i NQ 0 0 0 0 1 37 i i i i DRAFT i COMMUNITY RELATIONS i PLAN ALLIED CHEMICAL IRONTON COKE SITE i LAWRENCE COUNTY, OHIO 91.5LE4.0 March 21, 1984

This document has been prepared for the U.S. Environmental Protection Agency under Contract No. 68-01-6692. The material contained herein is not to be disclosed to, discussed with, or made available to any person or persons for any reason without the prior expressed approval of a responsible official of the U.S. Environmental Protection Agency.

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COMMUNITY RELATIONS PLAN

-CHEMICAL AND IRONTON COKE SITE

LAWRENCE COUNTY, OHIO

INTRODUCTION

An important aspect of U.S. EPA's response to hazardous waste sites is an active community involvement program to inform local citizens and officials of study activities and recommen- dations. To promote this exchange of information, U.S. EPA requires that a Community Relations Plan be prepared in connec- tion with each Remedial Action Site. This plan for the Allied- Chemical and Ironton Coke site serves as a guide for conducting specific community relations activities in the community during the period of the Remedial Investigation/Feasibility Study (RI/FS), Community relations activities were identi- fied through meetings and conversations with regulatory agency personnel and local citizens.

The Community Relations Plan for the Allied-Chemical and Ironton Coke site is presented in two parts. The first part is a community relation assessment, addressing the following items:

o An overview of the site status

o A history of community interest

GLT428/31 1 I o Identity of persons, groups, and officials who i have been at the forefront of community action i o A discussion of the issues that concern the public i o Communication techniques i o Public involvement in decisions concerning the i selection of a site remedy. 1 A community relations assessment was prepared in connection with the Allied-Chemical and.Ironton Coke site Remedial Action i Master Plan (RAMP) in August 1983, which has been included in this document. The assessment involved personal interviews i with U.S. EPA Region V staff; Ohio EPA; Lawrence County Health Department and Board of Commissioners; the City of Ironton, Coal Grove Village Administrator, the local Community Action Organizations and local citizens (see Table 1 for addresses and telephone numbers) . Some of the interviews have been updated since the completion of the RAMP.

The second part of this document is a plan for implementing the community relations techniques. It recommends the type and sequence of community relations activities during the period of the RI/FS. Included in Part 2 is a task-by-task work plan, a schedule of activities, persons/agencies respon- sible for executing the task, manpower allocations, and

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I budgeting considerations. The U.S EPA will be responsible I for implementing the community relations plan. i I I 1 I I 1 I 1

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\ COMMUNITY RELATIONS ASSESSMENT

SITE LOCATION

The Allied-Chemical and Ironton Coke site is located in the City of Ironton, Lawrence County, Ohio (see Figure 1). The site is on the southwestern boundary of Lawrence County, about 100 miles southeast of Columbus on the Ohio River.

The site comprises an active tar processing plant owned by Allied Chemical Corporation and an inactive coke plant formerly owned by Ironton Coke Corporation and now owned by Iron City Fuels. The industries are bordered by Ice Creek on the north- east, Lorrain Street and Cemetery Road on the north, an auto- mobile salvage facility on the south and the Norfolk and Western Railroad right-of-way on the southwest (see Figure 2).

The Allied Chemical Plant property includes a 3-acre waste disposal pit formerly called the Goldcamp Dump. In the early 1970's, Ironton Coke Corporation installed a series of waste- water treatment lagoons on the east side of its property by rechanneling Ice Creek. Three lagoons received plant effluent for settling. Wastewater was discharged to a fourth pond prior to disposal in Ice Creek, and sludge was disposed of in a fifth lagoon. Currently, lagoons Nos. 1, 2, 3 and 4 are nearly dry, with sludge material remaining on the bottom. Lagoon No. 5 is covered.

GLT428/31 ! 1 N«I^'/.///////-ll In llll It , -fuKST// Mij. I I liUte, U i nun Mi

LEGEND

——— PROPERTY BOUNDARY

/^7 IRONTON COKE PLANT LAGOONS 1000

500 SCALE IN FEET

FIGURE 2 SITE MAP ALLIED CHEMICAL - IRONTON COKE SITE DRAFT I The Ohio Attorney General's Office is currently conducting i discussions with the potentially responsible parties. SITE HISTORY

I The Goldcamp Company Gravel pit began disposal operations in 1947 and accepted approximately 103,000 tons of waste materials I until 1977. Allied Chemical company annexed this property and used the dump for disposal of plant wastewater pending I issuance of an NPDES permit to discharge into the Ohio River. In the early 1970 's, Semet-Solvay, a division of Allied Chemi- cal, re-routed Ice Creek to form four settling lagoons for use in their process wastewater handling. Ironton Coke, a subsidiary of McLouth Steel Co. of Detroit, purchased the property in 1977. McLouth Steel filed for bankruptcy in 1982 and the property was purchased by ARMM Coal. Iron City Fuels acquired the property from ARMM within a few weeks of the purchase.

In 1979 a groundwater investigation was performed at Allied Chemical Company by Geraghty and Miller, Inc., during which time 13 monitoring wells were installed. This study led U.S. EPA to identify the Goldcamp Dump as the principal source of phenol contamination in the groundwater. Allied Chemical initiated a series of five groundwater surveys for routine characterization of the water quality in 1979 and 1980.

GLT428/31 •q DRAFT mi In 1980, field investigations were initiated at Allied Chemi- cal and Ironton Coke. Access to the areas for investigation 9•U was limited due to employee strikes at the two companies. n Site visits in 1981 revealed possible sources of contamination H at lagoon 5 and storage areas at Ironton Coke.

HISTORY OF COMMUNITY RELATIONS ACTIVITIES

— The Allied Chemical and Ironton Coke site has generated only ^ a small amount of community reaction. An article appeared f in the Ironton Tribune and in the Huntington ———————Herald-Dispatc— ———h when the site was placed on the National Priorities List in 1982. According to Mr. Bob Evans of the Lawrence County Health Department, an article about dioxin that appeared in the Herald-Dispatch the week of August 8, 1983, referred to the presence of dioxin at this site. In 1982, WOWK-TV (Channel 13) and WGNT Radio, both in Huntington, West Virginia, contacted OEPA to inquire about the site; WOWK-TV provided news coverage of the site investigations.

Documented public concern has been negligible. Two complaints about site odors were made in 1982 to then-State Representa- tive Ron James, who in turn contacted Ohio EPA. No other inquiries or complaints have been received by Ohio EPA, the City of Ironton, the Village of Coal Grove, the Lawrence County Health Department, the Lawrence County Board of Com- missioners, or the Ironton/Lawrence Community Action

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Organization. No site specific public information activities have been conducted in the area by Ohio EPA or any of the above local entities.

I COMMUNITY RELATIONS ISSUES AND PARTICIPANTS I Hydrologic data indicate that the contaminated plume could be migrating toward the Village of Coal Grove's municipal well field, located less than 3,000 feet from the site. i This well field has approximately 1,250 service connections, serving 4,000 to 4,500 residents. The village is connected to the City of Ironton's water system. The Ironton system I is available as a backup water supply. Monitoring of the village wells has shown no contamination to date. Ohio EPA 1 routinely provides Mr. Mike Myers, Village Administrator, with information and sampling results. He has received no public inquiries about the site, but believes that public 1 interest would increase if more media coverage occurs or if contamination began to show up in private or public wells. He believes two concerns would arise from contaminated water supplies: 1) health impacts and 2) increased costs to water users if alternative water sources must be used. Mr. Meyers stated that it is important for the village to be kept in- formed of site developments in order to respond to public inquiries that might arise.

GLT428/31 I DRAFT The City of Ironton's water supply intake is located on the Ohio River about 2 miles downstream from the site. The pos- sibility exists that the contaminated plume is migrating into Ice Creek and the Ohio River, above Ironton's intake. Flooding of the wastewater lagoons could also occur, affect- ing the river's water quality. When contacted during the on-site community relations assessment, both the Mayor and I the Public Works Department indicated little knowledge about site activities. No public inquiries have been received by I the city.

Area industries could be affected if groundwater used for 1 industrial processes becomes contaminated. Economic hard- ship could result if they must treat the contaminated water I before use. In addition, some private wells along Third I Street, between the site and Ice Creek, may still be used. At this time, the number of wells in private use that might be affected is not known.

The Lawrence County Health Department has received informa- tion about the site from Ohio EPA. Again, this agency believes that public awareness and concern are very low at this time.

No active local environmental or public interest groups ex- ist in the Ironton area. The Sierra Club's Central Ohio Chapter has about 25 members in southeast Ohio. Although this chapter does not employ any staff, staff from the

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statewide chapter are often involved in issues concerning the southern portion of the state. A representative from i Sierra Club was contacted during the community relations assessment prepared for the Schilling landfill site, located 1 4.5 miles from Ironton. He stated that the organization's I main concern with regard to Superfund activities is that the general public be kept informed through newspaper articles 1 and other media coverage about site-related findings and activities. Sierra Club staff think that local residents 1 are not aware of the Superfund sites, I The closest League of Women Voters (LWV) is located in Ports- mouth. While its members are concerned generally with the cleanup of hazardous waste sites, the Portsmouth league dees not address issues that do not directly affect the town of Portsmouth.

The Ohio Public Interest Campaign (OPIC) is a statewide non- profit organization that focuses on issues relating to "eco- nomic justice and the environment." Its Appalachian chapter covers the 33 southeastern counties of the state, has about 700 members, and employs a staff of three. Hazardous waste issues are of greater importance to the Appalachian chapter than to OPIC as a whole. The Appalachian group recently published a newsletter about the twelve Superfund sites located in its region. It has stated a general position on the cleanup of the sites, including the need for remedial

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J. cleanup, comprehensive testing and monitoring, and community health surveys. The group generally feels that Ohio EPA and | U.S. EPA have not pursued enforcement diligently enough and , that cleanup activities have been delayed much too long. 1

I The local organization with the most interest in the site is probably the Ironton/Lawrence County Community Action Orga- I nization (CAO). .It is a private, non-profit agency that performs multiple public service functions, with an emphasis ' on social service programs for low-income people. CAO is I currently preparing a solid waste management plan to be sub- mitted to the Lawrence County Board of Commissioners. This report does not go into any detail about hazardous waste sites; however, CAO is interested in becoming involved with ' hazardous waste problems. CAO has received some information i about this site from Ohio EPA, but would like more detailed information. The organization also believes it is very impor- tant that information about any site activities or findings ^, be made available to the public.

Although public awareness of the site appears to be very low at this time, it could increase as a result of Superfund activities. This would be particularly likely if ground- water or surface water contamination affecting a large num- ber of residents is discovered. In addition to possible health impacts resulting from contaminated drinking water, issues that could arise include:

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o Impacts on aquatic organisms, birds, and other wildlife.

o Human health impacts from consumption of contam- inated fish or waterfowl.

o Reduction in recreational activities associated with the Ohio River.

o Decline in property values and overall area growth.

o Availability and cost of alternative water sup- plies.

COMMUNITY RELATIONS OBJECTIVES AND TECHNIQUES

Community Relations Objectives

1. Provide the general public, interested organizations, elected officials, and the media with timely, consistent information about the scope, progress, and findings of the remedial investigation/feasibility study. Provide a means for interested parties to express concerns and make inquiries, in order to ensure effective two-way communication.

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2. Provide all information, especially technical findings, in language that is understandable to the general public 1 3. Provide coordination and information exchange among agencies involved with the site. i 4. Identify any additional environmental, public interest, I or other groups that may become interested in the site as work progresses. Provide interested parties with i information about the study, as appropriate.

Develop a plan commensurate with the apparent low level I of public concern.

I Provide all interested parties an opportunity to review the RI/FS and comment on the remedial action alternatives I Provide a 3-week comment period, and 2 weeks' notice of the comment period.

7. Monitor public concerns and information needs throughout the RI/FS. Modify th community relations plan as neces- sary to respond to changes in community attitudes and needs.

Community Relations Techniques

GLT428/31 14 I DRAFT I The techniques listed below will be used to accomplish the community relations objectives. The selection of these tech- niques is based on the particular needs expressed by those persons interviewed in Lawrence County, and the judgements I of community relations specialists. 1. Mailing List

A mailing list of citizens, elected officials, organiza- tions, agencies, and media interested in the investigation will be developed and updated throughout the RI/FS work.

2. Briefing of Agencies and Officials

Local agencies and officials will be briefed at the beginning of the RI/FS to summarize the activities to date, the current status, and planned study activities. Briefings will be provided throughout the RI/FS as appro- priate. Briefings will be in the form of fact sheets, telephone calls, and/or meetings.

Ms. Vanessa Musgraves at the Region V EPA will serve as a central information contact for local officials and agencies with questions and/or concerns. Agencies and officials will be routinely provided with information before it is released to the media.

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Local agencies and officials will include:

o Village of Coal Grove—Village Administrator and Mayor's Office u o City of Ironton—Mayor's Office, Public Works Depart- ment, and/or Health Department i o Lawrence County Board of Commissioners i o Lawrence County Health Department i o Upper Township Trustees

i o Ironton/Lawrence County Community Action Organization i Briefings will be provided as necessary throughout the study.

3. Central Public Information Contact

The U.S. EPA Region V will designate Ms. Vanessa Musgraves (312/886-6128) as the community relations person respons- ible for coordinating the flow of information in the community.

4. Information Repository

GLT428/31 16 « DRAFT i A local repository for technical reports, fact sheets, and other written material will be established at the Briggs Public Library in Ironton, and the Lawrence County Health Department. Copies of relevant technical reports i will be available for public review at this location. i Fact sheets, report summaries and copies of the RI and FS reports will be placed in the file. Early briefings and press releases will notify the public of the loca- I tion of the information file. i 5. News Releases

The media is an effective means of providing information to the general public for this site. News releases i will be issued at appropriate times throughout the RI/FS, I including: i o At the beginning of the RI/FS to provide general background about the Superfund program and to i describe the purpose, activities, and schedule of i the study. i o At the completion of the remedial investigation, or whenever significant study or test results are i available. i i i GLT428/31 17 DRAFT

o Two weeks before the public comment period to iden- tify information contacts, location of the informa- tion repository, the procedure for making comments, and the public meeting(s), if any.

H o At the completion of the feasibility study to i announce the recommended alternative. m 6* Public Meetings

11 The need for public meetings will be evaluated throughout the study. Although little public interest is now evident, 9 activities at the site or findings of the remedial investigation/feasibility study could raise concerns fl and questions that might best be addressed at meetings. I Meetings would be appropriate: 1) at the outset of the remedial investigation, and 2) at the end of the feasi- J bility study to review alternatives and receive public comment. !

7. Public Comment Period

] A 3-week public comment period will be provided after release of the feasibility study. The comment period will be announced through and a press release issued 2 weeks before the comment period begins. Technical reports and summaries will be made available at the

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information repository. A public meeting(s) will be held to review the study findings and receive public comment.

8. Responsiveness Summary

A responsiveness summary will be prepared after the public comment period to summarize the comments received and indicate how the remedial action recommendations reflect these comments. It will be prepared in a format suitable for public distribution, if appropriate.

9. Direct Communication with Affected Water Users (optional - implement if necessary)

Direct communication with affected or potentially affected water users may be necessary during the RI/FS.

o Private well owners along Third Street, if a well survey is undertaken.

o Industries using well water if sampling is under- taken or if contamination is discovered.

o Workers at Allied Chemical if extensive onsite investigations are undertaken.

GLT428/31 19 t DRAFT I o Affected residents if contamination is discovered.

Communication will be through letters, telephone calls, or meetings, and will be coordinated with appropriate I local agencies. Sufficient information will be provided to clearly explain how water users are affected and what actions are being taken.

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COMMUNITY RELATIONS WORK PLAN

The following work plan specifies the community relations tasks to be completed during the Allied Chemical-Ironton Coke RI/FS. The tasks outlined below are based on the techni- cal milestones provided in the RI/FS work plan. The dates provided below (i.e., week 2, week 16 ... etc.) all indi- cate the date of task execution from the start of RI/FS work. Any changes in the RI/FS schedules will require corresponding changes in community relations activities. The work plan also includes staffing allocation by task, a task schedule, and a budget for contractor assistance.

ACTIVITY DESCRIPTION

Public Information Meeting

Meeting A; Week 8. A kickoff meeting will be held at the start of the remedial investigation to announce study activities and receive public comment.

Task 2: Central Information Contact

Contact Ongoing. A central information contact will be identified at U.S. EPA to serve as an infor- mation source throughout the RI/FS.

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Task 3: Local Official Briefing

Briefings: Ongoing. Keep officials and citizens briefed as the RI/FS progresses. They should be con- tacted prior to any community relations or RI/FS activities.

Task 4: News Releases

News Release A: Week 2. A news release will be issued prior to the public Information Meeting.

News Release B: During week 24 a news release will be issued following release of the remedial investiga- tion.

News Release C: Week 64. To announce the availability of the feasibility study, the dates of the public comment period and public meeting.

Other news release and/or advisories will be issued as ap- propriate throughout the RI/FS process. Activities which could require news releases include onsite activities, test results or enforcement actions.

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Task 5: Public Comment Period i Public Comment A: Week 61. A 3-week public comment period will i be provided for review of the feasibility study. There will be advance notice 2-weeks prior to the 3-week comment period. 1 i Task 6: Public Meetings l Meetinc A: Week 60. Meeting to discuss the recommenda- 1 tions of the feasibility study. I Task 7; Responsive Summary i Week 70. A summary of community relations activities conducted during the RI/FS will be prepared. The summary will also l outline public comments that were received during the RI/FS and how they were reflected in the final decision.

Task 8: Other Activities

Information Repository

! Ongoing. Information repositories will be established at the Lawrence County Health Department and at the Briggs Public 1 Library in Ironton. Reports and other technical material

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will be placed at these locations when they becomes available

Project Mailing List

Ongoing. A project mailing list will be prepared based on site interviews. The mailing list will be updated as needed throughout the RI/FS.

STAFFING PLAN

WorJc Hours Task 1: Public Information Meeting

(U.S. EPA) Community Relations Specialist 20 (U.S. EPA) Project Manager (OSC) 16 (OEPA) Community Relations Specialist 6 (Contractor) Technical Specialist 10 (Contractor) Graphics a (U.S. EPA) Clerical

Task 2: Central Information Contact

(U.S. EPA) Community Relations Specialist 24 (OEPA) Community Relations Specialist 8 (U.S. EPA) Clerical S

Task 3: Local Official Briefing

(U.S. EPA) Community Relations Specialist 24 (U.S. EPA) Project Manager (OSC) 16 (OEPA) Community Relations Specialist 12 (U.S. EPA) Press Officer 8 (U.S. EPA) Clerical 6

Task 4: Press Releases

(U.S. EPA) Community Relations Specialist 24 (OEPA) Community Relations Specialist 8 (U.S. EPA) Press Officer 4 (U.S. EPA) Clerical 3

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Task 5: Public Comment Period

(U.S. EPA) Community Relations Specialist

Task 6: Community Meeting

(U.S. EPA) Community Relations Specialist 20 (U.S. EPA) Project Manager (OSC) 16 (Contractor) Community Relations Specialist 4 (Contractor) Technical Specialist 10 (OEPA) Community Relations Specialist 8 (Contractor) Graphics 8 (U.S. EPA) Clerical 10 Task 7: Responsiveness Summary

(U.S. EPA) Community Relations Specialist 4 (U.S. EPA) Project Manager (OSC) 8 (Contractor) Technical Specialist 24 (Contractor) Community Relations Specialist 9

Task 8: Other Activities

(U.S. EPA) Community Relations Specialist 24 (U.S. EPA) Clerical 16 Staffing Summary

(U.S. EPA) Community Relations Specialist 148 (U.S. EPA) Project Manager (OSC) 56 (U.S. EPA) Clerical 52 (OEPA) Community Relations Specialist 42 (U.S. EPA) Press Officer 12 (Contractor) Community Relations Specialist 12 (Contractor) Technical Specialist 44 (Contractor) Graphics 16

TOTAL 382

A total of 382 person-hours have been allocated to community relations activities for the Allied Chemical-Ironton Coke site. The U.S. EPA will be responsible for 256 hours of work, the OEPA 42 hours, and the contractor 72 hours. The contractor labor cost are estimated to be about $3,400. Expenses are assumed to be about $500.

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GLT428/31 25 ALLIED CHEMICAL AND 1RONTON COKE/ 'E y RELA'i'lOHS FLAN - SCHEDUI.E - MAR. 21, 198A

WEEK Activity 12 16

Public Informaton Meeting

Central Information Contact -Ongoing-

Local Officials Briefing -Ongolng-

News Releases

Public Comment Period

Public Meeting

Information Repository -Ongoing-

Mailing List -Ongoing-

Responsiveness Summary

*0ptional news releases

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Table 1 (Page 1 of 3) ALLIED CHEMICAL AND IRTON COKE SITE MAILING LIST - MARCH 21, 1984

Mr. Michael R. Moschell Hazardous Materials Management State of Ohio Environmental Protection Agency Southeast District Office 2195 Front Street Logan, Ohio 43138 (614) 385-8501 Mr. Bob Evans, Sanitarian Lawrence County Health Department 2122 S. 8th Street Ironton, Ohio 45638 (614) 532-3962 Mr. Bill Lane, Clerk Board of County Commissioners Lawrence County Courthouse 111 South Fourth Street Ironton, Ohio 45638 (614) 533-4301 Mayor William Sheridan City of Ironton Memorial Hall Ironton, Ohio 45638 (614) 532-3833 Mr. John McCabe City of Ironton Public Works Department Ironton, Ohio 45638 (614) 532-3121 Mr. Mike Myers Coal Grove Village Administrator 405 Memorial Street Coal Grove, Ohio (614) 533-3617 Mr. Tony Crowe Ironton/Lawrence County Community Action Organization 305 North Fifth Street Ironton, Ohio 45638 (614) 532-3534 GLT428/22-1 DRAF1

Table 1 (Page 2 of 3)

Mayor Tom McKnight Village of Coal Grove 307 Pike Street Coal Grove, Ohio (614) 533-0102 Upper Township Trustees Town House Hecla, Ohio (614) 532-4800 Mr. George Patterson President Board of County Commissioners Lawrence County Courthouse 111 South Fourth Street Ironton, Ohio 45638 (614) 533-4301 Richard Renner Appalachian Ohio Public Interest Campaign P.O. Box 2612 Athens, Ohio 45701 (614) 593-7490 Ron Good Ohio Sierra Club 65 South Fourth Street Columbus, Ohio 43215 (614) 461-0734 Ironton Tribune** 2903 South Fifth Street Ironton, Ohio 45638 Herald-Dispatch 946 Fifth Avenue Huntington, West Virginia 25720 WSAZ-TV (Channel 3) 654 Fifth Avenue Huntington, West Virginia

**News releases should be submitted both for daily edition and for countywide weekly Extra edition. GLT428/22-2 DRAP

Table 1 {Page 3 of 3)

WOWK-TV (Channel 13) Huntington, West Virginia (304) 522-4581 WCHS-TV (Channel 8) Charleston, West Virginia WIRO/WITO Radio Radio Plaza Ironton, Ohio 45638 WKEE Radio Huntington, West Virginia WAMX Radio Ashland, Kentucky WGNT Radio Huntington, V/est Virginia

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