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COMMUNITY RELATIONS PLAN

RAYMARK INDUSTRIES, ING, SITE AND SURRaUNDlNG AREAS

StRATI=bRD> CONNECTICUT

For U.S. Environmental Protection Agency

By Halliburton NUS Corporation

EPA Work Assignnnent No. 42-1LH3 EPA Contract No. 68-W8-0117

HNUS Project No. 0890

February 1995

sIsHamburtonNUS " 5 ? C O R P O R A T I ON

COMMUNITY RELATIONS PLAN

RAYMARK INDUSTRIES, INC. SITE AND SURROUNDING AREAS

STRATFORD, CONNECTICUT

For U.S. Environmental Protection Agency

By Halliburton NUS Corporation

EPA Work Assignnnent No. 42-1LH3 EPA Contract No. 68-W8-0117

HNUS Project No. 0890

February 1995

Prepared By:

l l ^ - l ^ ^ i ^ Betsy Home Community Relations Specialist

Approved By:

ru^George D. Gardner ^ ^ Program Manager

TABLE OF COIMTENTS COMMUNITY RELATIONS PLAN

RAYMARK INDUSTRIES, INC. SITE AND SURROUNDING AREAS

STRATFORD, CONNECTICUT

SECTION PAGE

A OVERVIEW OF THE COMMUNITY RELATIONS PLAN 1

B DESCRIPTION OF THE RAYMARK PROPERTY AND OTHER 2 LOCATIONS IN STRATFORD B-1 Chronology of Events Affecting Cleanup of Properties . . . . 3

Contaminated with Raymark Waste

C COMMUNITY BACKGROUND 5 C-1 Community Profile 5 C-2 Chronology of Community Involvement 5 C-3 Key Community Concerns 6

D HIGHLIGHTS OF PROGRAM 12

E TECHNIQUES AND TIMING 12

ATTACHMENTS

ATTACHMENT A - LIST OF CONTACTS AND INTERESTED PARTIES

ATTACHMENT B - CHRONOLOGY OF COMMUNITY RELATIONS ACTIVITIES CONDUCTED TO DATE

ATTACHMENT C - LOCATIONS OF INFORMATION REPOSITORIES AND PUBLIC MEETINGS

A. OVERVIEW OF THE COMMUNITY RELATIONS PLAN

This Community Relations Plan identifies issues of community concern regarding the Raymark Industries, Inc. Site (Raymark) and its related contamination in Stratford, Connecticut, and outlines the community relations activities that have been undertaken (refer to the chronology in Attachment B). This Plan also describes additional activities that the EPA will conduct during the investigations and cleanup of the Raymark contamination problem.

Community concern about the Raymark property and other locations in Stratford has been high. Removal activities, conducted both by the State Department of Environmental Protection (DEP) and the Environmental Protection Agency (the EPA) began in the spring of 1993 in a number of widespread locations throughout the community. Prior to this, the EPA Removal Program had addressed Raymark contamination in two areas, Raybestos Memorial Ballfield and the Raymark Industries, Inc. facility. As a result of the more widespread efforts, issues of disruption, public health, decline of real estate values, and liability for cleanup of the contamination have been continuing themes echoed by residents and community leaders.

This Community Relations Plan has been prepared to assist the EPA in developing a comprehensive community relations program for citizens affected by the on-going, and future, cleanup activities. The EPA conducts community relations activities to ensure that the local public has input to decisions about Superfund actions and is well informed about the progress of those actions. The fol lowing sections comprise the remainder of the Plan:

Description of the Raymark Property and Other Locations in Stratford

Community Background

Highlights of the Program

Techniques and Timing

Attachments: A) List of Contacts and Interested Parties;

B) Chronology of Community Relations Activities Conducted to Date; and

C) Locations for Information Repositories and Public Meetings

The information on key community concerns in this Plan is based primarily on the field experience of the Community Relations Coordinator during the summer of 1993 and on interviews conducted with citizens of Stratford from March to May 1994. The bulk of the information describing the Raymark property and other locations in Stratford and the list of community relations activities conducted to date were derived

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from a Communications Plan developed by the Stratford Health Department's Project Coordinator. The EPA, and the other federal and state agencies involved in the cleanup, provided input to the Communications Plan.

The EPA New England office in Boston, Massachusetts, has assumed the lead responsibility for implementing much of the investigation and cleanup activities that relate to the Raymark contamination problems in Stratford. The EPA's Region I Superfund Community Relations program will conduct community relations activities at the Raymark property and other locations in Stratford in conjunction wi th the Stratford Health Department's Project Coordinator. Attachment A contains the names, addresses, and telephone numbers of key contacts.

B. DESCRIPTION OF THE RAYMARK PROPERTY AND OTHER LOCATIONS IN STRATFORD

Raymark Industries, Inc. and its predecessor, Raybestos Manhattan, Inc., operated a facility at 75 East Main Street in Stratford from 1919 until September 1989, when operations ceased. The facility produced brakes, clutch parts, and other friction-based products. Raymark's operations generated flammable and corrosive wastes, as well as lead-asbestos sludge containing many contaminants and scrap materials.

Raymark routinely disposed of its waste on their property and in other locations in Stratford. Other parties also took waste from the Raymark facility for use as f i l l , often in wet areas, throughout Stratford. From 1919 to July 1984, Raymark used a system of lagoons in an attempt to dewater the lead and asbestos wastes produced by its manufacturing process. As the lagoons filled wi th sludge, they were often dredged and the material was used as fill in Stratford or the lagoons were covered wi th asphalt and often built upon to increase the manufacturing and storage area of the facil ity. Throughout the summer and fall of 1992 and early 1993, the EPA covered and stabilized Raymark's waste at Raybestos Memorial Ball Field.

During the fall of 1992 and the spring and summer of 1993, Raymark, under the EPA oversight, stabilized and covered three of the four lagoons and removed thousand of bags of asbestos, as well as several containers, and tanks of hazardous materials. In addition to these activities, Raymark also redirected the surface water drainage on the Raymark property so that it no longer entered the fourth lagoon. The fourth lagoon was stabilized and covered during the summer of 1994. During this time period, Raymark secured the facility against trespassers by installing fencing and an electronic gate, and boarding up the lower floors of buildings.

B-1 Chronology of Events Affect ing Cleanup of Properties Contaminated wi th Raymark Waste

In February 1993, the Town of Stratford petitioned the federal Agency for Toxic Substances and Disease Registry (ATSDR) to conduct a public health assessment to evaluate human exposure and the potential for health problems associated with the Raymark contamination problem. ATSDR accepted the petition and agreed to conduct a public health assessment/health consultation and other health fol low-up activities in coordination with the Connecticut Department of Public Health and Addiction Services (CTDPHAS) and the Stratford Health Department.

In early March 1993, results from on-going environmental investigations at Raymark, carried out under the EPA's oversight, revealed the presence of dioxins/f urans beneath the surface of some areas on the Raymark property. ATSDR's health consultation on this data concluded that the dioxins/furans found on the property did not pose an immediate health threat because most of the ground surface was covered by asphalt and gravel and public access was restricted.

At the time, it was not known whether any of the waste that had been disposed off the Raymark property contained contaminants similar to those found on the property (asbestos, lead, PCBs, and dioxins/furans). The EPA and the DEP, in consultation with ATSDR and CTDPHAS, began an initial surface sampling effort, which focused on 15 known disposal areas identified by Stratford officials and Raymark. Residential properties, schools, recreation areas, and accessible public properties were sampled first.

In May 1993, the results from soil samples collected in April and May 1993 became available. The samples were from properties in Stratford where Raymark sludge was believed to have been used as fi l l . Results from the samples showed the presence of lead, asbestos, and PCBs in the soil. ATSDR issued a Public Health Advisory in May 1993, declaring that an imminent public health threat existed from exposure to these contaminants. In May 1993, a public meeting was held by the Town and attended by more than 400 people. In response, to the contamination problem, the Governor of Connecticut committed $5 million under State Superfund jurisdiction. In June 1993, the EPA committed $3 million for the continued evaluation and eventual cleanup of the Raymark contamination problem.

From June 1993 to December 1994, the EPA, working closely with DEP, ATSDR, and CTDPHAS expanded the breadth of the investigation. Sampling included residences, recreation fields, day care facilities, schools, and public areas in Stratford. In addition, planning for cleanup at locations identified as contaminated, and evaluating the environmental and health data (cancer registry and lead screening data) continued.

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As more information was gathered, more areas were added to the list of known Raymark waste locations. Through the EPA's sampling efforts, a number of municipal areas with contamination were found. Currently, the EPA is focusing on approximately 45 residential properties that pose a threat to human health and need to be remediated. In addition, the EPA is sampling and studying commercial properties, wetlands, ponds, and Ferry Creek to define the extent of contamination. Raymark continues the sampling on its own property, under EPA supervision, to define the type and extent of contamination.

In the spring of 1993, the EPA set up a Stratford command post to coordinate field work at those priority locations needing to be investigated and remediated. ATSDR provided staff in Stratford to support the environmental activities, developed health consultations on environmental sampling results, and funded a project coordinator for the community involvement activities at the Stratford Health Department. DEP and CTDPHAS also provided personnel stationed in Stratford to coordinate environmental and public health activities. The EPA and DEP also installed temporary protective measures on some residential, commercial, and municipal properties. The measures included sod, bark mulch, fences, and warning signs, which protect the public from exposure to the Raymark contamination until a permanent remedy is completed.

During the summer of 1993, the surface water and drainage at the Raymark facility was re-routed by Raymark so that storm water no longer discharged to Ferry Creek via Lagoon 4. This minimized the movement of contamination into Ferry Creek. Lagoon 4 was stabilized and covered during the summer of 1994.

On January 18, 1994, the EPA published a notice in the Federal Register that proposed adding to the National Priorities List (NPL) the Raymark property and other locations in Stratford where Raymark waste was found and posed a health threat. The NPL is a listing of abandoned or uncontrolled hazardous waste sites that the EPA deems potentially most harmful to public health and the environment. In September 1993, the EPA began cleanup of the first residential property. During the 1993 and 1994 construction seasons, the EPA has continued to remove waste from residential properties to prevent their inclusion in the Raymark NPL listing.

Raymark has conducted extensive sampling of soil and groundwater to determine the type, the extent, and the movement of contamination on their property. Using this data, the EPA will identify and study potential cleanup methods that might be used at the Raymark property. It is anticipated that both the investigation and study will be finalized by the spring of 1995.

Interagency efforts continue to: cover or restrict access to areas identified as posing a public health threat; sample locations to determine permanent clean-up measures; plan for health studies of populations at risk; cleanup residential parcels to prevent NPL listing; clean up the Raymark facil ity; and plan and implement community education programs.

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C. COMMUNITY BACKGROUND

C-1 Community Profile

Stratford is located immediately east of Bridgeport, on Long Island Sound. In Fairfield County, its residents are among those with a moderate to average income. Much of Stratford's population in the first half of this century was employed by one of several aviation-related industries. Among its distinguishing characteristics, Stratford has a significant older population and the largest number of real estate agents of any community in the state. Census data shows a population of spanish-speaking residents lives in Stratford, although few were encountered or affected by residential cleanups. Stratford also has a significant number of residents living in public housing, although none are near known areas of Raymark contamination. Stratford's 1990 population was 49,389.

The town is governed by a Council of ten members elected from each of the ten districts and one at-large member. The Town Council hires a Town Manager to oversee day-to-day operations.

C-2 Chronology of Community Involvement

In May and the summer of 1993, public concern about the contamination was at its highest. Since then, interest has decreased but the fol lowing groups have been involved and studies have resulted.

The Stratford Citizens Advisory Council (SCAC) was established in the spring of 1993 with assistance from the Stratford Health Department. Members include local residents, town representatives, and business owners that have been affected by or are otherwise interested in the Raymark property and other locations in Stratford. Some had been members of the Milford/Stratford Citizens Against Pollution (MSCAP). the first citizens group to form with a specific concern about Raymark, particularly its noxious air emissions. After a thermal oxidizer was installed in the mid-1980s, the odors emanating from the facility diminished significantly. The group met approximately monthly from the early 1980s until the facility closed in 1989.

SCAC's mission is to : "serve as a link between the community and the various government agencies involved and to hold these agencies responsible; help keep the media focused on the real issues; mobilize citizens to respond in a positive way; and promote effective citizen-wide education about the problem." ,

SCAC initially held weekly meetings but currently meets twice a month on Wednesdays at the Stratford Public Library. Representatives from ATSDR, CTDPHAS, the EPA, DEP, and other community and industry leaders have been invited speakers. SCAC has assisted the Stratford Health Department with distributing newsletters and

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other materials to public areas in Stratford and periodically issues their own newsletter.

The Stratford Medical Advisory Group was set up wi th assistance from the Stratford Health Department and CTDPHAS. The group consists of several occupational and environmental medicine physicians that consider health effects and impacts stemming from the Raymark property and other locations in Stratford. Responsibilities of the group include: answering questions and health concerns at public meetings; advising the community and local physicians; mailing health concern fact sheets; and mailing ATSDR case studies to local physicians.

The Raybestos Oversight Committee, chaired by Councilman Michael Koperwhats, was formed to plan for the long-term, tax producing use of the Raymark facil ity. Members include: State Representatives, Third District Congresswoman Rosa DeLauro's off ice, two citizens, and heads of the Stratford Health, Conservation, and Economic Development Departments.

The Stratford Health Department Survey, carried out in the spring of 1994, was developed by the town to canvas sentiments of people whose residences had been sampled and results confirmed that a health threat existed. The purpose of the survey was to determine their position on capping their property (with restrictions that would accompany leaving the material in place) rather than proceeding with plans for excavation.

The Health Effects Study, funded by ATSDR and jointly sponsored by UConn School of Medicine and the CTDPHAS, was initiated in February 1994. The study seeks to identify effects on human health resulting from exposure to Raymark waste. Participants complete a questionnaire and have a brief health examination, including blood analyses to determine lead and PCB levels, liver function, and blood lipids. Chest x-rays were also offered to adults.

A Lead Screening Program was undertaken during the summer of 1993. The Stratford Health Department and CTDPHAS sponsored free lead screening clinics for children, pregnant women, and concerned citizens.

The Public Works Screening Program, sponsored by the UConn School of Medicine, was conducted in the fall of 1993. Employees of the Stratford Public Works Department were offered a full physical examination and x-rays. Blood analyses were also conducted to determine blood lead and PCB levels.

C-3 Key Community Concerns

Since the spring of 1993, citizens have expressed concerns about a number of issues relative to the Raymark property and other locations in Stratford. These included health effects (short- and long-term); economic issues (real estate values); effect on

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the environment overall; the media portrayal of the waste problem; the lack of communication with residents; and the potential for listing on the NPL.

To more precisely consider these concerns and any others that people chose to raise, the EPA held interviews, and documented them in this Community Relations Plan. Although overall interest in the project remains high, the level of concern has lessened as the cleanup progressed. Compared to the summer of 1993 when the EPA was deluged daily with telephone calls from residents, real estate agents, and bankers, among others, recent calls to our office on the toll-free telephone line have slowed to a trickle. We are averaging two calls a week. Despite this trend, an effective community relations program should prepare for potentially increasing concern as long-term plans are presented for the Raymark property and other locations in Stratford. A successful program will attempt to educate and involve the community wi thout creating alarm. An understanding of local residents' historical familiarity with the facility and the problem is also helpful in planning community involvement.

The interviews were undertaken by conducting face-to-face meetings with affected citizens to more specifically determine their concerns and what they believed could be done to improve communication. In March, April, and May of 1994, the EPA conducted 35 interviews involving 54 people: twenty-three lived near the Raymark facility or inhabited residences tested for the presence of Raymark waste; two members of the Stratford Town Council; one town employee; one real estate agent; five owners of businesses on whose property Raymark waste had been found; and five members of the Stratford Citizens Advisory Council.

A total of 121 people were called to ask if they would like to be interviewed. Thirty-five interviews resulted (three were conducted over the telephone). Thirty-eight people were unreachable (no answer; ill; available only through an attorney; telephone unlisted or no longer in service; or did not respond to request to return the call, etc.) Twenty-three indicated either that they were too busy to respond or commented that they were satisfied with what the EPA was doing and did not feel that an interview would be worthwhile. Another 25 expressed varying degrees of anger toward the EPA, either refusing to be interviewed or to discuss the matter further.

The results of these interviews are summarized below.

Most were home-owners who had lived in Stratford for more than a decade: the person interviewed who had lived in town the longest had been a resident for 50 years; the interviewee with the shortest tenure had resided in Stratford for less than one year. They felt that because of accurate information provided by involved agencies or the media, they knew what the Raymark contaminants were and why they were a problem. The majority had only known about the problem for a year or t w o ; however, several recalled the odor and soot generated by Raymark operations back in the early 1980s; some remembered the "capping" conducted on some

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municipal properties in 1978; others recalled seeing/playing in the piles of waste scattered around the community when it was being offered as "clean f i l l . "

A general pattern of concern arose based on age: people who had lived in Stratford for several decades were less concerned about health issues than younger people interviewed, many of whom were parents of young children. Some of the "old t imers" had themselves or knew others who had worked at the Raymark facility for years and had developed no adverse or unusual health problems. Many of them tended to feel the problem was overblown, either by the media or by the troops of federal and state agencies that gathered to work in town in the spring of 1993. Younger people interviewed generally felt that the contaminants were a major concern and not enough was being done to clean it up.

Regardless of age or length of time spent in Stratford, nearly all those interviewed concurred that, in their estimation, real estate values had decreased appreciably because of the waste problem. Many confirmed that properties throughout the town, whether Raymark waste was found there or not, were also less valuable because of the stigma to the community as a whole.

Other principal concerns included the length of time it was taking to obtain the results of surface and depth soil sampling and the lack of a defined schedule for initiating and completing cleanup activities.

Health Concerns

Those residents who thought that health issues were a real concern expressed their fears mostly in terms of affects on their children (and animals). Numerous references were made to the increased numbers of cancer victims in areas near the Raymark property and other areas in Stratford where Raymark waste had been used as fil l. Others expressed concern about how long it might take before exposure to Raymark waste might be evident. They requested more medical monitoring for those who had been exposed. Two interviewees wondered whether the Raymark waste caused or contributed to the perceived high number of children in the Stratford schools with learning disabilities.

Several residents who had grown their own vegetables for a long time were more concerned about whether they could plant for the 1994 growing season (since they had been warned not to disturb the potentially affected portions of their yard) rather than whether any long-term consumption of the garden produce might result in long-term health problems. Only a few expressed concern about past consumption, particularly of tomatoes and zucchini.

A number of residents wondered how the EPA personnel and their contractors could be operating in "moon suits" so close to unprotected audiences (including children playing and business employees working) and not be concerned about whether their

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actions might affect the audience's health. Others hoped that air monitoring was being done during excavation activities to assure area residents that they were not breathing contaminated air.

Economic Concerns

Two major economic concerns revolved around the presence of the Raymark waste: a perception that real estate values had depreciated and that local taxes would increase.

Many felt that a town-wide decrease in home values had occurred, not just on those parcels where waste had been confirmed, but all over town . Worse, to some, the EPA had contacted them about sampling their property but they were not sure whether sampling had occurred or if it had, what the results were. Several people said they were unable to refinance mortgages or get title insurance on prospective residences because of the " l imbo" status in which they found themselves. Numerous instances were cited of sales falling through because of proximity to residences that were thought to have Raymark waste on them.

A substantial number of interviewees related their fear that the town of Stratford would be compelled to pay for cleanup activities on municipal properties and that those costs would be passed along to them in the form of increased property taxes. Several people noted that a recent town-wide re-valuation had resulted in an enormous jump in real estate assessments, just at a time when the marketable value of their holdings had plummeted.

Several people expressed concern that, based on the high media profile of areas of Stratford that received Raymark waste, the community was now notorious; no knowledgeable prospective business person or home seeker would relocate to the town. These persons lamented that just as the economy in the northeast was recovering from the recession, Stratford would miss out on the rebound.

An additional issue, adding the Raymark property (and perhaps portions of the t own , including individual residences) to the National Priorities List, was raised by several persons interviewed. Many felt that the listing would heighten the town's "black eye" as an undesirable place to live and work. If the designated NPL site boundary extended beyond the facility-proper to residential properties, it would impose an enormous burden on those homeowners as well as on those who lived nearby. Several others, however, sensed that the listing would quicken the pace of the inevitable cleanup and would hasten putting this problem behind them. Once completed, it would give Stratford a "clean bill of health", a boast few other areas could make. Several people requested that the EPA commit to presenting them with a "certificate of cleanliness" once the residential excavation activities were completed.

A number of people expressed concern as federal tax payers that the EPA was either wasting their money by excavating residential parcels or was spending too much per parcel for the work. They recalled the media quoting an EPA official stating that the cleanup cost of one of the residences was $500,000. Others thought the EPA contractors were being paid triple the normal rate because of the "emergency" nature of the cleanup. An additional concern was that the EPA "should do it once"; digging up the material and taking it to Raymark and then doing something again to it there was an extravagant use of federal funds.

Broad Environmental Concerns

Only two people interviewed articulated an overall concern for the affect of the Raymark waste on the environment as a broad issue. However, several expressed concern that the migration of Raymark-generated contaminants might have affected the near-shore fish and wildlife. Two people wondered if it had impacted Long Island Sound and if the EPA was investigating this possibility.

Nuisance Concerns

Several interviewees cited various nuisances that have resulted from the EPA's cleanup work. A few expressed concern that vermin (rats, raccoons, etc.) had been dislodged because of excavation activities on residential (and vacant) parcels. Other nuisance issues raised included dealing wi th truck traffic and congestion caused by workers' parked cars on neighborhood streets, and the cost of long-distance calling to the EPA in Boston.

Media Impact Concerns

Several people sensed that the media, particularly the print media, had added to the town's sense of panic in the spring of 1993 by exaggerating the imminence of the health risk. A number of interviewed homeowners related stories of reporters who had pressed them for interviews and pictures of their houses, and misquoted them or used comments that they had indicated would be off the record, at a time when most did not want the fact that contamination had been found (or even alleged) on their property to be publicized.

On the other hand, a few people interviewed suggested that the EPA use the media to publicize the cleaned up parcels once remediation had been completed. In fact, one interviewee strongly encouraged the EPA to hire a Madison Avenue advertising firm once the remediation was completed to ensure that Stratford's cleanup be given the same level of national media attention that was focused on the community in the spring of 1993 when the ATSDR health advisory was issued.

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Lack of Communication Concerns

Several persons complained that the persons doing the sampling did not appear when they said they would or that they sampled without first calling to give notice to the homeowner. On the whole, however, most people interviewed said that when they had an opportunity to meet with EPA representatives, they were courteous, punctual, informative, and patient in responding to questions and explaining technical information.

As to providing information in a timely, understandable fashion other than in person, the EPA was frequently berated. The communication concerns most often expressed during interviews were that the EPA had not provided sampling results promised months before and that the Agency was only increasing people's frustration by failing to articulate a schedule for cleanup activities. These failures had created a living limbo for many: they refused to invite friends to visit; they were ridiculed by co­workers; and one couple felt compelled to move events planned around their daughter's wedding to a remote location.

In a companion theme echoed by several people interviewed, the EPA staff was asked to be candid when they did not have an answer to a question posed about the cleanup process. The complaints revolved principally around receiving vague answers to highly technical issues and the scheduling of sampling and cleanup activities. The request was that when a crisp answer is not available, saying "we don' t know but we will know in X days/weeks/months" is better than providing a cloudy, often misleading response. Methods of communication were often raised. A number of interviewees had attended one or more public meetings on the Raymark waste problem. Many of those who had attended a meeting complained that too little notice had been given, that they were just there for people to vent their anxieties, and that the purpose of the-meetings had not been well thought out. Several suggested that smaller, focused meetings could be useful.

Two interviewees, one a residence owner, the other a renter, told similar stories about not receiving important information from the EPA. The owner stated that his renter received information from the EPA about sampling (access) but that he did not. The renter related that only the out-of-state owner received the sampling results and only after she made a fuss was she provided with the information.

Nearly all of the interviewees recalled having seen the Stratford Environmental Updates and they generally thought the material was useful in providing information on the status of the cleanup. However, many suggested that the documents were too focused on abstract risk issues when they should provide information in a way that is relevant to an audience that does not have technical training.

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Throughout the interview process, virtually all those queried were unclear about which agency was conducting which operation. Since governmental representatives seem to be interchangeable to the general public, it is imperative that these bodies closely coordinate their activities.

Future Use of the Ravmark Property Concerns

A few interviewees requested that the EPA become involved in seeing that the Raymark property be returned to the tax rolls. Those interviewees who expressed a preference for how the property should be used included turning it into: a BMX track; a recreation complex; home to a major league baseball team; a Post Office; a golf course; a tiered transportation center; a railroad station; and a complex for town emergency services. Malls and parking lots were ruled out.

D. HIGHLIGHTS OF PROGRAM

An effective community relations program is based on the ability to:

• facilitate communication among agencies involved with the Raymark Industries, Inc. cleanup;

• present the key concerns of the residents and business owners affected by the cleanup;

• facilitate communication between the agencies and the public through the media and other more direct communication tools;

• develop and maintain an open dialogue with the community and the media on issues of health and environmental activities; and

• deliver a consistent message and chronology of events to the public.

E. TECHNIQUES AND TIMING

The basic requirements for community relations activities include:

Information Repository Maintenance - The Stratford Public Library has been designated as the EPA Information Repository. The Reference Desk has an array of pertinent materials including: field investigation reports; removal action administrative record files; ATSDR Public Health Advisory; contaminant-specific toxicity reports (lead, asbestos, PCB, and dioxin); maps of properties in Stratford where Raymark waste was found and their sampling locations; and screening data. In addition, fact sheets and other educational materials on environmental health are available, including handouts on the prevention of lead poisoning and risk evaluation of disease for individuals in

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communities with suspected environmental contamination. This information is supplemented by the EPA and the Stratford Health Department on a regular basis.

Details about the EPA's Technical Assistance Grants are also included in the repository. Grants may be made available to residents who are interested in working with the EPA to cleanup the contamination. The EPA and other involved agencies will continue to add information to the repository as the investigations and cleanup progress. The EPA will also include upcoming reports that describe the type and severity of contamination and possible cleanup solutions for the Raymark facility. These reports, along with the Proposed Cleanup Plan that the EPA is recommending, will be available at the repository for the public to comment on. When these documents are available, a notice will be published in local newspapers such as the Connecticut Post, the Bard, and the Stratford Star, information will also be mailed to anyone on the EPA's mailing list.

Responsiveness Summary - This document is part of the Record of Decision (ROD). A ROD is the formal document choosing a cleanup plan for the Raymark Industries, Inc. facility. It will summarize public concerns and issues raised during the public comment period on the Proposed Cleanup Plan and other documents. In addition, the Responsiveness Summary will document the EPA and State responses to these concerns. The ROD and Responsiveness Summary will be available for public inspection and copying at the Library prior to the start of the cleanup. A notice will be published in the Connecticut Post, the Bard, and the Stratford Star when these are available.

Revision of the Plan - This Community Relations Plan should be revised when the ROD has been issued, to outline community relations activities appropriate to the remedial design and cleanup. The Plan revision should:

• Update facts and verify information in the Plan.

• Assess the community relations program to date and indicate if the same or different approaches will be taken.

• Develop a strategy to prepare the community for future involvement during the design and cleanup.

Another set of community interviews should be scheduled before the Plan is revised.

Fact Sheets and Mailings - Several different types of fact sheets may be used to address particular aspects of cleanup, including NPL listing. Question-and-Answer format fact sheets may be useful. Neighborhood-specific fact sheets or other information letters should be considered on an as-needed basis to specific neighborhoods or the entire mailing list.

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Establish a Telephone Link - As a result of comments made during the interviews, the EPA established a Stratford exchange telephone number that allows residents to call the EPA's Boston office without incurring long-distance charges. The number is 380-6034. Stratford citizens may leave a message of any length, indicating the issue they are calling about and the best time of day (and telephone number) at which the call can be returned. The EPA's Stratford Community Involvement Coordinator checks the machine for messages twice a week.

Continue Publication of the Stratford Environmental Update Newsletter - The town of Stratford published the first four issues of the newsletter with funding from the DEP. Subsequent issues are being sponsored by the EPA with articles included from the EPA, DEP, Stratford Health Department, ATSDR, CTDPHAS, Stratford Medical Advisory Group, and SCAC. As a result of requests made during the interviews, the newsletter format has been simplified and more articles focus on the Raymark facility and overall cleanup schedules. The mailing list has also been expanded.

Establish Information Contacts - To meet the information needs of local officials and community members, the EPA has designated two individuals as information contacts: Project Manager, Michael Hill, and the Community Involvement Coordinator, Liza Judge. Their addresses and telephone numbers (listed in Attachment A) will be included in materials distributed to the public. With the prominence and easy access of the Stratford Health Department, they continue to be a central contact for the community and funnel requests and concerns to the EPA and other agencies. The EPA also supports SCAC's expanded role in communications. Names of key contacts for Stratford residents to communicate wi th are included in Attachment A.

Conduct Informal Meetings with Residents - During the interviews, several people mentioned that the large, loosely structured public meetings were not ideal for dealing with the Raymark property and other locations in Stratford scattered throughout the community. To address this issue, the Stratford Health Department with the EPA and other agencies, has held many neighborhood meetings and intends to schedule more as the cleanup progresses. With the greater success of small format meetings, the EPA plans to schedule a number of small open house/information meetings for release of the Proposed Cleanup Plan and acceptance of public comments.

Provide News Releases to Local Media - Prepared statements might be released to local newspapers, such as the Stratford Star, the Bard, the Connecticut Post, and the A/ew Haven Register, and to local radio and television stations to announce discovery of any significant findings or to notify the community of any public meetings. Additional news releases are advisable before cleanup activities start.

Continue Interagency Coordination - To ensure that the numerous local, state, and federal agencies are working in tandem toward a common goal, a workgroup and regular communications points have been established with the Stratford Health Department as the focal point. These include:

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Stratford Interagency Workgroup - The workgroup is composed of representatives from the EPA, DEP, ATSDR, CTDPHAS, and the town of Stratford (including the Town Manager, and Departments of Health and Conservation). The workgroup meets on alternate months to update other interested agencies and officials on the status of activities. Other agencies include but are not limited to: U.S. Food and Drug Administration (FDA), U.S. Fish and Wildlife Service (USFWS), National Oceanic and Atmospheric Agency (NOAA), Connecticut Department of Agriculture, Connecticut Department of Transportation, U.S. Coast Guard, and U.S. Army Corps of Engineers (USAGE).

Agency Coordination Meeting - Moderated by the Stratford Health Department, a conference call is conducted on Thursday afternoons to brief and coordinate each agency's issues or activities. Participants meet to: discuss sampling and cleanup activities, address data evaluations and dissemination (health consultations, visits to property owners, and letters to owners), address media and public information issues [Stratford Environmental Update, press releases and/or briefings), and collaborate on environmental and health communication/education activities in Stratford, e.g., neighborhood forums and fact sheets.

Removal Cleanups - The EPA and USAGE meet regularly to coordinate plans for sampling and cleanup of residential properties.

DEP and EPA meetings - Representatives of these agencies meet as needed to coordinate data needs, sampling, and clean-up plans.

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ATTACHMENT A LIST OF CONTACTS AND INTERESTED PARTIES

Michael Hill Mail Code HEE-CAN6 Remedial Project Manager Waste Management Division U.S. EPA JFK Federal Building Boston, MA 02203 617-573-9653

Liza Judge Mail Code REA Community Involvement Coordinator Superfund Community Relations U.S. EPA JFK Federal Building Boston, MA 02203 617-565-3419

Andrea Boissevain Stratford Project Coordinator Stratford Health Department 2730 Main Street Stratford, CT 06497 203-385-4090

Elaine O'Keefe, Director Stratford Health Department 2730 Main Street Stratford, CT 06497 203-385-4090

Steve Tartaris Connecticut DEP 79 Elm Street Hartford, CT 06106-5127 203-424-3790

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Jennifer Kertanis Connecticut Department of Public Health and Addiction Services 150 Washington Street Hartford, CT 06106 203-240-9022

Suzanne Simon Agency for Toxic Substances and Disease Registry Region 1 60 Westview Street Lexington, MA 02173 617-860-4619

Dr. Eileen Storey Stratford Medical Advisory Group Section of Occupational and Environmental Medicine UConn, Farmington Avenue Farmington, CT 06030-6105 203-679-2386

Angle DeMello Stratford Citizens Advisory Council 84 Ward Street Stratford, CT 06497 203-386-0375

Janet Carlucci Stratford Citizens Advisory Council 193 Glenfield Avenue Stratford, CT 06497 203-377-2903

Mark Barnhart Town Manager Town Hall 2725 Main Street Stratford, CT 06497 203-385-4001

Michael Koperwhats, Chair Raybestos Oversight Committee 952 East Broadway Stratford, CT 06497 203-377-8022

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ATTACHMENT B CHRONOLOGY OF COMMUNITY RELATIONS ACTIVITIES CONDUCTED TO DATE

APRIL 1993 Fact sheet on public health activities in Stratford, CT issued (prepared by ATSDR for first public meeting).

Meeting held wi th the Wooster School teachers about their concerns regarding the discovery of dioxin at Raymark and the waste used to build the Wooster playing fields. Health Director, ATSDR, CTDPHAS, DEP and Michael Grey, M.D., UConn.

The EPA briefed officials and press on Raymark's past waste disposal practices and presented a course of action for addressing the problem.

MAY 1993 Wooster School Public meeting held, sponsored by DEP and the Stratford Health Department.

Fact sheets and packets on the environmental data issued (the EPA and DEP provided after first round of sampling). Fact sheet issued in a question/answer format on environmental and health questions for May 27, 1993 public meeting (CTDPHAS).

Fact sheet on the public health advisory (ATSDR) issued.

JUNE 1993 Meeting with citizens living in the southern end of Stratford, near a public housing area, held at the South End Community Center.

Meeting wi th physical education teachers at the Wooster School held. Health Director and ATSDR.

A booth was sponsored by the Health Department and the Stratford Citizens Advisory Council at the Stratford Day Family Fair.

JULY 1993 Meeting with senior citizens at the Baldwin Center held with the Town Manager, Town Councilman, Conservation Director and Health Director.

Meeting wi th parents and residents from a specific councilman's district held. Town Councilman, ATSDR, and the EPA.

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Meeting with people living near Wooster School held on the remediation activities to take place in July and August. Town Manager, Conservation Director, DEP, CTDPHAS and ATSDR.

The first Stratford Environmental Update issued.

AUGUST 1993 3rd and 4th Avenue Neighborhood Forum held. Neighborhood forum fact sheet for 4th and 5th Avenues issued.

The second edition of the Stratford Environmental Update issued.

SEPTEMBER 1993 Neighborhood forums held and fact sheet written for Lot K/Elm Street and Morgan Francis property.

Neighborhood forum held for residents living near Raybestos Memorial Field.

OCTOBER 1993 3rd and 4th Avenue Neighborhood Forum held.

NOVEMBER 1993 The third edition of the Stratford Environmental Update issued.

JANUARY 1994 EPA mailing list notified of Raymark's proposed addition to the National Priorities List.

FEBRUARY 1994 The fourth edition of the Stratford Environmental Update issued.

MARCH - MAY 1994 The EPA conducted interviews for the Community Relations Plan.

JUNE 1994 DEP held a public meeting to inform Wooster School parents and neighbors that the school cleanup was postponed until the summer of 1995.

The f i f th edition of the Stratford Environmental Update issued.

AUGUST 1994

SEPTEMBER 1994

Sidney Street Neighborhood Forum held.

Wil low Avenue Neighborhood Forum held.

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JANUARY 1995 The EPA sent affected residential property owners a letter indicating that they would not be held responsible for cleanup costs on their properties and that the EPA would protect them against third party liability for waste brought to the Raymark facility.

Second Elm Street Neighborhood Forum held.

Stratford Avenue Neighborhood Forum held.

FEBRUARY 1995 Sixth Edition of the Stratford Environmental Update issued.

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I I ATTACHMENT C

LOCATIONS OF INFORMATION REPOSITORIES AND PUBLIC MEETINGS

Information Repositories:

Reference Desk Stratford Public Library 2203 Main Street Stratford, CT 203-385-4164

Hours:

M,T,W Th F, Sa

Jim Kyed (HPC-CAN7) EPA Records Center 90 Canal Street, 1st Floor Boston, MA 02114 617-573-5729

Hours:

10:00 am - 8:00 pm 10:00 am - 6:00 pm 10:00 am - 5:00 pm

M-F 10:00 am - 1:00 pm 2:00 pm - 5:00 pm

Public Meeting Locations:

Locations for all public meetings will be coordinated through the Stratford Health Department.

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