NCD980840409_19900222_Charles Macon Lagoon & Drum_FRBCERCLA SPD_Revised Community Relations Plan-OCR

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NCD095459392 Chemtronics Inc.
Revised
Community Relations Plan
22 February 1990
t 1,ij7cu,/
ct. l
1 N.C. Superfund Se 10n ·.
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l~CANNEQ
, I FEB I 7 2017 ,
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, N.C. Superfund Section
REVISED COMMUNITY RELATIONS PLAN
FOR
THE CHEMTRONICS SUPERFUND SITE
REMEDIAL DESIGN/REMEDIAL ACTION
IN SWANNANOA, BUNCOMBE COUNTY, NORTH CAROLINA
February 22, 1990
Prepared by
Region IV, EPA
Atlanta, Georgia
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-vision of Chemtronics Communit-elations Plan
The original Chemtronics Community Relations Plan, dated April 4, 1985, was
developed by .Camp, Dresser & McKee, the Agency's REM II contractor. The
April 4, 1985 Community Relations Plan governed the Agency's community
relations activities through the Remedial Investigation/Feasibility Study
(RI/FS) stage of the Superfund process.
As the Potentially Responsible Parties prepare to embark on the Remedial
Design/Remedial Action stage of the Superfund process, it has become
necessary for the Agency to revise the April 4, 1985 Community Relations
Plan. The revised Community Relations Plan was developed by incorporating
information generated during the RI/FS, feedback from the community on RI/FS
community relation activities and changes brought about by the passage of
time. These changes include names, offices and addresses of governmental
officials and individuals on the Chemtronics mailing list.
The Agency is appreciative and complimentary of the community relations
activities and efforts of the Chemtronics Site Information Bureau during the
Remedial Investigation and Feasibility Study on behalf of two of the
Potentially Responsible Parties, Chemtronics, Inc. and Northrop Corporation.
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• TABLE OF CONTENT.
Section
1. 0 Introduction ......•.••.....••.....•.........••.••.•.....••..•... 1
2. 0 Background and Key Issues ......•••...••••...•.••••.....••.••.••. 1
2 .1 Site Location and Description ••...•.•••...•••............•• 1
2.2 Site History ...................••..•.•.••..•.•.••••••.••••• 3
2. 3 History of Community Concern •••••.••.•••.••................ 7
2.4
2.5
2.6
2.7
Previous Key Issues and Community Concerns ................. 9
EPA Community Community Relations Activities
Conducted During the RI/FS .............................. 11
Technical Assistance Grant •.....•.••....••.•••.••••••..... 13
Future Key Issues and Community Concerns to be
Addressed During the RD/RA Phase ••••••.••••••...••...... 13
3.0 Summation of the RI/FS Community Relations Program ..•.......... 14
4.0 Objectives of the Revised Community Relations Program •..•...... 15
5. 0 Community Relations Techniques ••.••..•••••••••••..•.•......•••. 17
6.0 Schedule of Community Relations Activities •.•••..•...........•• 21
FIGURES
Figure 1 Site Location Map ••••..••...•.•.................•••.••••.•..• 2
Figure 2 Map 'Locating On-site Disposal Areas •••••.••••••.••........... 4
TABLE
APPENDICES
Appendix A -List/Address of Contacts and Interested Parties
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REVISED COMMUNITY RELATIONS PLAN
CHEMTRONICS SITE, SWANNANOA, BUNCOMBE COUNTY, NORTH CAROLINA
1,0 INTRODUCTION
Thie revised community relations plan (CRP) identifies cormnunity concerns,
describes public involvement, and outlines proposed community relations
activities to lbe conducted during the remedial design and remedial action
(RD/RA) at the Chemtronice site in Swannanoa Township, North Carolina. The
United States •Environmental Protection Agency (EPA), Region IV office will
maintain lead responsibility for community relations activities associated
with the Chemtronice site.
The April 4, 1985 CRP was baaed on interviews conducted in Swannanoa Township
and Asheville, North Carolina, during February 1985. The revised CRP is
based on the April 4, 1985 CRP and the public response and interest shown
during the Remedial Investigation/Feasibility Study (RI/FS). The most
notable cormnunity relation activities conducted by the Agency were two public
meetings. The objective of the first meeting was to review the RI/FS work
plan (April 2, 1985) and in the second meeting, the Agency presented the
preferred remedial alternative as well as the other remedial alternatives
evaluated in the FS (February 23, 1988). The Agency participated in a public
meeting sponsored by the Potentially Responsible Parties (PRPs) and the Black
Mountain-Swannonoa Chamber of Commerce that discussed the
findings/conclusions of the RI (March 17, 1987). Cormnents submitted to the
Agency during the two public comment periods were also used to revise the
Chemtronics CRP. The first cormnent period followed the FS public meeting and
the second comment period was associated with the Record of Decision (ROD)
Amendment date April 5, 1988. The Administrative Record was also reviewed
prior to preparing this revised CRP.
2.0 BACKGROUND AND KEY ISSUES
Additional detail and information on the Chemtronics site can be obtained at
one of the four information repositories established in the Asheville are.
The location and telephone number for each repository is provided in
Appendix A, Subpart H.
2.1 Site Location And Description
The Chemtronics, Site encompasses approximately 1,027 acres and is located at
180 Old Bee Tre~ Road in a rural area of Swannanoa, Buncombe County,
approximately 8 miles east of Asheville, North Carolina (Figure 1). The
approximate center of the site lies at latitude 35°38'18" north and longitude
82"26'8" west. The Site is bounded on the east by Bee Tree Road and Bee Tree
Creek. The area to the north and west of the Site is comprised of sparsely
inhabited woodlands. Irmnediately to the south of the Site, there are several
industrial facilities which lie on land that was once part of the original
(Oerlikon) property.
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USGS Craggy Pinacle, N.C. & Oteen, N.C. Quads
Figure 1
Site Location Map
. Chemtr'onics Site
Swannanoa, North Carolina
Scale 1 :24,000
Source: Chemtronics Feasibility Study
(February 1988)
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The topography of the Site is steep, ranging from 2,200 to 3,400 feet above
mean sea level (amsl). The Site lies on the southeast side of Bartlett
Mountain and is moderate to heavily vegetated. Surrounding mountains reach
elevations of approximately 3,800 feet amsl.
The site can also be subdivided geographically into the Front Valley which is
drained by an• unnamed stream and Gregg Valley which is drained by Gregg
Creek. All surface runoff from the site discharges into Bee Tree Creek which
also is the prominent discharge location for the groundwater flowing
underneath the site. Bee Tree Creek flows into the Swannanoa River which
ultimately, empties into the French Broad River.
2.2 Site History
The property comprising the Chemtronics Site was first developed as an
industrial fa~ility in 1952. The Site has been owned/operated by Oerlikon
Tool and Arms Corporation of America (1952-1959), Celanese Corporation of
America (Hoechst-Celanese Corporation) (1959-1965), Northrop Carolina, Inc.
(Northrop Corporation) (1965-1971), Chemtronics, Incorporated, as apart of
Airtronics, I~c., (1971-1978), and Chemtronics, Inc. (1978 -1989). The Site
operated under the name of Amcel Propulsion, Inc. (1959-1965) under both
oerlikon and Celanese. Presently, the Site is owned by Chemtronics Inc., a
subsidiary of 'the Halliburton Company, but is currently leased to Jet
Research Incor'porate, another subsidiary of the Halliburton Company.
The primary products manufactured on-site were explosives, incapacitating
agents and chemical intermediates. The waste streams associated with these
manufacturing activities included various chlorinated and non-chlorinated
solvents and a~idic solutions. These chemical wastes were disposed of
on-site in buried drums, open trenches and through a drainfield. Jet
Research Company, is presently not anticipated to manufacture any chemicals
or chemical intermediates on-site. They are currently planning only to
perform assembly operations at the site.
Waste disposal occurred over a small portion (approximately than ten acres)
of the Site. Twenty-three individual on-site disposal areas were identified
and described by reviewing existing records and through interviews with
former and current Site employees. These 23 individual disposal areas can be
grouped into 6 discrete disposal areas: DA-6, DA-7/8, DA-9, DA-10/11, DA-23,
and the Acid Pit Area (APA) (Figure 2).
The Chemtronics Site was included on the first official National Priorities
List (NPL) published by EPA in December 1982. An RI/FS was performed by two
of the potentia·lly responsible parties ( PRPs) , Chemtronics, Inc. and Northrop
Corporation, under an Administrative Order of Consent signed and dated
October 1985. The third viable PRP, Hoechst-Celanese Corporation, declined
to participate in the RI/FS. The RI report, which examined air, groundwater,
soil, and surface water and sediment contamination at the Site and the routes
of exposure of those contaminants present to the public and environment was
accepted by the Agency in May 1987. The FS documents, which develops,
examines and evaluates alternatives for remediation of the contamination
------
Legend
.,,,,,,:r,, Approximate Disposal Area Boundaries
--Process Buildings
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400 0 ~· Scale In Feet
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Figure 2
Location Of Disposal Areas
_ Chem Ironies Site
Swannanoa, Norlh Carolina
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Source: Chemtronics Feasibility
Study (February 1988)
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found on site, was issued in draft form to the public in February 1988.
The ROD was signed on April 5, 1988 and was revised on April 26, 1989 by
means of a ROD Amendment. The necessity of the ROD Amendment was described
in the Explanation of Significant Difference Fact Sheet dated February 28,
1989 and the Legal Notice published in the Asheville Citizen-Times Newspaper
the week of March 6, 1989.
Below are the findings/conclusions stated in the RI report:
• Contaminants were found in the known disposal areas. The prevalent
contaminants in the soil were the volatile organic compounds
1,2-dichloroethene and trichlorethylene,
• Exposure to surface.soils at on-site disposal areas, except DA-9, is not
likely to cause adverse health effects, Exposure to surface soils and
materials at DA-9 could cause adverse health effects in humans.
* Within the surficial aquifer, the levels of the contaminants benzene,
chlorofoim, 1,2-dichloroethane, methylene chloride, picric acid,
tetrachlo·roethane, trichloroethene, RDX, TNT, chromium, and nickel
exceeded the drinking water and/or groundwater quality criteria stated
in Tables 6-2 and 6-3 of the RI report.
* Within the bedrock aquifer, the levels of the contaminants benzene,
1,2-dichloroethane, methylene chloride, and chromium exceeded the
drinking water and/or groundwater quality criteria specified in the
tables referenced above.
* Contaminated groundwater was found downgradient of the disposal areas.
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To date, the analytical data indicates that the contaminated groundwater
has not left the site.
The majority of the groundwater underneath the site discharges to Bee
Tree Creek and its tributaries; thereby, greatly reducing the likelihood
of contaminated groundwater reaching any private wells.
The presence of volatile organics pollutants in the surface water and
sediment of the unnamed stream and its tributaries along with the
groundwater and soil analytical data indicates contaminants are
migrating from DA-23, The concentrations of contaminants generally
decline downgradient,
The presence of volatile organics pollutants in the surface water and
sediments in the upper reaches of Gregg Branch along with the
groundwater and soil analytical data indicates contaminants are
migrating from DA-7/8, Concentrations were not detected in the lower
reaches of Gregg Branch, indicating that contaminant migration
downstream along this branch has not occurred.
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No contaminants attributable to past site activities were found in Bee
Tree Creek.
The following areas were targeted for remedial evaluation to be
undertaken in the FS: DA-6, DA-7/8, DA-9, DA-10/11, DA-23, the APA,
groundwater downgradient of the disposal areas in both valleys, and the
onsite pond on the upper reaches of the unnamed stream,
Complete analytical analyses, including analysis for 3-quinuclidinyl
benzilate (BZ) and ortho-chlorobenzalomelano nitrile (CS), were
performed on samples collected from three (3) off-site areas. No
priority pollutants were detected in these areas. CS was detected in
only one sample collected near the bottom of the Buckeye/Walnut Cove
Landfill at a very low concentration, 120 parts per billion.
Thirteen remedial alternatives for source control and seven remedial
alternatives for migration control were considered in the Chemtronice FS.
Below are tho~e alternatives from these groups that were given serious
consideration., One of the alternatives in each category is a· "No Action"
alternative. The No Action alternative examines the future threat posed by
the site if no corrective measures were taken. The No Action alternative
also provides a base line to compare the other alternatives to determine
potential gains to be obtained by each remedial alternative,
ALTERNATIVES EVALUATED
SOURCE CONTROL
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Capping --Capping or surface sealing involves the placement of a
stable (mechanically, chemically and long-term), multi-layer,
well-drained impermeable cover over the disposal area.
Off-site Landfilling --Thie alternative would involve the excavation
and ~ransportation of the buried drums and contaminated soils to a
permitted hazardous waste landfill off-site.
Soil V~nting --In-situ soil venting involves the removal of volatile
organics from the soil by mechanically drawing or venting air
through the contaminated soils.
Soil washing --Soil washing involves the removal of contaminants
from the soil by use of a washing/rinsing solution.
Stabilization/solidification --Thie alternative decreases or
eliminates the transfer or migration of contaminants by binding
them in a cement matrix.
• Incineration (On-site/Off-site) --Thie alternative involves the
excavation of the drums and contaminated soils and the incineration
of these materials. Destruction of contaminants would be 99.9999%.
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MIGRATION CONTROL AND GROUNDWATER TREATMENT
In both the Front Valley and Gregg Valley, a groundwater extraction system
will be installed to intercept and extract contaminated groundwater
migrating through the ground. The level and degree of treatment of the
extracted water will be determined by l) the level of contaminants found in
the extracted groundwater and 2) the ultimate discharge location of the
extracted water. These two facts will be determined in the Remedial Design
stage.
Coupled with any groundwater extraction or interception system, the water
withdrawn from the groundwater must be addressed in some fashion. The
following is a list of water treatment systems that were evaluated for this
site. The actual treatment system will depend on the criteria stipulated
by where the water is discharged to. The ultimate discharge points could
be the public sewer system (POTW), a surface stream or through on-site
irrigation.
Below is a list of different treatment technologies for the extracted
groundwater:
* Direct discharge to either the POTW, surface stream or on-site
irrigation;
* Air stripping of volatile contaminants from the water prior to
discharge. The level on contaminants in the air used for stripping
will determine if this air needs to be treated prior to discharge
to the environment.
• Air stripping and then additional treatment of the water for
non-volatile organics via either granulated activated carbon or
oxidation by ultraviolet light or ozone prior to discharge.
* A precipitation/flocculation process with sedimentation/filtration to
remove metals followed by air stripping and additional treatment,
as described above, of either the air or water if deemed necessary.
2.3 History of Community Concern
Prior to 1984, community concern over the Chemtronics site was generally low,
according to local officials and residents. Only a small number of residents
had concerned themselves with site activities.
The site was first brought to the attention of state officials in 1979 as a
result of complaints from a resident living near the site. On several
occasions the resident contacted state and local officials to complain of
foul odors coming from the site. In addition to the odors, the resident
complained to state officials of open acid pits existing on the Chemtronics
property, clall/ing that his dog was temporarily blinded after falling into
one of the pits. These complaints, first to local, then state, and then
federal officials, led to an investigation ·by the North Carolina Department
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of Natural Resources and Community Development in 1979 and subsequent EPA
involvement beginning in June 1980.
During the RI/FS, EPA regional officials contacted individuals and
organizationB that expressed concern about the site. A professor in the
Environmental Education Department at Warren Wilson College assisted EPA in
contacting interested citizens and environmental groups in the
Asheville/Swannanoa area. At the professor's request, EPA established a
public information repository in the college's library. Other information
repositories rave also been established. They are at the University of North
Carolina at Asheville (UNCA), Buncombe County's Office of Emergency Services,
and the Chemtronics Site Information Bureau. The addresses and contacts can
be found in Appendix A, Subpart H.
In February 1984, the Environmental Education Department at Warren Wilson
College conducted its annual environmental studies seminar and used the
Chemtronics site as a case study. Citizens, faculty members, representatives
of local, regional and state agencies, EPA representatives, as well as the
president of Chemtronics, attended. As a result of the seminar, the Buncombe
County Commis~ioners established an Hazardous Waste, Advisory Board (HWAB),
which demonstrated a strong interest in EPA response activities at the
Chemtronics site.
The HWAB acted primarily as an educational body that presented hazardous
waste issues to the county commissioners arid to citizens. The Board
developed a hazardous waste ordinance proposal which was presented to the
county commissioners for possible adoption in a meeting in February 1985. At
the meeting, the HWAB also requested an expanded membership (from its current
size of seven members to a size of ten to twelve).
HWAB members w~rked on another ordinance referred to as the "right to know"
ordinance. This would require companies in Buncombe County to provide
information to'employees in potentially dangerous working environments. This
"right to know" issue received increasing attention from the HWAB,
instructors at the local colleges, and certain residents. Some of the
questions rais~d concerned Chemtronics• current practice for making such
information available to its employees.
In 1987, the IIWAB was combined with another county advisory board to form-the
current board~ Environmental Affairs Board (EAB). The EAB has not taken an
active role with respect to the Chemtronics Superfund site and according to
Jon Creighton, Director of Planning and Development for Buncombe County, the
EAB does not intend to address any activities or issues related to the
Chemtronics site in the near future.
Until 1985, press coverage of activities at the Chemtronics site was
limited. In February 1985, EPA performed an immediate removal of two drums
labeled BZ and BZ/CS. Since the discovery of the BZ drums, the news media
has shown more interest in the site.
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In November 1984, EPA Region IV officials participated in a series of
meetings held to address community concerns with the Chemtronics site. Three
meetings were:held: l) an initial meeting with the HWAB; 2) a meeting with
the administration and faculty of Warren Wilson College; and 3) a meeting
with a group of approximately 10-15 local citizens. These meetings were
conducted largely to learn the extent of community concerns and interest and
determine the need and degree of future community activities. At the
meetings, leaflets were distributed inviting att_endees to place their names
on a mailing list.
Community concern and area press coverage increased as EPA on-site activity
increased. Residents who had not paid much attention to Chemtronics in the
past became concerned about the potential health hazard posed by the site.
One of the residents interviewed during development of the RI/FS CRP
expressed concern about the possibility of additional, undiscovered BZ will
remain on the Chemtronics property. In general, the community remains
concerned over. the possible presence of BZ on the Chemtronics property as
well as the materials disposed of off-site in municipal landfills.
A citizens' group, Citizens' Watch for a Clean Environment, was formed
following the February 1988 RI/FS public meeting. This entity has since been
incorporated as a nonprofit organization and has applied with the Internal
Revenue Service for 501 (c)(3) status. The Citizens' Watch group has also
submitted an application for a $50,000 Technical Assistance Grant (TAG) from
EPA. The TAG was awarded to the Citizens• Watch group and accepted by the
group on December 26, 1989.
2.4 Previous Key Issues and Community Concerns
According to citizens and government officials, previous community concerns
centered on groundwater contamination and a lack of sufficient information
concerning hearth and environmental hazards created by the site. Several
other concerns ·expressed included fears that property value have decreased
and that the French .Broad River, which the community has cleaned up could be
in danger of contamination. There are plane to use the French Broad River as
a source for potable water in the future.
The following points were of concern to the community during the RI/FS. Some
of these concerns may continue to affect community relations at the
Chemtronice site during the RD/RA phase.
A. Perceived' lack of objective information from EPA. Area residents have
expressed skepticism about the completeness and objectivity of EPA and PRP
generated information. Thie includes information provided at meetings and
information provided in the form of reports or other documents. A core
group of citizens, including members of the HWAB, and instructors at Warren
Wilson College and UNCA, are highly interested in the details of the scope
of work and schedule of site activities to be conducted by EPA. These
citizens have a good technical understanding of the problems and issues
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associated with hazardous waste sites and are interested in reviewing and
commenting on site reports and plans. In addition, these citizens are
sensitive to anything that may appear to be a "public relations" campaign;
they are i~tereeted in knowing about site activities either first-hand or
from what they consider ari impartial or objective source of information.
If details of site reports or plane cannot be made available for public
revieW and comment, for example because of enforcement actions, the
citizens expressed an interest in being informed of what is not available
and why in a timely fashion.
B. Effects of BZ Production. Although facts about BZ and its
manufacturihg are now released, at the time of production, neither the Army
nor the BZ-producing companies notified the public that such a chemical was
being manufactured at the facility. The true nature of a July 7, 1965 fire
that requir~d the evacuation of more than 2,000 area residents was for a
long time kept a secret. At the time, the local residents were informed
that rocket fuel was on fire and might explode. It was not until 1985 that
the area press publicized the alleged hallucinogenic effects of BZ and that
the fire was associated with the production of BZ. No evidence of the
actual chemical, BZ, was ever encountered during the RI field work. The
two exposed drums labeled BZ and CS/BZ were removed from the site in
February 1985. According to EPA, the material found in the drums consisted
of protective clothing and_ boots used in BZ production and posed no threat
to human health.
Since the discovery of the BZ-labelled drums in August 1984, people have
expressed alarm that the production of such a hazardous chemical in their
neighborhood was kept secret from them for so long. Because the revelation
was made in 1985, residents have expressed concern that EPA may not know of
everything that is buried at the site. Some residents fear that any
attempted cleanup actions could unearth more serious, unanticipated
problems or could pass over unidentified areas of waste disposal.
C. Groundwater and Surface Water Contamination. The State of North
Carolina fir~t detected groundwater contamination at the Chemtronics site
in 1979. Most of the residents in the Swannanoa Valley rely on private
residential wells for their drinking water supply. To date, no residential
well has been found to be contaminated as a result of disposal activities
on the Chemt~onice property. The characteristics of the geology in the
area make th8 chance of contaminated groundwater reaching those wells very
slight. In response to citizen fears that groundwater quality in the area
had deteriorated, EPA sampled 13 residential and industrial wells in
November 1984 and required the PRPe to sample 10 residential well as part
of the RI. No evidence of contamination was found in the residential wells
tested, but contamination was discovered in the production wells used by
Charles D. Owen Manufacturing. Thie facility is located near the
Chemtronice site. Existing evidence indicates that the contaminants found
in these wells did not come from the Chemtronice site but from Asheville
Finishing & Dye Company property.
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D. Contamination of Potential Future Drinking Water Source. There was and
continues to be a concern that the waters in the swannanoa River and the
French Broad River, as the Swannanoa River empties into the French Broad
River, are in danger of being contaminated by the Chemtronics site. The
concern emanates from the fact that the French Broad River may be developed
into a source of drinking water as the demand for potable water grows along
with the City of Asheville.
E. Employee "Right to Know". Intertwined with community concern over
cleanup of existing hazardous wastes at the Chemtronice site was the
community c~ncern over chemical production procedures and the release of
information,to workers and residents concerning the health effects
associated with chemicals produced or used at the Chemtronice site. As
mentioned previously, the HWAB worked on a "right to know" ordinance
requiring c~mpanies to.provide information to employees working in
potentally dangerous situations. The "right to know" issue gained
increasing public attention in Buncombe County. This issue received
I additional ~ttention due to the announcement that BZ was produced at the
Chemtronice •site. Individuals involved with the "right to know" campaign
have exprese'ed an interest in having EPA, in consultation with Chemtronice
officials, Prepare and conduct presentations on the past and present
I activities at the facility, identifying the substances handled and ways for
ensuring worker safety and health.
Another concern expressed by residents involved with the "right to know"
efforts was that Chemtronice, Inc. had reportedly hired a group called
"handiekills" to work in manufacturing chemical warfare decontamination
kite. Thie group of employees were reportedly comprised of mentally and
physically handicapped persons. Several area residents expressed concern
that these "handiekilled" employees were unaware of the potentially
dangerous products manufactured by Chemtronice and the hazards in which
they worked. The concern centered on the fact that the "handiekilled"
employees wo~ld had been lees able than other employees to react fast
enough to protect themselves in an emergency situation at the Chemtronice
facility.
2.5 EPA Commuriity Relations Activities Conducted During
the RI/FS
One positive aspect of the community relations activities conducted during
the Chemtronice RI/FS was the subcontracting to Warren Wilson College the
task of developing, producing and showing of two audio/visual presentations
describing the Superfund process and this process as it pertained to the
Chemtronice sit,e. The first presentation describes the Superfund process and
the history of the Chemtronice site. The second presentation expanded upon
the RI/FS proce.se and ties this process into field activities and RI findings
at the site.
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A third audio/visual presentation was to be developed that described the
RD/RA phase of the Superfund, but through a mutual agreement between Warren
Wilson College and Camp, Dresser & McKee, the Agency's contractor at the
time, warren Wilson College was not required to develop this third
audio/visual presentation. The Agency concurred with this decision.
Due to the heighten public awareness/involvement at the Chemtronics site,
four information repositories were established to improve the accessability
of information to the public. One of these information repository, the one
located at the Warren Wilson College library, was made the location of the
Agency's Administrative Record.
The Agency extended the public comment period from March 18, 1988 to April 1,
1988 after the February 23, 1988 public meeting in which the Agency presented
the proposed remedial alternative. The extension of the RI/FS public comment
period was in response tO the magnitude of comments received requesting for
an extension. The Agency was unable to extend the comment period to the
degree the public requested.
A major complaint voiced by the public centered on the limited amount of time
the Agency allowed the public to review and submit meaningful comments on
documents. Du~ to the size and technical complexity of the material in the
RI and FS documents, the citizens said that three weeks was not sufficient
time to submit' meaningful comments. There was also some dissatisfaction in
the limited number of copies sent to the information repositories.
Citizens have expressed skepticism that their written comments on the
Agency's propo~ed remedial alternative were not given sufficient
consideration prior to making a decision and the signing of the Record of
Decision. The citizens point out that the public comment period ended
April 1, 1988 and the ROD was signed April 5. The interim between April 1
and April 5 inCluded a weekend and citizens are skeptical that their comments
had any influence on the choice of the remedial alternative selected in the
ROD.
Citizens feel the Administrative Record is incomplete and that not all the
necessary documents are in the Administrative Record housed in the library at
Warren Wilson College. No particular documents were specified or alluded to
as missing in this criticism.
The citizens also stated that they wanted the Agency to designate a local
group/entity to evaluate and disseminate relevant information in a timely and
periodic manner to the community. The responsibility of this role will fall
on the Citizens• Watch Group upon receipt of the Technical Assistance Grant.
The community sontinues to be concerned that there are unidentified and
unreported areas of waste disposed both on-site as well as off-site. The
community feels that anecdotal information regarding off-site disposal have
been ignored by EPA.
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• -13-•
2.5.l Chemtronics, Inc. and Northrop Corporation Community Relations
Activlties
The Agency is appreciative and complimentary of the community relations
activities and efforts of the Chemtronics Site Information Bureau during the
Remedial Investigation and Feasibility Study and continuing into design on
behalf of Potentially Responsible Parties. During the RI/FS, the Bureau
developed numerous sources of data not contained at any of the other
information repositories. These sources include research and attitude
surveys, hours of video, hundreds of slides and photos, dozens of charts,
illustrations and graphs, and hours of audio recordings of meetings and
conferences.
2.6 Technical Assistance Grant
The Citizens' Watch Group for a Clean Environment, Inc. was established
following the Feability Study public meeting. With support from the Clean
Water Fund of North Carolina, the Citizens' Watch Group submitted an
application for a TAG in October 1988. The primary purpose for applying for·
the Technical Assistance Grant (TAG) was to be able to hire consultants,
whose tasks would include: assessing and interpreting data related to the
site, informing and educating people in their community,and helping citizens
make knowledgeable, informed comments during the Superfund process. It is
anticipated tnat the TAG will be granted by the end of Fiscal Year 1989.
2.7 Future Key Issues and Community Concerns to be Addressed During the
RD/RA Phase
A. The community has shown an active interest in keeping abreast of the
activities at the Chemtronics site and strongly desires to participate in
the planning, the design and the construction of the clean-up. There has
been strong public participation at the public meetings conducted by the
Agency. A recurring request of the community, at large, is for additional
review time as well as making more copies of documents available to the
public in a timely fashion.
B. To insure that the Administrative Record, maintained at Warren Wilson
College Library, is complete and that there be timely and unrestricted
access to all data and documents during the RD/RA.
c. Community members remain concerned that BZ may be present and
undetected in off-site and other on-site disposal areas.
D. SARA Title III -Specific questions/concerns center on what
contaminants were disposed of off-site and when and where these disposals
occurred.
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E. The community wants to maximize access to all documents, data, design
contractors, engineers and construction contractors, PRPs and EPA staff
during the·RD/RA process, Thie will help assure that coannunity concerns
are adequately addressed and that the technical assistant hired through the
TAG will be used most effectively by the coannunity ..
F. The French Broad River may be used as a source of drinking water at a
point downstream from the Chemtronice site in the future. The coannunity is
concerned that the water quality of the French Broad River not be affected
by cleanup activities at the Chemtronice site.
G. The Swapnanoa community is concerned about the groundwater
contaminatiOn, the surface water run-off, the health and environmental
hazards that may occur during the construction of the clean-up phase,
future land-use planning and off-site disposal areas.
H, Citizens• Watch for a Clean Environment (CWCE) is a non-profit
community based organization concerned about the safe and permanent
clean-up of hazardous wastes in the Swannanoa Valley, including National
Priority List Superfund sites, such as Chemtronics site. CWCE purposes to
help educate the coannunity regarding the proposed clean-up methods and to
provide citi.zens with a voice in that process. CWCE will also act as the
TAG recipien'.t from EPA and to represent all concerned citizens in the
administration of said grant.
3.0 SUMMATION, OF THE-RI/FS COMMUNITY RELATIONS PROGRAM
Following the February 23, 1988 FS public meeting in which the Agency
proposed its preferred remedial alternative, the Agency received numerous
comments. Below is a summary of the comments received.
As a result of the numerous requests to extend the public coannent period, the
publi_c comment period closing date was moved from March 18, 1988 to April 1,
1988. Of the 340 letters and petition containing over 830 names, over 80
percent including the petition requested the Agency to extend the public
comment period,beyond the April 1 closing date. The majority of the letters
asked that the'coannent period be extended until after the community receives
a TAG, The request was not granted because it was estimated that it would
take approximately eight months to a year for a TAG to be awarded and for the
community to procure a consultant and review the report the consultant
develops. And as stated before, there is some skepticism in the Swannanoa
coannunity that the coannents the coannunity submitted to the Agency during the
public comment .period were actually considered.
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Twenty percent of the letters indicated that eignator was against the
remedial action as proposed, 11 percent specifically stated they were against
incineration, 5 percent said they concurred with capping the disposal areas
on site, and some of the other letters centered in on general items,
requesting additional studies, off-site disposal areas, and requesting
additional i~formation. Only a handful of the letters received during the
public comment period contained technical comments on the proposed remedial
alternative.
Thie degree of response showed strong interest, concern and commitment on the
part of the residents of Swannanoa and surrounding communities in protecting
their environment.
The Agency received only one comment as a result of the public comment period
on the ROD Amendment. Thie public comment period ran February 24, 1989 to
March 21, 1989.
4.0 OBJECTIVES OF THE REVISED COMMUNITY RELATIONS PROGRAM
The principle objectives of the community relations program during the RO/RA
phase at the Chemtronice site are the following:
Provide area residents with an understanding of the.superfund process
·and a context for the cleanup at the site. EPA should clarify what
can and cannot be accomplished under the Superfund and SARA laws.
Such an understanding will promote more realistic public expectations
about the time and complexity involved with Superfund site cleanup.
Provide accurate, understandable information concerning all phases of
the remedial response action to interested residents. EPA should work
closely' with interested groups and individuals (i.e., Citizens• Watch
for a Clean Environment, Clean Water Fund of North Carolina,
instructors at Warren Wilson College and UNCA, officials at NCDNRCD
and EAB, etc.) to identify specific information needs of the
community.
Provide,reeidente and local officials with an opportunity for input
into site-related issues and decisions. As earily as feasible, EPA
should make available to the public for review various documents.
Due to time constraints placed on the PRPe by the March 22, 1989
Administrative Unilateral Order, it is necessary to keep review time
of draft documents by all reviewing entities, including the public, to
a three (3) week time frame. In some incidences, it may be possible
to extent the review period.
Clarify and communicate regularly with the community on specific
issues of concern. These issues include:
Groundwater Contamination. It is particularly important that
citizehs understand the· current condition of the groundwater and the
potential, if any, for contamination of residential wells.
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Surface Water Contamination. If contamination is found in
surface water off-site, then residents need to know what
hazards they may expose themselves to by eating fish from Bee
Tree Creek or Owen Lake or by wading or using the water for
their gardens and livestock
Land-Use restrictions. CWCE is concerned that the Chemtronics
site is not deeded for residential, recreational or industrial
use at any time in the future.
Clean Air. One of the proposed treatment technologies for
addressing the contaminated groundwater is air-stripping. The
community does not wish to trade contaminated groundwater for
contaminated air.
• Presence and effect of contaminants found on-site. The Agency should
also continue to provide information that clarifies the health effects
of the materials found at the site.
• Schedule of cleanup activities presented in detail, in the form of a
dated bar chart. Thia schedule should be updated quarterly.
other concerns the community would like to see address at the Chemtronica
site are:
* A complete assessment of off-site disposal areas. The assessment
should include at a minimum: the location of the off-site disposal
area(a), chemicals disposed of and the point in time of the disposal
and
• Future ,land-use planning for the Chemtronica site. Restrictions for
land use should be delineated along with the mechanisms in place to
insure 1enforcement of the restrictions.
These activiti~a are not community relations activities and therefore are not
addressed in this CRP.
- ------- -- -----17-
5.0 COMMUNITY RELATIONS TECHNIQUES
The following techniques are suggested for the Chemtronics community relations program:
Community Relations
Technique
1) Establish close working
relationship with Citizens•
Watch for a Clean Environment,
Inc. and the Chemtronics Site
Community Advisory Board.
2) Meetings and other coordinated
activities with Citizens•
Watch for a Clean Environment,
Inc., such as workshops
for the public on specifics, etc.
Objective
To ensure that accurate,
understandable information
is provided to interested
citizens.
To identify and clarify
issues of potential concern
and provide accurate,
understandable information to
the community.
-- --
Details of Community
Relations Technique
-
The Citizens• Watch for a
Clean Environment is respec.
among residents and local
officials and should be heavily
involved in all community
relations activities at the
site. Chemtronics Site Community
Advisory Board, which meets on a
regular basis, would provide a
good forum to help disseminate
information as well as provide
input and discussion of issues.
EPA should meet and consult with
the Citizens' Watch for a Clean
Environment and the Chemtro~
Site Community Advisory Boa191'on
a periodic basis to identify
community concerns and issues and
discuss the most effective way of
providing information to the
public to clarify issues.
----------- -
-18-
5.0 COMMUNITY RELATIONS TECHNIQUES (continued)
Community Relations
Technique
3) Slide presentation for local
residents.
4) Fact Sheets/Technical Summaries
Objective
To ensure that accurate,
understandable information
is ~rov_ided t;o interested citizens.
To ensure that accurate,
understandable information is
provided to interested
citizens.
--- --
Details of Community
Relations Technique
A presentation with general
introductory information on
Superfund followed by a 15 minute
slide show on the Chemtroni.
site. To be most effective, e
slide show should be presented
early in the process, if
possible, sometime during the
developing of the remedial design
plan.
Fact sheets or technical
summaries should be prepared to
explain and summarize the
following site reports:
Remedial Design
Remedial Design at 30%
Remedial Design at 95%
Completion of Source •
Control Remediation
Completion of Migration
Control Remediation
Additional fact sheets will be
generated periodically that
summarize the findings of the
long term monitoring efforts.
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5.0 COMMUNITY RELATIONS TECHNIQUES (continued)
Community Relations
Technique
5) Maintain established information
repository and replace/add
missing documents.
6) Public notices, press releases
7) Public comment period on the
draft remedial design. The
design will include both migration
and source control activities as
well as the bioassays for surface
water monitoring.
8) Small public meetings
Objective
To ensure that accurate,
understandable information is
pr~vid~d to interested
citizens. Upon community
review and notification to
the Agency of missing
documents in the Administrative
Record, replace said documents.
To ensure that accurate,
understandable information is
provided to interested
citizens.
To provide an opportunity for
citizen input to site related
issues and decisions.
To facilitate citizen input
during the public comment
period
--- - --
Details of Community
Relations Technique
-
Fact sheets/technical summaries,
and site reports (including the
community ·relations··plan) should
be included in the informat··
repositories Warren Wilson
College, UNCA, the.County Office
of Emergency Medical Services,
and Chemtronics Site Information
Bureau.
Public notices and press releases
serve to announce meetings or the
release of program documents for
public review.
The opportunity for the public
and consultant hired through the
TAG to comment will be provided
for documents before the .•
documents are finalized.
small public meetings (10-15
participants) will be useful in
answering questions and receiving
comments on the documents
distributed. A representative
for the PRPs will be invited to
attend these meetings.
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-20-
s.o COMMUNITY RELATIONS TECHNIQUES (continued)
Community Relations
Technique
9) Provide a forum for open and
public community meetings.
Objective
To facilitate citizen input
during the public comment
period.
-- --- --
Details of Community
Relations Technique
Public meeting will be
useful for disseminating
ihfOrination and assessing the
community's overall reactio •
•
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6.0 SCHEDULE OF COMMUNITY RELATIONS ACTIVITIES FOR THE CHEMTRONICS SUPERFUND SITE REMEDIAL DESIGN/REMEDIAL ACTION
COMMUNITY
RELATIONS
TECHNIQUES
Fact Sheets/
Technical
Summaries
Results Reports
Complete
Revised
Community
Relations
Plan
Start
Remedial
Design
Activities
X
Review
·Data
Generated
by
Pilot
Testing
X
Pre-design 30%
Inspection Design
Report Package
X X
TECHNICAL
95%
Design
Package
MILESTONES
Initiate ·completi.on
Remedial
Action
(including
an O&M
plan and a
Site
Health and
Safety Plan)
X
of
Remedial
Action
Activities
X
Initiation
of
Operations
&
Maintenance
X
X------------------------------------X
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Deletion
of.e
fr
National
Priority
List
X
• Information
Repositories
X-----------------------------(maintained and updated throughout the remedial response)---------------------X
Public Meetings
(as needed)
Public Comment
Period
Responsiveness
Summary
X---------------------X
X-------------------------------------------X
X----------------------------------------------X
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• APPENDIX A •
LIST OF CONTACTS AND INTERESTED PARTIES
A. Federal Representatives
U.S. Senator Terry Sanford
United States Senate
Washington D.C. Office
716 Hart Senate Office Building
Washington, D.C. 20515
[phone]
District Office:
Senator Terry Sanford
57 Battery_Park Avenue
P.O. Box 2137
Asheville, NC 28802
[phone]
U.S. Senator Jesse Helms
United States Senate
Washington D.C. Office
'409 Dirksen Building
Washington, D.C. 20515
[phone]
District Office:
P.O. Box 2888
Raleigh, NC 27602
[phone]
U.S. RepreBentative James McClure Clarke
United States House of Representatives
Washington D.C. Office
il5 cannon Building
Washington, D.C. 20515
( 202) 22 5-6401
District Office:
1 Pack square
Asheville, NC 28801
[phone]
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B. Federal Agency Officials
Jon Bornholm
Remedial Project Manger
A-2
U.S. Environmental Protection
Agency 345 Courtland Street, N.E.
Atlanta, Georgia 30365
[phone]
Beverly Mosely
Comm~nity Relations Coordinator
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
[phone]
C. State Officials and Representatives
Governor James G. Martin
State Capitol Building
Raleigh, NC 27611
[phone]
Senator Roberts. swain
612 Northwestern Bank Building
Asheville, NC 28801
[phone]
Senat_or Dennis Winner
81-B Central Avenue
Ashev'ille, NC 28801
( 704)' 2 58-0094
Repre~entative Marie Colton
392 Charlotte Street
Asheville, NC 28801
[phone]
RepreBentative Narvel Jim Crawford
P.O. Box 21
Room 1013
Raleigh, NC 27611
[phone]
Repre~entative Gordon Greenwood
118 Portman Villa Road
Black'Mountain, NC 28711
[phone]
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• A-3
Representative Martin Nesbitt
903 Northwestern Bank Building
Asheville, NC 28801
D. Local Agencies and Officials
Will+am Meyer, Director
Solid Waste Management Section
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North Carolina Department of the Environment, Health
& Natural Resources
P.O. Box 2091
Raletgh, NC 27602
[phone]
Lee c.rosby, Head
Superfund Branch
North Carolina Department of the Environment, Health
& Natural Resources
P.O. Box 2091
Raleigh, NC 27602
[phone]
Charlotte Varlashkin
North Carolina Department of the Environment, Health
& Natural Resources
P.O. Box 2091
Raleigh, NC 27602
[phone]
Donald Link, Regional Geologist
North Carolina Department of the Environment, Health
& Natural Resources
and 1Community Development
59 Woodfin Place
Asheville, NC 28801
[phone]
Steve ·Reid
' Public Affairs Office ' North Carolina Department of the Environment, Health
& Natural Resources
Albemarle Building
325 N.'Saliebury Street
Raleigh, NC 27611
[phone]
Buncombe County Corruniasioners
Dr. Gene Rainey, Chairman
Buncombe County Courthouse
Asheville, NC 28801
( 704) 255-5533
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• A-4 •
Buncombe County Environmental Affairs Board
Jon Creighton
46 Valley street
Planning & Development
Asheville, NC 28801
[phone]
Potentially Responsible Parties Project Coordinator
John Schultheis
P.O. Box 536
Swannanoa, NC 28778
[phone]
F. Local Media
Newspapers:
Asheville Citizen
Clarke Morrison
P.o.'Box 2090
Asheville, NC 28802
( 704) 252-5611
AsheVille Times
Clarke Morrison
P. o. Box 209·0
Asheville, NC 28802
[phone]
Black Mountain News
James E. Aycock
411 West State Street
P.O. Box 8
Black Mountain, NC 28711
( 704) 669-8727
Charlotte Observer
Jack Horan
P.O. Box 32188
Charlotte, NC 28232
[phone]
Television:
WBTV-'TV
News 'Director
One Julian Price Place
Charlotte, NC 28208
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• A-5
Television (continued):
WFBC-TV
News. Director
402 Northwestern Bank Building
Asheville, NC 28801
WLOS-TV
Mr. Sherrill Barber
288 Macon Avenue
Asheville, NC 28802
[phone]
WSOC-TV
News Director
P.O. Box 34665
Charlotte, NC 28234
WSPA-TV
46 Haywood Street
Asheville, NC 28801
( 704,) 258-9772
WYFF-TV
1 Harisel Avenue
Suite C
Asheville, NC 28806
[phone]
Radio:
WAYF
News Director
400 Radio Road
Charlotte, NC 28216
WBTV
News Director, Radio
One Julian Price Place
Charlotte, NC 28208
WCQS
73 Broadway Street
Asheville, NC 28801
[phone]
WFGW/WMIT
Black Mountain Highway
Black Mountain, NC 28711
[phone]
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WISE
News Director
90 Lookout
Asheville, NC 28804
WMY-I
Park Place Office Building
Asheville, NC 28801
[phone]
wsoc
News Director, Radio
P.O. Box 34665
Charlotte, NC 28234
WSPA
36 Haywood Street
Asheville, NC 28801
( 704) 253-9999
WWNC
News Director
Box 6447
Asheville, NC 28816
G. Other In~erested Parties
Millie Buchanan
A-6
Clean Water Fund of North Carolina
138 :East Chestnut Street
Ash~ville, NC 28801
[phone]
Ms. Lauren A. Elobecke
P.O. Box 5345
Swannanoa, NC 28778
Ms. Jennie Rominger
Clean Water Fund of North Carolina
138 East Chestnut Street
Asheville, NC 28801
[phone]
Ms. Lindsay Jones
Route 1, Box 304
Zirconia, NC 28790
[phone]
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Leah R. Karpen, President
League of Women Voters
A-7 •
205 .Miles Building - 2 Wall Street
Asheville, NC 28801
[phone]
Emily Blanchard-Reid
124 Mockingbird Road
Swarinanoa, NC 28778
[phone]
John F. Schultheis
Nimmo & co.
P.O. Box 536
Swannanoa, NC 28778
( 7041) 686-4336
Mr. Roger T. Smith
438 Hazel Mill Road
Asheville, NC 28806
Bob Watson, President
Citizen's Watch For A Clean EnVirorunent
P.O. Box 956
Asheville, NC 28815
[phone]
Dr. Richard Maas
Environmental Studies Program
UNC@A
University Heights
Asheville, NC 28804
( 704) 251-6441
Marilyn Pagett
247 Blueberry Lane
Swan~anoa, NC 28778
Carol Lee Crawford
Bee Tree Road
Swanrianoa, NC 28778
H. Location of Information Repositories
Buncombe County Office of Emergency
Medical Services
Contact: M. Jerry VeHaun
8 New Leicester Highway
Asheville, NC 28806
[phone]
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• A-8 •
H. Location of Information Repositories (continued)
Chemtronice Site Information Bureau
P.O. Box 18177
Asheville, NC 28814
(704.) 252-8268
University of North Carolina at Asheville
Ramsey Library
Contact: Dr. Gary Miller
One University Heights
Asheville, NC 28804-399
[phone]
Warren Wilson C9llege Library
701 Warren Wilson College Road
Swanhanoa, NC 28778
[phone]