COMMUNITY INVOLVEMENT PLAN

Iowa- Light & Power Former Manufactured Gas Plant Site Norfolk, Nebraska

September 2012

U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 7

30284730

i Superfund The U.S. Environmental Protection Agency's (EPA)

Superfund Community Involvement Program is committed

to providing communication between citizens and the Agency.

Active public involvement is crucial to the success of any public project.

EPA's community involvement activities at the

Iowa-Nebraska Light & Power Former Manufactured Gas Plant Site

Are designed to; "

Inform the public of the nature of the environmental issues associated with, the Site,

Involve the public in the decision-making process that will affect them,

Involve the public in the responses under consideration to remedy these issues, and

Inform the public of the progress being made to implement the response actions. Table of Contents

Section Page

1.0 Overview of the Community Involvement Plan 1 2.0 Capsule Site Description 1 2.1 Site History 1 2.2 Site Description/Location 2 2.3 Site Inspections and Cleanup Activities 2 3.0 Community Background 4 3.1 Community Profile 4 3.2 History of Community Involvement 4 3.3 Key Community Concerns 5 3.4 Response to Community Concerns 5 3.5 Summary of Communication Needs 5 4.0 EPA's Community Involvement Program 6 4.1 Goals 6 4.2 Objectives ...6 4.3 Key Messages 6 4.4 Target Audiences 7 4.5 Projected Schedule for Community Involvement Activities 7 4.6 Community Involvement Resources 7

Appendices:

A Federal Elected Officials 9 B State Elected Officials ; . 9 C Local Contacts 10 D EPA Regional Contacts 10 E State Agencies 10 F Meeting Locations _'_ 10 G Local Media _• 11 H Repository Locations 11 I Community Interview Questions 12 1

Section 1.0 Overview of the Community Involvement Plan

The EPA developed this Community Involvement Plan (CIP) to facilitate two-way communication between the community impacted by the Iowa-Nebraska Light & Power Former Manufactured Gas Plant (MGP) Site and to encourage community involvement in Site activities. This is the first CIP developed for this Site. The EPA will utilize the community involvement activities outlined in this plan to ensure that residents are continuously informed and provided opportunities to be involved in the Superfund process.

The CIP addresses the Site relationship to the community and the EPA (Section 2.0), provides a background ofthe community (Section 3.0), presents the EPA's community involvement program (Section 4.0), and provides a listing of resources available, (Appendices). The EPA drew upon several information sources to develop this plan, including community interviews and Site files. The EPA's Regional Office in Kansas City, Kansas, will oversee the implementation of the community involvement activities outlined in this plan. After October 15, 2012, the Regional Office will be located in Lenexa, Kansas.

Section 2.0 Capsule Site Description

2.1 Site Background and History

The Norfolk Light & Fuel Company began acquiring the parcels forming the Site in September 1902 and began operating a gasoline town plant in 1903. Both the gasoline town plant and the MGP operated between 1907 and 1909. The 1909 Sanborn Fire Insurance Map is the first available that shows the MGP; however, it does not indicate the type of gas manufactured at the plant. The MGP originally produced gas by the Tenney water gas process. The Norfolk Light & Fuel Company manufactured utility gas until 1924 when the Nebraska Gas Co. took ownership. However, historical deed records indicate that the Central West Public Service Company of Nebraska purchased a portion of the Site from the Norfolk Light & Fuel Company in July 1927, currently referred to as the Black Hills (BH) parcel.

The Iowa-Nebraska Light & Power (INLP) Company purchased the BH parcel in 1931 and switched the MGP to a carbureted gas process. The BH parcel was purchased in 1945 by Central Electric and Gas Company, who operated the Site until 1948 when it was converted to a propane-air plant. In 1976, Central Electric and Gas Company sold the Site to Minnesota Gas Company. People's Natural Gas Company purchased the BH parcel in 1993 from Arkla, Inc. (successor to Central Telephone & Utilities Corporation, Minnesota Gas Company and Minnegasco). In 2008, the property was purchased by Black Hills/Nebraska Gas Utility Company, LLC, the current owner of the Site, from Aquila (formerly Peoples Natural Gas Company, a division of Utilicorp United, Inc.). 2

In 1941, Consumers Public Power District, now Nebraska Public Power District (NPPD), acquired from INLP Company, all properties and assets of INLP in the State of Nebraska used or useful in the production, transmission, distribution, and sale of electric energy, including the NPPD Parcel. Per the Bill of Sale between INLP and Consumers Public Power District, dated April 4, 1941, this purchase specifically excluded the sale of any property or assets of INLP situated in Nebraska which were used or useful primarily in the production, manufacture, storage, transmission, distribution or sale of natural or manufactured gas.

Sanborn Fire Insurance maps from 1909, 1916, 1925, and 1946 show that significant changes were made to the MGP during its operating life. Based on the 1955 Sanborn Fire Insurance map, all above-grade former MGP structures were removed from the Site.

2.2 Site Description/Location

The City of Norfolk is in the east northern portion of the State of Nebraska in Madison County.

The Site is west of 7th Street between Norfolk and Madison Avenues and is bisected by the alley running east-west between 7th and 8lh Streets. The east portion of the Site north of the alley, as well as the northeast portion of the area south of the alley (BH Parcel), is currently owned by Black Hills/Nebraska Gas Utility Company, LLC. The remainder of the Site, referred to as the NPPD parcel, is owned by the NPPD.

The BH Parcel contains historical MGP buildings once used as office, warehouse, and maintenance areas. The NPPD Parcel contains administration offices, a maintenance building, an electrical substation, and a gravel-covered area used for parking and equipment storage (including transformers). The buildings located on the Site are currently not occupied. Commercial tenants occupy the buildings to the west of the BH Parcel north of the alley.

The Site is in an area zoned for multiple uses, including downtown and mixed use, public facilities, retail, and single family residential. The commercial properties near the Site include a paint, wall covering, and carpet store, an equipment rental store, an antique store, a tattoo parlor, a tire repair shop, a pizza delivery restaurant, an abandoned restaurant, and a building supply center/lumber yard. The closest residences are located along the west side of 8th Street adjacent to the NPPD Parcel.

2.3 Site Inspections and Cleanup Activities

Two environmental Site investigations were completed previously; a site investigation by HDR Engineering in 1992 (HDR 1992) and an Expanded Site Inspection (ESI) by the EPA in 2001 (EPA 2001). These investigation activities included the installation of three monitoring wells, numerous soil probes/borings, and the sampling and analysis of soil, ground water, and storm sewer samples. 3

The HDR site investigation included six soil borings, three of which were eventually converted to monitoring wells. Semi-volatile organic compounds (VOCs) including polynuclear aromatic hydrocarbons (PAHs) and VOCs including benzene, toluene, ethylbenzene, and total xylenes (BTEXs) were detected in each boring. The water removed from all three monitoring wells after purging and sampling had a sheen and odor. BTEXs and PAHs were detected in all of the ground water samples.

The EPA ESI included the collection of soil and ground water data intended to determine the extent of soil contamination at the Site and the extent of ground water contamination downgradient and cross-gradient of the Site. The investigation also included collecting storm sewer samples and ground water samples from municipal, private and monitoring wells. ' ,

The soil samples analyzed by the EPA Region 7 laboratory contained detections of the PAHs including pyrene, naphthalene, phenanthrene, indeno( 1,2,3 cd)pyrene and chrysene. Background soil samples were collected from one probe advanced northwest of the Site. BTEXs and PAHs were not detected in any of these samples.

At all sample locations with PAH detections, naphthalene was detected. A background ground water sample was collected from probe GP-8 between 33 and 37 feet below ground surface. The sample contained no PAHs or BTEXs. The only potential MGP- related analyte detected in the sample was barium at 74.4 micrograms per liter (ug/L).

The sampled municipal wells located between the Site and the North Fork of the Elkhorn River are approximately 0.5 miles east ofthe Site. All of these municipal wells contained VOCs including benzene at concentrations ranging from 0.14 to 3.8 ug/L. Chlorinated VOCs were also detected in the municipal well samples. No PAHs were detected in any of the samples.

The benzene contamination in municipal wells M-l and M-2 has been attributed to a leaking underground storage tank (LUST) near the city's water supply wells. Municipal well M-l 0, approximately 3.5 miles west of town, was sampled as a background well and did not have any detections of VOCs or PAHs (EPA 2001).

No private wells were found to contain PAHs. The only private well to contain any BTEX compound was the Henningsen Food Well which contained 0.02 ug/L of benzene. This well at 324 North 3rd Street is-approximately 0.5 miles northeast and cross-gradient of the Site. Several LUST sites are located between this well and the Site.

No BTEXs or PAHs were detected in any of five storm water samples except 3 ug/L of naphthalene in the sample collected upgradient of the Site at the intersection of 8' Street and Norfolk Avenue. The remaining samples were collected between the Site and the sewer's discharge point at the North Fork of the Elkhorn River. Those samples contained no potential MGP-related analytes with the exception of barium at concentrations ranging from 45 to 85.6 ug/L. It does not appear that contaminants are migrating from the Site via the storm sewer system and impacting local streams or sediments. 4

3.0 Community Background

3.1 Community Profile (2011)

Norfolk is a city in Madison county in the state of Nebraska. It is the principal city of the Norfolk Micropolitan Statistical Area. Norfolk was founded in 1866. According to the United States Census Bureau, the city has a total area of 10.78 square milesj all land. Norfolk is located 113 miles northwest of Omaha and 83 miles west of Sioux City.

As of the 2010 census, there were 24,210 people, 9,910 households, and 6,005 families residing in the city. It is the ninth largest city in Nebraska. The population density was 2264.7 people per square mile. There were 10,625 housing units at an average density of 993.9 per square mile. The racial makeup of the city was 88.0% White, 1.6% African American, 1.4% Native American, 0.6% Asian, 6.3% from other races, and 2.0% from two or more races. Hispanic or Latino of any race were 12.1 % ofthe population.

There were 9,910 households out of which 29.0% had children under the age of 18 living with them, 46.3% were married couples living together, 10.6% had a female householder with no husband present, 3.7% had a male householder with no wife present, and 39.4% were non-families. 32.5% of all households were made up of individuals and 11.3% had someone living alone who was 65 years of age or older. The average household size was 2.36 and the average family size was 3.00. 1 • >

The median age in the city was 35.5 years. 24.5% of residents were under the age of 18; 12.1% were between the ages of 18 and 24; 23.6% were from 25 to 44; 25.1% were from 45 to 64; and 14.6% were 65 years of age or older. The gender makeup of the city was 49.0% male and 51.0% female.

As of 2000 the median income for a household in the city was $34,609, and the median income for a family was $45,460. Males had a median income of $31,445 versus $21,397 for females. The per capita income for the city was $16,990. About 7.0% of families and 11.0% of the population were below the poverty line, including 11.6% of those under age 18 and 12.2% of those age 65 or over.

3.2 History of Community Involvement

In July 2012 a display ad was placed to announce a Public Availability session. A Public Availability Session was held at the Norfolk Public Library in July, 2012. In August 2012, a Fact Sheet was distributed to the community via mail announcing the public comment period for the Engineering Evaluation/Cost Analysis and the availability of the Administrative Record in the Norfolk Public Library. 3.3 Key Community Concerns

Community interviews were conducted with residents of Norfolk in September, 2012. The interviewees consisted of private citizens, city officials, and business owners.

As a whole, the community did not display a great awareness of the environmental contamination associated with the Site. One interviewee was a former employee of the Iowa-Nebraska Light & Power Company and worked at the Site for more than twenty years. This resident was not aware of any environmental contamination at the Site. In another example, an interviewee was aware of the Site and its past history, and was not surprised to learn of environmental contamination at the Site.

A major concern expressed during community interviews was the cost associated with the response action. Of particular concern was whether tax payers, in particular local Norfolk tax payers, would be responsible for paying costs associated with the cleanup.

Knowledge Of the EPA's Superfund program was limited among residents and businesses in the area. Only approximately 25% of interviewees were aware ofthe Superfund program, however this knowledge was mostly limited and superficial. Additional environmental concerns in the community focused on nitrate levels. High nitrate levels are ubiquitous in Nebraska and citizens are very aware of the levels of nitrate in the ground water. There were no other major environmental concerns expressed during the community interviews.

3.4 Response to Community Concerns

Due to the general interest in the overall cost of the response action and questions over who is responsible for paying response costs, an explanation of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) was given to each interviewee. This explanation included the role of Superfund as an enforcement program and that cost recovery activities are conducted when a viable potentially responsible party (PRP) is identified. Interviewees were pleased to learn that a PRP is involved and that costs paid by taxpayers will be minimal.

3.5 Summary of Communication Needs

All community members interviewed indicated they want to be placed on the mailing list for Site updates. All were interested in receiving Site updates at regular intervals: with major milestones or accomplishments, and regular intervals in the absence of major milestones. The intervals ranged from monthly to every six months. The community desires to be kept well informed of the remediation process by the EPA, both during times of major activity and at intervals between major actions at the Site.

The primary method for communicating directly with the community should be through the mailing list and the newspaper. Residents indicated that regular mail updates would be the best way to keep the community informed of Site activities. Residents also 6 mentioned the newspaper, television, and radio. Local media options are detailed below in Appendix G. These are the most widely used news sources in the local area, according to community interviews.

For public meetings or public availabilities, the public indicated a variety of possible locations. These locations are detailed below in Appendix C. Community residents indicated that meeting times during the week, after 7 p.m. are preferred/Wednesday evenings should be avoided because many residents attend church. Friday evening should also be avoided during football season.

4.0 EPA's Community Involvement Program

4.1 Goals

The overall goal of the EPA's community involvement program is to promote meaningful' two-way communication between citizens and the EPA, and to provide opportunities for the community for meaningful and active involvement in the process. The EPA will implement the community involvement activities described below. The following plan is based on the community interviews described earlier; it addresses each issue that was identified as being important to the community.

4.2 Objectives

The EPA will strive to achieve each of the following objectives through implementation of the community involvement program:

1. Share Site information with the community on a timely basis and in nontechnical language. 2-. Encourage, and publicize opportunities for community input regarding Site activities and proposed cleanup plans. 3. Notify local officials, residents, and businesses in the Site area before field work or other actions take place. 4. Maintain Site information in the community and make it accessible to all interested residents and other stakeholders. 5. Increase the level of awareness and understanding of the Superfund process and specific activities involved in the process.

4.3 Key Messages

The EPA will use the following key messages for community involvement activities related to the Iowa-Nebraska Light & Power Site: .) 1. The EPA is addressing the Site using the Superfund process and will comply with Superfund requirements and EPA technical criteria. 2. Throughout site activities, EPA will share information about the Site and include community residents and stakeholders in the cleanup process. 3. Municipal wells belonging to the city of Norfolk are not contaminated with coal-tar-related contaminants associated with the Site.

4.4 Target Audiences

The community involvement program will focus on the following audiences:

• Residents and businesses located near the Site. • Elected and administrative officials of local, state, and federal agencies serving the Site and the community. • Area news media as a vehicle for informing the general public.

• Developers and real estate agencies.

4.5 Projected Schedule for Community Involvement Activities

• August-September 2012: Conduct community interviews. • September 2012: Complete Community Involvement Plan. • Community updates through mailings and display ads as appropriate. Throughout the Superfund process, the EPA is committed to providing the community ample opportunity for involvement. The next steps in the Superfund process are:

• Issue an Enforcement Action Memorandum • Enter into an Administrative Agreement and Order on Consent with the Respondents to conduct the removal action • Conduct the removal action • Oversee implementation of post-removal site control s

4.6 Community Involvement Resources

• Technical Assistance Grants (TAG) A Technical Assistance Grant (TAG) provides money for activities that help your community participate in decision making at eligible Superfund sites. An initial grant up to $50,000 is available to qualified community groups sO they can contract with independent technical advisors to interpret and help the community understand technical information about their site.

Additional information can be found online at the EPA TAG web page: http://www.epa.gov/superfund/community/tag/

• Technical Assistance Services for Communities (TASC) TASC js a program that provides independent educational and technical assistance to communities. TASC primarily supports the Superfund program. In addition, support may also be provided to communities impacted by the Resource 8

Conservation and Recovery Act or federal facilities or dealing with air or water environmental problems.

This EPA program offers technical assistance to help communities better understand and become involved in the cleanup process for hazardous waste sites.

Additional information can be found online at the EPA TASC web page: http ://www. epa. gov/superfund/comm uni tv/tasc/

• Community Advisory Group (CAG) A Community Advisory Group is made up of representatives of diverse community interests. Its purpose is to provide a public forum for community members to present and discuss their needs and concerns related to the Superfund decision-making process. A CAG can assist EPA in making better decisions on how to clean up a site. It offers EPA a unique opportunity to hear-and seriously consider-community preferences for site cleanup and remediation.

Additional information can be found on the EPA CAG web page: http://wwwiepa.gov/superfund/community/cag/

Community members with questions regarding TAG, TASC or CAG may also contact:

Ben Washburn Community Involvement Coordinator 11201 Renner Boulevard Lenexa, KS 66219 [email protected] (913)551-7364 Appendix A: Federal Elected Officials

United States Senators

MikeJohanns 404 Russell Senate Office Building Washington, D.C. 20510 Phone (202) 224-4224 Omaha Office 9900 Nicholas St., Suite 325 Omaha, NE 68114 Phone(402)758-8981 Fax (402) 758-9165

Ben Nelson 720 Russell Senate Office Building Washington, DC 20510 Phone (202) 224-6551

Northeast Nebraska Office P.O. Box 791 South Sioux City, NE 68776 Phone (402) 209-3595 Fax (866) 789-6460

United States House of Representatives

Jeff Fortenberry 1514 Longworth HOB Washington, DC 20515 Phone (202) 225-4806 Fax (202) 225-5686

Norfolk Office 125 S. 4th Street, Suite 101 Norfolk, NE 68701 Phone (402) 379-2064 Fax (402) 379-2101

Appendix B: State Elected Officials

Senator Mike Flood District 19 State Capitol P.O. Box 94694 Lincoln, NE 68509 1

Appendix C: Local Officials

Sue Fuchtman Mayor 309 West Madison Ave Norfolk NE, 68701

Appendix D: EPA Regional Contacts

Owens Hull, Remedial Project Manager. [email protected], (913) 551-7226

Ben Washburn, Community Involvement Coordinator, [email protected], (913) 551-7364

Barbara Peterson, Site Attorney, [email protected], (913) 551-7277

EPA Regional Contacts may be reached via mail at: 901 N. 51'1 Street Kansas City, KS 66101

After October 15, 2012, EPA Regional Contacts may be reached via mail at: U.S. Environmental Protection Agency Region 7 11201 Renner Boulevard Lenexa, KS 66219

Or via telephone toll-free at EPA Region 7: (800)223-0425

Appendix E: State Agencies

Nebraska Department of Environmental Quality 1200 "N" Street, Suite 400 P.O. Box 98922 Lincoln, NE 68509 (402)471-2186

Appendix F: Potential Public Meeting Locations

Lifelong Learning Center Northeast Community College 801 East Benjamin Ave Norfolk, NE 68701 Norfolk Public Library 308 Prospect Avenue Norfolk, NE 68701 (402)844-2100

Appendix G: Local Media Information

Norfolk Daily News 525 Norfolk Avenue Norfolk, NE 68701

KTIV-TVCh.4 3135 Floyd Blvd. Sioux City, IA 51108

KETV-Ch.7 2665 Douglas Street Omaha, NE 68131 ,

KMTV-Ch. 3 10714 Mockingbird Drive Omaha, NE 68127

WJAG, KQKX & KEXL Radio 309 Braasch Avenue P.O. Box 789 •Norfolk, NE 68702

Appendix H: Repository Locations

EPA Region 7 Records Center . 901 N. 5ffi Street Kansas City, KS 66101

After October 15, 2012, the EPA Region7 Records will be located at: EPA Region 7 Records Center 11201 Renner Boulevard Lenexa, KS 66219 (800)223-0425

7:00 a.m.-5:00 p.m. 12

Norfolk Public Library 308 Prospect Avenue Norfolk, NE 68701 (402)844-2100

9:00 am - 8:00 pm Monday - Thursday 9:00 am - 5:00 pm Friday - Saturday 1:30. am -4:30 pm Sunday

t Appendix I: Community Interview Questions

The following questions were asked to the community in September, .2012, when community interviews were conducted for the completion of the Community, involvement Plan.

1. How long have you lived or worked in this community?

2. What do you think is the most important environmental problem facing your community today?

3. What do you know about the Superfund Program?

4. Are you aware of the Iowa-Nebraska Light & Power Former Manufactured Gas Plant Site? (Provide background information about the site).

5. From what you know or have heard of the situation, do you have any major concerns about your own health or safety?

6. Have you heard anyone express other concerns? Have you been hearing any talk about the sites from other residents or business people?

7. Do you want to suggest individuals or groups who should be included on the project mailing list?

8. When the EPA schedules any public meetings about the site, what day and time would be most convenient for you?

9. What do you think would be the best location for public meetings in your area?

10. How can the EPA best provide you with information concerning site activities? How would you like to be informed (mail, newspapers, television, radio)?

11. How often do you want to' receive information about the sites?

12. What radio and television stations and newspapers do you listen to/watch or read? 13

13. An information repository has been established for the site at the Norfolk Public Library. Were you aware of this repository and are you likely to visit the library to review these materials?

14. Do you have any other questions or comments that you'd like to express? .