Community Relations Plan
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COMMUNITY RELATIONS PLAN HI-PLAINS CHEMICAL COMPANY SITE MENLO, KANSAS APRIL 1992 30479947 Superfund A. OVERVIEW OF COMMUNITY RELATIONS PLAN This community relations plan identifies issues of community concern regarding the Hi-Plains Chemical Company site in Menlo, Kansas, and outlines activities to be conducted during and in conjunction with a removal at the site. Generally, community concern about the site is relatively restrained, primarily because contamination at the site has been known for approximately 14 years, because pesticides are a common element in most small agricultural communities, and because no one is known to have suffered any ill effects from toxaphene or other pesticides on the site. Nonetheless, residents are concerned that they do not know the extent of the contamination, that they do not know the potential effects of exposure to the contaminants of interest, and that, generally, they haven't been kept adequately informed of developments associated with the site. Several residents indicated they had heard rumors the entire town would be bought out by the federal government because of extensive contamination, with those expressing an opinion being divided roughly equally as to whether they would favor or oppose a buy out. Whatever the knowledge level and viewpoints of individuals in the community, concern is expected to increase as EPA and its contract crews begin removing contaminated soil and other materials. Because of the limited number of residents involved and the availability in the Menlo Rexford Cooperative (Menlo Co-op), an ample, conveniently located meeting room, efforts should be undertaken to meet directly with interested parties at a public information meeting. This community relations plan has been prepared to assist EPA in developing a community relations program tailored to the needs of the population affected by the Hi-Plains Chemical Company site. EPA conducts community relations activities to ensure that the local public has input into decisions on Superfund actions and is well-informed on the progress of its actions. These sections follow: o Capsule Site Description o Community Background o Highlights of Program o Techniques and Timing o Attachments: List of Residents and Interested Parties and Locations for Information Repository and Public Meeting Areas of community concern and other information in this plan are based primarily through interviews conducted February 19-20, 1992, with representatives of 14 of the 22 households in Menlo, the manager of the Menlo Co-op, and the present owner of the site. In addition, contact was made with a representative of Northwest Kansas Groundwater Management District No. 4, clerks of Thomas and Sheridan counties and other potentially interested parties. Background information also was obtained 2 from "Site Assessment: Hi-Plains Chemical Company, Menlo, Kansas," Ecology and Environment, Inc., February 6, 1992," and from material provided by the Thomas County Historical Society. The U.S. Environmental Protection Agency (EPA) Region VII has lead responsibility for managing any removal at Hi-Plains Chemical Company; the EPA Region VII Office of Public Affairs will oversee all community relations activities at the site. B. CAPSULE SITE DESCRIPTION The Hi-Plains Chemical Company site covers approximately 4 acres on the northern edge of Menlo, Kansas (NW 1/4, SE 1/4 of Section 13, Township 8S, Range 13W). Menlo is on the border of Thomas and Sheridan counties, with its easternmost north-south street separating Sheridan County to the east and Thomas County to the west. Seven of its approximately 60 residents are in Sheridan County, while the remaining residents and the site are in Thomas County. The closest residence is within one block of the site. The Hi-Plains site includes a 125- by 75-foot former grade school building that was abandoned in 1963, at which time Harlan H. Williams began using the property for his aerial crop-spraying service. Beginning in 1975, a group of interrelated companies — Hi-Plains Sprayers, Schmitt Brothers Aerial Agricultural Services Co., Hi-Plains Chemical, Inc., etc. — operated from the site. The principals in the firms were brothers Leonard J. Schmitt and Robert D. Schmitt. The pesticide applicators used a partial basement under the west end of the school building for storage and knocked out the walls in the northeast corner of the building, which allowed them access to the gymnasium in that quadrant of the school for use as an airplane hangar. An open portion of the site north of the building was used as an aircraft runway. Several empty above-ground storage tanks are located at the northwest corner of the building. An underground storage tank and dispensing pump are located east of it and a septic tank and leach field lie west of it. The abandoned pesticide facility plant is slightly less than a block west of the closest residence and is a block northwest of the Methodist Church. High Plains Sprayer and Hi-Plains Chemical Company produced a grasshopper and cricket bait that utilized 1.2-percent toxaphene as the active ingredient. The formulation, sold as Hi-Plains Border Bait and Hopper Stopper, was registered with EPA under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). Other pesticides reportedly handled on the site included 2,4-dichlorophenoxyacetic acid (2,4-D), 2-(2,4,5-trichlorophenoxy) propionic acid (2,4,5-T), Meta-Systox R (oxydemotonmethyl,) disulfoton, Ramrod (propochlor), and atrazine. Operators of the Hi-Plains Chemical site reportedly employed poor pesticide management practices, resulting in complaints as early as 1978. The Kansas Department of Health and Environment (KDHE) cited the operators for improper disposal of pesticide wastes, improper storage of pesticide stocks and waste residues and inadequate security after an 3 inspection in 1980. EPA restricted toxaphene's use to certified pesticide applicators in November, 1982. In 1983, Hi-Plains Chemical ceased operations and abandoned the property, leaving behind stockpiles of pesticides and waste products, with toxaphene being prevalent. Toxaphene is known to cause cancer in animals and is also a suspected carcinogen in humans. Excessive exposure could cause damage to the liver, kidneys, central nervous system, and the myocardium (heart muscles). Its use subsequently was banned completely by EPA under FIFRA. Soil-sampling efforts have shown toxaphene to be the most prevalent contaminant, though in March 1986, KDHE found atrazine as high as 250 milligrams per kilogram (mg/kg); endrin, 8.3 mg/kg; and parathion, 6.7 mg/kg. Ecology and Environment, Inc.'s (E & E's) Field Investigation Team found toxaphene as high as 3,600 mg/kg in January 1987. Comprehensive sampling by E & E's Technical Assistance Team (TAT) in September 1991 showed toxaphene in 53 of 205 surface soil samples, at levels of 5.7 to 6,400 mg/kg. A total of 44 samples in 14 4,700-square- foot sections had toxaphene levels above the removal action limit of 15.7 mg/kg that has been proposed for the site. At depth sampling indicates that three sections, where surface contamination with toxaphene exceeds 560 mg/kg, may require excavation to a depth of about 1 foot. Plaster from walls within the building was found to contain as much as 10,000 mg/kg of toxaphene. No samples from the site failed Toxicity Characteristic Leaching Procedure tests, which determine whether contaminated materials are likely to be mobilized in water. C. COMMUNITY BACKGROUND 1. Community Profile Located in North Randall Township, Thomas County, Kansas, Menlo received its name in 1899, when a post office was established at a site where Zillah had existed. Zillah and Mystic, located a mile and one-quarter northwest, had merged at the site of Menlo in 1888, when a branch line of the Union Pacific Railroad reached it. By 1905, Menlo had 25 institutions. By the 1920s, it provided business for a depot, three elevators, a stockyards, a hotel, three general stores, a bank, five gas stations, a newspaper, various other shops, and a movie theater. The city had 40 residences and was noted for its windmills. The first school was built in 1890, with a new larger frame building constructed in 1904. During a period of school consolidation in the 1920s, a large brick school building was constructed. Enrollment reached 200 elementary and 100 high school students. Menlo, like many communities around it, was a victim of the Depression in the 1930s and of a various social trends, including lessened dependence on local businesses because of the expansion of highways and the influence of 4 automobiles. The school district was lost through consolidation in 1963, and the brick building was abandoned. Today Menlo is typical of small western Kansas towns, in that its skyline is dominated by a large grain elevator, the Menlo Rexford Cooperative Elevator. Most commerce is related to agriculture, with both dryland and irrigation techniques being applied to surrounding farmland. The nearby area is flat, becoming more rolling to the south as the south fork of the Solomon River is approached. Residents are self-employed, own and/or work on surrounding farmland, or hold jobs in Colby, the county seat, which is located 18 miles west of the junction of U.S. 24 and K-186, an intersection located 2 miles north of Menlo. In addition to the elevator, there is a bar/cafe, and a used auto parts business. Children attend grade school in Rexford and junior high and high school in Selden, as part of a consolidated school district. 2. Chronology of Community Involvement The Hi-Plains Chemical Company site was brought to the attention of KDHE in 1978, when a Menlo resident expressed concern that ground water pollution might occur, because the operators were mixing pesticides over an open well in the former grade school building.