspection (PA/SI). EPA uses the PA/SIs to determine whether further action at a site is necessary. EPA then evaluates the site by using the Hazard Ranking System (HRS). The HRS is a mathematical measurement tool which assigns each site a score based on the possibility that contamination will spread through ground water, surface water, or air. It also takes into account other factors, such as the location of nearby residences. EPA places sites scoring over 28.5 on the National Priorities List (NPL). The NPL is EPA's list of the nation's most serious hazardous waste sites that are eligible for money for cleanup from Superfund.

Selecting and Implementing the Clean-up Plan

After placing a site on the NPL, EPA conducts a remedial investigation and feasibility study (RI/FS). The RI examines the nature and extent of contamination at a site and the potential associated health and environmental risks. The FS analyzes the different clean-up plans that EPA could use at a site. EPA then announces its preferred clean-up method, or remedy, in a document called the Proposed Remedial Action Plan (Proposed Plan). EPA then announces a 30-day public comment period for the Proposed Plan. During this time, EPA holds a public meeting to provide information and address the community's questions about the Proposed Plan. EPA takes all comments into account and may change its recommended clean-up method based on citizen input. After reviewing all public comments, EPA makes a final decision and selects a clean-up method. This selection is announced in a document called the Record of Decision (ROD). The ROD is EPA's official report that documents the background information on the site, describes the chosen clean-up plan, outlines the clean-up plan selection process, and summarizes all public concerns and comments.

The next step is theremedial designand remedial action (RD/RA), during which EPA supervises the design and implementation of the clean-up plan outlined in the ROD. When necessary, EPA can modify the ROD to reflect minor changes to the clean-up plan. During the remedial design, EPA prepares the technical plans and specifications for implementing the chosen clean-up plan. During the remedial action, EPA or the potentially responsible parties conduct the construction or other work necessary to implement the clean-up plan.

After EPA or the potentially responsible parties complete the remedial design and remedial action work at a site, EPA continues to monitor the site during the final stage of cleanup, operation & maintenance (O&M) phase, to ensure that the clean-up levels are being achieved at the site. After determining that all appropriate clean-up actions have been completed at a site, EPA will delete that site from the NPL.

FIGURE A-1. Superfund Process Flowchart

(Not available in on-line version)

Relevant EPA Groups

Headquartered in Washington, D.C., EPA has 10 regional offices, each of which has community relations and technical staff involved in Superfund site cleanups. EPA Region III encompasses Pennsylvania, Delaware, Maryland, Virginia, West Virginia, and Washington, D.C. The EPA Region III office is located in Philadelphia, Pennsylvania. It houses several divisions, branches, and sections that work on a number of hazardous waste sites. The EPA branches most involved with the Malvern TCE Site are described below.

Superfund Community Involvement Branch (Region III)

This branch oversees communication between EPA and all residents, public officials, media representatives, and community groups interested in Superfund sites. The Superfund Community Involvement Branch is responsible for planning, coordinating, and implementing activities to enhance communication and community involvement for each site. Each site is assigned a Community Involvement Coordinator (CIC) who works closely with EPA technical staff to keep the local community informed and involved during Superfund clean-up work. The CIC for the Malvern TCE Site is Carolyn Szumal. Please refer to Appendix C for her address and telephone number.

Superfund General Remedial Branch (Region III)

This branch is responsible for all long-term clean-up work at Superfund sites. EPA remedial personnel are responsible for conducting site assessments; remedial investigations; feasibility studies; treatability tests; and other clean-up activities. Each site is assigned a Remedial Project Manager (RPM), who supervises the work performed by EPA technical staff, private contractors, and other parties involved in site study and clean-up actions. The RPM for the Malvern TCE Site is Linda Dietz. Please refer to Appendix C for her address and telephone number.

Superfund Removal Branch (Region III)

EPA's Superfund Removal Branch manages short-term actions and emergency removal responses. These actions include responses to accidental releases of hazardous substances, as well as short-term work at sites on the NPL. Immediate removal actions are supervised by EPA On-Scene Coordinators (OSCs). Currently, there are no removal activities occurring at the Malvern TCE Site.

State Role

Pennsylvania Department of Environmental Protection (PADEP)

The Pennsylvania Department of Environmental Protection (formerly known as the Pennsylvania Department of Environmental Resources - PADER) is the state agency that supports EPA-led activities at Superfund sites in Pennsylvania. PADEP reviews and comments on site work and studies, participates in community involvement activities, and provides technical assistance to EPA. Please refer to Appendix C for information about the PADEP representatives involved with the Malvern TCE Site.

Appendix B: Technical Assistance Grant (TAG) 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 residing near a site to hire a technical expert to review and interpret site reports generated by EPA or other parties. Citizens can find complete information about technical assistance grants in an EPA document entitled The Citizen's Guidance Manual for the Technical Assistance Grant Program. This document is available through the EPA Region III Office. For information on how to apply for a technical assistance grant, or to request a copy of the guidance manual, contact:

Carolyn Szumal (3EA30)
Community Involvement Coordinator
U.S. EPA, Region III
1650 Arch St.
Philadelphia, PA 19103-2029
215-814-5533
1-800-553-2509
szumal.carolyn@epa.gov

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requires that EPA accept all applications submitted for technical assistance grants. Only one group per site can receive a technical assistance grant, so EPA urges local residents and groups to join together to apply.

The following are Federal publications on the Technical Assistance Grant program that citizens can obtain by calling EPA's toll-free publications number: 1-800-553-6847.

Appendix C: Interested Party and Contact List

C-1. Federal Agency Officials

Carolyn Szumal
Community Involvement Coordinator
U.S. EPA, Region III
1650 Arch St.
Philadelphia, PA 19103-2029
215-814-5533

Linda Dietz
Remedial Project Manager
U.S. EPA, Region III
1650 Arch St.
Philadelphia, PA 19103-2029
215-814-3195
dietz.linda@epa.gov

U.S. Department of the Interior

Geological Water Resources Division
Great Valley Corporate Center
111 Great Valley Parkway
Malvern, PA  19355
610-647-9008

C-2. State Agency Officials

Pennsylvania Department of Environmental Protection (PADEP)

Division of Environmental Health
Room 1020 H&W Building
P.O. Box 90
Harrisburg, PA  17108
717-783-1376

April Flipse
Lee Park, Suite 6010
555 North Lane
Conshocken, PA  19428

C-3. Federal Elected Officials

The Honorable Arlen Specter

U.S. Senate
600 Arch Street
Suite 9400
Philadelphia, PA  19106
215-597-7200

U.S. Senate
Hart Office Building
Room 530
Washington, DC 20510-600
202-224-4254
senator@specter.senate.gov

The Honorable Rick Santorum

U.S. Senate
1 South Penn Square
Widener Building, Suite 960
Philadelphia, PA  19107
215-864-6900

U.S. Senate
Russell Senate Office Building
Suite 120
Washington, DE  20510
202-224-6324
senator@santorum.senate.gov

The Honorable Robert Walker

Congressman
595 Exton Common
Exton, PA  19341
610-363-8409

C-4. State Elected Officials

Governor Tom Ridge
225 Main Capitol Building
Harrisburg, PA  17120
717-787-2500
governor@state.pa.us

The Honorable Robert Flick
State Representative
229 W. Lancaster Avenue
Devon, PA  19333
610-688-8002

The Honorable Robert Thompson
State Senator
270 Lancaster Avenue
Liberty Square, Suite E-One
Frazer, PA  19355
610-296-7828

C-5. Local Officials

Borough of Malvern

Mayor Dominic Pisano
Borough of Malvern
Box 437
Malvern, PA 19355
(610) 644-2602

Borough Council
Borough of Malvern
Samuel Burke, President
Cheryl Force, Vice President
Box 437
Malvern, PA 19355

Dr. Clifford Lewis (610) 644-2602
Patrick McGuigan, Borough Manager
Henry Briggs
Stephen Yohannan
Florence Zaccheo

Environmental Advisory Council
Alice Presley Chairperson
14 Ridge Road
Malvern, PA 19355

Don Ridge
35 Beechwood Avenue
Malvern, PA 19355

Joan Jackson
22 Summit Road
Malvern, PA 19355

East Whiteland Township
East Whiteland Twp. Building
Charles DiSipio,Supervisor,Chairman
Edward Galante, Supervisor
Eric Reed, Codes Enforcement Officer
Stuart Levin, Supervisor
209 Conestoga Road
Frazer, PA 19355
(610) 648-0600

C-6. Media Newspapers

Daily Local News
250 N. Bradford Avenue
West Chester, PA 19382
(610) 696-1775

Suburban Advertiser
P.O. Box 292
Exton, PA 19341
(610) 363-2815

Appendix D: The World Wide Web (Internet)

EPA maintains a world wide web (WWW) site for information related to the Malvern TCE Site. The WWW Site houses information for all 10 EPA Regions. To access the EPA Region III page:

EPA's address is http://www.epa.gov

  1. Click on Region in the Office, Region, and Laboratories menu item.
  2. Select Region 3 on the map or from the listing.
  3. Select Hazardous Waste Management Division from the next menu listing.
  4. Click on the Superfund button to view a listing of Superfund sites and their contacts.

Appendix E: Information Repository Locations

Chester County Library
400 Exton Square Parkway
Exton, PA 19341
610-363-0884
Contact: Richard Lindberg

U.S. Environmental Protection Agency
1650 Arch St.
Philadelphia, PA 19103-2029
(215) 814-3157
Contact: Anna Butch
butch.anna@epa.gov

Appendix F: Fact Sheets for the Malvern TCE Superfund Site

Appendix G: Glossary of Technical Terms

Consent Decree
A legal document, approved by a judge, that formalizes an agreement reached between EPA and potentially responsible parties (PRPs) through which PRPs will conduct all or part of a clean-up action at a Superfund site; cease or correct actions or processes that are polluting the environment; or otherwise comply with EPA-initiated regulatory enforcement actions to resolve the contamination at the Superfund site involved. The consent decree describes the actions PRPs will take and may be subject to a public comment period.
Information Repository
A location where the administrative record file is placed for public review. It is comprised of technical documents, reports, fact sheets, and other site-related information.
Methylene Chloride
A man-made, chemical compound made from methane gas or wood alcohol. It is widely used as a solvent in paint strippers, as a propellant in aerosols, and as a process solvent in the manufacturing if drugs. It is also used as a metal cleaning and finishing solvent. Methylene chloride is also known as dichloromethane.
National Priorities List (NPL)
EPA's list of the most serious uncontrolled or abandoned hazardous waste sites identified for possible long-term remedial action 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. A site must be on the NPL to receive money from the Trust Fund for remedial action.
Proposed Plan
A plan for site cleanup that is available to the public for comment.
Public Comment Period
The time allowed for the public to express its views and concerns regarding an action by EPA.
Public Notice
Notification by EPA informing the public of actions such as the issuance of a draft permit or scheduling of a hearing. EPA is required to ensure proper public notice, including publication in newspapers.
Record of Decision (ROD)
A public document that explains which clean-up alternative(s) will be used at National Priorities List sites.
Remedial Project Manager (RPM)
The EPA or state official responsible for overseeing on- site remedial action.
Superfund Program
The program operated under the legislative authority of CERCLA and SARA that funds and carries out EPA solid waste emergency and long-term removal and remedial activities. These activities include establishing the National Priorities List, investigating sites for inclusion on the list, determining their priority, and conducting and/or supervising the cleanup or other remedial actions.
Tetrachloroethylene
A man-made, organic chemical compound that is used as an industrial metal degreaser and in the synthesis of fluorocarbons. It is an effective solvent and is frequently used in the dry cleaning and textile industries. Tetrachloroethylene is also known as perchloroethylene.
1,1,1-Trichloroethane
A man-made, organic chemical compound that is used as an industrial metal cleaner and as an additive in various synthetic chemical processes. It is an effective solvent and is frequently used in the dry cleaning and textile industries.
Trichloroethylene (TCE)
A synthetic, highly volatile, organic chemical compound that is commonly used as a dry-cleaning agent, a solvent, and as an industrial degreaser.
Volatile Organic Compound (VOC)
Man-made carbon-based chemicals that vaporizes when it comes into contact with air. These chemicals are commonly used as solvents, degreasers, and dry cleaning chemicals.

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