March 17, 2006
Dear Borough Council,
I just read in the Tri County Record that the Whitford Corp. is moving their headquarters to the old Graco building on
Pine St. While I am very glad to see the building occupied again, I am concerned about toxic chemicals which will be
released into our community's air, land, and groundwater. I did a little research and discovered that in 2002, Whitford
was ranked among the top polluters for Chester County. Here is the link concerning it:
Here is a report from the U.S. EPA identifying the toxic releases from Whitford's plant in Frazer, Pa. in 2003:
As the above report indicates, Whitford (Frazer plant) released almost 6,000 pounds of a chemical called Methyl Ethyl
Ketone into the air in 2003. Here is a link which lists the health hazards of this chemical:
I do not know if Whitford plans to do manufacturing with toxic chemicals in Elverson, but if they do, it could be very
detrimental to everyone living in the area, especially the children.
Sincerely,
James TerBush
Elverson, PA
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April 12, 2006
Dear Borough Council,
I sent email to you last month concerning the Whitford Corp. plans to move their manufacturing facility into the former
Graco building on Park Ave. Below is a copy of that email. I am writing again because I have not received a reply.
I would like to once again express my concerns about having a chemical manufacturing plant located in Elverson,
especially one that has been identified as being one of the worst polluters in Chester County. Here are some questions
that I have for you:
Do the chemicals which the Whitford Corp. intends to release into the air pose a health threat to the residents of Elverson?
Do the chemicals have an odor? If not, how will residents know when the chemicals are present in the air?
Is the Elverson Fire Company trained and equipped to handle a chemical spill or other emergency at Whitford's plant?
How would the residents of Elverson be notified in the event of an emergency at Whitford's plant, and how would they be
evacuated?
Is it safe and legal for a chemical manufacturing plant to be located just a couple hundred yards away from a day care
facility?
Is it possible that a chemical spill at Whitford's plant could contaminate Elverson's community wells?
I am sure that the Whitford Corp. is eager to move into an area that has few environmental restrictions, and one that will
allow them to conduct business out of the public view and with little government oversight. However, I do not believe that it
would be in the best interest of Elverson's residents to have a chemical polluter located so close to them.
Thank you in advance for your consideration.
Sincerely,
James TerBush
Elverson, PA
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April 14, 2006
Dear Borough Council,
I received email on 4/12 from Robert Trout, Manager of Regulatory Affairs at the Whitford Corp., stating that "it is our
intention to address your concerns in an open, honest, and forthright manner." I look forward to their response.
In the meantime, here is a press release from the Whitford Corp in response to EPA concerns over PFOA, a chemical
used in the making of non-stick coatings:
I would like to draw your attention to the following words that Whitford used to characterize the concerns which have been
raised over PFOA: "noise", "fuss", and "hoopla".
However, for a better understanding of PFOA and the health risk it may pose to everyone, please go to the following websites:
I have scheduled to meet with the Pennsylvania Department of Environmental Protection and examine its public records
concerning the Whitford Corp. I encourage you to do the same. To contact the DEP, please call (484) 250-5910.
It's important to know Whitford's past environmental track record because it reveals what we can expect from them if they
relocate to Elverson. One thing I already can tell you is that in 2000, Whitford's 25 acre site in East Whiteland Township
underwent remediation for soil contamination. 560 tons of soil, contaminated with dichlorobenzene and VOCs, had to be
excavated and disposed.
Sincerely,
James TerBush
Elverson, PA
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April 19, 2006
Dear Borough Council,
Here are some recent news stories concerning PFOA (the chemical Whitford uses to produce its fluoropolymer coatings):
Here is an exerpt from the last link, which is a report written by several groups of Dupont Shareholders concerning its
liability from PFOA :
"DuPont's Fayetteville Works production facility in Fayetteville, North Carolina is the only site in the U.S. where PFOA is
produced. Despite the $7 million DuPont spent on environmental controls to contain PFOA when it opened the plant in 2002,
on-site testing at DuPont's 2,200 acre property detected PFOA in more than 25 monitoring wells, as have tests of residential
wells up to a mile from the facility. Samples taken from the nearby Cape Fear River have also been found to contain PFOA.
DuPont's testing of its workforce at the facility shows that the average concentrations of PFOA in blood samples rose from
an average of 11 parts per billion per worker in 17 workers in 2002 to an average of 450 parts per billion in 37 workers in 2005..."
"DuPont supplies various companies, both small ones similar to PTFE Compounds, Inc. as well as larger ones. Any of these
companies may have released similar pollutants into the environment with little or no notice from regulators until recently. Now
attention is growing on these companies, with concomitant pressure to eliminate emissions of PFOA and PFOA precursors."
I do not pretend to be an expert on this subject, nor do I consider myself to be an environmental activist. However, I hope
that the above links (and the links in my previous email messages) will show that the health of our residents may be put at
risk if the Whitford Corp., which has a poor environmental track record, is allowed to begin making fluoropolymer coatings for
all of North America here in Elverson.
Thank you again for your consideration.
Sincerely,
James TerBush
Elverson, PA
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April 22, 2006
Dear Borough Council,
Here is a news article which appeared a couple days ago concerning a class-action lawsuit against Dupont for failing to
disclose the risks of using non-stick cookware:
It's relevant to Elverson because the Whitford Corp. uses these same chemicals to manufacture its fluoropolymer coatings,
and these chemicals are likely to end up in our air and water supply.
I have not received a response yet from Robert Trout, Whitford's Manager of Regulatory Affairs, concerning its poor
environmental track record, but they have removed their sign from the intersection of Rt. 23 and Pine St., so I believe that
is a step in the right direction.
Sincerely,
James TerBush
Elverson, PA
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May 1, 2006
Dear Borough Council,
I received a letter this morning from Robert Trout, Whitford's Regulatory Affairs Manager, in response to email that I sent to
you on 3/17 and 4/14. He said they intend to be good neighbors, which hopefully means they will not pollute our air or our
water.
To help ease concerns, I encourage the Whitford Corp. to get an air quality permit from the DEP and submit a plan approval
application to the DEP before doing any more work to their facility in Elverson. They currently do not have an air quality permit
for their Frazer facility, and up until last Tuesday, they have never had an inspection by the DEP for air quality. The DEP is
currently evaluating data to determine if the Whitford Corp. requires an air quality permit. Every resident in Elverson requires an
emissions permit for their car. Graco had an emissions permit to operate in Elverson. It's unthinkable that a paint manufacturer,
which will be manufacturing tons of paint each month using many types of solvents, would be allowed to operate in Elverson
without an air quality permit.
Whitford has recently built state-of-the-art manufacturing facilities in Singapore, Germany, Brazil, and China. I would like to see
Whitford build a state-of-the-art manufacturing facility in Elverson. That kind of facility would have control technology installed to
reduce air emissions. Why should we have to live with anything less?
Sincerely,
James TerBush
Elverson, PA
P.S. Why is the Whitford Corp. moving from Frazer?
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May 3, 2006
Mr. Robert L. Trout
Whitford Corporation
Box 2347
West Chester, PA 19380-0110
Dear Mr. Trout,
Thank you for taking the time to address my concerns and for the invitation
to visit your new Elverson facility. Enclosed is a copy of an email that I sent to
Elverson’s Borough Council in response to your letter.
As a resident, I am very much aware of the environmental damage that Graco
Children’s Products, Inc. caused in my community. I want to do everything I
can to prevent that from ever happening again.
I was not aware that the soil contamination at your Frazer site was caused by
a previous owner. I had read that your corporation was one of the few sued by
the EPA for turning the Strasburg Landfill into a Superfund site, and assumed
that your Frazer site was contaminated by you as well. I commend you for
working with the DEP to correct the problem.
I would very much like to see your Elverson facility once it is completed. As I
mentioned to Borough Council, I hope that it will be a state-of-the-art facility
with the best available control technology for reducing air emissions.
Sincerely,
James TerBush
Elverson, PA
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On 5/19/06, the PA DEP Air Quality Department cited the Whitford Corporation for "Failure to obtain an operating permit
before construction, modification, or reactivation of a new source or control device." To view the violation details, click here:
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Below is email that I sent to Suzanne Adams, PA DEP Air Quality Department, on 10/12/06:
Dear Suzanne,
Could you please give me an update regarding the Whitford Corp. and its air quality violations. Have these violations been
resolved and do they have DEP approval to begin operations at their new facility on Park Ave. in Elverson? According to the
DEP's website, these violations have not yet been resolved:
In today's Tri County Record, Robert Trout, Whitford's manager of Regulatory Affairs, announced that their manufacturing
unit will move in on Oct. 28-29, and production will begin on Nov. 1. He is also quoted in the article as saying, "The regulatory
issues have been resolved."
Any information that you can give me on this matter would be greatly appreciated. Thanks.
Sincerely,
James TerBush
Elverson, PA
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Below is email that I received from Suzanne Adams, PA DEP Air Quality Department, on 10/20/06:
Mr. TerBush,
Per your request I looked into the status of Whitford Corp.'s air quality permit. According to the permitting engineer,
the company has decided to limit its VOC emissions to below 2.7 tons per year. In so doing, they are exempt from the
requirement to obtain a permit. They must maintain records to demonstrate that their emissions are below the threshold
and they must also comply with any other applicable requirements of 25 PA Code. DEP will inspect to insure that they
are remaining below the 2.7 tpy threshold.
Suzanne Adams
Air Quality
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Below is email that I sent to Suzanne Adams, PA DEP Air Quality Department, on 10/20/06:
Dear Suzanne,
I think the air quality permit should be based on their POTENTIAL to emit VOCs, and not on the honor system. That is
how other states issue air quality permits. I don't see why Pennsylvania should implement the federal law any different.
According to the article in the Tri County Record, Whitford plans to have 15 tractor trailors of chemicals going in and out of
their facility EVERY day. In my opinion, that represents a LOT of potential for VOC emissions. At the very least, the DEP
should require air quality monitoring equipment to insure that VOC emissions are below the limit that you deemed to be
acceptable.
There are many smaller companies in Pennsylvania that have been required to obtain air quality permits. I don't believe they
were given the opportunity to decide to limit their VOC emissions to below 2.7 tons per year.
Sincerely,
James TerBush
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Below is email that I received from Suzanne Adams, PA DEP Air Quality Department, on 10/20/06:
Mr. TerBush,
I have asked the permitting area to respond to the actual vs. potential issue and will forward that to you. The facility will
not be operating on the "honor system" as they are subject to inspections of their recordkeeping at any time the DEP deems
appropriate. Records of emissions must be based on acceptable calculation methodology and be backed up by inventory
and process data. Since VOC emissions are all "fugitive" i.e. they don't come out of a stack, it is not possible to quantify
them by any means OTHER than records. In this respect Whitford will be treated exactly like other facilities, both permitted
and not, who are emitters of fugitive VOCs. The fifteen tractor trailers you refer to cannot be assumed to be containing material
that will affect air emissions. The DEP's actions are based on the laws and regulations of PA; we cannot act on any basis
other than this.
Suzanne Adams
Air Quality
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Below is an article that appeared in the Tri County Record on 10/17/06
Sketch plans for a 90-home development presented to Elverson Borough
By TORY LINGG
Tri County Correspondent
ELVERSON - Sketch plans for a ninety-home development was presented by Merle Stoltzfus to Elverson Borough Council at their Oct. 3 meeting. It is planned for the area between the Pennsylvania Turnpike and Route 401 west of Yoder Road. A meeting was held in April with PennDOT and representatives from West Nantmeal Township to discuss improvements on a stretch of Route 401 from Yoder Road west past the intersection of Brick Lane to the pipe under Route 401.
Stoltzfus said, "Penn-DOT is interested in fixing the intersection but not paying for it. The estimated cost is $750,000. The cost is a problem.'' He wants to negotiate with West Nantmeal Township to find ways to save money. He asked the borough for a lot of cooperation. It won't be constructed with public dollars. West Nantmeal might look for some funds from grants. When they are done there will be sight distance at all intersections.
"PennDOT will take an interest in improving the location when people start getting killed.. This is an update on what is occurring. None of this happens fast,'' he said.
Robert Trout, manager, Regulatory Affairs of the Whitford Corporation, said, "The Whitford Company will move into the vacant GrayCo factory first and Polymeric Corp. will move in later in the year.'' Regarding truck traffic, he said, "There would be about 12 courier pick ups and from 10 to 15 tractor trailer deliveries and pick ups daily. They will try to consolidate truck traffic, if possible.'' The large trucks will use Parke Avenue and the vehicular traffic will use Pine Street.
There are about 50 workers on the site now getting things in shape. New office buildings are being constructed. The administration staff will move in Oct. 21-22. Business will be conducted from the site on Oct. 23. The manufacturing unit will move in on Oct. 28-29. Three shifts will be situated during October 30-31. Production will begin on Nov. 1.
Trout said, "It is no small task moving an entire manufacturing company. We are going to make it happen. The regulatory issues have been solved.''
The Whitford Corporation will have 75 to 80 people working three shifts. Polymeric will have 70 employees working two shifts. The Whitford Corporation is located in Frazer. Polymeric is located in Phoenixville. The Whitford Corporation manufactures coatings for cooking utensils.
Trout said, "The large floor space gives both companies space to grow.''
Borough Manager Jack McEwen said, "The Town Watch Program now in-cludes all of Elverson. There are block captains for all of Elverson, which includes Summerfield.'' Summerfield is part of the borough.
Some of those responsible for painting graffiti on walls, signs and buildings have been apprehended by the Caernarvon Police Department. Some of those caught were from other areas, coming to the area in cars. McEwen said, "It has been found the designs found in graffiti carry special messages from gang members.''
Traffic calming will start soon on Route 23. The project has been cut back quite a bit because of costs. Traffic islands to slow traffic will be located at the east and west ends of the borough. Four more overhead street lights will be located in the center of town. The work will be done before winter.
Council has been reviewing the proposal to construct apartments for seniors of moderate income at the location of the Elverson Fire Department. Council wants Delaware Valley Redevelopment Company, which has proposed the project, to scale it down. Glen Worgan, a representative of the company, had proposed 70 units for seniors of moderate income. Delaware Valley Redevelopment Company had renovated the old Honey Brook Elementary School into apartments for seniors.
Residents with side walks should remove grass growing between the cracks, debris and over grown bushes from the side walks.
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If you have questions about the Whitford Corp. plan to move its North American manufacturing facility to
Elverson, please contact Borough Council and express your concerns:
Elverson Borough Council
P.O. Box 207
Elverson, PA 19520
