U.S ENVIRONMENTAL PROTECTION AGENCY

ALTERNATIVE REMEDIAL CONTRACTING STRATEGY

REGIONS VI, VII, VIII

RECEIVEDWAR 3 1 1995SPPD BRANCHBBCZOH VIZ

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COMMUNITY RELATIONS PLANCHEMICAL COMMODITIES, INC. SITE

OLATHE, KANSAS

EPA CONTRACT NO. 68-W8-0122EPA WORK ASSIGNMENT NO. 91-7JL3

EPA REGION VII

JACOBS ENGINEERING GROUP INC.8208 MELROSE DRIVE, SUITE 210

LENEXA, KANSAS 66214(913) 492-9218

JACOBS PROJECT NUMBER 12-D291-00

MARCH 1995

S00080607SUPERFUND RECORDS

TABLE OF CONTENTS

SECTION

1.0 OVERVIEW OF COMMUNITY RELATIONS PLAN1.1 Summary of Community Involvement and ConcernsU Identifying and Addressing Superfund Sites

2.0 SITE DESCRIPTION

3.0 COMMUNITY BACKGROUND3.1 Community Profile3.2 Community Site Involvement

4.0 KEY COMMUNITY CONCERNS

5.0 OBJECTIVES OF THE COMMUNITY RELATIONS PROGRAM

6.0 TECHNIQUES AND TIMING

REFERENCES

PAGE

112

445

6

7

8

10

LIST OF FIGURES

Figure 1 Site Location MapFigure 2 Site Features Prior to Removal ActionFigure 3 Site Features - 1994Figure 4 Schedule of Community Relations Activities at the Chemical Commodities, Inc. Site

LIST OF APPENDICES

Appendix A List of Contacts and Interested PartiesAppendix B Questions for Interviews with Concerned Citizens for the Chemical Commodities, Inc. SiteAppendix C Locations of Information Repositories and Potential Locations for Public MeetingsAppendix D Acronym List

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COMMUNITY RELATIONS PLANCHEMICAL COMMODITIES, INC.

OLATHE, KANSAS

1.0 OVERVIEW OF COMMUNITY RELATIONS PLAN

This Community Relations Plan (CRP) identifies issues of community concern regarding the ChemicalCommodities, Inc. facility in Olathe, Kansas. It has been developed as a guide for community relations activitiesto be conducted prior to and during the Engineering Evaluation/Cost Analysis (EE/CA) for the site. TheEE/CA will evaluate removal options for addressing remaining subsurface soil and groundwater contaminationat the site. Several site investigations were previously conducted to determine the types and amounts ofcontaminants present at the site.

The U.S. Environmental Protection Agency (EPA) conducts community relations activities to ensure that thepublic is both kept informed about the response actions at a site and has input into decisions about these actions.This CRP has been developed to meet the specific needs of the community affected by the ChemicalCommodities, Inc. site. The CRP consists of the following sections:

• A site description and history

• A brief community profile

• A history of community involvement with the site

• A discussion of major site-related issues and concerns

• A discussion of community relations objectives and activities

• A site map before and after previous removal actions (Figures 1, 2, and 3)

• A list of contacts and interested parties (Appendix A)

• A copy of the questionnaire used in community interviews (Appendix B)

• The location of each information repository and potential public meeting places (Appendix C)

• A list of commonly used acronyms and glossary terms (Appendix D).

Information presented in this CRP was obtained through interviews with local officials and residents, from siterecords kept by EPA, and from historical newspaper articles regarding the site. Community interviews were heldDecember 5, 6, and 7, 1994. Follow-up telephone conversations between EPA and residents occurredDecember 15 and 20, 1994.

1.1 Summary of Community Involvement and Concerns

Although the Chemical Commodities, Inc. site was added to the National Priorities List (NPL) of abandonedhazardous waste sites in May 1994, area residents do not seem overly concerned about health risks associatedwith the facility in its current condition. This is due in part to previous removal actions conducted at the site(i.e., stabilization, segregation, and transportation off-site for disposal of regulated chemicals; excavation andconsolidation of contaminated soils; and decontamination of the main chemical storage warehouse). Communityconcern about the site is localized and lower than in the past because recycling operations at the site have ceased,

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and all the stored chemicals have been removed. Area residents witnessed fires and contaminated run-off fromthe facility in 1977, and many have lived with the presence of the facility for more than 20 years. Most of thenearby community are not overly concerned about the present condition of the facility as long as chemicalrecycling operations are not resumed. Residual community concern focuses on the pace of cleanup; future useof the site, including the warehouse; contaminated groundwater due to downward migration of contaminants;property values; and health concerns associated with contaminated run-off polluting residential vegetable gardens,fish in nearby lakes, and potentially the drinking water. Several new residents have moved into the neighborhoodsince activities related to Chemical Commodities, Inc. have ceased. Many of them know virtually nothing aboutthe site.

The resumption of removal activities at the site, however, is likely to reawaken the community's concern. Aneffective community relations program for this site should prepare for the potential revival of community interestand attempt to educate residents so that they can better understand the Superfund process. In particular, thecommunity relations program for Chemical Commodities, Inc. should enlist the support and cooperation ofOlathe and Johnson County officials. These individuals have a long-standing familiarity with the area and itsresidents, hold visible positions of responsibility within the community, and have an established network ofcommunication. They should be considered as a key resource in the effort to communicate openly and effectivelywith the people living in Olathe.

12 Identifying and Addressing Superfund Sites

In 1980, Congress enacted the Comprehensive Environmental Response, Compensation, and Liability Act(CERCLA, more commonly known as "Superfund"). CERCLA authorizes EPA to investigate and respond toreleases (or threats of releases) of hazardous substances that may endanger public health and the environment.Superfund also established a fund of $1.6 billion to pay for the investigation and remediation of sites whereparties responsible for the problems are unable or unwilling to remediate the sites. Congress amended andreauthorized Superfund in October 1986 through the Superfund Amendments and Reauthorization Act (SARA),increasing the size of the fund to about $8.5 billion.

After a potential site is initially identified, it is investigated either by a state agency or EPA. The site is thenevaluated using a system called the Hazard Ranking System (HRS), which scores the site based on the followingfactors:

• Possible health risks to the nearby population

• Potential hazards (e.g., from ingestion, inhalation, dermal contact) created by substances at thesite

• Potential for the substances at the site to pollute or harm the environment

• Potential for the substances at the site to contaminate groundwater, surface water, drinkingwater supplies, soil, or air

• The amount and type of contaminants at the site

• Actual or potential receptors exposed to site contaminants.

If a site's problems are serious enough (i.e., its HRS score is high enough), it will be listed on EPA's NPL, anational roster of uncontrolled or abandoned hazardous waste sites eligible for investigation and remediationunder the Superfund program. After placement on the NPL, EPA plans and conducts a remedial investigationand feasibility study (RI/FS) or a removal action. If a removal action is performed, then an EE/CA is required.

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An EE/CA is essentially a focused FS, a study that expedites the evaluation of removal options, so that individualcritical hazards at a CERCLA site can be dealt with quickly as interim actions while the studies supporting theremediation process are completed. A full FS usually evaluates options for long-term and permanentremediation of an entire site, and the alternatives developed and evaluated are typically more complex than fora removal. With some exceptions, fund-financed removal actions, other than those authorized underSection 104(b) of CERCLA, shall be terminated after $2 million has been obligated for the action or 12 monthshave elapsed from the date that removal activities begin on-site.

2.0 SITE DESCRIPTION

Chemical Commodities, Inc. is located on one and one-half acres approximately 20 miles southwest of KansasCity, within the city limits of Olathe, Johnson County, Kansas (Figure 1). The actual street address is300 through 320 Blake Street. The site is located less than one mile southeast of the downtown business districtof Olathe. Chemical Commodities, Inc. is bordered on the east by the St. Louis and San Francisco (Frisco)Railroad, on the south by a vacant lot owned by J. Gershon, and on the north and west side by residential areas.Five residences are adjacent to the site and approximately 800 people live within one-quarter mile of the site.The adjacent houses are occupied by families with young children and retirees (EPA, 1990).

Chemical Commodities, Inc. was formed in the late 1940s. The company engaged in the resale of chemicalswhich were surplus, off-specification, recycled, or had exceeded their specified shelf life. The company movedthe facility to the Olathe location in 1951, occupying a building that was formerly an ice plant. Various chemicalmaterials in many types of containers were stored in sheds and trailers throughout the site and in a one and one-half-story block warehouse that is approximately 50 feet by 100 feet in dimension (Ecology and Environment,1981). Chemical substances consisting primarily of chlorinated solvents were detected in soils, surface water, andgroundwater from on-site and immediately off-site. Contamination of these environmental media was a directresult of numerous chemical spills from poorly maintained containers housed in inadequate storage facilities.

Several fires occurred at the Chemical Commodities, Inc. facility, resulting in numerous reports of chemicalreleases and explosions. Negligent violations were also noted during an EPA emergency response concerninga vehicle belonging to Chemical Commodities, Inc. that caught fire while transporting a large quantity ofammonium perchlorate. Because of these incidents, EPA and Kansas Department of Health and Environment(KDHE) staff determined that an assessment of site conditions at Chemical Commodities, Inc. was warranted.A removal assessment of the facility was conducted from December 1988 through March 1989, resulting in thediscovery of several hazardous conditions. Incompatible chemicals were being stored together. Extensive leakagewas occurring from numerous containers, and some containers of chemicals were deteriorating due to leakingroofs. Many poorly labeled or unlabeled chemicals were also present throughout the site. In addition,shock/heat-sensitive chemicals were discovered inadequately stored, producing potentially explosive conditions.Field activities included a soil-gas survey, surface water and groundwater sampling, surface and subsurface soilsampling, and limited chemical container sampling. Sampling results indicated significant levels of organicsolvents existed in groundwater, surface water, surface soil, and subsurface soil (EPA, 1990).

On July 10,1989, the EPA Region 7 Administrator signed an Action Memorandum to authorize a cleanup actionat the site. The removal action at the site was performed under three phases. Phase I consisted of sitecharacterization and stabilization. Phase II covered the transportation and disposal of the various lots ofhazardous chemicals. The final phase, Phase III, addressed decontamination of the warehouse and soilremediation. Figure 2 presents the features of the site before removal actions were performed.

To reduce the most immediate and significant threats posed by the site, all regulated chemical materials werestabilized, segregated, and transported off-site for proper disposal. Approximately 309 tons of surface soil thatexceeded site-specific action levels (established by EPA Region 7 and agreed upon by the Agency for ToxicSubstances and Disease Registry) were excavated and transported to a disposal facility in Calvert, Kentucky for

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incineration and disposal. In addition, 1,000 cubic yards to 1,320 cubic yards of less-contaminated soils wereexcavated and consolidated in a lined 60-foot by 80-foot plot on-site. Native soils were used to backfill theseexcavated areas, which were subsequently seeded with grass. Grading was also conducted to control surfacewater run-off from the site.

A groundwater interceptor trench was constructed along the north and east sides of the site, where DenseNonaqueous Phase Liquid (DNAPL)-contaminated groundwater was collected and directed through an airstripping unit designed to remove volatile organic compounds (VOC). This system will remain in operation untilthe DNAPLs are reduced to concentrations below established cleanup levels. Only near-surface soils and soilsexcavated during installation of the interceptor trench were addressed during this removal action due tobudgetary constraints of the removal program, limiting cleanup efforts to the minimization of immediate andsubstantial threats posed by the site.

Interior floors and walls of the main chemical-storage warehouse were grit blasted to reduce surficialcontamination. The effectiveness of this procedure was demonstrated by a marked reduction of sampled airborneVOCs inside the warehouse following its decontamination, as compared to pre-cleanup sample results. Debrisfrom dismantled storage structures was disposed in a sanitary landfill, except for a limited amount of flooringmaterial that exceeded the Resource Conservation and Recovery Act (RCRA) regulatory Toxicity CharacteristicLeaching Procedure (TCLP) limit for chromium. This debris was subsequently combined with the contaminatedsoils that were consolidated on-site.

EPA conducted two bench-scale studies to assess the effectiveness of in-situ volatilization and low-temperaturethermal treatment for contaminated soils. However, a high clay content in the site soils prevented thesetechniques from achieving the cleanup levels required by RCRA and the State of Kansas.

To complete the site cleanup, EPA is proceeding with a non-time-critical removal action to address remainingsubsurface soil and groundwater contamination. Figure 3 presents the features of the site as they presently existafter previous removal actions were completed. As part of the cleanup process, an EE/CA is being preparedthat includes a risk evaluation of the site in its current condition.

3.0 COMMUNITY BACKGROUND

3.1 Community Profile

Johnson County was established in 1855, and John T. Barton founded the town of Olathe in 1856 (ProfilePublications, 1991). Olathe is the county seat of Johnson County. Today the population of the town is morethan 63,000, and a population in excess of 85,000 is expected by the end of the 20th century (Profile Publications,1991). Olathe is one of the fastest growing towns in Kansas. In 1991, its police department had a staff of117 full-time officers and the fire department operated five fire stations and had a full-time staff of80 firelighters.

More than 110 industries are located in Olathe. However, the largest employer in the town is government. In1994, the City of Olathe, Johnson County, and the State of Kansas together employed 4,871 workers. The OlatheSchool District employs 2,000 workers, and Olathe Medical Center has about 1,200 workers. Other majoremployers in the town include the Federal Aviation Administration Air Traffic Control Center, Bendix-King/Allied Signal, Mid-Central Sysco, and Osborne Labs (Profile Publications, 1991).

Because of its rapidly increasing population, most of the current issues in Olathe are associated with growth.Residents and officials are concerned about the protection of green space, the expense and quality of the schooldistrict, and providing schools and public services for the increasing population. A Chamber of Commercemember believes that Olathe is a "not-in-my-backyard town." Some residents feel that Olathe is undergoing an

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identity crisis as it changes from a primarily agricultural community to a residential community that housesprofessional workers who commute to the larger Kansas City metropolitan area to work.

In contrast to Olathe as a whole, much of the area west of Interstate 35, which is where Chemical Commodities,Inc. is situated, is older, more established, and has a "small-town" feel. South Keeler and South Blake Street,the immediate neighborhood surrounding Chemical Commodities, Inc., is a middle to lower class area of Olathe,located along the railroad tracks. Residents in the area are primarily older, retired people and families withchildren. Many of the residences in the neighborhood are rental units.

Those residents who have lived in this area since problems associated with Chemical Commodities, Inc. beganhave seen the neighborhood cycle from primarily young families to primarily older people, back to an increaseof families with young children again. As a whole, current residents do not seem to feel that the neighborhoodis particularly close-knit. Based on information gathered during interviews, the new families and renters whohave moved into the neighborhood do not appear to interact to a great extent with the long-time residents.

32. Community Site Involvement

Local officials stated that community reaction to the proximity of the Chemical Commodities, Inc. site has beenminimal in the last two years. The Johnson County Environmental Department has had no complaints in twoyears, and the only inquiries received on the site have been from people buying property in the area. These callsare referred to the EPA (Prilutsky, 1994). However, in 1977, citizen concern about the hazards posed by thesite brought citizens out to city commission meetings to protest operations at the facility. Numerous fires hadoccurred at the site, exposing people to chemical fumes and property to run-off generated during fire fightingoperations and heavy rains. Run-off from the site was traced to Mill Creek, and the City of Olathe water supplylakes are located one-half mile south of the site. Run-off from the site had entered backyards of residents livingalong the northern border of the site, and the City Health Department had recommended residents not eatvegetables grown in their gardens.

In July 1977, The Daily News of Johnson County reported that more than 30 residents of Olathe gathered at CityHall to voice complaints and concerns to City Commissioners about health and fire hazards at ChemicalCommodities, Inc. A fire at the facility on July 4, 1977 prompted the meeting (Daily News, 1977a). Rainfallafter the fire and water from fighting the fire carried contamination into backyards between Keeler Street andBlake Street, killing or damaging grass and garden produce as far as Cedar Street. Area residents wereevacuated during the holiday fire. Damaged grass, sickness in the neighborhood, dangers to firemen, andwhether or not Chemical Commodities, Inc. was disposing hazardous materials in the city landfill were topicsof discussion at the City Commission meeting. Neighbors also complained of discolored snow and drums thatspontaneously combusted and flew as high as 75 feet into the air from the energy of the blasts.

Later the same year, in October 1977, the City of Olathe filed a suit in Johnson County District Court seekinga mandatory injunction against Chemical Commodities, Inc. (Daily News, 1977b). The city claimed in the suitthat Chemical Commodities, Inc. violated the Uniform Fire Code, created a public nuisance by failing to properlymanage chemicals which cause noxious odors and smells, and by discharging quantities of chemicals uponadjacent properties, public streets, and thoroughfares.

During the recently conducted community interviews, both new residents who know little about the site and thosewho have lived next to Chemical Commodities, Inc. for more than 20 years expressed concern that theirneighborhood may become another "Love Canal" or "Chernobyl." Despite this concern, no community groupshave formed to participate in the investigation of the site or to voice an opinion as to how the site should orcould be addressed (Olathe Chamber of Commerce, 1994) (Harris, 1994). In general, affected residents havedealt with the remediation at the site with resignation that it came so late and is so slow. One unsigned notein the project file for Chemical Commodities, Inc. indicates that at one time local residents felt abandoned by

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the authorities who were charged with ensuring their safety. Other nearby residents appear to know nothingabout the facility's history; they hardly notice it is there, have heard their children talk of playing in it, andwondered why their water was sampled by health authorities every month.

Currently, the residents want to be informed about the site, but generally do not want to become personallyinvolved. They have been receptive to information supplied by EPA during one-to-one telephone conversationsin response to questions raised during community interviews. Some Olathe officials believe that since thechemicals have been removed, which was the original concern, further public involvement will be low. Thelocally affected citizens seem to prefer going to the City Commission for assistance in dealing with the site.

4.0 KEY COMMUNITY CONCERNS

At the present time, community concern over Chemical Commodities, Inc. is localized to the immediateneighborhood surrounding the site. However, even these nearby residents are less concerned now than they werea few years ago, now that the chemicals are gone. This decreased concern about Chemical Commodities, Inc.should not be construed as lack of interest. Citizens are not indifferent to the possible environmental effectsfrom the site; their attitude might be more accurately characterized as resignation. Citizens and officials arehappy with the cleanup effort so far, but the site has been a problem for so many years that there is a residualnegative attitude whenever residents have to deal with the site at all.

Both residents and officials have vocalized a bottom-line desire to "just know that it is clean." This statementreflects the community's fatigue with dealing with the problems associated with Chemical Commodities, Inc.However, further EPA activities on-site may renew community interest. The following kinds of concerns, voicedindividually and in a low-key manner during community interviews, are likely to become more visible andpressing during removal activities:

Information on the site. New residents would like to know a brief history of Chemical Commodities, Inc., whilelong-time residents expressed frustration that they have not received information regarding results from previousinvestigations. The most significant avenue of information transfer has been via word-of-mouth, especially sincethere have been few media releases the past few years. Recent efforts by EPA to answer the questions of theresidents in one-to-one telephone conversations have been effective at clearing up misconceptions about thecurrent hazards associated with the site. Some residents, whose only sources of information have been neighborsand friends, have been misinformed about the history of the site. Many of the city officials interviewed learnedabout Chemical Commodities, Inc. through co-workers and in relation to their job, rather than through themedia. A history of the site is not as important to these officials as is a statement from the EPA that the siteis "clean." These officials said that EPA's judgment that the site is "clean" is sufficient.

Planned EPA activities and future of the site. Most of the community interest is centered around EPA's furthercleanup activities and on the final use of the site. Specific questions regarding EPA activities include: Is the largepile of dirt on the site contaminated and will it be removed? How deep (or shallow) is the contamination? Isthere contamination underneath the building? And, who presently maintains the grounds on the property?

The community is concerned and somewhat confused on issues related to the contaminated groundwater. Theywant to know how deep (or shallow) the contamination is and whether contaminated groundwater could everseep to the surface. Some nearby residents have sunken garages and there is always water in the sump pumps.They want to know if there is any exposure danger here or if there are any dangers associated with havinginactive wells on a nearby residential property. Some residents are confused about how the wells on ChemicalCommodities, Inc. property are utilized. They do not know whether the wells are monitoring wells or wells thatemployees from Chemical Commodities, Inc. used to dispose chemicals.

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The community is also concerned about the children who climb the fence and play on site property. They wantto know what is going to happen to the warehouse on-site and would like it to be removed. Some residents haveexpressed concern that another related industry might replace Chemical Commodities, Inc. Some of thecommunity is interested in the site becoming a green space and wondered if the grass would be safe enough tosit on.

Property values. Although the railroad tracks that run through the neighborhood have already devalued thenearby properties, some residents are concerned that a revived public interest in the site could decrease theirproperty values even more. A resident noted that there is one house that has been for sale for several years andwonders if that is in part due to its proximity to Chemical Commodities, Inc. Some residents and officials havesuggested not having any press releases until the site is clean to keep from "reigniting concern needlessly."

Public health. Long-time residents are concerned about their newer neighbors who have not lived in the arealong enough to know about the City Health Department's recommendation not to eat vegetables grown in theirgardens. Residents want to know if they ever will be able to eat these vegetables. Also, residents are concernedover the possible contamination of the nearby lakes which receive run-off from the site. In particular, they areconcerned about whether or not fish from these lakes are safe to eat, if it is safe to swim in the lakes, and ifthere is any possibility of the contaminated run-off migrating through the lake and into the drinking water.

Residents have stated that there have been numerous cases of cancer in the immediate neighborhood. Onecouple from the neighborhood complained of illnesses that were not in either of their family histories. Severalpets have died of cancer and others have growths on their bodies.

5.0 OBJECTIVES OF THE COMMUNITY RELATIONS PROGRAM

The community relations program at the Chemical Commodities, Inc. site should be designed to allow thecommunity to learn about, and participate in, the Superfund remedial process without arousing unnecessaryalarm. To be effective, the community relations program must be gauged according to the community's needfor information and its interest and willingness to participate in the remedial process. Figure 4 shows the timingof community relations activities in relation to site remediation activities.

The community relations program at the Chemical Commodities, Inc. site should take the following approaches:

Educate area residents and local officials about the EPA Superfund process. Some residents are not familiarwith the Superfund process or the role of city, county, state, and federal environmental agencies in hazardouswaste site activities. Public education should include descriptions of the various departments within local, county,state, and federal environmental agencies; the responsibilities each department carries; and the ways in whicheach department coordinates with other agencies.

Educate the community about the removal process at the Chemical Commodities, Inc. site. Residents shouldbe provided with information on technical activities at the site and on removal options as they are developed inthe EE/CA. The purpose, progress, and schedule of activities at the site should be provided. Particularattention should be given to individuals requiring specific information, such as residents whose property isadjacent to the site or whose property has been or will be sampled.

Educate the community on the potential impact of the site on human health and the environment. Residentsshould be provided with information on actual and potential human health and environmental risks associatedwith the site and with information about any health advisories regarding the site. This information should bemade available to the public in layman's terms in fact sheets and in meetings. EPA should clearly explain thatthe goal of the program is to protect public health and the environment from unacceptable levels of risk,consistent with the requirements of the Superfund law.

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Enlist the support and participation of local officials in coordinating community relations activities.Appropriate Olathe officials to involve in a community relations program include the Fire Marshal, the Mayor,and the City Manager. These officials are visible, trusted leaders, and are the source to whom the residents lookfor information concerning Chemical Commodities, Inc. They are also a valuable resource in EPA's effort tounderstand and monitor community concern. To gain support of local officials, they need to be kept regularlyinformed of site activities, plans, findings, and developments. The Fire Marshal, in particular, is a key contactsince he keeps the City Manager updated, who, in turn, is the key resource of most of the other Olathe officials.

Let the people "set the pace" for the community relations program. Be aware that federal involvement in localissues is not always well regarded by townspeople. Although the community seems to be satisfied with EPA'sactivities up to this point, they are frustrated that EPA took so long to take the problems at the site seriously.The residents, in particular, are hesitant to call the EPA; they prefer calling the city. Thus, close contact withOlathe officials is important. Large, formal meetings will almost certainly be inappropriate for this community.

Recent efforts by EPA project management staff to reach out to concerned citizens in one-to-one telephoneconversations have been effective at addressing specific questions and concerns raised during communityinterviews. This form of communication is consistent with the community's stated preference for informationwithout increased media attention.

6.0 TECHNIQUES AND TIMING

Information repositories. An information repository is a file which contains a series of site-related documentsand general information about the Superfund program, including consent orders, work plans, reports, fact sheets,and technical summaries. The repository allows easy public access to information on the nature of site problemsand removal activities. An information repository will be located at the Olathe Public Library, and one alreadyexists at the EPA Region 7 docket room. These repositories will be updated as removal options are developedin the EE/CA. These information repositories should be regularly inventoried for completeness. Appendix Ccontains the addresses of the information repositories for Chemical Commodities, Inc.

Establish and maintain an information contact. The EPA Community Relations Coordinator will serve as themain point of contact to receive and respond to requests for information on the site and to coordinate theimplementation of this plan. The contact's name, telephone number, and mailing address should be prominentlydisplayed in all site publications and advertisements.

Fact sheets. Fact sheets are intended to provide the community with information about the site in layman'slanguage. Fact sheets should be produced as new information becomes available to keep the public up-to-dateon the site's progress. The fact sheets should be mailed to those on the regular site mailing list, and the EPAshould place copies of the fact sheets in the information repository for the site.

Conduct informal meetings with residents. A meeting with interested residents is advisable prior to any majoractivity on-site. This meeting should allow members of the public to speak to representatives of EPA, the state,the county, and the city on a one-to-one basis. Notification of this meeting should be sent to people on themailing list in Appendix A.

Press releases. Prepared statements might be released to the local paper, Tlie Daily News, to announcesignificant developments in the site cleanup process. In order to reach a maximum audience, the article shouldbe published on a Wednesday, when Tlie Daily News is free and is distributed to all residents in Olathe. Theinformation should be presented in a positive tone, particularly since both town officials and residents haveexpressed concern about negative information spreading throughout Olathe which might devalue the propertiesin the site neighborhood. This form of communication with the public should be used to announce importantmilestones, not to provide regular updates. EPA will place copies of the press releases in the information

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repository. Olathe also has a public access cable television station which could be utilized to announce a publicmeeting.

Contact and mailing lists. A list of contacts is provided in Appendix A of this CRP. A mailing list of residentsand other interested individuals is also maintained by EPA. These lists will be updated throughout the removalprocess. An opportunity for individuals to be included on the site mailing list should be provided in each factsheet prepared for the site, as well as in other documents. This form of communication will be used to regularlyupdate the contacts. These mailings will provide a brief background of the site, advertise the public meeting,and provide answers to the community's questions. These mailings should be sent quarterly or whenever newand pertinent information becomes available. The City Administrator would like to know of any major activitythree months ahead of the start date if possible.

Public meeting/meeting transcript. A public meeting to be held before the commencement of removal actionactivities will provide an opportunity for EPA to present the preferred removal option, to answer questionsdirectly, and to discuss the future activities planned for the site. According to community residents, interest inthe site is localized and the desire to become involved is low. The number of possible attendants at the meetingwill probably be well below 100. This meeting might be held in a resident's home, Central School, or theConference Room at the Olathe Public Library. The meeting should be coordinated with the Fire Marshal andthe City Manager. A representative of the Olathe Chamber of Commerce should also attend. A meetingtranscript should be prepared and made available to the public.

Public comment period. A 30-day public comment period will be held after completion of the EE/CA andEPA's proposal of a selected removal option. The purpose of the comment period is to provide all interestedparties an opportunity to express their opinions about the proposed alternative and contents of the AdministrativeRecord, and to participate in the final decision-making process for site remediation. The comment period willbe announced by advertisement in Tlie Daily News. EPA will also directly contact interested parties on themailing list contained in Appendix A of this plan. Up to a 30-day extension of the public comment period maybe granted if requested by concerned parties.

Responsiveness Summary. All significant comments received during the public comment period will beaddressed in a document called the Responsiveness Summary. The Responsiveness Summary will document howEPA responded to each public comment. EPA will place copies of the Responsiveness Summary in theinformation repositories for the site.

Revised Community Relations Plan. Before the Action Memorandum is signed by EPA, this CRP will berevised to account for changing concerns of the community. The revised CRP will verify and update theinformation contained in this plan, assess the community relations program to date, and develop communityrelations activities appropriate for the removal phase of the site work. EPA will place copies of the revised CRPin the information repositories for the site.

Site contact. The Fire Marshal is responsible for keeping the City Manager updated on Chemical Commodities,Inc., and he also has distributed flyers to the nearby residents. Since he regularly contacts the EPA on the statusof this site and is in direct communication with various members of the community, he was selected as the sitecontact. He will be updated bimonthly or more frequently if information becomes available.

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REFERENCES

EPA, 1992. "Community Relations in Superfund: A Handbook," Office of Emergency and Remedial Response,Washington, DC 20460, EPA/540/R-92/009.

EPA, 1990. "Amended Action Memorandum - Chemical Commodities, Olathe, Johnson County, Kansas,"Memorandum from Morris Kay, Regional Administrator, to Don R. Clay, Assistant Administrator, Office ofSolid Waste and Emergency Response, April 31, 1990.

Ecology and Environment, 1981, "Field Investigation of Uncontrolled Hazardous Waste Sites," On-siteInvestigation of Chemical Commodities, Inc., Olathe Kansas, Task Report to the Environmental ProtectionAgency under Contract Number 68-OI-6056.

Harris, Kent, Olathe Fire Department, 1994. Telephone conversation with Rita Janssen of Jacobs EngineeringGroup Inc., October 28, 1994.

Olathe Chamber of Commerce, "Olathe, DeSoto and Gardner Clubs and Organizations," list provided to JacobsEngineering Group Inc., October 31, 1994.

Prilutsky, Inna, Johnson County Environmental Department, 1994. Telephone conversation with Rita Janssenof Jacobs Engineering Group Inc., October 28, 1994.

Profile Publications, 1991. Olathe Area Chamber of Commerce Profile of Olathe, Produced for the OlatheChamber of Commerce by Profile Publications, P.O. Box 436, Crystal Lake, Illinois.

The Daily News of Johnson County, 1977a. "Chemical controversy aired at commission," No byline, July 20,1977,page 10.

The Daily News of Johnson County, 1977b. "Olathe files injunction against chemical firm," No byline,August 6, 1977, page 2A.

n:\12d29100\wp51\communit\crpce327.wp503/29/95 10

FIGURES

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Quadrangle Localionb—————————————' —^ f / //~^.Source: U.S.G.S. Topographic Map, Olathe Quadrangle

Approximate Sc»l« in Mi lea1072 ,

SITE NAU61-OCATIONCHEMICAL COMMODITIES, INC.OLATHE, KANSAS__________

JACOBS ENGINEERINGJE GROUP INC.______

DRAWN BY: MD DATE. 09/27/94

" CHECKED BY JH DATE: 09/27/94

JACOBS pnojec ixo

12-D291-00

ARCSFIGURE NO

1

0291-00-002

MortonBuilding

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CEDAR STREET

DrugStorage

Area

RailroadMaintenance

AreaUndergroundStorage Tank

Fence atProperty Boundary

Above-groundVertical StorageTanks

ConcreteFoundation

KDHE MW 13:O r*>

OKDHE MW «4

LEGENDO Monitoring Well

75

Approximate Scale In Feet

f CUBE OCSCAIPTO4

SITE FEATURES PRIOR TO REMOVAL ACTION

CHEMICAL COMMODITIES, INC.OLATHE, KANSAS

JE JACOBS ENGINEERING GROUP INC.

MD 12/27/94JH/RJ "ut 12/27/94

JACOB wrajto to

12-D291-00

ARCS

0291-00-005

CEDAR STREET

RailroadMaintenance

Area

' Consolidation Pile

Water TreatmentArea

KDHE MW *3 : :o 'O Vacant LotKDHE*4

Fence atProperty Boundary

ttGURC DESCRlPTON

SITE FEATURES - 1994

LEGENDO Monitoring Well• Boreholes

0 75

Approximate Scale in Feet

Monitoring Well (removed after Interceptor Trench installation)

CHEMICAL COMMODITIES, INC.OLATHE. KANSAS

JE JACOBS ENGINEERING GROUP INC.

MD 12/27/94O.ECMOSV JH/RJ 12/27/94

.wcoes PROJECT NO

12-D291-00

ARCS

U luOLATHE, KANSAS

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•J HHHH TECHNICAL MILESTONES |

COMMUNITYRELATIONSACTIVITIES

1 . Interview officials,agency representatives,community members

2. CommunityRelations Plan

3. InformationRepository

4. EPA/KDHE Contact

5. Contact/Mailing List

6. InformationalMeetings

7. Fact Sheet

8. Kickoff Meeting

9. Public Meeting

10. Public CommentPeriod

1 1 . Response to PublicComments

12. Revise CommunityRelations Plan

Planning forEngineeringEvaluation/

Cost Analysis(EE/CA)

•

• ——

• ——

• ———

• ———

•

•

Conduct theEE/CA

•

/ rrtrv\

• ———

EE/CA ReportComplete

ts and fact sheets

———— (contact

———— (update a

— (hold meeting

•

—————— (as ne

ActionMemorandum

deposited as avaik

—————monthly) ————

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•

•

Non-Tlme-CrltlcalRemoval ActionImplementation

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•

Removal SiteCloseout

•

D291-00-SCHED

APPENDICES

APPENDIX AList of Contacts and Interested Parties

APPENDIX A

LIST OF CONTACTS AND INTERESTED PARTIES

A. Federal Officials

Jan MeyersRepresentative 3rd District7133 W. 95th StreetSuite 217Overland Park, KS 66212(913) 383-2013

Bob DoleUnited States Senator500 State Ave.Kansas City, KS 66101(913) 371-6108

Nancy Landon KassebaumUnited States Senator4200 Summerset, Suite 152Prairie Village, KS 66208(913) 648-3103

B. State Officials

Bill GravesGovernorCapitol BuildingTopeka, KS 66603(913) 296-3232

Larry KnocagKansas Department of Health and EnvironmentBureau of Environmental RemediationForbes FieldBuilding 740Topeka, KS 66620(913) 296-1660

Kay O'ConnorState Representative1101 N. CurtisOlathe, KS 66061(913) 764-7935

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Vincent SnowbargerState Representative1451 E. Orleans Dr.Olathe, KS 66061(914) 764-0457

C. County Officials

Inna PrilutskyJohnson County Environmental Department11180 Thompson Ave.Lenexa, KS 66219(913) 492-0402

Bruce CraigJohnson County Commissioner25495 W. 135th StreetOlathe, KS 66061Phone not listed

D. Citv of Olathe Officials

Mike McCurdyCity Manager126 S. CherryOlathe, KS 66061-0768(913) 791-6200

Kent HarrisFire MarshalP.O. Box 768Olathe, KS 66051-0768(913) 782-4500

Michael HaskinMayorCity Hall100 Santa FeP.O. Box 768Olathe, KS 66051-0768(913) 782-0706

Elaine NeedhamCity Council2345 E. CedarOlathe, KS 66061(913) 780-3102

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Diane UtzSolid Waste ManagerP.O. Box 768Olathe, KS 66051-0768(913) 764-6477

E. U.S. EPA Officials

Rowena MichaelsDirectorOffice of External ProgramsU. S. Environmental Protection AgencyRegion 7, Office of External Programs726 Minnesota AvenueKansas City, KS 66101(913) 551-7003

Bruce MorrisonWork Assignment ManagerU. S. Environmental Protection AgencyRegion 7, Superfund Division726 Minnesota AvenueKansas City, KS 66101(913) 551-7003

Barbara PetersonAttorneyRegion 7, Superfund Division726 Minnesota AvenueKansas City, KS 66101(913) 551-7277

Hattie ThomasCommunity Relations CoordinatorU. S. Environmental Protection AgencyRegion 7, Office of External Programs726 Minnesota AvenueKansas City, KS 66101(913) 551-7003

F. Interested Organizations

Steve GoodhueOlathe Chamber of CommerceP.O. Box 98Olathe, KS 66051(913) 764-1050

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Craig VollandSierra Club609 North 72nd StreetKansas City, KS 66112(913) 299-4443

Craig WolfSierra Club9844 GeorgiaKansas City, KS 66109(913) 299-4443 or(913) 299-4474

G. Media

Max EvansOlathe Daily News514 S. KansasP.O. Box 130Olathe, KS 66061(913) 764-2211

Mike MansurEnvironmental ReporterKansas City Star14500 East 42nd StreetSuite 250Independence, MO 64055(816) 234-4300

Kansas City StarJohnson County News Office1729 GrandKansas City, MO(913) 234-7700

Joyce Morrison, Assignment DeskKCTV-5 StationP.O. Box 5555Kansas City, MO 64109(913) 677-5555

Bev Chapman, News DeskKMBC TV Channel 91049 CentralKansas City, MO 64105(913) 221-9999

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Tom Christianson, Assignment ManagerKSHB TV-Fox 41News Line4720 OakKansas City, MO 64112(816) 932-4141

WDAF Channel 4Mike McDonaldNews Director3030 SummitKansas City, MO 64108(816) 753-4567

Katie McGuckinKMBZ KMBR Radio4935 Belinder AvenueShawnee'Mission, KS 66205(913) 236-9800

KFKF FM 94.1Randy BirchNews Director4717 Grand, Suite 600Kansas City, MO 64112(816) 753-4000

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APPENDIX B

Questions for Interviews withConcerned Citizens for the Chemical Commodities, Inc. Site

APPENDIX B

QUESTIONS FOR INTERVIEWS WITH CONCERNED CITIZENS FORTHE CHEMICAL COMMODITIES, INC. SITE

Site History

1. What do you know about the history of the Chemical Commodities, Inc. facility?

Environmental-Issues?

Hazardous Waste Issues?

2. When did you become aware of these issues? How did you become aware of these activities?

3. What is your understanding of how the site came to be?

Community Profile

1. How would you describe your community? What are its major economic features? Its social structure?

2. What are the main issues in the area?

3. Have you heard of environmental studies being done on air at CCI; on groundwater at CCI? Can youremember how you heard about them?

Environmental Concerns

1. Do you have any current concerns about the site? What are they?

2. Have you any problems on your property that you think are attributable to the hazardous materials on-site?If so, what are.they?

3. Are you satisfied with the responses of EPA, KDHE, and the facility owner?

4. Have there been any health concerns in your community so far?

5. Have you or anyone in your family had health problems which you think are attributable to the site? If so,please explain your reasoning.

6. Have you contacted anyone (such as EPA, KDHE, local, state, or federal officials or agencies) to discussyour concerns, or for information?

Whom did you contact?

What specifically did you request?

Was the response satisfactory? If not, what should have been done?

7. If you had a question or concern, what would you do? Whom would you call?

nM2d29100\wp51\communit\apbrjdl9 wpS03/13/95 B-l

Community Involvement

1. How are you currently receiving information about the environmental activities at the site (e.g., radio,newspaper, word-of-mouth, flyers, etc.)?

2. Have you participated in community involvement activities concerning the site?

What was the nature of your involvement?

How effective do you think these activities have been?

Would you like to be added to the mailing list?

3. Would you like to be more involved in future activities regarding the site? How (e.g., public meetings, slidepresentations, etc.)?

4. Do you receive information from the following sources? Are any of these sources good ways that we canprovide you and the community with information?

Newspaper

TV

Radio

Information Repository Suggested Locations

Community Meeting Suggested Time and Place

Informal Community Group Meeting

Civic and Environmental Groups

Other

5. How often do you want to receive information?

General Public

1. How sensitive are the residents in the area to environmental issues? Is there much community concernabout the site?

2. Are there any environmental groups involved?

3. Have any of your friends and neighbors talked with you to express interest or concern about theenvironmental study, and, if so, what were their concerns?

4. In your opinion, what is the public opinion of the site, and cleanup effort?

5. What kinds of environmental issues have attracted the most public attention?

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In Closing

1. Is there anything we have not mentioned that you would like to talk about?

2. Can you suggest anyone else (friend, neighbor, group) who we should contact or who might want to beincluded on the mailing list?

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APPENDIX CLocation of Information Repositories and

Potential Locations for Public Meetings

APPENDIX C

LOCATION OF INFORMATION REPOSITORIESAND POTENTIAL LOCATIONS FOR PUBLIC MEETINGS

Information Repositories

Olathe Public Library201 East ParkOlathe, Kansas 66061(913)764-2259

Hours:9:00 a.m. - 9:00 p.m. Monday-Thursday9:00 a.m. - 6:00 p.m. Friday9:00 a.m. - 5:00 p.m. Saturday1:00 p.m. - 6:00 p.m. Sunday

EPA Region 7 Docket Room726 Minnesota AvenueKansas City, KS 66101(913)551-7241

Hours: 7:30 a.m. to 5:00 p.m. Monday-Friday

Potential Public Meeting Locations

Olathe Public Library201 East ParkOlathe, Kansas 66061(913) 764-2259

Seats: 75Contact: Mary Johnson

Central Elementary235 South WaterOlathe, Kansas 66061(913) 780-7370

Seats: 100Contact:

Olathe District SchoolsKathy Messick780-8196 - SchedulingWould prefer a minimum of two weeks notice for an evening meeting.

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APPENDIX DAcronym List

APPENDIX D

ACRONYM LIST

EE/CA Engineering Evaluation/Cost Analysis

EPA U. S. Environmental Protection Agency

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CRP Community Relations Plan

DNAPL Dense Nonaqueous Phase Liquid

FS Feasibility Study

HRS Hazard Ranking System

KDHE Kansas Department of Health and Environment

NPL National Priorities List

RCRA Resource Conservation and Recovery Act

RI Remedial Investigation

SARA Superfund Amendments and Reauthorization Act

TCLP Toxicity Characteristic Leaching Procedure

VOC Volatile Organic Compounds

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