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Lawrence Todtz Farm Site
MCA Camanche, Clinton
County, Iowa
*-7 *
Lawrence Todtz Farm P
Community Involvement Plan
January 2016
SECTION 1
Overview of the Community Involvement Plan
This Community Involvement Plan identifies issues of concern and interest to the community potentially
affected by the Lawrence Todtz Farm Superfund Site located in Camanche, Clinton County, Iowa.
Terms that are in bold text are defined in the Glossary in Appendix D and/or identified within the
acronym list in Appendix E of this CIP. This CIP contains information from the files of the U.S.
Environmental Protection Agency Region 7 office, as well as information gathered by EPA during
community interviews and conversations with other interested parties and regulatory authorities.
EPA will use the information in this CIP to help identify and address current matters of concern, and to
review past community involvement efforts as the cleanup project progresses. The CIP will also provide
guidance to EPA staff and help to ensure that community needs are addressed throughout the cleanup
process.
The CIP is intended to:
• Encourage community interest and participation throughout EPA's involvement at the site.
• Initiate and support two-way communication between the EPA and the community.
• Help ensure that community members understand the Superfund process, and the opportunities it
offers them to participate in the decision making process regarding the site cleanup.
EPA Invites Your Comments
In This Plan
If you have comments on this community
Section 1 — Overview of the Community Involvement
involvement plan, please contact:
Plan
Pamela Houston
Section 2 —Community Involvement Plan Objectives
Community Engagement Specialist
Section 3 — Community Involvement Activities to date
Phone: (913) 551-7699
Section 4 — EPA Background
Email: Houston.pamelafSiepa.pov
Section 5 — Site Background
U.S. EPA Region 7
Section 6 — Community Background
Enforcement Coordination Office
Appendix: A-F
11201 Renner Boulevard
Lenexa, Kansas 66219
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Community Involvement Plan - Lawrence Todtz Farm Site - Camanche, IA
This CIP was developed for the Lawrence Todtz Farm Site by Community Engagement Specialist
Pamela Houston. EPA Region 7 is conducting activities at the site under the guidelines of the
Comprehensive Environmental Response, Compensation, and Liability Act, a federal law passed in
1980 and commonly known as "Superfund"; the Superfund Amendments and Reauthorization Act,
enacted in 1986; and the National Oil and Hazardous Substances Pollution Contingency Plan, revised in
1990.
Cleanup Responsibility: Federal and state regulatory authorities each have a role to play in
cleaning up hazardous waste sites.
When EPA has the primary responsibility for Superfund activities at a site, the state provides technical
and regulatory guidance and support to EPA, as needed. In some cases, the state takes the lead while
EPA provides regulatory and technical support. ^
SECTION 2
Community Involvement Plan Objectives
Throughout the investigation and cleanup of the site, EPA will endeavor to keep community members
informed of and involved in the cleanup process. To do this, EPA may employ a variety of tools and
techniques, some of which are described in the next section. The specific communication effort will be
based on the level of community interest, identified
community issues and concerns, and the complexity and
duration of the site investigation and cleanup. The level of
participation sought by some communities or individual
community members varies. EPA encourages those who want
a greater level of participation to consider forming a
Community Advisory Group and/or applying for Technical
Assistance Plan funding. For additional details on the TAP
and CAG programs contact the Community Engagement
Specialist listed in Appendix A.4.
The CIP for this site is intended to provide general Superfund
program information to interested community members, as
well as help them identify the many participation opportunities and options available to them throughout
the cleanup. The CIP is also intended to be an information resource for EPA staff members assigned to
the site team. The following community involvement objectives help to ensure that avenues of
communication between EPA and the community are established and maintained.
Objectives include:
• Provide timely, site-specific information to community members so that they are able to participate
in, or closely follow, site-related activities to the maximum extent they desire and the process allows.
• Provide a direct contact for community members by assigning a CES tor this site. The CES will act
as a liaison between the community and EPA.
• Provide opportunities for community input that are tailored to the needs and concerns of the
community.
• Help ensure that community members are well informed, so that they are knowledgeable about site
activities and the Superfund process.
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• Enhance communications between EPA and local officials to help ensure that officials are informed
of site-related activities and that EPA benefits from the officials' insights regarding the community
and its concerns, the site and its history, and local regulatory issues.
• Enhance communications between EPA and the media to help ensure reporters are provided timely
information about site-related activities and events and are aware of site-related pertinent topics.
SECTION 3
Community Involvement Activities
By performing the following activities, EPA can help ensure that community members know about the
Superfund process and the actions taking place at the site, and that they are aware of the opportunities
for the community to participate in site-related decisions. By providing accurate information about the
site investigation and cleanup, EPA will enable interested parties to make recommendations regarding
the site that are appropriate for their community.
• Assign an EPA Community Engagement Specialist
A site assigned CES provides community members a direct link to EPA Region 7 and acts as a
liaison between EPA and the community. As a member of EPA's site team, the CES can often
respond to inquiries as they are received. Should an inquiry require specific information that the
CES does not have, the CES can obtain the information or refer the inquiry to an appropriate
specialist, such as the remedial project manager or toxicologist assigned to the site. Interested
parties may contact the CES at any time, whenever questions or concerns arise, and the CES will
make every effort to respond promptly and accurately to all inquiries. (See Appendix A.4 for all
related EPA contact information, including the RPM.)
• Establish a toll-free hotline number for the public
EPA maintains a hotline for Superfund inquiries. The hotline can be used to reach EPA or the
Agency for Toxic Substances and Disease Registry employees located in the EPA Region 7 office.
During working hours, the community engagement staff may answer the hotline. When calls are
answered by an answering machine, callers should state which site they are calling about in addition
to leaving their names, phone numbers and the reasons for their calls. Every effort will be made to
return calls promptly. The toll-free number is 1-800-223-0425.
• Prepare and distribute fact sheets to residents and interested parties
Fact sheets (also referred to as community updates or newsletters) are useful when communicating
with large groups about topics of common interest. For example, fact sheets are helpful for
explaining specific events and issues, discussing and dispelling rumors, explaining relevant scientific
or technological data, or informing interested parties about progress or problems related to the site or
the schedule of work.
Fact sheets should be provided on an as needed or annual basis. An annual fact sheet should be
considered when site activities are "invisible" to the community for long periods of time, as is
the case when laboratory analyses are being completed, data is being verified, reports are being
written, or access and other legal agreements are being negotiated.
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• Develop and maintain a mailing (and contact) list
Mailing (and contact) lists are developed and maintained to facilitate distribution of materials,
such as fact sheets and meeting notices, to interested and potentially affected community
members. The lists also provide EPA a quick reference to key community members, such as
local officials and community group leaders, in the event EPA wants to provide a timely notice
about unanticipated events, such as sudden media interest in site activities.
Local residents, local businesses, elected officials, and the media are routinely included on
mailing and contact lists. Community surveys and local tax maps form the basis of most mailing
lists, but the lists are revised to include those who request to be added (or deleted) and those who
provide their names and addresses on meeting and event sign-in sheets or correspondence. EPA
makes every effort to protect the privacy of community residents, which includes denying
requests to share personal information, such as names, addresses and individual residential
sampling results, with nongovernment persons. The mailing list will be periodically updated and
revised throughout the course of the cleanup. Email lists as well as U.S. Postal Service lists may
be verified on a regular basis to ensure the most up to date information is maintained.
• Make site-related information, including data and documents, available to community members
locally
Information is always available to community members at EPA Region 7 in Lenexa, Kansas.
However, EPA must also make it available to local residents at easily accessible locations, such
as a local library or municipal building. The available information may be in any one of several
forms, including paper copies, online (via the Internet), or CD-ROM, depending on the
capabilities and preferences of the local host facility. The information made available will
include documents comprising the Administrative Record, as well as this C1P and other site-
related documents. The Administrative Record is also accessible at the following website:
http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=()70()039. The Camanche Public-
Library and the Clinton Public Library have been established as the local information
repositories host, and will maintain a site file for public review. Some of the site file information
is also posted on the EPA website at: http://www2.epa.gov/superfund. (See Appendix B.l for
location and contact information for the EPA Region 7 office and the local repositories, as well
as how to access files from EPA's Administrative Record website.)
• Keep local officials well informed about site activities and developments
By keeping local officials abreast of the work schedule and site-related developments, EPA can
promote a collaborative relationship to help ensure that officials are able to respond
knowledgeably to citizens' inquiries. When local officials are well informed, they can enhance
the flow of accurate information between EPA and concerned community members. (See
Appendix A.3 for contact information for local officials.)
• Keep local media well informed about site activities
By distributing timely and accurate information to the local media, EPA can minimize
misinformation and speculation about site-related risks and cleanup activities. News releases,
written materials, and direct phone calls are all appropriate ways to provide information to media
representatives. The media should always be notified of public meetings and similar events, and
may be offered opportunities to participate in news briefings or conduct interviews with EPA
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officials. Upon request, or when circumstances warrant, special information sessions or news
conferences can be useful to ensure that complex situations are understood and can, thus, be
accurately conveyed to the public. Every effort will be made to address media inquiries quickly.
(See Appendix A.8 for media contacts.)
• Conduct public meetings and/or public availability sessions
Public meetings are required when EPA is approaching a formal decision, and they are recommended
whenever project milestones are reached, such as the start or finish of a remedial investigation. When
conducted, public meetings will be held at a convenient location during evening hours so that most
interested parties will be able to attend. Public availability sessions are less structured than meetings.
Generally, there are no formal presentations. Instead, community members are invited to come at
their convenience within the set time frames, and talk one-on-one with EPA and other experts
associated with the site cleanup activities. Public availability sessions may include afternoon and
evening hours so that interested parties can attend at their convenience.
• Place public notices in local publications
Public notices regarding required and elective activities will be selectively placed in the Clinton
Herald newspaper. (See Appendix A.8 for a list of all local media.) To ensure the widest
possible exposure, public notices about Superfund activities are often run as retail display ads,
rather than placed in the classified or legal notice sections. Public notices announce important
site-related developments, public meetings and availability sessions, the release of site-related
documents, or any other information of importance to the community at large.
• Hold public comment periods
Superfund law requires EPA to advertise and conduct public comment periods at key points in
the cleanup process, such as prior to making official cleanup decisions or significant changes to
previously announced cleanup decisions. Although there is no requirement that EPA conduct
public meetings during comment periods unless a request is received, EPA Region 7's policy is
to do so.
Meetings held during comment periods allow community members to discuss EPA's rationale for
proposed actions with EPA and other regulatory authorities. At public meetings held within
public comment periods, community members may express their opinions and concerns for
inclusion in the official record, without having to provide a written statement to EPA. A
stenographer transcribes all meetings held during official comment periods, and prepares an
official transcript of the proceedings for EPA's records. Those who do not attend the official
meetings may still submit their comments via regular mail or email within the announced public
comment period time frames.
• Prepare Responsiveness Summaries and Record of Decision
A Responsiveness Summary is a required part of the official cleanup decision document, known
as the Record of Decision. The RS summarizes all substantive comments submitted to the EPA
during the comment period and provides EPA's responses to them. EPA prepares the RS after the
public comment period closes.
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• Promote information sources available through EPA
EPA provides various sources of information to assist community members in understanding the
Superfund process and site-related activities. EPA representatives may be contacted directly by
phone, mail, or email. Information may also be accessed through EPA websites at:
http://www2.epa.gov/superfund.
A toll-free hotline (1-800-223-0425) is available to call in questions or concerns. Additionally,
EPA has established a local repository to store site-related information and documents for public
viewing. Contact information and additional information resources will be included in all
materials that are distributed to community members.
• Provide support for Community Advisory Groups
CAGs are community lead groups that are intended to represent and include all interested
members of the community, including representatives of the potentially responsible parties. By
meeting regularly to discuss the cleanup and the community s issues and concerns, CAGs often
help to keep the community informed and involved in the cleanup process. CAGs can also
provide valuable information to EPA and to local governments concerning the future use of
Superfund properties and the communities' collective long-term goals. Although these groups are
not funded by EPA. the agency can assist interested community members in forming CAGs and
can also provide support services to the groups, such as assistance with production and mailing
of newsletters they develop.
• Provide information about the Superfund Job Training Initiative
The SuperJTI program is designed to provide job training for residents living near Superfund
sites, particularly residents in disadvantaged communities. EPA has partnered with the National
Institute of Environmental Health Sciences to support pre-employment training and classroom
instruction. SuperJTI is a valuable program that can enhance community involvement and
benefit the local economy. SuperJTI can help residents gain career job skills and may provide an
employment base for Superfund site cleanup contractors.
• Revise community involvement plan as needed
Superfund projects can take several years to complete. It is important that the CIP is periodically
updated to reflect changing concerns of the community as the site cleanup progresses. The CIP
contact list should be revised whenever elections result in a change in elected officials, or when
personnel changes affect nonelected official contacts. This is the first CIP for this site.
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SECTION 4
EPA Background
Superfund Program
Superfund cleanups are very complex and require the efforts of many experts from numerous
disciplines. Experts in various sciences, engineering, construction, public health, management,
law, community and media relations, and numerous other fields will be called upon to
participate. The Superfund program is managed by EPA in cooperation with individual states and
tribal governments. The program locates, investigates, and cleans up hazardous waste sites and
responds to hazardous materials emergencies and the threat of hazardous materials releases. An
example of a threat of release is an abandoned, or poorly maintained, facility where hazardous
substances are stored in deteriorating, or inappropriate, containers and are unprotected from
vandalism; and/or the facility is without emergency response capabilities, such as alarms or fire
suppression systems.
Superfund is a federal program. It was created in 1980 under the Comprehensive Environmental
Response, Compensation, and Liability Act, which was amended in 1986 by the Superfund
Amendments and Reauthorization Act. Superfund is guided by the National Oil and Hazardous
Substances Pollution Contingency Plan. The NCP outlines the procedures that EPA must follow
when investigating or addressing a release of hazardous materials into the environment. Under
CERCLA. EPA has the authority to:
• Prevent, control, or address actual or possible releases of hazardous substances.
• Require parties responsible for environmental contamination to conduct or pay for
cleanup.
• Provide funding for cleanup activities when money is not available from responsible
parties.
Potentially responsible parties currently fund about 70% of all Superfund cleanups nationwide,
and frequently conduct cleanup activities under EPA oversight. Funding for the remaining site
cleanups has, historically, come from a trust fund (a.k.a. the Superfund) established by Congress
with revenue from a tax levied on the chemical and petroleum industries. However, EPA's
authority to collect the tax expired in 1995, and fund monies are being depleted. Since the tax
expired in 1995, Congress has not reauthorized it. EPA does not have the authority to reinstate
this tax.
EPA currently funds cleanup actions with what monies remain in the trust fund, as well as with
monies from other sources, such as general revenue funds and funds which become available
when other funded projects are delayed, discontinued, or completed under budget. Careful
prioritization of cleanup projects ensures that all sites that pose a significant risk to human health
or the environment will continue to be funded for the foreseeable future. As always, EPA will
continue to seek reimbursement of cleanup costs from polluters whenever possible.
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Identifying Sites for Cleanup
EPA investigates hazardous waste sites throughout the U.S. and U.S. Territories. A preliminary
assessment/site inspection is performed at each site to determine whether hazardous
contaminants pose a significant risk to human health or the environment, such that additional
investigation or cleanup is needed.
Each site is evaluated using the Hazard Ranking System. The HRS is a measurement tool that
calculates a site-specific score based on the potential for a hazardous substance to reach a
receptor. It is a numerically-based screening system that uses information from the PA/SI to
assess the relative potential of a site to pose a threat to human health or the environment. Part of
the HRS calculation considers exposure pathways. EPA places sites with an HRS score of 28.50
or higher on the National Priorities List. HRS scores do not determine the priority in funding
EPA remedial activities, or the ranking place of a site on the NPL.
Selecting and Implementing a Cleanup Plan
After a site is placed on the NPL, EPA performs a remedial investigation and a feasibility study.
The RI identifies the types, concentrations, and extent of contamination, and defines subsurface
conditions at the site. A risk assessment is then performed to determine the threat these findings
pose to human health and the environment. The risk assessment is incorporated into the RI
report. The FS considers the physical characteristics of the site and evaluates possible cleanup
technologies that could be used to control, remove, or reduce the contamination identified by the
RI. Information from these studies is used to develop several possible cleanup alternatives that
could be used at the site. After comparing the alternatives, EPA will recommend the cleanup
method believed to be the best for the site in a Proposed Remedial Action Plan. A 30-day public
comment period begins when the PRAP is released to the public. The community is asked to
review the plan and offer comments on EPA's proposed actions. All pertinent comments
received during the comment period must be considered by EPA before a final decision is made.
After reviewing the community's comments, EPA will prepare a Responsiveness Summary to
summarize the comments received, as well as EPA's responses. 1 he summary is attached to the
document that records the cleanup alternative selected by EPA for the site. This document is
called a ROD.
Implementing EPA's Cleanup Decision
When a ROD is signed, EPA must decide whether to conduct the next steps itself or to seek
cooperation from PRPs. If financially-viable PRPs are available, EPA may negotiate their
participation in the remedial design and remedial action. Remedial design refers to the period
when a work plan is written, and drawings and specifications are developed for the cleanup
alternative selected by the ROD. This period can take several months depending on the
complexity of the design and other factors, such as the need to conduct pilot studies, obtain
permits, or conclude legal negotiations. When the remedial design is completed and approved,
the remedial action may begin. Remedial action refers to the actual work that will turn the
cleanup design into a reality. Some typical activities that are conducted during remedial actions
include fence and field office installation, vegetation clearing, well drilling and installation,
general construction, and earthmoving activities. EPA may seek reimbursement from the PRPs
for the cost of any work performed by EPA at any time during the cleanup process.
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When the remedial action is completed, operation and maintenance will begin, unless all
contaminants have been removed from the site. In addition to site-specific Operation &
Maintenance and routine monitoring, sites not ready for unrestrictive use are thoroughly
reviewed by EPA every five years, to ensure the remedy is operating as planned, that it remains
protective of human health and the environment, and that it is in compliance with any applicable
or relevant and appropriate requirements.
Once a site is listed on the NPL, it will remain a Superfund site even after the cleanup is
completed, until the site is formally deleted from the list. A site can be removed from the NPL
only after the cleanup goals established for it have been reached and confirmed, and EPA
certifies that the cleanup is complete. When this point is reached, EPA must publish a Notice of
Intention to Delete a site in the Federal Register. The notice will also be published in one or
more local newspapers, announcing the NOID and the public comment period regarding the
4.1 Site-Related EPA Offices and Branches
EPA has 10 regional offices across the nation and a headquarters located in Washington, D.C.
Each regional office has both community involvement and technical staff involved in Superfund
site cleanups. EPA Region 7 is comprised of Missouri. Kansas, Iowa and Nebraska and nine
Tribal Nations. The EPA Region 7 office is located in Lenexa, Kansas. It houses several different
offices and branches that work on a number of hazardous waste sites.
Descriptions of the EPA offices that are involved in the site include:
Superfund- Superfund is responsible for cleaning up some of the nation's most contaminated
land and responding to environmental emergencies, oil spills and natural disasters. To protect
public health and the environment, the Superfund program focuses on making a visible and
lasting difference in communities, ensuring that people can live and work in health, vibrant
places.
Removal - Removals are generally short-term actions to prevent, minimize, or mitigate damage
to human health and welfare or the environment: Removals can be triggered by fires, leaks,
explosions, or other releases or threats of releases of hazardous substances. Removal responses
may be conducted as emergency or time-critical situations if the release or threat of a release
poses a threat to public health, welfare, or the environment. Removals also can be non-time-
critical. This type of an action allows for a longer time period (six months or more) for planning
the response.
Remedial - Remedial actions are designed to provide permanent solutions to mitigate risk to
human health and the environment from the release of hazardous substances to the maximum
extent practicable. Remedial sites typically have contamination of more than one environmental
medium (soil, surface water, or groundwater) by many types of chemicals. Common remedial
actions include the excavation and treatment of contaminated soil, containment and treatment of
leachate, or the extraction and treatment of contaminated groundwater.
NOID.
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Enforcement Coordination Office - The role of the Enforcement Coordination Office is to
maintain overall operation and management. ECO develops policies and procedures outlining
specific responsibilities for organizations within Region 7; develops reports to routinely review
regional data accuracy and establishes accountability and evaluation protocols for use within the
region.
Office of Public Affairs - The primary office for all EPA communications. The Director of the
Office of Public Affairs is the principal advisor to the regional administrator on all issues
concerning short-term and long-term strategic communications.
Environmental Sciences and Technology Division - Conducts research, development, and
technology transfer programs to increase the understanding of environmental exposures to
human and ecological receptors.
Office of Regional Counsel - EPA Offices of Regional Counsel are located within each EPA
regional office and provide day-to-day support to each region and headquarters for all general
legal matters, including defensive litigation and counseling issues. Specifically, these
responsibilities entail counseling regional program staff and managers on the application of
statutes, regulations, case law, and policies, as well as any other legal issues that arise.
4.2 The Agency for Toxic Substances and Disease Registry
ATSDR is an agency of the U.S. Department of Health and Human Services. It was created in
1980 under CERCLA to prevent adverse human health effects and diminished quality of life
associated with environmental pollution. ATSDR is not a regulatory agency like EPA. It is a
public health agency that advises EPA on the health effects associated with exposure to
hazardous materials. ATSDR is required, under Supertund law, to become involved with all sites
proposed to the NPL. Specifically, ATSDR conducts public health assessments of and/or health
consultations with NPL site (or proposed NPL site) communities.
4.3 State Role
Superfund cleanups require EPA and states to work together. In most cases, EPA is the lead
regulatory agency conducting cleanups, but states may choose to take the lead. Typically,
however, states provide support to EPA by bringing their technical expertise and resources to
bear and providing regulatory guidance. In addition, states are responsible for 10% of the cost of
the cleanup, and for Operation and Maintenance of cleanup technologies in place after the
cleanup construction is completed. The state agency cooperating in the cleanup of this site is the
Iowa Department of Natural Resources. (See Appendix A.6 for contact information for the state
representative for this site.)
The Iowa Department of Health and Human Services is the state health agency associated with
this site. The EPA and ATSDR consult with state health authorities on site-related health matters,
as needed, to keep each entity informed of issues that may be of concern to local residents. (See
Appendix A.7 for contact information)
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4.4 Local Role
EPA has been and will continue to consult with city officials during the cleanup process, to
ensure that cleanup activities are conducted in accordance with local ordinances. The city and
county officials can provide EPA with information concerning the operating history of sites and
regulatory issues, as well as community concerns and demographics. They also may act as a
conduit of information to concerned community members who may contact them for site-related
news and updates. (See Appendix A.3 for contact information for local officials.)
SECTION 5
Site Background
5.1 Site Description
The Lawrence Todtz Farm site is located approximately 1.5 miles west of Camanche, Iowa, in
Clinton County. Camanche is located along the Mississippi River about two miles south of
Clinton, Iowa. The site consists of a 2.6-acre impoundment located in the northeast section of a
former 13-acre landfill, all of which is located on the 120-acre Todtz family farm. Three ponds
are situated within the landfill and downgradient of the impoundment. Willow Lake is located
cross and downgradient of the site. Bandixen Lake is located downgradient of the site.
5.2 Site History and EPA Actions to date
Between 1959 and 1969, sand and gravel were mined from a 12-acre parcel on the Lawrence
Todtz farm. The mined area was used subsequently as a landfill for disposal of municipal refuse
from 1969 to 1975. The impoundment was constructed within the northwest corner of the landfill
by DuPont in 1971. An estimated 4,300 tons of "wet end" cellophane process wastes were
disposed of in the impoundment from 1971 to 1975. The waste leached into the groundwater,
contaminating groundwater with heavy metals and volatile organic compounds.
The Lawrence Todtz Farm site was identified as a potentially uncontrolled hazardous waste site
and was proposed for the NPL in June 1986. On April 5, 1988, EPA entered into an
Administrative Order of Consent with DuPont to perform a remedial investigation/feasibility
study for the site. The Administrative Order of Consent was issued pursuant to Sections 104 and
122 of CERCLA. The RI identified the DuPont impoundment as the probable source of
groundwater contaminants, including tetrahydrofuran, carbon disulfide, hexavalent chromium
and arsenic. Based on the results of the investigation, EPA signed a Record of Decision in 1988
and selected the remedy to clean up the site. DuPont conducted the remedial design/remedial
action required by the ROD and pursuant to a Consent Decree, which was entered by the court
on November 6, 1990. The remedial action was completed in 1991.
The long-term remedy included installation of a two-foot-thick soil cover over the impoundment,
development of vegetation on the cover, installation of a private well in the deeper bedrock
aquifer, installation of additional downgradient monitoring wells and a long-term monitoring
program. Cleanup activities finished in 1991. Institutional controls prohibit the site from hosting
residential or agricultural uses, excavation activities and the use of groundwater. Semiannual
groundwater sampling of the shallow aquifer was conducted until 1997 and is now conducted on
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an annual basis with EPA oversight. Sampling of the bedrock aquifer was conducted on a
semiannual basis for the first two years and was required to be conducted every five years
thereafter. At EPA's request, DuPont has been conducting annual monitoring of the bedrock
aquifer. Additional protective remedial measures can be implemented if groundwater monitoring
detects contaminants exceeding specific action levels outlined in the ROD.
Surface water, sediment and fish sampling has also been performed in Willow Lake to verify that
the contamination is not impacting the lake at concentrations that could affect human health. The
lake is used for recreational use, including fishing.
EPA has conducted several Five-Year Reviews of the site's to verify the remedy continues to be
protective per CERCLA. These reviews ensure that the remedies put in place protects public
health and the environment, and functions as intended by site decision documents. The 2015
Five-Year Review found that the remedy is protective in the short-term for human receptors:
however, the same protectiveness determination could not be made for ecological receptors due
to lack of information. Further information will be obtained to assess whether sediment or
surface water poses an unacceptable level of ecological risk to biologic communities within the
onsite ponds located in the landfill. It is expected that this evaluation will require approximately
24 months to complete, after which a protectiveness determination may be made. Several
additional recommendations have been made in the five-year review that when implemented will
ensure long-term protectiveness of the remedy.
5.3 Site Contamination
Sampling and analysis of soil and shallow groundwater conducted before and during the
remedial investigation/feasibility study concluded that concentrations of carbon disulfide,
toluene, tetrahydrofuran, arsenic, lead and benzene were present in the impoundment.
Concentrations of arsenic and lead were detected at levels above background concentrations.
Monitoring well locations shows maximum concentrations identified in groundwater collected
from wells immediately downgradient of the DuPont impoundment reported in the 1988
Remedial Investigation/Feasibility Study Report (prior to the remedial action).
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SECTION 6
Community Background
6.1 Community Profile
Camanche. Iowa Demographics
Per the Camanche, Iowa, website www.camancheia.org:
Population: 4,448 County: Clinton Median Household Income: $41,859, Median Home
Price: $80,200. Median Age: 40.5
6.2 Environmental Justice
An EJSCREEN was prepared for this site. None of the 12 indicators were above the level in
which EPA would classify this site to be an EJ community. EJSCREEN is a tool for pre-
decisional use only. It can help identify areas that may warrant additional consideration, analysis,
or outreach. It does not provide a basis for decision-making, but it may help identify potential
areas of EJ concern. Users should keep in mind that screening tools are subject to substantial
uncertainty in their demographic and environmental data, particularly when looking at small
geographic areas. (See Appendix C for EJSCREEN Map)
Community Interests and Concerns
Interviews by EPA with members of the local community conducted on July 27, 2015, revealed
that community concerns were focused on human health and groundwater. Interviews conducted
were educational and provided an update of ongoing EPA actions at the site.
Some key questions about the site included:
• What is your understanding of the contamination related to the site?
• What are your concerns about the site and its cleanup?
• What is the best way to provide information to you?
• What was the source of your knowledge?
• Would you like more information about the site?
Individuals interviewed were asked what they knew about the site, who or what was the source
of their knowledge and what they thought about actions conducted by the EPA at the site. They
were also asked if they would like more information about the site and what EPA is doing there.
6.4 Response to Community Concerns
The areas of community concerns were determined primarily during personal interviews
conducted with businesses in the area. The business owners appeared to be satisfied with recent
EPA actions at the site. The interview process provided EPA an opportunity to update the
community on activities at the site. On July 27, 2015, interviews were conducted by EPA with
nearby local businesses.
• What is the best way to provide information to you?
• What was the source of your knowledge?
• Would you like more information about the site?
United States
Environmental Protection
Agency
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Community Involvement Plan - Lawrence Todtz Farm Site - Camanche, IA
EPA Questions
Public Comments
Have you heard of the Lawrence Todtz Farm
Superfund site?
Over half of the community members interviewed were
familiar with the site.
Have you heard of the solvent (THF) before?
With the exception of the fire department, no one was
familiar with the chemical in questions.
Do you have any concerns about the site and/or
cleanup in general?
Only general concerns were expressed.
Have you contacted the state/EPA to inquire about the
site?
Neither the state nor EPA were contacted for further
information
Have you visited the library to review the sites
administrative record?
With the exception of the library workers, no one had
visited the library.
Are you currently receiving information about this
site?
Only 1 of the 10 persons interviewed had received
information about the site.
What is the best way to provide information to you?
Responses varied, but the most popular answers were
newspaper and email
What kind of information would you like to receive?
Newsletters containing general updates
Preferred format of information directly from the EPA?
Newsletters and fact sheets
How often would you like information about this site?
As necessary
Is the EPA viewed as a credible, trustworthy source of
information?
Generally, yes.
What do you think of EPA's relationship with the
community?
Many of the community members thought EPA had a
positive relationship with the community
Is there anyone in particular whom you think we
should be sure to include in our community interviews?
City Administrator, Public Works Director.
Is there anything else you would like to share about the
site?
N/A
Additional comments:
N/A
6.5 Community Involvement Core Principles
Community involvement at the site will focus on the following core principles:
1. Timely and accurate responses to questions raised by area residents, local officials,
organizations, and the media.
2. Establishment of an information repository in the community.
3. Informal public dialogue between EPA representatives and all interested parties.
4. Preparation of a responsiveness summary.
5. Revision to this plan as necessary.
6. Assistance to communities by providing information on the following; as necessary:
• How to apply for a Technical Assistance Grant
• How to apply for Technical Assistance Services for Communities
• How to form a Community Advisory Group
United States
Environmental Protection
M rn Agency
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Community Involvement Plan - Lawrence Todtz Farm Site - Camanche, IA
Appendix A
List of Contacts
A.l Federal Elected Officials
Joni Ernst, U.S. Senator
111 Russell Senate Office Building
David Loebsack, U.S. Representative
1527 Longworth House Office Building
Washington, DC 20515
Phone: (202) 225-6576
Washington, DC 20510
Phone (202) 224-3254
Chuck Grassley, U.S. Senator
135 Hart Senate Office Building
Washington, DC 20510
Phone: (202) 224-3744
David Young, U.S. Representative
515 Cannon House Office Building
Washington, DC 20515
Phone: (202) 225-5476
Rod Blum, U.S. Representative
213 Cannon House Office Building
Washington, DC 20515
Phone: (202) 225-2911
Steve King, U.S. Representative
2210 Rayburn Office Building
Washington, DC 20515
Phone: (202) 225-4426
A.2 State Elected Officials
Terry Branstad, Governor
1007 East Grand Ave.
Des Moines, Iowa 50319
Phone: (515) 281-5211
A.3 City/Local Officials
The City of Camanche does not list specific addresses or phone numbers for its council members; rather,
they would prefer to be contacted by calling City Hall, at the number listed below.
Mayor: Kenneth Fahlbeck
Council Members:
Marvin Lind
Mike McManus
Paul Varner
Trevor Willis
William Wruck
City Hall Mailing Address:
917 3rd Street
P.O. Box 77
Camanche, Iowa 52730
City Hall phone: (563) 259-8342
United States
Environmental Protection
Agency
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Community Involvement Plan - Lawrence Todtz Farm Site - Camanche, IA
Appendix B
Information Repositories and Potential Meeting Locations
B.l Repository Locations
Records Center
U.S. Environmental Protection Agency Region 7
11201 Renner Boulevard
Lenexa, Kansas 66219
Phone: (800) 223-0425
Hours: 7:00 a.m. - 5:00 p.m.
Camanche Public Library
102 12th Avenue
Camanche, Iowa 52730
Phone: (563) 259-1106
Clinton Public Library
306 8th Avenue S.
Clinton, Iowa 52732
Phone: (563) 242-8441
Local Media Information
Clinton Herald Newspaper
221 Sixth Avenue S.
Clinton, Iowa, 52732
(563) 242-7101
news@clintonherald.com
United States
Environmental Protection
Agency
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Community Involvement Plan - Lawrence Todtz Farm Site - Camanche, IA
Appendix C
&EPA EJSCIttEN Report
to. 1 Okie ftoa tekinl M «t Jimi it J»?1I KWt. ETA Reason 7
<(ffMiiufc Pofxitotiom 224
Set«ledl VSnriaMes
Stale
Pvfceratjtie
[PA Report
Pemnalie
USA
Percentile
DW»
EJ Index tor PM2.5
33
32
2*
EJ Index for Cfccne
36
38
30
EJ Ma far MMA Diesel PM
32
25
18
EJ Index for NATA Ar Toxics Cancer Rb4
SB
36
3*
EJ Index for NATA Respiratory Hazard Indr*
M
33
»
EJ Index for NWTA Neurological *tard Index
38
3B
33
EJ Index far Tnfiic PtoxmCj and Volume
ee
53
*t
EJ Index for Lead Paint Indicator
S3
32
21
EJ Index for Prarimty to Mn ores
2
2
1
EJ Index for Piorimty to RMP sites
15
B
3
EJ Index for P»a»imtty to TSDFs
112
«
40
EJ Index for Prownwly to Major Direct Osdhar^efs
16
O
11
EJ Index fcr the Selected Area Compared to *# Ptcplev Btock Groups r the St^te/Regor/WS
101
n
%
¦State Percentile ^Regions! Percentile 0 i/3A Percentile
The report shows environmental. dema^TKttc, and EJ indicator Miues It 9kmis trmrarmerum and 3fropc*ic raw sau ((eg.. Vk eaimated ccrcertTtcri or
oeone »the or], and ateo shows vrfiatperoertjte each raw aata .efc* represents These percentiles prowde perspective on how tt* selected Dtod group cr
bufler eree compares to the entire state EPA region, cr nation. For emnffe. if a pwe*i tocahoa is at the 93th percentile nationwide this means that on>t 3
percent or the US oapjtrbon has a hghertaoc* group value thwi the avenge person in the location toeing analyzed The years for »*ich the data w? a*MaWe
and the methods used, vary across t**se rtdicators Important cv«ats and uncertainties appay to this screen ing-tc^ I information, so it is essential to understand
the limitations on approprirte inter gelations and apptioaians of tnese indcators Please see EtSCTEBN doamertabon far daussan or these issues Before using
reports
SeptentMH 28.201! i/a
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Environmental Protection
M % Agency
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Community Involvement Plan - Lawrence Todtz Farm Site - Camanche, IA
EJSCREEN Report
for 1 mile Ring Centered at 41.787*30X90.232714. IOWA, EPA Region 7
Approximate Population: 224
MHBMPnHHHHMMHHBWMaHMMMHMBHIIMI
WH | *J m' Um
ww p»« f • ¦ '• ' ' ¦"*;
RlrtfH Al*n "•» ¥ ura *»~«»
*s 5W8»B#iM*5
Jfc United States p * „ ,> lis
Environmental Protection a^1 I
#« Agency
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Community Involvement Plan - Lawrence Todtz Farm Site - Camanche, IA
£EPA r3rS"'WMC" EJSCREEN Report EfCijC
fen 1 milt Ring Cenwied at 41.7879>:i3.-80.392714. rJWA. EPA Region 7
Approximate Population; 224
Selected Variables
Raw
Data
State
Avg.
*tein
Slate
EPA
Region
A*£.
%jlein
BPA
Region
USA
Avg.
%iein
USA
Environmental Indicators
Particulate Matter (nw 25 m t&m')
11
&.a
93
10.1
80
9.78
76
Ozone (**)
43
42
74
465
36
46 1
29
HAT A Diesel PM &*/»>*)'
0 627
0671
56
Q741
6&TOh
0.824
50-6EMh
NATA Cancer Risfc r-®t p*~ m «>r)
31
35
49
33
<5001
49
<5om
NIA.TA Respiratory Hazard Index"
1.1
13
56
1.4
5&«om
23
<50m
MATA Neurological Hazard Index'
QD37
0064
49
0052
<50lh
0.063
<5om
Traffic Proximity and Volume (e»i> tra«c court.* » mad)
6.4
76
25
61
22
110
15
Lead Paint Indicator (v *rr-i9tOH®..jint)
034
0.45
27
0.37
43
03
53
NPC PTOXTTTiity {ate murt/tm d stansionai use only It can help identify areas that may warrant additional consideration, analysis, or outreach It does not
provide a &as»s for decision-making, but rt way help identify potential areas of EJ concern Users should keep m mrnd that screening tools are subject to substantia!
uncertainty in the?r demographic and environmental data, particularly when looking at small geographic areas Important caveats and uncertainties apply to this
screening-level information so it is essential to understand the imitations on appropriate interpretations and applications of these indicators Please see
EJSCREEN documentation for discussion of these issues before usmg reports This screening tool does not provide data on every environmental impact and
demography factor that may be relevant to a particular locaton EJSCREEN outputs should be supplemented with additional information and local knowledge
before taking any action to address potential EJ concents
September 28. 2015 3/1
A United States .
Environmental Protection 1 aSc I lJ
Lb I Agency
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Community Involvement Plan - Lawrence Todtz Farm Site - Camanche, IA
Appendix D
Glossary of Technical Terms
Administrative Record: The official files containing the remedial investigation report, risk assessment,
feasibility study, and all other documents that provide the basis for EPA's selection of a remedial
cleanup alternative at a Superfund site.
Applicable or Relevant and Appropriate Requirements: Any state or federal statute that pertains to
protection of human life and the environment in addressing specific conditions or use of a
particular cleanup technology at a Superfund site.
Cleanup: An action taken to deal with a release or threatened release of hazardous substances that could
adversely affect public health and/or the environment. The word cleanup is used to reter to both short-
term removal response actions and long-term remedial actions at Superfund sites.
Community Engagement Specialist: An individual EPA assigns to work closely with technical stafl to keep
the local community informed about, and involved in, a site cleanup.
Community Involvement Plan: A document that assesses a community's concerns about a site, recommends
activities that EPA may conduct to address these concerns, and suggests means to foster communication
between EPA and the community.
Comprehensive Environmental Response, Compensation, and Liability Act: A federal law (commonly
known as "Superfund") passed in 1980 and modified in 1986 by the Superfund Amendments and
Reauthorization Act. The law gives EPA the authority to investigate sites where there is a suspected
threat to public health or the environment caused by the release or potential release of hazardous
substances. The law also created a special tax on the chemical and petroleum industries. Money was
collected under the tax until 1995 and deposited into a trust fund to be used to clean up abandoned or
uncontrolled waste sites. Under the law, EPA can pay for the site cleanup when the parties responsible
for contamination cannot be located or are unwilling or unable to perform the cleanup. EPA can also
take legal action to require parties responsible for site contamination to clean up the site or pay back the
federal government for the cost of the cleanup.
Contamination: An adverse effect on air, water, or soil caused by any physical, chemical,
biological or radiological substance or matter.
Exposure Pathways: Route or way in which humans or the environment may come into contact with
contaminants.
Feasibility Study: A study that examines information provided by the remedial investigation activities
and evaluates possible cleanup methods that can be used to remove or reduce contamination at a site.
Groundwater: The supply of fresh water found beneath the earth's surface in empty areas between
rocks and soil particles. Groundwater is a major source of drinking water.
United States
Environmental Protection
Agency
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Community Involvement Plan - Lawrence Todtz Farm Site - Camanche, IA
Hazard Ranking System: A measurement tool used to evaluate the risks to public health and the
environment posed by a hazardous waste site. The HRS calculates a score based on the potential of a
hazardous substance moving from the site through the air, water or soil. EPA places sites with a HRS
score of 28.50 or higher on the National Priorities List.
Information Repository: A collection of documents about a specific Superfund site and the general
Superfund process. EPA usually places the information repository in a public building that is
conveniently located.
National Priorities List: EPA's list of the nation's most serious hazardous waste sites identified for long-
term cleanup under Superfund.
Operation and Maintenance: (1) Activities conducted after a Superfund site action is completed to
ensure that the action is effective. (2) Actions taken after construction to ensure the constructed facility
is properly operated and maintained to achieve expected effectiveness and efficiency levels.
Potentially Responsible Parties: The companies or people responsible for the contamination at a
site. Whenever possible, through administrative and legal actions, EPA requires these parties to
clean up hazardous waste sites they have contaminated.
Preliminary Assessment/Site Inspection: The preliminary assessment is the initial process of collecting
and reviewing available information about a known or suspected waste site or release. The assessment is
followed by the more extensive site inspection. The purpose is to gather information necessary to score
the site, using the Hazard Ranking System, and to determine if it presents an immediate threat requiring
prompt removal.
Proposed Plan: A plan that discusses the remedial investigation and feasibility study and proposes
various cleanup methods for a site. EPA highlights its preferred cleanup method in this plan.
Public Comment Periods: Designated periods of time during which EPA requests the public to review
and comment on specific documents and/or EPA actions. For example, EPA holds a minimum 30-day
public comment period to allow community members to review and comment on a proposed remedial
action plan.
Record of Decision: A formal document that discusses in detail the cleanup plan EPA has decided to
implement at a site.
Remedial Action: The actual construction or implementation phase that follows the remedial design of
the selected cleanup plan for a Superfund site.
Remedial Design: The engineering phase that follows the Record of Decision. During this phase,
technical drawings and specifications are developed for the remedial action at a site. It is similar to a
blueprint or work plan.
United States
Environmental Protection
Agency
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Community Involvement Plan - Lawrence Todtz Farm Site - Camanche, IA
Remedial Investigation: A study in which EPA identifies the types and amounts of site contamination
and determines the threat this contamination poses to human health and the environment.
Remedial Project Manager: EPA or state official responsible for overseeing onsite remedial action.
Responsiveness Summary: A summary of oral and written comments that EPA receives during a public
comment period and EPA's responses to those comments. The Responsive Summary is part of the
Record of Decision.
Superfund: A fund that can be used to finance cleanup actions at hazardous waste sites. The fund was
established under the legislative authority of the Comprehensive Environmental Response,
Compensation, and Liability Act with monies received largely from a tax levied on the chemical and
petroleum industries. Fund monies can be used by EPA to respond directly to releases or threatened
releases of hazardous substances that may endanger public health, welfare, or the environment. The
term "Superfund" also refers to the EPA programs which conduct cleanups using these fund monies.
Superfund Amendments and Reauthorization Act: Modifications to the Comprehensive Environmental
Response, Compensation, and Liability Act enacted on October 17, 1986.
United States
Environmental Protection
Agency
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Appendix E
List of Acronyms
AR
ARARs
ATSDR
CERCLA
CAG
CES
CIP
EPA
FS
HRS
IDNR
JTI
MCL
NCP
NOID
NPL
O&M
PA/SI
PRAP
PRP
RI
RI/FS
ROD
RPM
RS
SARA
TAG
TAP
THF
VOCs
Administrative Record
Applicable or Relevant and Appropriate Requirements
Agency for Toxic Substances and Disease Registry
Comprehensive Environmental Response, Compensation, and Liability Act
Community Advisory Group
Community Engagement Specialist
Community Involvement Plan
U.S. Environmental Protection Agency
Feasibility Study
Hazard Ranking System
Iowa Department of Environmental Quality
(Superfund) Job Training Initiative
Maximum Contaminant Level
National Contingency Plan (shortened from National Oil and Hazardous
Notice of Intent to Delete
National Priorities List
Operation & Maintenance
Preliminary Assessment/Site Inspection
Proposed Remedial Action Plan
Potentially Responsible Party (ies)
Remedial Investigation
Remedial Investigation/Feasibility Study
Record of Decision
Remedial Project Manager
Responsiveness Summary
Superfund Amendments and Reauthorization Act
Technical Assistance Grant
Technical Assistance Plan
Tetrahydrofuran
Volatile Organic Compounds
United States
Environmental Protection
Agency
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Community Involvement Plan - Lawrence Todtz Farm Site - Camanche, IA
Appendix F
For health-related questions regarding vapor intrusion, contact your local health department or the Agency for
Toxic Substances and Disease Registry at 1-888-422-8737 or visit their website at www.atsdr.cdc.gov.
JL United States D , 9,
.V.LUA Environmental Protection a8c I
X#L_I
l Agency
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Community Involvement Plan - Lawrence Todtz Farm Site - Camanche, IA
If you have questions or need additional information, please contact:
Pamela Houston
Community Engagement Specialist
U. S. EPA Region 7
Enforcement Coordination Office
11201 Renner Boulevard
Lenexa, KS 66219
Toll-free: 1-800-223-0425
Email: houston.pamela@epa.gov
&EPA
United States
Environmental Protection
Agency
Erin McCoy
Remedial Project Manager
U. S. EPA Region 7
Superfund Division
11201 Renner Boulevard
Lenexa, KS 66219
Toll-free: 1-800-223-0425
Email: mccov.erin@epa.gov
Reasonable Accommodations: EPA Region 7 is committed to providing reasonable accommodation to
individuals with disabilities. If you require a reasonable accommodation to participate in the meeting,
please notify the EPA Reasonable Accommodations Coordinator, Jonathan Cooper, at 800-223-0425 or
cooper.ionathan@epa.gov. Speech or hearing impaired individuals should email or call using the local
relay service.
gr% United States
Environmental Protection
M % Agency
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