COMMUNITY RELATIONS PLAN
                           EARTH TECH
                  EPA CONTRACT NO. 68-W8-0079
                                
                                
                  WESTINGHOUSE CONSENT DECREE
                        SUPERFUND SITES
                      COMMUNITY RELATIONS
                                
                                
                                
                         WA NO. 22-5BZZ
                      PROJECT NO. 04022.11
                                
                                
                                
                                
                          AUGUST 1994
                                
                                
                                
                                
                            Region 5
              U.S. Environmental Protection Agency
                       Chicago, Illinois
                                
                 TABLE OF CONTENTS
                                                    Page
INTRODUCTION     1
SITE BACKGROUND AND HISTORY     2
       Status of Sites     5
            ABB Plant 5
            Fell Iron and Metal 6
            Anderson Road Landfill   8
            Bennett's Dump 8
            Lemon Lane Landfill 9
            Neal's Dump    10
            Neal's Landfill     11
            Winston-Thomas Sewage Treatment Plant   12
CONSENT DECREE HIGHLIGHTS 14
     Permit Applications 15
     Consent Decree Revisited 16
COMMUNITY BACKGROUND 16
     Community Profile 17
     Community Involvement 18
     History of Community Concerns 19
     Interested Parties 20
          Governmental 20
              Consent Decree Parties 20
                 U.S. Environmental Protection Agency 20
                 Indiana Department of Environmental 
                 Management 21
                 Indiana State Department of Health 22
                 Monroe County 23
                 City of Bloomington 23
                 Utilities Services Board 24
              Other Governmental Parties 24
                 U.S. Fish and Wildlife Service 24
                 Agency for Toxic Substances and Disease
                 Registry 26
                 National Institute for Occupational Safety and
                 Health 27
                 Bloomington Environmental Commission 28
          Non-Governmental 28
              The Coalition Opposed to PCB-Ash in Monroe 
              County 28
              Anarchists Political Action Committee for Health
                   and the Environment 29
              People Against the Incinerator 29
              Near West-Side Neighborhood Association 30
              Sassafras Audubon Society 30
              League of Women Voters 30
              Student Environmental Action Coalition 31
              Physicians for Social Responsibility South Central
                   Indiana Chapter 31
              Sierra Club:  Uplands Group 31
              Greater Bloomington Chamber of Commerce 32
              Other Interested Parties 32
EPA COMMUNITY RELATIONS IN THE BLOOMINGTON AREA 33
     EPA's Response to Current Community Concerns 33
COMMUNITY INTERVIEWS 35
FUTURE COMMUNITY RELATIONS ACTIVITIES 39
COMMUNITY RELATIONS STAFFING 41
INTRODUCTION
  To ensure that the changing concerns and interests of the
community are identified and addressed, the Community Relations
Plan (CRP) is updated periodically.  This CRP is an updated
version of the 1987 CRP.  It identifies the more recent issues of
community concern regarding the eight polychlorinated biphenyls
(PCB) contaminated sites in the Bloomington, Indiana area (which
includes Monroe and Owen Counties) where PCBs were disposed of
during the late 1950s through the mid 1970s by Westinghouse
Electric Corporation (Westinghouse).  The original CRP outlined
the time line for the cleanup activities and the United States
Environmental Protection Agency's (EPA's) plan to keep the
community involved throughout the process.
  This plan describes the community relations activities
conducted by the EPA since the 1987 CRP was published.  The
technical cleanup activities will continue to be performed by
Westinghouse with EPA oversight as outlined in the 1985 Consent
Decree signed by EPA, the City of Bloomington, Monroe County, the
State of Indiana, and Westinghouse.  While EPA oversees the site
cleanup activities, the community will continue to be involved in
EPA's decision-making process and will be informed of significant
milestones. 
  This CRP is divided into the following sections:
* Site Background and History
* Consent Decree Highlights
* Community Background
* EPA Community Relations in the Bloomington Area
* Future Community Relations Activities
* Community Relations Staffing
  The EPA has conducted a series of meetings with various
community, civic, neighborhood, and environmental activist groups
from 1987 to the present to discuss the local concerns of the
community regarding the PCB-contaminated sites.  For this CRP,
the EPA took into consideration the contents of these meetings. 
EPA also solicited residents adjacent to the sites and invited
them to speak individually with EPA personnel.  The EPA also met
with the Township Trustee for each of the sites, the Mayor and
Deputy Mayor, the Monroe County Environmental Health Specialist,
and the Bloomington PCB Coordinator.  The Indiana Department of
Environmental Management (IDEM) Community Relations Liaison
accompanied EPA at many of these community meetings.  Appendix A
includes a list of key public officials, civic groups,
environmental activists, and community group leaders in the
Bloomington area.  Appendix B lists information repositories and
meeting facilities suggested for public meetings in Bloomington. 
Appendix C contains selected correspondence, press releases and
fact sheets related to the Bloomington sites from 1987 to the
present.  Appendix D provides a list of common acronyms and
glossary of terms used by government agencies, civic and
environmental organizations that may be unfamiliar to the general
public. 


SITE BACKGROUND AND HISTORY
  
  
  From 1958 to 1977, Westinghouse Electric Corporation
manufactured electrical equipment including capacitors containing
PCBs at their Bloomington, Indiana Plant.  Off-specification
capacitors were discarded in local landfills and limestone
quarries.  In 1976, Congress passed the Toxic Substances Control
Act (TSCA), which restricted the use of PCBs for most commercial
purposes.  In 1977, Westinghouse discontinued the manufacture of
PCB-filled capacitors at their Bloomington plant.
  EPA has identified eight sites in Monroe and Owen Counties,
Indiana containing a large volume of PCB-contaminated materials. 
Westinghouse was later named as the potentially responsible party
(PRP).
  The eight major sites were designated as Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA,
also known as "Superfund") sites.  Two of these sites (ABB Plant
and Fell Iron and Metal) were addressed under the EPA removal
program and the other six sites (Winston-Thomas, Anderson Road
Landfill, Bennett's Dump, Lemon Lane Landfill, Neal's Dump, and
Neal's Landfill) were addressed under the remedial program.  Four
of the six remedial sites (Bennett's, Lemon Lane, Neal's Dump,
and Neal's Landfill) scored above 28.5 on the Hazard Ranking
System (HRS) and were designated as National Priorities List
(NPL) sites.  NPL sites are a relatively small subset of a larger
inventory of potential hazardous waste sites, but they comprise
the most complex and environmentally compelling cases. 
Westinghouse, as a PRP, is required to clean up the ABB Plant
(former Westinghouse Plant) and Fell Iron and Metal under a
CERCLA Administrative Order.  The other six sites are covered
under a 1985 Consent Decree subject to the jurisdiction of the
Federal District Court for the Southern District of Indiana.  The
Consent Decree parties include EPA, the State of Indiana, the
City of Bloomington, Monroe County and Westinghouse.
  In addition to the eight above-listed sites, EPA has
investigated 75 potential sites, primarily "scavenger" sites
identified by community activists and public officials.  The
results of those investigations are available at the local Public
Information Center (PIC) (see page 33 for details on PIC) and
repositories (Appendix D).  The city of Bloomington has contacted
102 residents with garden sites thought to have been contaminated
with PCB sludge from the Winston-Thomas Treatment Plant .  Only
28 of the 102 property owners agreed to allow the city access to
sample.  The analytical results are available from the
Bloomington PCB Coordinator at the city of Bloomington Utilities
Department, (812) 339-1444. 
 
INSERT MAP HERE

Status of Sites

ABB Plant (former Westinghouse Plant)
  
  The ABB Plant (see maps on pages D94-D95), the former
Westinghouse Plant, at 300 North Curry Pike is 2 1/2 miles west
of Bloomington.  The 148-acre facility was built in 1957, and was
used to manufacture electrical equipment including capacitors and
transformers containing PCBs.  PCBs were used in the transformers
and capacitors from 1958 until 1977.  Westinghouse used an oil
consisting primarily of a mixture of PCBs as an insulating fluid
in its capacitors.  A trade name for the PCB mixture was called
Inerteen.  PCBs were used in the capacitors because of their
fire-resistant quality at the Bloomington, Indiana plant. 
Westinghouse stopped using this PCB oil mixture after Congress
passed IDEM, banning the use of PCBs in most commercial
applications.  
  The first step in the Superfund process is to define the
contaminants in a preliminary assessment/site investigation
(PA/SI).  IDEM conducted a PA/SI in late 1988 and found PCBs in
soils on site with concentrations to 176,000 parts per million
(ppm).  EPA also found PCBs in their sampling results for this
site later in the same year.  In May 1989, EPA issued an
Administrative Order to Westinghouse, requiring a "removal
action" at the Plant site.  The initial removal measures taken
were:
* Installing a fence around the site perimeter
* Posting warning signs surrounding the site
* Targeting the contaminated areas to be excavated
* Constructing an on-site temporary storage facility
  Once the contaminated areas were identified and the temporary
storage area (TSA) constructed (July 1992) the excavation of the
contaminated areas began at the ABB Plant.  The excavation of
PCB-contaminated soils started in August 1992 and was completed
in December 1993.  The PCB-contaminated soil and materials were
excavated and approximately 12,000 cubic yards are stored in the
on-site TSA.  In addition to the PCB-contaminated soils,
trichloroethylene (TCE) and perchloroethylene- (PCE) contaminated
soils were also found on site and were excavated and transported
to an off-site facility permitted to handle these materials. 
Consistent with the Administrative Order issued in May 1989, EPA
intended to perform an Engineering Evaluation/Cost Analysis
(EE/CA) to identify alternative disposal options for the soils
stored in the on-site TSA.  In the Fall of 1994, EPA received a
proposal from Westinghouse and ABB for the disposal of the
materials stored in the on-site TSA to a RCRA landfill in Tooele,
Utah.  Following a public meeting and a five week period for
public comment, EPA approved the proposal.
Fell Iron and Metal
  Fell Iron and Metal (FIM) is an active scrap metal and salvage
yard located in downtown Bloomington at 503 North Rogers Street. 
The 5.4-acre site began as a recycling and metal salvaging
facility in 1948.  FIM accepted Westinghouse's off-specification
electrical capacitors and transformers containing Inerteen from
1958 until 1968.  PCBs from these capacitors and transformers
were released into the ground at the Fell site when they were cut
open by Fell employees for salvaging the metals.  Further
releases occurred when PCBs leaked from the discarded capacitors
after their cases rusted and when PCB-contaminated surfaces of
scrap capacitors came into contact with the environment.
  The Monroe County Health Department (MCHD) requested that the
EPA investigate the Fell site.  In September 1984, the EPA's
Emergency Response Team inspected the site and ordered an
"Immediate Removal Action."  The site was sampled and then scored
for possible inclusion to the NPL.  The HRS score (22.69) was not
high enough for the site to be placed on the NPL.  EPA, however,
suggested that site conditions posed a threat to human health and
the environment and, consequently, issued Westinghouse and Fell
Iron and Metal an AdministrativeOrder on July 6, 1988 to clean up
the site.  Fell and Westinghouse prepared and submitted a work
plan to EPA and the initial removal actions began in October
1988.  The work performed included:
* Installing a fence around the site
* Constructing an on-site temporary storage facility in 1989
* Conducting on-going soil sampling, air and ground water
monitoring 
*    Removing surface capacitors
*    Excavating and storing contaminated soils
*    Filling in excavated areas with clean fill
  In 1989, EPA performed an EE/CA to identify the most promising
technologies available to cleaning up the contaminated soils and
materials at the Fell site.  These alternatives include:
* On-site incineration
     *    Incineration in the proposed Westinghouse incinerator for
     the Bloomington Consent Decree sites
     * Disposal in an off-site permitted landfill
* In-situ vitrification
  The EPA then issued fact sheets describing the EE/CA process
and the alternatives under consideration by the EPA.  EPA also
conducted workshops within the community to explain the proposed
cleanup methods and held a public comment period from September
27, 1989 through November 13, 1989.  A discussion concerning
compliance with any Applicable or Relevant and Appropriate
Requirements (ARARs) was contained in the EE/CA.  EPA determined
that it was appropriate to develop the information related to
ARARs, so they published all of the ARARs identified by EPA and
IDEM.  The public had 30 days to comment on the ARARs beginning
January 3, 1992, and were later granted a 15 day extension. 
  The EPA selected incineration as the method for disposing of
the Fell site soils and materials.  EPA's decision gave
Westinghouse an opportunity to use the incineration remedy
provided in the Consent Decree, provided that Westinghouse could
meet a schedule for the construction and operation of the
incinerator.  Alternatively, Westinghouse was required to
incinerate the materials in an off-site permitted incinerator. 
In April 1993, EPA issued a Unilateral Administrative Order (UAO)
requiring Westinghouse to implement this remedy.  Because of
public concern, EPA stayed the UAO.  EPA issued the stay in July
1993, indefinitely postponing the effective date of the April
1993 Order.


Anderson Road Landfill
  
  The Anderson Road Landfill, located in northeastern Monroe
County, is the County's solid waste landfill and is operated by
the Monroe County Solid Waste Management District.  A small area,
about 3/4 of an acre of the present 80-acre landfill, was used
for the disposal of PCB-laden capacitors and materials by
Westinghouse during the 1960s and the early 1970s.
  Approximately three acres of the landfill were excavated by
Westinghouse in 1987 to remove all of the PCB-contaminated soil
and materials disposed of three by Westinghouse.  Cleanup
measures included:
     *    Excavating and transporting the PCB-contaminated capacitors
     and materials to the Winston-Thomas Interim Storage
     Facility.
     *    De-watering the on-site pond and transferring it to the
     Winston-Thomas Tertiary Lagoon.
     *    Regrading and backfilling all excavated areas.
       Once these cleanup measures were completed, the County placed
a soil cover over the final clay cap.  Although the site is not
listed on the NPL, the contaminated materials from the site are
subject to remediation under the terms of the 1985 Consent
Decree.  In 1989, the IDEM issued a permit to Monroe County for
the use of this site as the County's landfill.  No other
activities are planned for this site.
Bennett's Dump
  Bennett's Dump, located 2.5 miles northwest of Bloomington on
Packinghouse Road, is adjacent to Star Quarry (formerly Bennett's
Stone Quarry), an active limestone quarry.  Westinghouse PCB-contaminated capacitors and other materials were dumped at the
approximately four-acre site in the early 1960s.
  EPA conducted a PA/SI in May 1983 in response to a complaint
from the MCHD.  The site was placed on the NPL in September 1984. 
Soil samples indicated PCB concentration levels as high as
380,000 ppm.  EPA performed a removal action at the site in June
1983, which included:
* Investigating the extent of contamination.
* Removing visible capacitors and surface contamination.
* Fencing the site.
* Posting warning signs along Stout's Creek bordering the dump.
* Installing a clay cap.
  In addition to the removal action conducted by EPA,
Westinghouse hydro-vacuumed the stream sediments at Stout's Creek
on the site's eastern edge.  These sediments were transported to
and stored at the Winston-Thomas Interim Storage Facility.  The
55,000 cubic yards of contaminated material remaining at the dump
awaits final disposition under the terms of the 1985 Consent
Decree.


Lemon Lane Landfill
  
  
  The Lemon Lane Landfill is approximately 10 acres in size, and
is located on the northwest side of Bloomington on the corner of
Vernal Pike and Highway 37.  The site was operated by the City of
Bloomington as a municipal solid waste (MSW) facility from about
1950 to the mid 1960s.  Westinghouse PCB-contaminated capacitors
and materials were deposited in the facility during the last
several years of operation.  Capacitors were often broken open at
the site by scavengers, trying to reclaim the metal, and,
consequently, exposing the ground to PCB-contamination.
  The IDEM conducted a PA/SI at the Lemon Lane Landfill in 1981
and found PCB concentration in on-site soils as high as 57,000
ppm.  The site was scored by EPA and placed on the NPL in
September 1983.
  Removal measures performed for the Lemon Lane Landfill began
in May 1987 and were completed on September 17, 1987.  These
measures included:
     *    Removing surface capacitors and storing them at the Winston-Thomas Interim Storage Facility.
     * Fencing the perimeter of the site.
     *    Installing a high density polyethylene cap over the entire
     site.
     *    Installing methane gas collection and filter systems.  
       
       The Lemon Lane Landfill is located over two sinkholes.  Some
of the topographical features unique to the area surrounding the
landfill are caves, creeks, and perennial and intermittent
springs.  Many hydrological investigations have been conducted as
a result of these unique geological features.  These studies
indicate that there is a hydrologic connection between the Lemon
Lane Landfill and about 12 springs that discharge within several
thousand feet of the landfill.  IDEM and EPA sampled spring water
and sediment in 1991 and 1992, respectively, and the analytical
results show both PCBs and certain solvents present in the
sediment and water.  In June 1992, EPA sent a letter to area
residents notifying them of the low levels of PCBs found in the
springs.  
  Many citizens would like to see the springs fenced and signs
posted warning that PCBs have been found in the springs. 
Officials from EPA and U.S. Fish and Wildlife Service (FWS)
jointly conducted an ecological risk assessment of this area. 
The health risks associated with the PCB levels were too low to
justify the posting of warning signs or the installation of a
fence.  EPA intends to ensure monitoring of the springs to
evaluate the fate and transport mechanisms of the identified
contaminants.  
  The 176,000 cubic yards of PCB-contaminated soils and
materials await final disposal.


Neal's Dump
  
  
  Westinghouse's Bloomington plant discarded PCB-filled
capacitors and PCB-contaminated rags in a 1/2-acre site known as
Neal's Dump located near White River in Owen County, Indiana. 
These activities occurred between 1966 and 1971.  Soil sampling
results indicate PCB concentration levels to 220,000 ppm at the
site.  PCBs in the ground water were detected at 31 parts per
billion (ppb).  The site was scored and listed on the NPL in June
1986.
  Westinghouse conducted some initial removal measures to
prevent contamination from migrating off-site.  These measures
included:
* Fencing the site perimeter.
* Installing a clay cap.
     *    Monitoring site conditions and surface drainage control.
     These are interim measures and additional measures may be needed.
  Westinghouse conducts semi-annual ground water monitoring at
Neal's Dump as required by the Consent Decree.  In May 1991, PCBs
were detected in ground water at low levels in the on-site wells. 
EPA continues to oversee Westinghouse's on-site well monitoring
and may take further action if migration of PCBs continues in the
ground water.
  Several homes are located adjacent to the site and the
residents rely on the ground water for their drinking water
supply.  Because the residents adjacent to the site have
expressed concern about the need for independent sampling of
their wells, IDEM has collected samples of ground water.  IDEM's
sampling results are available at the PIC.  Neal's Dump awaits
ultimate disposition of the 14,000 cubic yards of remaining PCB-contaminated materials.


Neal's Landfill 
  
  
  Neal's Landfill, an 18-acre landfill located in the
southwestern portion of Monroe County on Highway 48, was used as
an industrial and municipal waste landfill from 1950 to 1972. 
Westinghouse dumped PCB-filled capacitors, transformers, and
insulation material in Neal's Landfill from 1966 to 1967.  Soil
sampling results indicate PCB concentrations up to 219,000 ppm. 
PCBs were also found in ground and surface water at up to 9.7
ppb.  The site was placed on the NPL in September 1983.
  Westinghouse performed cleanup measures in December 1983 which
included:
* Removing surface capacitors.
* Fencing the site perimeter.
     *    Installing a clay cap and in-situ erosion control measures.
     *    Conducting area well-user surveys and residential or
     monitoring well sampling.
       Westinghouse constructed and began operation of a Spring
Treatment System at Neal's Landfill.  This system was intended to
treat PCB-contaminated water discharging to Conard's Branch of
Richland Creek from three on-site springs and one seepage. 
Westinghouse received a National Pollutant Discharge Elimination
System (NPDES) permit for the Spring Treatment System on July 1,
1988.  Bi-monthly monitoring reports showing the system's PCB
effluent concentrations are submitted by Westinghouse to IDEM and
EPA.  The NPDES permit limited PCB concentrations in the
discharges to 1 ppb.  Westinghouse's springwater is currently in
compliance with this limitation.  There have been citizen suits
protesting the effluent limitation.  The current PCB effluent
level enforced by IDEM is 0.1 ppb in NPDES permits.  The courts
have maintained that since Westinghouse's permit states that they
must treat to 1.0 ppb, they do not have to meet a more stringent
standard.  Local environmentalists believe that Westinghouse
should be required to meet the 0.1 ppb effluent limit since the
Consent Decree states that Westinghouse must meet all current
applicable federal, state, and local laws.  
  The 320,000 cubic yards of PCB-contaminated material at Neal's
Landfill awaits final disposition.
Winston-Thomas Sewage Treatment Plant
  The Winston-Thomas Sewage Treatment Plant, located on the
southern edge of Bloomington, is the city's former wastewater
treatment facility.  During the 1960s and 1970s, PCB-contaminated
effluent from the Westinghouse Plant at Curry Pike was discharged
through the Winston-Thomas Sewage Treatment facility.  Several
areas of this 26-acre facility are contaminated with PCBs from
the Westinghouse plant including a large tertiary treatment
lagoon, two abandoned lagoons, sludge drying beds, trickling
filters, and sludge storage tanks.  Sludge sampling results have
indicated PCB concentrations of up to 4,000 ppm.  Levels of up to
22.1 ppb were found in surface water runoff from the site. 
  The Winston-Thomas facility was closed by the city of
Bloomington in 1983.  In 1986, an Interim Storage Facility (ISF)
located adjacent to the Winston-Thomas Plant was approved and
subsequently constructed by Westinghouse.  Excavated materials
from the other PCB-contaminated sites around Bloomington, along
with the sediments from five area stream beds and excavated
materials from Anderson Road Landfill, were transported to and
stored in the ISF.  Westinghouse conducts monthly inspections and
submits these inspection reports to EPA.  These documents can be
found in the information repositories established under the
community relations program.
  Westinghouse conducted other interim remedial measures
beginning in November 1990, including:
* Performing cleanup work related to the digester tanks.
* Conducting area well-user surveys and sampling.
*    Removing and incinerating excavated capacitors from other
     Bloomington PCB-contaminated sites.
       When Westinghouse decontaminated the water in the digester
tanks and transported the water to an out-of-state facility,
Citizens Information Committee (CIC) members objected that the
public was not informed until after the work was completed.  CIC
members have asked that they be informed before any contaminated
material is taken out of the county.  Area environmental
activists have also commented that they would like additional
signs, that are easily understood by children, posted around the
sludge pond.  They have also commented that they would like the
waist high fence around the lagoon to be extended upward and more
consistent with the fencing around the ISF.
  Approximately 10,000 tons of contaminated materials stored in
the ISF await final disposition.


CONSENT DECREE HIGHLIGHTS
       After lengthy attempts to assign legal liability to
Westinghouse regarding several sites in Bloomington, the City
sued Westinghouse to pay for the PCB cleanup at Winston-Thomas. 
EPA followed suit and also sued Westinghouse for contamination at
Neal's Dump and Neal's Landfill under the Clean Water Act and the
IDEM.  These statutes did not obligate Westinghouse to pay for
the cleanup.  Later, EPA amended their complaint to include
CERCLA violations.
  Later, in December 1983, the Federal Court consolidated the
separate suits against Westinghouse.  Settlements negotiations
ensued.  In 1984, the parties prepared a Consent Decree which
identified the cleanup activities for six municipal and
industrial waste sites in the Bloomington area (Anderson Road
Landfill, Bennett's Dump, Lemon Lane Landfill, Neal's Dump,
Neal's Landfill, and Winston-Thomas Treatment Plant).  These
sites total approximately 650,000 cubic yards of PCB or
contaminated soil.  One of the requirements of the Consent Decree
is that Westinghouse design and construct a high temperature
incinerator fueled by MSW to destroy the estimated 650,000 cubic
yards of PCB-contaminated material from the six Bloomington
Consent Decree sites.  Westinghouse is also responsible for
disposal of the resulting incinerator ash.  To meet this
requirement, Westinghouse submitted applications for the
construction of a hazardous waste landfill in the Washington
Township area of Bloomington.  If permitted, the incinerator and
ash landfill must meet all applicable federal, state and local
laws.
  Westinghouse agreed to accept responsibility for cleanup of
the contaminated sites.  The City and the County's solid waste
were to be used as fuel for the incinerator.  This was thought to
alleviate the area of a serious problem, a landfill filled to
capacity, with no place for local garbage.  It would also help
Westinghouse recover some of their costs for the cleanup as they
could charge a tipping fee for processing garbage similar to
those fees charged by the County at the local landfill.  However,
to date, the Consent Decree remedy has not been implemented and
the sites have not been cleaned up.
  Realizing the difficulties associated with an incinerator as
an implementable remedy in Bloomington, the Consent Decree
parties agreed to explore alternative remedies to incineration. 
In February 1994, the parties officially launched a joint effort
to assess alternative remedies, and outlined their plan in
Operating Principles of the Parties for exploration of
alternative remedies for the six sites addressed by the Consent
Decree (Operating Principles).  The community approves of the
exploration of alternative remedies and that the Consent Decree
remedy is not implemented.  However, the community perceives that
since the Consent Decree was signed, Westinghouse had too much
authority in the negotiations process.
Permit Applications
  In July 1991, Westinghouse submitted to the EPA and IDEM
several environmental permit applications for the incinerator and
landfill.  Westinghouse must apply for several major permits
covering all aspects of the incinerator and landfill including
design, operation, emissions, air quality, ground water
monitoring, and environmental impact (see Appendix D - EPA
Information Update: Westinghouse Permit Application and Review
Process, August 1991 - for more information regarding the
permitting process).  In addition to the permits, Westinghouse
must also conduct risk assessments for the incinerator and ash
landfill.  
  Immediately following Westinghouse's submission of the permit
applications, the Indiana State Legislature enacted Public Law
128-1991 (House Enrolled Act 1429) requiring that IDEM conduct a
study of alternative PCB clean up technologies to incineration
before permit applications for a hazardous waste incinerator can
be considered.  This legislation states that IDEM had from July
1991 to July 1993 to conduct this study.  The deadline was
extended to July 1995.  Because IDEM is the lead agency for most
of the permits, other agencies cannot review the permit
applications until IDEM completes their review.  
  In 1993 the Indiana State Legislature enacted Public Law
36-1993 (Senate Enrolled Act 389), which requires that a
hazardous waste disposal facility (which includes incinerators)
obtain a certificate of environmental compatibility from the
State.  A certificate of environmental compatibility may not be
granted to a PCB incinerator if the incinerator will burn
municipal waste as a fuel or if the incinerator has not been
incorporated as part of the solid waste management district's
solid waste management plan.  These laws, enacted by the State,
effectively limit the Consent Decree parties' ability to enforce
the remedy outlined in the Consent Decree

Consent Decree Revisited
  Progress regarding the cleanup of sites has reached an impass
because no party has enforced the Consent Decree and the Consent
Decree sites have not been cleaned up.  The Consent Decree
parties have jointly decided to make a good faith effort and
explore alternatives to incineration.  To explore alternatives,
the sites must be characterized, data gaps identified, and
additional data can be collected, if necessary.
  The parties have agreed to start the data collection process
at the Lemon Lane Landfill and to continue the data collection on
a site-by-site basis until all of the Consent Decree sites have
been addressed.  The parties understand and recognize the need
for full public participation while exploring alternative
remedies, and have agreed to provide information and openly
exchange ideas with the public during the investigation of
alternatives process.  The parties, however, do not have an
established time line for this investigation.

COMMUNITY BACKGROUND
  
  This chapter is intended to provide both a brief description
of the Bloomington community from 1987 to the present, and an
overview of the public's concerns related to the Bloomington area
PCB-contaminated sites.  This chapter is organized into the
following sections:
* Community Profile
* History of Community Concerns
* Interested Parties
* Current Community Concerns

Community Profile
  
  The city of Bloomington, situated in the rolling hills of
Southern Indiana, located approximately 50 miles south of
Indianapolis, was established as the Monroe County seat in 1818. 
Bloomington was chosen as the site for Indiana University just
two years later.  The university abutts the downtown area and
provides academic majors through ten different schools at its
Bloomington campus.
  About 60,000 of Monroe County's 108,438 (1990 Census)
residents live in Bloomington and over 36,000 students attend the
University.  In addition to the campus community, Bloomington
often is characterized as the State's major cultural center and
boasts prime business communities and recreational areas of the
State.  Bloomington has a cosmopolitan flavor seldom found in a
community of its size.
  The focal point of downtown is the Monroe County Courthouse. 
Surrounding the Courthouse are 11 blocks of specialty shops
including toy stores, clothing outfitters, gourmet coffee and
espresso shops and a wide array of ethnic restaurants.  Just
outside of the downtown area are several beautiful lakes.  Lake
Monroe, a 10,750 acre lake, is the largest lake in the State.  It
borders the Hoosier National Forest on its western and southern
shores.  Lake Lemon, a 1,650 acre lake, is characterized by its
ridge and ravine topography, and Griffy Lake is a 109 acre lake
with a 1,200 acre nature preserve.  These lakes provide
Bloomington and surrounding communities with many recreational
opportunities.  Lake Monroe provides the city of Bloomington with
its primary drinking water supply.
  Bloomington's city government is comprised of 20 departments,
all with department coordinators, whom the Mayor oversees.  The
Bloomington Common Council is the City's legislative body and is
responsible for approving fund appropriations, resolutions
supporting or approving legislative matters, and adopting
ordinances which affect the City's Municipal Code.  The Mayor
works with the City's Legal Department to enforce the Municipal
Code.

Community Involvement
  The community's interest in the PCB sites is broad based and
is as long standing as the initial discovery of PCBs in 1976. 
The level of community awareness and participation in activities
related to the sites is exceptionally high.  Community members
are highly knowledgeable of site history, PCBs, incineration,
permitting and construction issues, the government's function,
and the various levels of government involved in the site cleanup
process.
  Various members of the community have been extremely active in
expressing their concerns to City, County, State, and Federal
officials regarding these sites.  They have employed a wide
variety of techniques to convey their concerns, including: 
lobbying governmental officials (i.e., local, State and EPA
Regional officials, members of Congress, and the U.S. EPA
Administrator); filing law suits for damages against Westinghouse
and Monsanto; attempting to intervene in suits regarding the
Consent Decree; hosting parades with Greenpeace to draw attention
to the sites; producing an audio cassette of PCB protest songs;
and sponsoring hot air balloon rides to emulate how the proposed
incinerator emissions would blow over the City of Bloomington.
  Although there are a large number of individuals in the
community interested in the PCB sites, they have tended to join
or organize groups that represent their interests and perception
of the issues associated with the sites.  Many of these groups
are multi-issue groups that existed prior to the discovery of the
sites (i.e., pre-existing political and environmental
organizations), while others were formed solely for the purpose
of representing their members' interests related to the sites. 
Both types of groups have been vital participants in activities
sponsored by the Consent Decree governmental parties during
formal public comment periods, public meetings, various stages of
the PCB-related issue, and sponsoring their own activities.
History of Community Concerns
  After the signing of the Consent Decree in August 1985 and
during some of the initial removal actions at the sites, the EPA
regional office received numerous letters complaining about the
lack of public involvement in the decision-making process.  One
of the major complaints from citizens was that no formal Remedial
Investigation/Feasibility Study (RI/FS) was ever required by EPA
for the Bloomington area PCB-contaminated sites.  The 1985
National Contingency Plan (NCP), that the EPA initially based its
procedures on at this period of time, did not require an APACHE. 
Today's standards in the Superfund Enforcement Process, require
that an RI be conducted to assess the extent and nature of
contamination at a site.  An FS is then prepared after the RI to
examine and evaluate various remedial alternatives.  Following a
public comment period on the EPA's preferred alternative and the
draft FS report, the EPA chooses a remedy and outlines the remedy
in the Record of Decision (ROD) for the site.
  Another major complaint was that the EPA did not issue a ROD
for the sites.  Because the EPA was preparing a lawsuit against
Westinghouse, many of the decisions made regarding alternatives
assessment were not documented (EPA, July 1990).  Early in the
Superfund process, the EPA's method of developing case
information for responsible party lead sites, as opposed to EPA
lead sites, was done by conducting an Enforcement Decision
Document, so a ROD was not formulated for the Bloomington area
sites (EPA, 1990).  Also, because the EPA was in litigation with
Westinghouse, many documents were enforcement confidential.  The
citizens were not allowed to see the Administrative Record until
the EPA had settled the case and then it was only made available
through a Freedom of Information Act (FOIA) request.
  These events led to public mistrust of the EPA.  Most of the
early public meetings regarding these sites were contentious and
during the early removal actions, the citizens accused the EPA of
not keeping them informed of the ongoing cleanup actions.  The
main objection was that EPA personnel were located in Chicago,
and was difficult for citizens in a small Indiana town to
communicate with them.  In response to the public's concerns, EPA
established a PIC and a telephone hotline in Bloomington in
January 1989, and staffed the PIC with a local resident, so they
could provide ongoing information to the citizens regarding the
cleanup.  The PIC and telephone hotline are discussed in more
detail in Chapter 4.

Interested Parties
  This section provides a brief description of each of the major
parties (Consent Decree, governmental and non-governmental), and
their involvement in the community and the PCB-contaminated
sites. 
Governmental

Consent Decree Parties
  U.S. Environmental Protection Agency (EPA)
  To address the Nation's hazardous waste sites, Congress passed
CERCLA in 1980 and charged EPA with the enforcement of this
program.  Once Superfund was underway, EPA began the process of
site discovery and site evaluation, and quickly realized that it
was much larger than Congress or EPA had expected.  Thousands of
potential hazardous waste sites existed.  The waste disposal
practices of many industries contributed to the detriment of the
Nation's land and waters.  EPA selected the worst waste sites in
the nation and began implementing remedies to clean them up.  In
Bloomington, Indiana, where Westinghouse had discarded capacitors
in local landfills for years, EPA was responsible for seeing that
Westinghouse cleaned up this contamination.
  The EPA was represented by the U.S. Department of Justice
(DOJ) in negotiations with Westinghouse and matters relating to
the Consent Decree.  The DOJ filed suit against the Westinghouse
Corporation for the cleanup of Neal's Landfill and Neal's Dump in
January 1983.  This suit was filed under Sections 104, 106 and
107 of CERCLA and Section 7003 of the Resource Conservation and
Recovery Act (RCRA).  A Consent Decree was lodged with the United
States District Court for the Southern District of Indiana in
August 1985.  Under this decree, EPA is responsible for Federal
approval of required plans and permits and technical oversight
and supervision of work performed at the sites.
  EPA's involvement in the community relations aspects of the
cleanup includes sponsoring and participating in numerous public
meetings, writing and distributing fact sheets detailing all
phases of cleanup activities at specific sites, generating fact
sheets regarding incineration and the permitting process, and
establishing four site information repositories located in
Bloomington and Ellettsville.  EPA also was responsible for the
establishment of a CIC, which the EPA Project Manager and
Community Involvement Coordinator meet with regularly to engage
in a mutual dialogue regarding the sites.  The CIC meets about
every six weeks.
  Indiana Department of Environmental Management (IDEM)
  The State of Indiana, as represented by the Environmental
Management Board of the Indiana State Board of Health (ISBH),
intervened as a plaintiff in EPA's suit against Westinghouse. 
ISBH also was a key negotiator in defining the site cleanup
requirements.  Hearings held by the ISBH during 1975 and 1976
precipitated the legal proceeding against the Westinghouse
Corporation.  Subsequently, the IDEM was created on April 1,
1986.  The responsibility for the Bloomington PCB sites formerly
belonged to ISBH as the representative for the State of Indiana
on the Consent Decree.  However, IDEM is now the State agency
handling matters relating to Westinghouse.
  The State of Indiana, through IDEM, is responsible for issuing
the solid waste permit for the incinerator.  In addition, the
State, like EPA, has technical oversight authority over cleanup
activities and shares approval authority with EPA and the City of
Bloomington for the hazardous waste incineration permit, storage
facility and site safety plans, and Westinghouse-prepared risk
assessments.  IDEM's Office of Environmental Response is
responsible for overseeing the implementation of the Consent
Decree for the State of Indiana.  IDEM's Office of Solid and
Hazardous Waste Management specifically handles permitting and
enforcement of RCRA and oversight of permitted solid waste
facilities.
  Since 1976, the IDEM along with EPA has continued to conduct
field tests to determine the levels of surface water, ground
water and soil contamination at each of the eight sites.  The
IDEM responds to inquiries from the public and participates in
public forums, community meetings (such as the CIC) and media
interviews.  IDEM continues to review information generated from
site activities and investigate the PCB-contaminated sites. 
Currently, IDEM is in the process of selecting a contractor to
study alternative cleanup technologies to incineration.  The
study includes an assessment of the efficiency and the technical
and economic feasibility of alternative cleanup technologies.
  Indiana State Department of Health (ISDH)
  The ISDH is responsible for protecting the health of the
citizens of the State of Indiana.  The Environmental Epidemiology
Section of the ISDH, in its assessment of hazardous waste sites,
determines any current or future impact on public health;
develops health advisories; determines whether additional action
should be taken to reduce and/or eliminate exposures; and
determines whether additional information on human exposure or
associated health risks are needed, such as through epidemiologic
studies or site-specific biological testing.
  The ISDH has a cooperative agreement with the Agency For Toxic
Substances and Disease Registry (ATSDR) to write public health
assessments for all Superfund hazardous waste sites in Indiana. 
Because the six Consent Decree PCB sites are located in the same
general area, have the potential to affect the same population,
and are contaminated with a common chemical, one public health
assessment will be written for the six sites.  The ISDH has
written a report entitled "Preliminary Data Evaluation and
Pathway Analyses Report" for the six Consent Decree PCB sites. 
This report will be the foundation of the ATSDR project and will
be incorporated into the public health assessment for the sites.
  The report has undergone data validation review by State and
Federal environmental agencies.  It has also undergone public
review and comment.  The final document can be found in the EPA
information repositories.
  Monroe County
  The involvement of Monroe County stems, in part, from the fact
that the County was considered a PRP liable for the cleanup of
the Anderson Road Landfill, which, at the time of the Consent
Decree implementation, was owned by the County and operated by
private contractors as a MSW landfill.  The County accepted PCB
capacitors from the Westinghouse plant for disposal at the
landfill in 1972.  As stated in the Consent Decree, the County
must also provide Westinghouse with MSW to fuel the incinerator
once it is permitted.
  The County has authority to administer its zoning and health
regulations in relation to the implementation of the Consent
Decree.  The County's participation to date has included
assisting the State in conducting studies on PCB blood levels in
local residents and Westinghouse employees; receiving reports of
abandoned capacitors and initiating investigation (via the County
Board of Health) of such reports; and informing City, State and
Federal government officials of its findings.  The MCHD also has
assigned staff specifically to follow implementation of the
Consent Decree.  County representatives participate in technical
meetings on project safety, interim cleanup plans, and
incinerator permits.  Finally, the MCHD has served as a source of
information for other governmental agencies, community
organizations, and individuals concerned about the PCB problem in
the community.
  City of Bloomington
  The City of Bloomington initially became involved in the PCB
sites because of concerns regarding contamination throughout the
Winston-Thomas Wastewater Treatment Plant owned and operated by
the City.  In 1981, the City filed suit (separate from EPA)
against Westinghouse for the cleanup of the Lemon Lane Landfill
(located in the City) and the Winston-Thomas Wastewater Treatment
Plant.  Beginning in 1983, the EPA, City, and Westinghouse agreed
to stay the litigation in order to conduct settlement
discussions.  Consequently, the EPA and City suits were
consolidated.  As a result, the City of Bloomington, as
represented by the Utilities Services Board (USB), was very
active in the Consent Decree negotiation process and, more
recently, in filing an additional suit for damages against
Monsanto (the manufacturer and distributor of the PCB oil).
  As outlined in the Consent Decree, the City has approval
authority for site safety plans, risk assessments, and the
permits for the construction and operation of the IFS and
incinerator.  The City also has the authority to approve or
disapprove the route for transporting hazardous material from the
sites to the storage facility and incinerator.  The City and
County must provide MSW to Westinghouse to use as fuel for the
incineration of the PCB-contaminated materials.
  The City, like EPA and the State, has sponsored and co-sponsored 
numerous public information meetings, television panel
discussions with representatives of the various Consent Decree
parties (including the Westinghouse Corporation and members of
local citizens' organizations) as well as press conferences.  In
1985, at the request of the City, the DOJ agreed to extend its
30-day public comment period on the lodged Consent Decree for an
additional two weeks.
  Utilities Services Board (USB)
  The USB provides potable water to Bloomington residents, as
well as wastewater collection and treatment services.  The USB's
initial involvement in the PCB sites was a result of its
responsibility for the Winston-Thomas Sewage Treatment Plant,
which was found to contain PCB-contaminated sludge and sediments. 
The USB filed suit against Westinghouse on behalf of the City in
1981.  The USB is the City agency under the Consent Decree with
the authority to approve or disapprove Westinghouse's plans as
outlined in the Consent Decree.
Other Governmental Parties
  U.S. Fish and Wildlife Service (FWS)
  The FWS is not a Consent Decree party, but the agency provides
two important services or functions with regards to the EPA's
responsibilities set forth in CERCLA.  The first is to provide
technical assistance pursuant to the FWS' authority as stated in
Section 662(a) of the Fish and Wildlife Coordination Act:
  "... whenever waters of any stream or other body of water are
proposed or authorized to be ... modified for any purpose
whatever, ... by any Department or Agency of the United States,
or by any public or private agency under the United States Fish
and Wildlife Service ... with a view to the conservation of
wildlife resources by preventing loss of and damage to such
resources as well as providing for the development and
improvement thereof in connection with such water-resource
development."
  Furthermore, Section 665 of this Act also directs the FWS to:
  "... determine the effects of domestic sewage, mine,
petroleum, and industrial wastes, erosion silt, and other
polluting substances on wildlife, and to make reports to Congress
concerning such investigations and recommendations for
alleviating dangerous and undesirable effects of such pollution." 
The Fish and Wildlife Coordination Act also provides for the
"distribution of data on progress and results of such
investigations for the use of Federal, State, municipal, and
private agencies, individuals, organizations, or enterprises."
  A second function of the FWS is to act on behalf of the
Secretary of the Department of Interior (DOI) as a natural
resource trustee for endangered species, migratory birds,
anadromous fish, and Federal Lands that are listed in 40 CFR
300.600 of the NCP, as natural resources for which the Secretary
has trusteeship.  This trustee authority was delegated to the
Secretary by the January 23, 1987 Executive Order 12580 and by
the NCP, pursuant to federal regulations, 40 CFR 300.600, to
pursue Natural Resource Damage Assessments, pursuant to CERCLA
and the Federal Water Pollution Control Act (FWPCA) as amended in
33 U.S.C. 1251 and 43 CFR 11.
  The FWS has been critical of the Consent Decree because of its
failure to include ecosystem health and natural resource
destruction.  The FWS maintains that the interim measures taken
by Westinghouse to prevent off-site migration are not protective
of the ecosystem.  Specifically, they feel that there is
bioaccumulation of PCBs in the migratory waterfowl feeding at the
Winston-Thomas Treatment Plant's contaminated sludge lagoon, and
the FWS would like Indiana citizens to be compensated for natural
resource damages caused by Westinghouse's past actions.
  Agency For Toxic Substances and Disease Registry (ATSDR)
  ATSDR is a federal public health agency and is part of the
Public Health Service within the U.S. Department of Health and
Human Services.  ATSDR was created in 1980 by Superfund
legislation and is not a regulatory or enforcement agency, like
the EPA.  The mission of ATSDR is to prevent exposure and adverse
human health effects, and to prevent diminished quality of life
associated with exposure to hazardous substances from waste
sites, unplanned releases, and other sources of pollution present
in the environment.  The ATSDR acts to protect public health
through its programs, which include public health assessments,
surveillance, chemical registries, health studies, environmental
health education, and applied substance-specific research, and by
working with other federal, state, and local government agencies. 
ATSDR is the principal federal public health agency involved with
issues concerning the human health hazards of hazardous waste
sites and emergencies resulting from unplanned releases of
hazardous substance into the environment.
  ATSDR is undertaking a multi-phased project to address
community concerns related to the impact on public health of 
PCB-contamination in the Bloomington area, including Monroe and Owen
Counties.  The project has three purposes:  (1) to conduct a
comprehensive assessment of the public health impact of the six
of the eight hazardous waste sites containing PCB-contaminated
wastes; (2) to determine any potential public health implications
of incinerating the PCB-contaminated wastes; and (3) to identify
and evaluate pertinent public health considerations of other
technically feasible non-incineration remedial strategies.
  Four tasks, are being conducted concurrently to fulfill these
three purposes:  (1) develop a preliminary evaluation of all
past, present, and future human exposure pathways, available
health outcome data, and community health concerns associated
with the six sites; (2) conduct a comprehensive review of past
PCB-related health studies; (3) perform an evaluation of the
public health implications of incinerating PCB-contaminated
wastes; and (4) evaluate the public health considerations of
other technically feasible non-incineration remedial strategies.
  The final report of the preliminary evaluation of the exposure
pathways associated with the six sites has been completed and was
distributed to the community.  In September 1993, ATSDR convened
40 national experts at a workshop in Bloomington to identify and
evaluate data and information related to the public health
implications of the disposal of PCBs.  The proceedings of the
expert panel workshop are scheduled to be released in draft form
for public comment in August 1994.  Health education focused on
clinical aspects of environmental exposure to PCB-contamination
was given to 90 area physicians and other health care
professionals.  ATSDR periodically briefs various members of
Congress on its activities in the Bloomington area.  Work has
begun on the public health assessment, which is expected to be
distributed for public comment in late 1994.  ATSDR also provides
90-day updates to the local community on its activities in the
Bloomington area.
  National Institute For Occupational Safety and Health (NIOSH)
  NIOSH is an institute within the Centers for Disease Control
and Prevention (CDC) under the United States Department of Health
and Human Services.  NIOSH, established under the National
Occupational Safety and Health Act of 1970, is charged with
conducting research to make the nation's workplaces healthier and
safer.  
  NIOSH conducted their first investigation in Bloomington at
the Westinghouse Electric Corporation on June 1-3, 1976.  The
purpose of this investigation was to evaluate exposures of
electrical and materials' technicians to PCBs.  They have since
conducted two morbidity reports in 1981 and 1984 and a mortality
report in 1989.  NIOSH also concluded a health hazard evaluation
at the ABB Plant in November 1993 that assessed potential hazards
associated with oxyacetylene burning.
  NIOSH is currently updating the 1989 Westinghouse/ABB worker
cohort mortality study to determine if PCBs appear to be related
to illnesses in former workers at the Westinghouse/ABB plant. 
The study looks at the relationship between exposure of the
workers to PCBs and several causes of death.  The workers who
have died since 1986 have been identified and death certificates
have been ordered for each one.  After NIOSH receives these death
certificates, the total cohort mortality data will be analyzed. 
  Bloomington Environmental Commission (EC)
  The EC serves as an advisory body to the Mayor, Board of
Public Works, Common Council, and the Planning Commission for the
City of Bloomington.  The EC responds to citizens complaints and
reviews and makes recommendations to the Mayor and Common Council
regarding these issues.
  The EC is composed of 12 volunteer members, six appointed by
the Mayor and six appointed by the Common Council.  Currently the
EC is conducting environmental reviews of proposed developments
within the City's jurisdiction and is involved in the Master Plan
Implementation in the Lake Monroe Watershed.  In 1994, the EC
produced a document, Bloomington Environmental Quality
Indicators, which included a chapter on PCBs in Bloomington.
Non-Governmental
The Coalition Opposed To PCB-Ash In Monroe County (COPA)
  COPA, founded in February 1990, is a non-profit, grass roots,
multipartisan, coalition of many individuals opposed to the
construction of a hazardous waste incinerator and ash landfill in
Monroe County.  COPA's strategy for preventing construction of an
incinerator and ash landfill in Monroe County has included
information sharing, litigation, and political pressure and
lobbying.
  In May 1992, COPA received four Technical Assistance Grants
(TAG) ($50,000 per NPL site) from EPA so that they could hire a
technical advisor to assist them in understanding the complex
technical issues regarding the four Bloomington area NPL sites. 
COPA hired Environmental Compliance Organization (ECO) to review
site data to determine technical accuracy and to identify data
gaps.  COPA supports the EPA and the other parties' willingness
to explore alternatives to incineration and would like to be
involved in the alternatives review process.
Anarchists Political Action Committee for Health and the
Environment (APACHE)
  APACHE is a grassroots organization with a deep abiding
respect for the Apache Indians and other Native Americans.  This
group is very active and aggressive in civil disobedience and are
vehemently opposed to an incinerator in the Bloomington area. 
APACHE believes that the Consent Decree is a blockade to progress
and that by making Westinghouse an equal partner with the other
parties in the negotiation process, limits the government's
ability to enforce the decree.  They would like to see the
Consent Decree eradicated and a traditional APACHE performed so
that the parties and the public can begin to understand the full
extent of the PCB problem.
People Against The Incinerator (PATI)
  PATI, another grassroots organization, was organized in
February 1987 by two members of Tough Women Against Toxics.  PATI
organized in opposition to the proposed Westinghouse MSW-fueled
incinerator, and their primary purpose was to stop Westinghouse
from building an incinerator in Bloomington.
  Initially, PATI advocated examination of alternative
technologies, such as pyrolysis, plasma arc, and biodegradation,
and preferred that the material be excavated and stored in
bunkers until one of these technologies could be used.  However,
PATI has since modified its position, and now feel that there is
no suitable technology.  They advocate a "let it be" attitude and
they do not want the material to be excavated because of the
possible health risks associated with airborne PCBs. 
Near West-Side Neighborhood Association (NWSNA)
  The NWSNA is a non-partisan, voluntary organization dedicated
to fostering better communication between area residents,
protecting Single Family Residential zoning status, and
encouraging neighborhood pride.
  The NWSNA is primarily interested in the PCBs stored at the
Fell Iron and Metal site.  It reviewed and decided to oppose the
EPA's proposed cleanup plan to incinerate site contaminants.  The
NWSNA also pointed out the technical, legal, and safety
considerations made in the proposed plan that were unclear and
overlooked.  A recommendation was made that no action be taken at
the sites until a safer cleanup method was identified.
Sassafras Audubon Society (SAS)
  The Indiana SAS is dedicated to protecting wildlife and
natural areas, and to promoting environmental education.  It is
concerned about the contamination of land, air and water as it
affects wildlife, public health and general environmental
quality.  They have been involved in the PCB issue by attending
CIC and public meetings, and submitting written comments during
public comment periods.
League of Women Voters (LWV)
  The LWV supported the signing of the 1985 Consent Decree
because it gave the local populace the opportunity to participate
in the cleanup process; however, it did so with reservation.  The
SAS is concerned about incinerating the PCBs and landfilling the
ash, since it most likely will be considered hazardous.  The SAS
believes that before any actions are taken, the risks associated
with removing, incinerating, and landfilling PCBs should be
determined, as well as the risks associated with exposure at the
contaminated sites.  Also, the SAS supports investigation of
alternative remedies.  Appropriate "state-of-the-art" monitoring
of toxic products in the air, ground water, and the food chain
should take place before, during, and after the remedial action
to protect the health of the citizens of Monroe County.  The SAS
strongly suggests openness in dialogue not only with the public,
but also among the Consent Decree members.
Student Environmental Action Coalition (SEAC)
  SEAC is a grassroots network of student and youth
environmental groups on more than 2,000 high school and college
campuses across the country, including Bloomington, that are
working together to build a strong student movement to save the
environment.  Through SEAC, campus environmental groups network,
share resources, educate each other, build coalitions, and
challenge the limited mainstream definition of environmental
issues at public meetings.
  SEAC's members have demonstrated against the proposed
Bloomington incinerator by marching in front of the local PIC and
chanting protest songs.  SEAC also has been involved in the local
PCB issue by attending CIC meetings and offering input.
Physicians for Social Responsibility (PSR) South Central Indiana
Chapter
  The local PSR chapter is a grassroots single issue-oriented
group within the National organization of 40,000 plus members. 
PSR organized originally as a disarmament group that focused on
nuclear arms issues but has recently broadened its mission to
include environmental issues.
  The PSR's South Central Indiana Chapter, comprised of local
physicians, began its focus on the Bloomington PCB issue in the
summer of 1990.  The PSR advocates solutions other than
incineration,  they strongly support the decision by the Consent
Decree parties to look at alternatives to incineration on a site
specific basis.
Sierra Club:  Uplands Group
  The Uplands Group, a regional group of the Hoosier Chapter of
the Sierra Club, was established in 1974.  In its early days, it
worked on the establishment of the Nebo Ridge Wilderness
proposal, which eventually evolved into the Deam Wilderness in
the Hoosier National Forest.
  The Uplands Group also has been very concerned about the PCB-contamination of the environment around Bloomington and Monroe
County.  The Group opposed the use of an incinerator to destroy
the contaminated soils because of the potential risk to the local
population.  Incinerating the soils could have created air
pollution in the form of heavy metals and dioxin, and disposing
of the ash in the landfill could have caused ground water
contamination.  Ash disposal could be a permanent drain on County
taxpayer's resources.  The Group believes that a comprehensive
APACHE detailing site characteristics and all possible site
specific alternatives should have been considered before any
final solution was debated by the parties and the public.
Greater Bloomington Chamber of Commerce
  The Chamber was founded in 1915 to influence, develop and
maintain a healthy business climate for the Bloomington area. 
Today, the Chamber continues as the area's main protector of
business interests and the collective voice for hundreds of firms
on issues affecting their livelihood.
  The Chamber reportedly commends the Consent Decree parties for
their willingness to work cooperatively towards a resolution. 
Since 1991 the Chamber has supported a comprehensive evaluation
of alternative technologies.  The Chamber supports local
participation in the PCB cleanup and supports the assignments of
direct expense of PCB disposal.  The Chamber calls upon the City
and County to be diligent through whatever permitting processes
may be needed, to assure protection of the health, welfare, and
interests of our community.
Other Interested Parties
  There are other groups and individuals that have been active
and vocal participants in the activities related to the PCB
sites.  In 1991, the Monroe County Council and the Bloomington
Common Council both passed resolutions questioning the building
of an incinerator in Bloomington before alternative technologies
have been reviewed or an APACHE performed.  A copy of these
resolutions can be found in Appendix D.
Individual members from various groups have also been active in
the Bloomington PCB issue.  The Bloomington Rotary, former
Indiana Public Interest Research Group (INPIRG) members, and
several Indiana University School of Public and Environmental
Affairs (IU SPEA), biology and chemistry professors have been
vocal and active participants in public meetings and CIC
meetings.  Rotary members have been active in attending public
meetings and CIC meetings to gain further insight regarding the
PCB issue.  Their members have a variety of stances on the issue
and are not able to represent a single position.  Former INPIRG
members would like a written evaluation of the pros and cons of
alternative technologies, a cash performance bond posted by
Westinghouse to cover the costs of the cleanup, and for the City
of Bloomington to submit the Consent Decree to a vote by the
city's residents, among other things.  In 1991, INPIRG, along
with COPA, filed a motion with the U.S. District Court asking
that the court require EPA to perform an APACHE and to vacate the
Consent Decree.  IU SPEA professors have varying viewpoints, but
at least one would like to see seasonal site characterizations
done before a remedy is selected.  As well, this individual would
also like to see biomonitoring on wildlife done to determine
effects on human health and the ecosystem.
EPA COMMUNITY RELATIONS IN THE BLOOMINGTON AREA
EPA's Response to Current Community Concerns
  Responding to the public's concern about communicating with
EPA from their Chicago Regional Office, EPA established a PIC in
January 1989.  On EPA 's behalf, a contractor under a Technical
Enforcement Services (TES) contract, staffed the PIC in Fountain
Square Mall, located in the immediate downtown Bloomington area. 
The purpose of the PIC is to give information to citizens
regarding the PCB cleanup in a timely manner.  Initially, it was
staffed with an outside geologist/environmental consultant who
acted as a liaison between EPA and the public.  After the first
year of operation, it was staffed with a local resident, also a
contractor.
  On March 31, 1994, the TES contract ended and the PIC staffing
was taken over under the Alternative Remedial Contracting
Strategy (ARCS) contract.  When the ARCS contractor took over the
contract, the ARCS contractor relocated the PIC within Fountain
Square.  The PIC relocated to the third floor of Fountain Square
(Suite 322), and continues to be staffed by a local resident
Monday through Thursday, from 1 pm to 5 pm, and by appointment.
  The PIC staff maintain both detailed written and computer logs
of all phone calls and visitor conversations.  These phone and
visitor logs are shared with the EPA Work Assignment Manager
(WAM) and Project Manager to ensure that issues of community
concern are brought to the attention of the EPA.
  In November 1989, at the urging of members of PATI, a CIC was
formed to provide an avenue for information sharing and dialogue
between EPA Region 5 and the community.  The committee is
comprised of private citizens and representatives of local and
state government, environmental activist and civic groups,
Indiana University faculty, the legal community, and medical and
health professionals.  The committee meets every six weeks to
discuss issues of immediate community concern regarding the local
PCB sites.  Committee members are charged with the responsibility
of disseminating information to their constituents, and a
chairperson for the committee.  The U.S. EPA provides a permanent
meeting space within the PIC.  The meetings are videotaped for
possible broadcast on the local public access television channel.
  In addition to establishing a CIC and PIC, since the 1987 CRP,
EPA has held more than 16 public meetings and information forums
as well as published and distributed numerous fact sheets
regarding the Bloomington PCB site cleanups.  EPA has also
visited residents adjacent to the PCB-contaminated sites to
discuss the cleanup as it continues around their neighborhood. 
Also, the EPA maintains four information repositories in the area
to provide the community access to information on the Bloomington
PCB sites.  Residents can also go to the local PIC or to one of
the four information repositories to seek information regarding
the cleanup.  
  In 1993, EPA and their Community Involvement contractor
contracted with the Indiana University Center for Survey
Research, to conduct a telephone survey of a random sample of
Monroe County, Indiana residents.  The purpose of the survey was
to assess the community's attitudes toward PCBs and EPA's cleanup
efforts.
  The survey team completed 527 telephone interviews asking
Monroe County residents a variety of questions regarding the PCB
cleanup.  In particular, questions targeted public knowledge of
incineration as a technology and as an appropriate remedy for
Bloomington's PCB-contaminated sites.  Of those interviewed,
76.8% were aware of the proposed incinerator but 52% were not
aware that the incinerator was required by a federal Consent
Decree.  Of those aware of the incinerator, 79.3% had concerns
about incineration fueled by solid waste and 83.6% had concerns
about incineration fueled by some other fuel source (i.e.,
natural gas, wood, coal).  When asked if EPA is perceived as a
believable source of information, 68.7% affirmed EPA as a
believable source of information.  In response to whether the
public was given adequate opportunity to express its opinion
regarding the proposed incinerator in the last couple of years,
60.2% agreed with the statement that the public had been given
adequate opportunity to express opinions regarding the proposed
incinerator.  Another question asked in the survey was whether or
not residents knew about the monthly CIC meetings.  Only 19.1%
knew about these meetings.  A copy of the telephone survey
questions and results can be found in Appendix D.  The results of
the survey are also available at the local repositories and the
PIC.
  In anticipation of updating this CRP, EPA conducted community
interviews from May 17 through May 19, 1994.  The purposes of
these interviews were twofold; to reach those residents near the
sites, a sector of the population that seemed overlooked during
previous meetings; and to examine the changes that may have
evolved in community perceptions since the discovery of the
sites.  
COMMUNITY INTERVIEWS
  During three days in May 1994, community interviews were
conducted by the U.S. EPA.  The purposes of these community
interviews were to (1) gauge changes in community perceptions and
impressions about the activities and progress at the sites since
the CRP was initially prepared and (2) collect perceptions and
impressions from members of the community that were not typically
present at the public meetings or otherwise prominently involved
with the issues associated with the site.  These interviews were
also conducted to determine what other major issues may be raised
by the community, the anticipated level of community interest in
these issues, the most likely community participants in the
process, and the key individuals that may represent them.  In
addition, these interviews were used to identify the information
needs of the community in order to help clarify the objectives
and the elements of the community relations program.  
  The interviews were conducted "in-person" with both
individuals and with groups of individuals that agreed to meet
together for these interviews.  The interview team conducted the
interviews at individual's homes, offices, churches, community
centers, and at other locations that were convenient to the
residents.  The community interviewed included residents and
officials from the City of Bloomington, Monroe County, Owen
County, Bloomington Township, Perry Township and Richland
Township.
  In general, the following core set of questions were posed
during each interview, with any follow-up questions tailored to
the response of the interviewee and the various issues raised
during the interview:
  *     What do you know about the PCB sites?
  *     Are you aware of the PIC in downtown Bloomington?
  *     How well has information about the sites been communicated to
  the community?
  *     How can we better communicate the information to you?
  *     Have you heard about the meetings being scheduled for the
  following week?
       All of the individuals involved in the community interviews
were familiar with the PCB sites.  Most were aware of the PIC,
although the role of the PIC was not well understood by some. 
Information communicated about the sites, as well as the upcoming
meetings, has been adequate, as relayed during the interviews. 
However, each method of communication was identified by the
interviewees as possessing certain inherent limitations.  For
example, not all members of the community interested in the
issues read the newspaper or read the newspaper from the City of
Bloomington.  Additionally, not all members of the community
interested in the issues watch television or have cable with the
community access channel (which telecasts the CIC meetings). 
Some members of the community interested in the issues can meet
only during the day while others can meet only at night or on
weekends.  Several comments made during the interviews reflected
the reluctance of individuals to attend public meetings where
they believed their viewpoints would be effectively negated by
the more vocal and radical individuals that typically dominate
these meetings.  Everyone interviewed appreciated the face-to-face 
interviews but recognized the difficulty and time involved
in utilizing this means of communication on a regular basis. 
However, it was pointed out that it may be necessary to make such
efforts in order to be more effective in community dialogs.
  The primary concern expressed most frequently during the
interviews was the lack of information that was easy to
understand for the average community resident.  The information
being provided was too technical and utilized terms not well
understood by many community residents and officials. 
Consequently, as expressed by many interviewees, most community
members are concerned that the risks associated with the sites
are not being clearly explained so that better informed decisions
can be made by those most affected by releases from the sites. 
The use of language and terminology contributed to
misunderstandings and distrust about what is being done at the
sites and why it is being done.  For example, there is concern
about understanding comparative risks associated with
incineration and the alternatives that are being studied.
  Another concern relayed to the interview team was the
domination of the process by persons and groups representing
viewpoints that were perceived as extreme in the community
regarding the sites, such as those reporting that there was
nothing wrong with the sites and those playing on fear and panic
about the health risks associated with the sites.  In some
interviews, there was a desire to utilize a more balanced
approach, or to hear from the "middle ground", on the issues and
to consider some compromises so that action on the sites could
progress without continued delays by the various parties.  Again,
it was emphasized that the technical language being used by the
parties in discussions about the sites contributed to the
mistrust of the various viewpoints portrayed in the media and in
other communication about the sites.
  Some community members were also concerned that progress on
the sites has slowed down substantially.  Some believe that the
sites should be cleaned up immediately while others believe that
the sites should just be left alone and not disturbed. 
Regardless of the viewpoint about what should be done, many
believed that the activities at the sites are not accomplishing
anything to clean up the sites or to take care of the people who
live near the sites.  According to most of the interviewees, the
issues regarding the sites are not as prominent in community life
as they once were and it was noted that some of the controversy
has died down.  However, there is concern that a complacency may
exist in those responsible for addressing the contamination at
the sites since the public discussion on the issues has lessened
over time.
  Since public officials in their respective communities are
typically the first to be contacted when someone in the community
has questions about the sites, several of these officials
indicated that they would appreciate having up-to-date
information in order to respond accurately and effectively.  When
they have received questions about the sites, and they feel
relatively uninformed since they are not able to provide an
answer, they often will try to seek out others in their community
that might be more knowledgeable about the sites.  However, the
information may still be out-dated, inaccurate, or difficult to
understand and explain to others. 
  Some interviewees expressed a need to understand more about
the process for cleaning up the sites.  For example, some in the
community would like to know how remedies are selected and the
basis for remedy selection so that they can feel comfortable with
the solution since they will have to live with it.  They have a
need to have the process involved described to them and proof
provided to the community that the selected remedy is the best
available solution based on certain established criteria.  In
addition, they would appreciate this information being presented
before a remedy is selected so that they may have some input in
the process and in the selection of the remedy.  The concern
expressed was that decisions will be made before the community
has had a chance to understand it and influence the selection of
a remedy.
  The dissemination of the results from analytical testing of
well water and soils was identified by some interviewees as an
issue that needs to be addressed.  There was concern that the
information was not being provided to the community, especially
to those whose water wells had been tested.  In addition, there
was a feeling by some that the information was purposely being
withheld and not being shared as it was stated and understood. 
It was also pointed out by a few that the collection and analysis
of water and soil samples at the sites were not adequately being
undertaken to identify all possible contaminants associated with
the sites and, consequently, all possible human health and
environmental risks were not being addressed.  
  To help the Consent Decree parties understand how the
community would like to be involved in the process, the parties
scheduled five meetings for May 24th and four meetings for May
25th by reservation only.  Because of the low number of citizens
making appointments for these meetings, they were reduced to two
meetings on May 24th.  At these meetings, citizens were quizzed
regarding an effective way to communicate with them in the
future.  Some people said that this type of meeting was good for
them.  Others said that evening meetings would be better and that
meetings requiring appointments were not an appropriate forum for
public meetings.
FUTURE COMMUNITY RELATIONS ACTIVITIES
  Under the Operating Principles guidelines, the parties have
agreed that any resolution of PCB issues must take local concerns
into account.  It is of their opinion that the community be kept
informed and involved as the process moves to conclusion.  The
parties intend to achieve this through using a number of formats
to answer the public's questions and openly exchange ideas.  The
parties wish to accommodate as many individuals and community
organizations as are interested and have planned community
outreach activities, including:
  *     meeting and presenting material to the community using large
  group meetings, small group meetings, and public availability
  sessions;
  *     distributing publications and other written materials to the
  local media and interested citizens, including fact sheets and
  a newsletter;
  *     producing a "guided tour" video detailing activities and the
  current status of the sites; and
  *     producing videotapes that will feature scientists and other
  experts detailing technical issues associated with the sites,
  such as ground water flow and site geology.
  To coordinate these activities, the parties will continue to hold
regularly scheduled meetings to discuss and plan upcoming
community relations efforts.
  In addition, the EPA remains committed to responding to
citizens' concerns regarding the Bloomington PCB-contaminated
sites.  EPA will maintain a Bloomington PCB PIC staffed by a
local resident to act as a liaison between EPA and local public
officials, community organizations and citizens.  Functions
performed by PIC staff include:
  *     answer telephone hotline inquiries;
  *     respond to issues or concerns when asked;
  *     write and distribute press packets and information updates to
  keep the media and public informed of site activities;
  *     update and maintain a mailing list of persons interested in
  site information;
  *     attend public meetings and CIC meetings to address issues of
  public concern;
  *     give presentations regarding site activities to local civic,
  school, and university groups; and
  *     maintain the local repositories with site data, reports,
  plans, and alternative technologies information.
       Through maintaining a presence in the community, the EPA feels
that it may more clearly understand the attitudes and concerns of
the community and, in turn, the community has an accessible link
with which to communicate questions and ideas to EPA.
COMMUNITY RELATIONS STAFFING
  The primary EPA Region 5 community involvement contact for the
Bloomington sites is Dave Novak.  He will be guided or directed
in his actions by Region 5's Public Affairs Director, Margaret
McCue, and Community Relations Section Chief, Toni Lesser. 
Community relations activities will be coordinated by Mr. Novak
along with Dan Hopkins, Region 5 Remedial Project Manager (RPM)
for the Bloomington sites, and Jeffrey Cahn, Region 5 Assistant
Regional Counsel.  Community relations contractor assistance will
be provided by Earth Tech.  Sona Chambers, Earth Tech Senior
Community Relations Specialist, will be in charge of the day-to-day 
operations at the PIC along with another part time Community
Relations Specialist.  They may be contacted at the PIC at 322
Fountain Square Monday through Thursday from 1-5 pm EST or by
telephone at (812) 333-5EPA.
    
    
    
    
    APPENDICES TABLE OF CONTENTS  (not included)

            Appendix A   Key Public Officials, Civic Groups,
            Environmental Activists, Community Group Leaders
            and Media In The Bloomington Area
            
            Appendix B   Information Repositories and Meeting
            Facilities
            
            Appendix C   Selected Correspondence, Local and State
            Legislative Actions, Press Releases and Fact
            Sheets Related To The Bloomington Sites From 1987
            To The Present
            
            Appendix D   Common Acronyms and Glossary of Terms Used By
            Government Agencies, Civic and Environmental
            Organizations