United States Emergency and OSWER Directive 9230.0-28
Environmental Protection Remedial Response PB94-963293
Agency (5201G) EPA540-K-96-001
December 1995
&EPA Guidance for Community
Advisory Groups at
Superfund Sites
(JJX) Printed on Recycled Paper
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Acknowledgments
The Community Advisory Group guidance is the product of the efforts of many people; individuals
from the following groups have participated in its review and development: EPA Regional Offices, EPA
OSWER Offices, OERR Environmental Justice Task Force, National Environmental Justice Advisory
Committee, Association of State and Territorial Solid Waste Management Officias and EPA's Office of
General Counsel. In particular, the Community Involvement Team (OERR), Linda Garczynski (OSWER),
Hale Hawbecker (OGC), Jane Lemke (Wl), Verne McFarland (R6), Marilu Martin (R5), Marcia Murphy
(CA), Murray Newton (OERR), Charles Openchowski (OGC), Sonya Pennock (R8), and Suzanne Wells
(OERR) each have made valuable contributions to the development and quality of this guidance.
— Diana Hammer (OERR), Project Manager
Notice
The policies set out in this memorandum are intended solely as guidance. They are not intended, nor
can they be relied upon, to create any rights enforceable by any party in litigation with the United
States. EPA officials may decide to follow the guidance provided in this memorandum, or to act at vari-
ance with the guidance, based on an analysis of specific site circumstances. The Agency also reserves
the right to change this guidance at any time without public notice.
For More Information on CAGs
Contact your Regional Community Involvement Manager or a staff member of the Community Involve-
ment and Outreach Center at EPA Headquarters. (See the list of contacts in Appendix E.)
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Contents
Page
I. Background I
2. Community Advisory Group (CAG) Development 2
3. CAG Startup 7
4. CAG Membership 7
5. CAG Member Training 10
6. Administrative Support for the CAG I I
7. CAG Operations 12
8. CAG Response to Requests for Comments 14
9. EPA Response to CAG Comments 15
10. Roles and Responsibilities 15
I I. Appendices 19
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1. Background
> Environmental Justice Task Force
> Purpose of this Guidance
> Selecting Sites
The United States Environmental Protection
Agency (EPA) is committed to involving the
public in the Superfund cleanup process. In
fact, there are many examples throughout the
Superfund program where community involve-
ment has enhanced, rather than impeded the
Superfund cleanup decision-making process.
While recognizing that providing additional op-
portunities for community involvement may re-
quire additional time and slow the cleanup pro-
cess down initially, EPA believes this is time well
spent, and that early and effective community in-
volvement will actually save time in the long run.
EPA is committed to early, direct, and meaning-
ful public involvement and provides numerous
opportunities for the public to participate in
site cleanup decisions. One of these opportuni-
ties for community involvement, is the EPA's
Technical Assistance Grants (TAGs) program.
EPA awards TAGs to eligible community groups
so they can hire their own, independent Tech-
nica Advisor, enabling community members to
participate more effectively in the decision-
making process at Superfund sites. For more
information on the TAG program, see the "Super-
fund Technical Assistance Grants" quick reference
fact sheet (EPA 540-K-93-001; PB93-963301).
Community Advisory Groups (CAGs) are an-
other mechanism designed to enhance com-
munity involvement in the Superfund process.
CAGs respond to a growing awareness within
EPA and throughout the Federal government
that particular populations who are at special
risk from environmenta threats—such as
minority and low-income populations—may
have been overlooked in past efforts to en-
courage public participation. CAGs are an ef-
fective mechanism to facilitate the participation
of community members, particularly those from
low-income and minority groups, in the deci-
sion-making process at Superfund sites.
1.1 Environmental Justice Task Force
The Office of Solid Waste and Emergency Re-
sponse (OSWER) Environmenta Justice (EJ)
Task Force was established in 1993 to analyze
environmental justice issues specific to waste
programs and develop recommendations to
address these issues. The EJ Task Force advised
that the creation of Community Advisory
Groups would enhance public involvement in
the Superfund cleanup process. Specifically in
its April 1994 report, titled OSWER Environ-
mental Justice Task Force Draft Final Report
(EPA 540-R-94-004), the Task Force recom-
mended implementing a program involving
CAGs at a minimum often sites nationwide by
the end of FY94 and providing guidance to
support the CAG activities.
1.2 Purpose of this Guidance
As lead Agency at a Superfund site, EPA has an
important role to play in encouraging the use
of Community Advisory Groups (see Section
10.3, under "Roles and Responsibilities"). This
guidance document is designed to assist EPA
staff [primarily Community Involvement Coor-
dinators (CICs) and Site Managers, such as Re-
medial Project Managers, On-Scene Coordina-
tors, and Site Assessment Managers] in working
with CAGs at Superfund sites (this includes re-
medial and appropriate removal sites).
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This guidance addresses the objectives, func-
tions, membership, and scope of authority for
CAGs. It emphasizes practical approaches and
activities, and is designed to be flexible enough
to meet the unique needs of individual local
communities. The guidance is based on the
Agency's experience in carrying out community
involvement activities pursuant to the National
Oil and Hazardous Substances Pollution Con-
tingency Plan (NCP), the Superfund Amend-
ments and Reauthorization Act of 1986
(SARA), and policy documents issued by EPA
and other Federal agencies. It also draws on
concepts articulated in the President's Execu-
tive Order on Environmental Justice 12898,
EPA/OSWER's Environmental Justice Task
Force report, the "Restoration Advisory
Board Implementation Guidelines" developed
by the EPA and the Department of Defense
(9/94), and the "Interim Guidance for Imple-
menting Restoration Advisory Boards" draft-
ed by the California Environmental Protec-
tion Agency (I 1/93).
This guidance provides a number of consider-
ations to assist Community Involvement Coor-
dinators (CICs) and Site Managers in working
with a successful CAG. CAGs need not con-
form to all aspects of this guidance. Conse-
quently, this guidance is intended to provide a
starting point or frame of reference to help
groups organize and begin meeting. A CAG's
structure and operation, however, should re-
flect the unique needs of its community.
EPA will not establish or control CAGs; howev-
er, the Agency will assist interested communi-
ties in CAG activities. Further, EPA anticipates
that the CAGs will serve primarily as a means
to foster interaction among interested mem-
bers of an affected community, to exchange
facts and information, and to express individual
views of CAG participants while attempting to
provide, if possible, consensus recommenda-
tions from the CAG to EPA.
1.3 Selecting Sites
While EPA is initially focusing the CAG concept
and guidance on Superfund sites with environ-
mental justice concerns, the methods and prin-
ciples are intended to be applied broadly and
to include other Superfund sites as well. In
some cases, the sites selected for a CAG may
already have some form of community advisory
group and EPA could help formalize the group,
recognizing it as being representative of the
community. In other cases, sites may be select-
ed where a community advisory group doesn't
yet exist, but where a CAG would be useful to
encourage full community participation in site
cleanup activities. See Section 2.2, "Determin-
ing the Need for a CAG" for more information
on appropriate sites for a CAG.
2. Community Advisory Group
(CAG) Development
> CAG Scope of Authority
> Determining the Need for a CAG
> Preparation for the CAG
Information Meeting
> CAG Information Meeting
Community Advisory Groups are important
tools for enhancing community involvement
in the Superfund process. Through CAGs,
EPA seeks to achieve direct, regular, and
meaningful consultation with all interested
parties throughout all stages of a response
action.
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2.1 CAG Scope of Authority
A CAG should serve as a public forum for rep-
resentatives of diverse community interests to
present and discuss their needs and concerns
related to the Superfund decision-making pro-
cess with appropriate Federal and State/Tribal/
local governments. The CAG is designed as a
mechanism for all affected and interested par-
ties in a community to have a voice and actively
participate in the Superfund process. However,
it is important to remember that the CAG is
not the only mechanism for community involve-
ment at a site; as the lead Agency, EPA continues
to have the obligation to inform and involve the
entire community through regular as well as inno-
vative community involvement activities.
EPA cannot, by law, abrogate its responsibility
to make the final decisions at a site; however,
by providing the perspective of the local com-
munity, the CAG can assist EPA in making bet-
ter decisions. A CAG that is broadly represen-
tative of the affected community offers EPA a
unique opportunity to hear—and seriously
consider —community preferences for site
cleanup and remediation. It is particularly im-
portant that in instances where an EPA decision
and/or response differs from a stated CAG
preference regarding site cleanup, EPA accepts
the responsibility of explaining its decision and/
or response to CAG members.
A CAG allows the Agency to exchange infor-
mation with members of the affected com-
munity and encourages CAG members to
discuss site issues and activities among them-
selves. The CAG also can provide a public
service to the rest of the affected community
by representing the community in discussions
regarding the site and by relaying information
from these discussions back to the rest of the
community. CAGs thus can be a valuable tool
for both the Agency and communities through-
out the cleanup process.
2.2 Determining the Need for a CAG
The CIC should consult with other site team
members (for example, the Site Manager and
Attorney) in selecting an appropriate site for a
CAG. The team may consider a number of
factors during the selection process, including:
Generally, what is the level of community inter-
est and concern about the site?
• Might that level of community interest and
concern warrant a CAG?
• Has the community expressed an interest in
forming a CAG?
• Does a group similar to a CAG exist?
• Do groups with competing agendas exist at
the site?
• Are there any environmental justice issues or
concerns regarding the site?
• What is the history of community
involvement at the site?
• What is the likelihood of long-term cleanup
activity at the site?
Depending on the status of the cleanup pro-
cess at the site, substantial information may ex-
ist about the community. For example, if the
site is in the RI/FS phase, the Community Rela-
tions Plan, developed based on interviews with
community members, is a good information
source.
A community with a high level of interest and
concern about site activities should be a strong
candidate for a CAG. In addition, a site in the
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early stages of a long-term cleanup without an
existing community group may be a strong can-
didate site for an effective CAG. Communities
at removal sites, particularly non-time critical
removal sites, also may benefit from a CAG
(keeping in mind, however, the time necessary
to begin CAG operations when considering a
CAG for removal sites).
If a group exists which is representative of the
local community (for example, a local environ-
mental group that has been active at the site or
a TAG recipient group), a CAG may not be ap-
propriate—if the existing group can fulfill the
role of a CAG. If competing groups exist at a
site, however, their disparate interests and
agendas can undermine even the best efforts of
agencies, elected officials, and concerned citi-
zens to forge a CAG. This situation should be
given serious consideration in making the deci-
sion to promote CAGs at such sites.
A CAG can be formed at any point in the
cleanup process but may be most effective ear-
ly in the cleanup process. Generally, the earlier
a CAG is formed, the more CAG members
can participate in and impact site activities and
cleanup decisions.
2.3 Preparation for the CAG Information
Meeting
The CAG Information Meeting is the setting for
introducing the CAG concept to the communi-
ty. Before the CAG Information Meeting, the
CIC may begin the process of informing and
educating the community about the purposes
of the CAG and opportunities for membership
and participation. This is especially important at
Superfund sites where the community may have
had relatively limited participation in the Super-
fund process. This section offers suggestions,
concerns, and methods that EPA (in conjunc-
tion with others such as State/Tribal/local gov-
ernments) may use to notify a community
about the formation of a CAG. These are not
the only options—techniques will necessarily
vary from site to site and from community to
community. In many instances, it may be useful
to target multiple newspapers as well as alter-
native media (for example, public service an-
nouncements on the radio, public access chan-
nels on cable television, free circulation news-
papers) to more effectively reach out to com-
munities. Other outreach options include fly-
ers, announcements in local churches, etc. Re-
member also, that another important and effec-
tive method to "spread the word" about the
CAG is through the personal relationships that
Agency representatives have established in the
community. No matter what method or me-
dia is used, EPA (in conjunction with others
such as State/Tribal/local governments) must
provide the information in a manner readily
understandable to community members.
2.3.1 Fact Sheet
EPA (in conjunction with others such as State/
Tribal/local governments) may prepare and dis-
tribute a brief fact sheet describing the CAG
prior to the CAG Information Meeting. A sam-
ple CAG fact sheet is included as Appendix A.
In preparing the fact sheet, EPA may consult
with the State/Tribal/local government. EPA
may wish to expand existing networks used in
distributing information about public involve-
ment activities for the distribution of CAG-re-
lated fact sheets and other materials.
Community interviews conducted prior to de-
velopment of the Community Relations Plan
for the site, as well as the plan itself, are poten-
tial sources of information to identify effective
methods for distributing the CAG fact sheet.
4
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Depending on the status of the response ac-
tion, the interviews and plan may not have
been completed for all sites. If this is the case,
EPA staff may conduct limited community inter-
views with local officials and community lead-
ers, making special effort to contact those lead-
ers with ties to the environmental justice and
other site-related concerns of the community.
For example, these sources could include
churches and community organizations in mi-
nority and low-income neighborhoods. This
will ensure that credible information sources
identified by members of the community are
used to supplement and reinforce direct mail-
ing of the fact sheet. In addition, copies of the
fact sheet should be available in the information
repositories and at the CAG Information
Meeting.
The fact sheet is designed to describe the pur-
pose of the CAG and membership opportuni-
ties and delineate the role of CAG members.
If a significant segment of the community is
non-English speaking or visually impaired, EPA
(in conjunction with others such as State/Tribal/
local governments) should translate the fact
sheet for distribution to these members of the
community.
2.3.2 Public Notice
EPA (in conjunction with others such as State/
Tribal/local governments) may prepare a public
notice or display ad to advertise the CAG In-
formation Meeting in general circulation news-
papers serving the affected communities
around the site. To ensure that all segments of
the affected population are notified, notices in
newspapers that serve low-income, minority,
and non-English speaking audiences in the com-
munity also should be considered.
The notice should be published approximately
two weeks in advance of the CAG Information
Meeting and should include the following
information:
• Time and location of the meeting;
• CAG purpose and membership
opportunities;
• The roles and responsibilities of CAG
members;
• A statement that the meeting is open for
public attendance and participation;
• Topics for consideration at the CAG
Information Meeting; and
• Name and phone number of contact
person(s) to obtain more information.
The public notice should appear in a prominent
section of the newspapers, where it is likely to
be read by the majority of community mem-
bers. A sample CAG public notice is included
as Appendix B.
2.3.3 News Release
EPA personnel (in conjunction with others
such as State/Tribal/local governments) may
prepare and distribute to the local media a
news release to explain the purpose of the
CAG and announce the time and location of
the initial information meeting. Depending on
local media coverage of Superfund and other
environmental issues related to the site, it may
be appropriate to prepare a more extensive
media packet of information to update the
local media on public involvement activities and
overall response plans and progress.
2.3.4 Agenda
EPA, in consultation with the State/Tribal/lfl-
ea governments and residents, may develop
an initial agenda for the CAG Information
Meeting. The agenda should reflect important
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community concerns raised in relation to the
Superfund response. Again, the results of
community interviews conducted in the pro-
cess of developing Community Relations Plans
and other community involvement activities
may provide a source of information and back-
ground on community concerns. Demonstrat-
ing an awareness of and sensitivity to concerns
expressed by the community is an important
element in maximizing the potentia benefits of
CAGs.
2.4 CAG Information Meeting
EPA may sponsor the CAG Information Meet-
ing and may consult with the State/Tribal/local
government in its preparation. EPA (in conjunc-
tion with others such as State/Tribal/local gov-
ernments) should attempt to hold the CAG In-
formation Meeting as early as possible in the
cleanup process.
EPA personnel (and/or others such as State/
Tribal/local governments) may facilitate the
CAG Information Meeting; however, for this
and subsequent meetings, it may be preferable
to have someone from the community with fa-
cilitation experience or a professional meeting
facilitator serve as facilitator. A neutral facilita-
tor is particularly effective at sites where some
controversy is anticipated. Facilitation may pro-
duce a better sense of fairness and indepen-
dence, helping to ensure more productive
discussions.
The Information Meeting should serve to intro-
duce the CAG concept to the community. The
following topics may be appropriate to discuss
at the meeting:
• Purpose and overview of the CAG;
• Goal of representing diverse community
interests;
• Interface between the CAG and other
community involvement activities;
• Membership opportunities;
• Suggested member selection process and
timetable;
• Examples of a CAG Mission Statement and
operating procedures (including community
leadership);
• Suggested member responsibilities;
• Overview of site cleanup plans and progress;
and
• Open discussion/question and answer period.
The Information Meeting and subsequent CAG
meetings should be held in a centra location
and at a convenient time for community mem-
bers. In addition, EPA (and/or others such as
State/Tribal/local governments) should consider
requirements of the Americans with Disabilities
Act (ADA) and the Rehabilitation Act of 1994
in choosing a location (for example, accessibility
by wheelchairs and availability of signers and
readers, as necessary, to assist hearing and visu-
ally impaired participants).
Resources permitting, EPA (and/or others such
as the State/Tribal/local governments) may pro-
vide appropriate administrative and logistical
support for arranging the meeting and docu-
menting its proceedings. Preparation of a con-
cise and easy-to-read summary of the meeting
also should be considered. Such a summary will
help facilitate effective communication with lo-
cal community members. The summary should
be translated for interested members of the
community who are non-English speaking or
visually impaired. The summary should be
made available for public review in the infor-
mation repositories and through other dis-
semination methods no later than one month
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after the Information Meeting. Copies of the
summary also may be mailed to all communi-
ty members who attend the initial meeting
and to those who are on mailing lists used
for other community involvement activities
related to the site.
3. CAG Startup
The time period between the CAG Informa-
tion Meeting and the implementation of a fully
functional CAG may vary from site to site. EPA
should encourage CAGs to be in full operation
within six months after the information meet-
ing, in order to maximize their effectiveness in
the Superfund cleanup decision-making pro-
cess. There are several key activities that
should be completed during this time period to
ensure successful CAG operation. These activ-
ities are described in the following sections.
4. CAG Membership
> Size of the CAG
> Membership Composition
> Roles and Responsibilities of CAG
Members
> Membership Solicitation
> Membership Selection Models
4.1 Size of the CAG
The number of members in the CAG may vary
from site to site depending on the composition
and needs of the affected community. The
CAG should determine the size of its member-
ship; when doing so, the CAG should consider
the following factors:
• Diversity of the community;
• CAG workload; and
• Effective group discussion and decision-
making (i.e., pros/cons of larger vs. smaller
groups).
Federal Facility Environmenta Restoration Ad-
visory Boards, groups similar to CAGs, general-
ly average around 20 members. While it often
is difficult to ensure that everyone has an op-
portunity to participate and to achieve closure
on discussions in larger groups, the CAG
should be large enough to adequately reflect
the diversity of community interests regarding
site cleanup and reuse.
4.2 Membership Composition
To the extent possible, membership in the
CAG should reflect the composition of the
community near the site and the diversity of lo-
ca interests, including the racial, ethnic, and
economic diversity present in the community—
the CAG should be as inclusive as possible. At
least half of the members of the CAG should
be local community members (sometimes
referred to as "near neighbors").
CAG membership should be drawn from the
following groups:
• Residents or owners of residential property
near the site and those who may be affected
directly by site re eases;
• Those who potentially may be affected by
releases from the site, even if they do not live
or own property near the site;
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• Local medical professionals practicing in the
community;
• Native American tribes and communities;
• Representatives of minority and low-income
groups;
• Citizens, environmental, or public interest
group members living in the community;
• TAG recipients, if a TAG has been awarded at
the site;
• Local government, including pertinent city or
county governments, and governmental units
that regulate land use in the vicinity of the site;
• Representatives of the local labor community;
• Faci ity owners and other significant PRPs;
• The local business community; and
• Other local, interested individuals.
Clearly, persons with an obvious conflict of in-
terest at the site should not be members of the
CAG, e.g., remedy vendors, lawyers involved in
pending site litigation, non-local representatives
of national groups, and others without a direct,
personal interest in the site.
In order to prevent the PRP (or another inter-
est group) from dominating CAG discussions,
the community shall have the authority to limit
the number of these representatives or desig-
nate them as ex-officio members.
4.3 Roles and Responsibilities of CAG
Members
Generally, CAG members will be expected to
participate in CAG meetings, provide data and
information to EPA on site issues, and share
information with their fellow community mem-
bers. EPA (along with State/Tribal/local govern-
ments, as appropriate) should help the CAG
clearly define and maintain these roles and re-
sponsibilities (see Section 10.2, under "Roles
and Responsibilities").
4.4 Membership Solicitation
For the CAG concept to be successful, the mem-
bership of each CAG should reflect the diverse in-
terests of the community in which the Superfund
site is located. It is also important that each
community have the lead role in determining
the membership appropriate for its CAG. This
will help encourage participation in and support
for the CAG. EPA should not select or ap-
prove/disapprove individual CAG members but
must certify that the CAG is representative of
the diverse interests of the community.
EPA, in coordination with the State/Tribal/lo-
cal governments, should inform the commu-
nity about the purposes of the CAG and
opportunities for membership and participa-
tion. This public outreach effort needs to be
tailored to the individual community in which
the CAG is to be formed. This is especially im-
portant at sites which are in the early stages
of the Superfund cleanup process, sites at
which opportunities for community participa-
tion have been limited, and/or sites where
there has been relatively little community or
media interest.
EPA (in coordination with others such as the
State/Tribal/local governments) should make
every effort to ensure that all individuals and
groups representing community interests are
informed about the CAG and the potential for
membership so that each has the opportunity
to participate in the CAG. For example, EPA
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may begin the public outreach effort regarding
CAG membership before the CAG Informa-
tion Meeting by distributing the CAG fact
sheet and publishing public notices and news
releases.
Depending on the results of community-wide
efforts to solicit nominations for CAG mem-
bership, it may be necessary to refine and fur-
ther focus efforts for specific groups. These ef-
forts may be reinforced with a letter to individ-
uas and groups representing diverse communi-
ty interests. A sample letter regarding CAG
membership is included as Appendix C. CAG
information also can be mailed to those ex-
pressing interest generally in the site and/or
specifically in the CAG. CAG information a so
should be made available through the local in-
formation repositories. The information also
may be reformatted and posted in other visible
locations such as information kiosks and com-
munity centers.
If there is not enough community interest to
form a CAG after all solicitation efforts have
been exhausted, EPA (in conjunction with
others such as State/Tribal/local governments)
may issue a public notice through all available
outlets to announce that efforts to form a
CAG have been unsuccessful. A sample of
such a public notice is included as Appendix D.
4.5 Membership Selection Models
The selection of CAG members should be ac-
complished in a fair and open manner in order
to maintain the level of trust needed for suc-
cessful CAG operation. The members of the
CAG should reflect the composition of the
community and represent the diversity of local
interests. In designing the method for develop-
ing a CAG that is most appropriate for the
affected community, it may be useful for EPA
(in conjunction with others such as State/Tribal/
local governments) to offer some type of
facilitation.
The following Membership Selection models
are examples that may be used and adapted to
best meet the particular needs of a community.
Of course, each community is unique and no
one model will work in all instances; in fact, it
may be appropriate to develop an entirely dif-
ferent model for selecting CAG members.
Similarly, formal membership selection models,
such as those described in this section, may not
always be necessary. For example, selecting a
group may be as simple as widely advertising
the opportunity to join the CAG and then rec-
ognizing the CAG as consisting of the respon-
dents. The key is that the CAG represent the
interests of the community and that the CAG
be able to function as a group. The exact se-
lection process is secondary, as long as the pro-
cess is fair and open.
4.5.1 Screening Panel Model
Under this model, EPA, consulting with and in-
volving the State/Tribal/local government,
could assist the community in organizing a
short-term Screening Panel to review nomina-
tions for membership on the CAG prior to final
member selection. After the opportunity to
form a CAG has been announced, the local
community should identify (using a fair and
open manner) CAG members who represent
the diverse interests of the community. The
panel should, to the extent practical, reflect the
diversity of interests in the community since the
panel would be expected to choose CAG
members who are equally representative. The
panel may select a chairperson from among its
members.
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The Screening panel should consider establish-
ing and publicizing the following:
• Procedures for nominating members for the
CAG, including the way members of the
community can nominate themselves to be
CAG members (panel members also may
nominate themselves to be CAG members.);
• The process for screening nominations and
making recommendations for membership;
• The criteria to be used in screening
nominations and determining membership
recommendations; and
• A ist of any recommended nominees for
membership on the CAG.
The Screening Panel Chairperson may forward
the panel's recommended list of nominees to
the appropriate EPA Regional Administrator for
review and comment (not for approval/disap-
proval of individuals) with regard to its ability to
represent the interests of the community.
4.5.2 Existing Group Model
Under this model, an existing group in the
community—such as a group with a history of
involvement at the Superfund site—may be se-
lected as the CAG for that community, if, in
fact, it does represent the diverse interests in
the community. If the group does not appear
representative of the community, EPA may ask
the group to expand its membership to include
any community interests not represented.
4.5.3 Core Group Model
Under this model, EPA, consulting with and in-
volving the State/Tribal/local governments,
could select a Core Group that represents the
diverse interests of the community. EPA (in
conjunction with others such as State/Tribal/lo-
cal governments) may remind the community
that a person may nominate himself or herself
through the application process. For example,
members of the Core Group could include
seven members representing the following in-
terests: two local residents, local government,
environmental, civic, labor, and business. The
members of this Core Group then would se-
lect the remaining members of the CAG in a
fair and open manner.
4.5.4 Self-Selecting Group Model
Under this model, after EPA (in conjunction
with others such as State/Tribal/local govern-
ments) announces the opportunity to form a
CAG, the local community identifies (in a fair
and open manner) CAG members who they
believe represent the diverse interests of their
community. Realistically, it may take some
communities a significant amount of time to ful-
ly select the CAG members.
4.5.5 Local Government Group Model
Under this model, the local government would
select, in a fair and open manner, members of
the community to serve on the CAG. This
model may be appropriate at sites where a
positive working relationship and established
communication channels exist between the
local government and the community.
5. CAG Member Training
Many of those selected as members of the
CAG may require some initial training to en-
able them to perform their duties. EPA may
work with the State/Tribal agencies, the local
government(s), local universities, the PRP(s),
and others, to provide training and prepare
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briefing materials for CAG members. EPA also
may work with these organizations and appro-
priate local groups to develop a method for
quickly informing and educating new CAG
members about cleanup issues, plans, and
progress. Every effort should be made to tailor
the training to the specific needs of the CAG
members. For example, some CAG members
may require more extensive training than oth-
ers; similarly, some may need training materials
in alternative formats, such as in a language oth-
er than English. It is extremely important for
the success of the CAG process that all mem-
bers have an adequate opportunity to under-
stand the Superfund process and the cleanup
issues related to their respective sites. It also is
important that the CAG function as a group,
meaning some CAGs may need training on
how to function effectively as a group.
Training may be accomplished at regular CAG
meetings and/or through activities such as the
following:
• Formal training sessions;
• Briefing books, fact sheets, and maps; and
• Site tours.
Every effort should be made to provide CAG
members with appropriate and necessary train-
ing, subject to available resources.
Technica staff from local, State/Tribal, and Fed-
era agencies involved in site cleanup may at-
tend CAG meetings. They may serve as tech-
nical resources and provide information about
their respective areas of expertise to CAG
members.
6. Administrative Support for
the CAG
EPA, together with State/Tribal governments,
the local government(s), local universities, the
PRP(s), and others may assist the CAG with
administrative support on issues relevant to the
Superfund site cleanup and decision-making
process.
Resources permitting, EPA also may expand ex-
isting site contractor support work assignments,
for example, to provide administrative support
and translate documents with EPA staff
oversight.
Administrative support for the CAG may in-
clude the following:
• Arranging for meeting space in a central
location;
• Preparing and distributing meeting notices
and agenda;
• Taking notes during meetings and preparing
meeting summaries;
• Duplicating site-related documents for CAG
review;
• Duplicating and distributing CAG review
comments, fact sheets, and other materia s;
• Providing mailing services and postage;
• Preparing and placing public notices in local
newspapers;
• Maintaining CAG mailing lists;
• Translating or interpreting outreach materials
and CAG meetings in cases where there is a
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significant non-Engish speaking portion of the
community; and
• Faci itating CAG meetings and special-focus
sessions, if requested by the CAG.
After CAG members have been selected, EPA,
in coordination with the State/Tribal agencies
and the local government, may assist the CAG
in developing a news release or fact sheet an-
nouncing the startup of the CAG and providing
the names of CAG members. The news re-
lease or fact sheet also can be used as a vehicle
for publicly thanking all members of the com-
munity who expressed an interest in CAG par-
ticipation, encouraging their continued involve-
ment through attendance at CAG meetings,
and announcing the first CAG meeting.
7. CAG Operations
> Chairperson
> Mission Statement and Operating
Procedures
> Meetings
7.1 Chairperson
CAG members may select a Chairperson from
within their ranks and determine an appropri-
ate term of office. It may be useful to advise
that the Chairperson be committed to the
CAG and willing to serve for an extended
period of time (e.g., two years) to ensure conti-
nuity. Members have the right and responsibility
to replace the Chairperson as they believe nec-
essary. The processes for selecting and dismiss-
ing a Chairperson should be detailed in the
CAG's operating procedures.
7.2 Mission Statement and Operating
Procedures
Each CAG should develop a Mission Statement
describing the CAG's specific purpose, scope,
goals, and objectives. The mission statement
and subsequent CAG activities should focus
on actions related to Superfund site issues con-
sistent with the purpose of a CAG.
Each CAG should develop its own letterhead.
Each CAG also should develop a set of proce-
dures to guide day-to-day operations. Topics
to be addressed in these operating procedures
include the following:
• How to fill membership vacancies;
• How often to hold meetings;
• The process for reviewing and commenting
on documents and other materias;
• How to notify the community of CAG
meetings;
• How the public can participate in and pose
questions during CAG meetings; and
• How to determine when the CAG has
fulfilled its role and how it will disband.
7.3 Meetings
All CAG meetings should be open to the
public. The meetings should be announced
publicly (via display ads in newspapers, flyers,
etc.) well enough in advance (e.g., two weeks)
to encourage maximum participation of CAG
and community members.
EPA personnel (and/or others such as State/
Tribal/local governments) may facilitate CAG
meetings, however, it may be preferable to use
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someone from the community with facilitation
experience or a professiona meeting faci itator.
A neutral facilitator is particularly effective at
sites where some controversy is anticipated. Fa-
cilitation may produce a better sense of fairness
and independence, helping to ensure more
productive discussions. If a facilitator is regular-
ly used during CAG meetings, it may be helpful
to further clarify both the Chairperson's and fa-
cilitator's roles to avoid direct conflict between
the facilitator and Chairperson.
The intent of the CAG is to ensure ongoing
community involvement in Superfund response
actions. As such, regular attendance at CAG
meetings by all CAG members should be antic-
ipated. Even though they are not CAG mem-
bers, the EPA Site Manager and the CIC may
attend meetings and encourage representatives
of other pertinent Federal agencies and State/
Tribal/local governments to attend meetings as
well. Governmental attendees should not be so
numerous, however, as to inhibit meeting dis-
cussions. Consistent attendance, however, can
demonstrate commitment to meaningful public
participation in the cleanup process.
7.3.1 Meeting Frequency
CAG meetings should be scheduled on a regu-
lar basis. CAG members should determine the
frequency of CAG meetings based on the
needs at their particular site. Meetings should
be held often enough to allow the CAG to re-
spond to site issues within specified timeframes
and allow for timely communication of CAG
actions and site activities to the rest of the
community. Frequency of meetings should be
covered in the CAG's operating procedures.
7.3.2 Location
The CAG meetings should be held in a location
agreed upon by CAG members. It is useful to
consider a location convenient to CAG mem-
bers, as well as central enough to encourage at-
tendance by other interested members of the
community. Meeting spaces such as local librar-
ies, high schools, and senior centers may be ac-
ceptable locations. The location should meet
requirements of the Americans with Disabilities
Act and the Rehabilitation Act of 1994 (for ex-
ample, accessibility for those in wheelchairs).
7.3.3 Meeting Format
The format for CAG meetings may vary de-
pending on the needs of the CAG. A basic
meeting format might include:
• Review of "old" business;
• Status update by the project technical staff
and CAG member discussion;
• Discussion and question/answer session
involving members of the public in
attendance;
• Summary and discussion of "action items" for
the CAG; and
• Discussion of the next meeting's agenda.
Prior to announcing each meeting, CAG mem-
bers may wish to agree upon the meeting's
purpose, agenda, and format. If necessary, ar-
rangements should be made to provide a trans-
lator or interpreter and/or facilitator. EPA (in
conjunction with others such as State/Tribal/
local governments) may assist the CAG in mak-
ing appropriate arrangements.
7.3.4 Special-Focus Sessions
The CAG also may consider holding special-fo-
cus sessions from time to time. These meetings
would focus on a single topic and provide an
opportunity for the CAG to solicit input, dis-
cuss, or gather information on a specific issue
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requiring attention. If an expert cannot attend
a special-focus session—travel and attendance
in person may not always be possible—it may
be useful for the CAG to schedule a confer-
ence call with that expert to discuss a particular
issue. EPA (in conjunction with others such as
State/Tribal/local governments) may provide
support for special-focus sessions on issues rel-
evant to the Superfund site cleanup and deci-
sion-making process.
7.3.5 Meeting Documentation
The CAG should prepare a concise summary
of each meeting, highlighting the topics dis-
cussed, agreements reached, and action items
identified. EPA and others such as the State/
Tribal/local governments may provide support
for this effort. The CAG may want to consider
preparing a summary, rather than a verbatim
transcript, to facilitate effective communication
with local communities. If a significant segment
of the affected population is non-English-speak-
ing or visually impaired, they also should trans-
late the summary, as appropriate, for these
members of the community.
The meeting summary should be available for
public review in the information repositories
and through other dissemination methods
within one month of the meeting. Copies of
the summary a so may be mailed to all
community members who attended the meet-
ing and to those who are on the CAG mailing
list. If the CAG mailing list is larger than EPA's
site mailing list, EPA may expand its mailing list
to include interested community members
from the CAG list.
8. CAG Response to Requests
for Comments
EPA (in conjunction with others such as State/
Tribal/local governments) should ma
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should choose, on a case-by-case basis, the
most appropriate mechanism to ensure that
comments are provided within specified time-
frames. One option available for the CAG to
gather input from its constituents is by holding
a special-focus meeting. To assist in the process,
EPA (in conjunction with others such as State/
Tribal/local governments) should prepare exec-
utive summaries in plain language describing the
document and its key points.
9. EPA Response to Comments
from the CAG
Since EPA representatives may attend CAG
meetings regularly, EPA may have the opportu-
nity to respond to many CAG comments on
key documents and other issues in the context
of meeting discussions. These responses
should be documented as part of the inter-
change during the CAG meeting and, unless
otherwise stated, should not be considered
part of the formal Agency "Response to Com-
ments" (as required under Sections I 13 and
I 17 of CERCLA and 40 CFR 300 of the Na-
tional Contingency Plan). EPA should recognize
the nature of the comments (whether state-
ments of individual preferences or statements
supported by all CAG members), and give the
comments corresponding weight for consider-
ation. In cases where there are numerous
comments to address in a meeting context,
EPA may respond to them in writing.
10. Roles and Responsibilities
> CAG Chairperson
> CAG Members
> EPA (as Lead Agency)
> State/Tribal Regulatory Agency
> CAG - TAG Interface
EPA is committed to early, direct, and meaning-
ful public involvement. Through CAGs, com-
munity members have a direct line of commu-
nication with EPA (as well as with the State/
Tribal/local governments, depending on their
level of involvement) and many opportunities
for expressing their opinions. As a representa-
tive public forum, CAG members are able to
voice their views on cleanup issues and play an
important role in cleanup decisions. This is es-
pecially important before key points in the
cleanup process. For example, CAG members
may express preferences for the type of reme-
dy, cleanup levels, future land use, and interac-
tion with the regulatory agencies. Since the
CAG, by definition, is intended to be represen-
tative of the affected community, the regulatory
agencies will give substantial weight to the pref-
erences expressed by CAG members. This is
particularly important if the preferences reflect
the position of most CAG members or repre-
sent a consensus from the CAG. EPA must not
only listen to views expressed by CAG mem-
bers but address their views when making site
decisions.
EPA, the State/Tribal/local governments, the
CAG Chairperson, and CAG members each
have an important role to play in the develop-
ment and operation of the CAG and in con-
tributing to its effectiveness as a forum for
meaningful public participation in Superfund re-
sponse actions.
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The following 1st, while not comprehensive, in-
cludes some of the key functions of each
player.
10.1 CAG Chairperson
I. Prepare and distribute an agenda prior to
each CAG meeting.
2. Ensure that CAG meetings are conducted in
a manner that encourages open and
constructive participation by all members
and invites participation by other interested
parties in the community.
3. Ensure that all pertinent community issues
and concerns related to the Superfund site
response are raised for consideration and
discussion.
4. Attempt, whenever possible, to reach
consensus among CAG members by
providing official comments or stating
positions on relevant issues and key
documents.
5. Facilitate dissemination of information on
key issues to the community.
10.2 CAG Members
Serve as a direct and re iable conduit for
information flow to and from the
community. CAG members have a
responsibility to share information with
other members of the affected
community—the people they represent.
Their names should be publicized widely
within the local community to ensure that
community members and interest groups
have ready access to CAG members. If
CAG members do not wish to have their
phone numbers isted publicly, an alternative
contact system should be explored to
ensure that the community has access to
CAG members.
2. Represent not only their own personal
views, but a so the views of other
community members while serving on the
CAG. CAG members should honestly and
fairly present information they receive from
members of the community; tentative
conclusions should be identified properly as
such.
3. Review information concerning site cleanup
plans, including technical documents,
proposed and final plans, status reports, and
consultants' reports and provide comments
and other input at CAG meetings and other
specia-focus meetings.
4. Play an important role at key points in the
cleanup decision-making process by
expressing individual community preferences
on site issues.
5. Attempt, whenever possible, to achieve
consensus with their fellow members before
providing officia comments or stating
positions on relevant issues and key
documents.
6. Assist the Chairperson in disseminating
information on key issues to the community.
7. Attend all CAG meetings.
8. Be committed to the CAG and willing to
serve for an extended period of time (e.g.,
two years). Terms may be staggered for
continuity.
9. Serve voluntarily and without compensation.
10.3 EPA (as Lead Agency)
Provide information on the opportunity to
form the CAG.
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2. Attend CAG meetings to provide
information and technical expertise on
Superfund site cleanup.
3. Facilitate discussion of issues and concerns
relative to Superfund actions.
4. Listen and respond to views expressed by
CAG members, giving them substantial
consideration when making site decisions,
especially when views are those of most or
all CAG members.
5. Work with others, as appropriate, to
support and participate in training to be
provided to CAG members.
6. Assist the CAG with administrative and
logistical support and meeting facilities.
10.4 State/Tribal Regulatory Agency
I. Attend all CAG meetings.
2. Serve as an information referral and
resource bank for the CAG on State- or
Tribal-related issues.
3. Support training to be provided to CAG
members.
4. If the lead agency, assume responsibilities
under Section 10.3.
10.5 CAG - TAG Interface
representative of the TAG group to be a
member of the CAG. The Regions also should
encourage the TAG and CAG to work togeth-
er toward common goals with respect to site
remediation.
If no TAG currently exists for this site, commu-
nity members are still eligible and are encour-
aged to apply for a TAG. Having a CAG at a site
in no way precludes an eligible group at that
same site from receiving a TAG.
TAG recipients can use their TAG funds to hire
their own independent Technical Advisor to
help them better understand and more effec-
tively participate in the decision-making process
at Superfund sites.
If a TAG has been awarded to a community
group for work at this particular site (with
the CAG), the Region should encourage a
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Points to Keep in Mind Regarding Community Advisory Groups
• Consult with and involve appropriate State and Tribal Governments.
• Consult with and involve appropriate local governments.
• Involve communities EARLY in the Superfund process.
• Maintain open communication channels.
• Share information.
• Be sincere.
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11. Appendices
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APPENDIX A: Fact Sheet
COMMUNITY ADVISORY GROUP (CAG)
(Name and Location of Site)
The U.S. Environmental Protection Agency (EPA) believes it may be useful for the com-
munity (communities) of (name of community or communities affected) to establish a Community
Advisory Group (CAG) to ensure that all segments of the community have an opportunity to partici-
pate in the decision-making process at (name of the site).
The Superfund program under the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA) covers the cleanup of sites involving the improper disposal of hazard-
ous substances throughout the country. Community involvement is an important element of the Su-
perfund process, and EPA encourages it. EPA's comprehensive Community Involvement Program
for (name of the site) began in (date). (Provide a brief description of accomplishments of the Com-
munity Involvement Program at this site, if possible.)
EPA, in cooperation with (name of the State/Tribal Regulatory Agency and any other parties to the
cleanup agreement)., has begun work to cleanup (name of the site).
(Provide a brief description of the site and the cleanup-related activities to date.)
A Community Advisory Group (CAG) provides a setting in which representatives of the
local community can get up-to-date information about the status of cleanup activities, as well as dis-
cuss community views and concerns about the cleanup process with EPA, the State/Tribal regulato-
ry agency, and other parties involved in cleanup of the Superfund site. The CAG is a public forum
in which all affected and interested parties in a community can have a voice and actively par-
ticipate in the Superfund process.
Getting Involved. CAGs are made up of members of the community. CAG membership is
voluntary and members should be willing to serve two-year terms. CAG members will meet regu-
larly and review and comment on technical documents and plans related to the environmental stud-
ies and cleanup activities at (name of site). Members will help EPA and the community exchange
information about site activities and community concerns. CAG members will meet with individu-
als and groups in the community to obtain their views and hear their concerns related to site clean-
up. All CAG meetings will be open to the public. CAG members will be chosen from among
nominations submitted by individuals and groups in the community. (May provide more details
about the specific membership selection model here.) The deadline for membership application
is (date).
For More Information Contact: (local contact name, address, and telephone number).
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APPENDIX B: Public Notice #1
(Name and Location of Site)
Formation of Community Advisory Group
The U.S. Environmental Protection Agency (EPA) believes it may be useful for the com-
munity (communities) of (name of community or communities affected) to establish a Community
Advisory Group (CAG) to ensure that all segments of the community have an opportunity to partici-
pate in the decision-making process at (name of the site).
The Superfund program involves cleaning up hazardous waste sites throughout the country.
EPA encourages community involvement and considers it to be an important element of the Super-
fund process.
The CAG will provide a setting in which representatives of the local community can get up-to-date
information about the status of cleanup activities, as well as discuss community views and concerns
about the cleanup process with EPA, the State regulatory agency, and other parties involved in clean-
up of the site The CAG will be a public forum in which all affected and interested parties in a
community can have a voice and actively participate in the Superfund process.
EPA will sponsor a meeting on (date) at (time) to discuss the purpose of the CAG, provide
information on how CAG members should be chosen, and answer questions concerning cleanup
plans and activities at the site. (Provide a brief description of specific site-related issues to be dis-
cussed.) The meeting will be held at (meeting location address).
The CAG will be made up of members of the community. CAG membership is volun-
tary and members serve without compensation. Members should be willing to serve two-year terms.
The CAG will meet regularly to review and comment on technical documents and plans related to
the environmental studies and cleanup activities at (name of site) and to relay community views and
concerns related to the site. All CAG meetings will be open to the public, and all members of the
community are encouraged to participate.
For more information about the CAG, contact: (local contact name, address, and tele-
phone number).
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APPENDIX C: Sample CAG Letter
Dear (name of Community Member/Organization):
The community (communities) of (name of community or communities affected) is establishing a
Community Advisory Group (CAG) to ensure that all segments of the community have an opportu-
nity to participate in the decision-making process at (name of the site).
The Superfund program involves cleaning up hazardous waste sites throughout the country. EPA
encourages community involvement—an important element of the Superfund process.
The CAG will provide a setting in which representatives of the local community can get up-to-
date information about the status of cleanup activities, as well as discuss community views and con-
cerns about the cleanup process with EPA, the State/Tribal regulatory agency, and other parties in-
volved in cleanup of the site.
The CAG will be made up of members of the community, and members should reflect the di-
verse interests in the community. CAG membership is voluntary and members serve without com-
pensation. Members should be willing to serve two-year terms. The CAG will meet regularly to re-
view and comment on technical documents and plans related to the environmental studies and clean-
up activities at (name of site) and to relay information between EPA and the community about the
ongoing activities at the site. They will be expected to meet often with individuals and groups in the
community to obtain their views and hear their concerns related to site cleanup issues.
CAG membership offers an outstanding opportunity to represent the community and help ensure
the most effective remediation of the (name of site).
If you have any questions about CAGs, please call at .
Sincerely,
(name of EPA Regional CIC
and, if possible, a local community leader)
Enclosure
25
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APPENDIX D: Public Notice #2
(Name and Location of Site)
Insufficient Community Interest for
Community Advisory Board (CAG)
The U.S. Environmental Protection Agency (EPA) believed it would be useful for the
community (or communities) of (name of community or communities affected) to establish a Com-
munity Advisory Group (CAG) to ensure that all segments of the community have an opportunity to
participate in the decision-making process at (name of the site).
The CAG would provide a setting in which representatives of the local community could get up-to-
date information about the status of cleanup activities, as well as discuss community views and con-
cerns about the cleanup process with EPA, the State/Tribal regulatory agency, and other parties in-
volved in cleanup of the site. The CAG would be a public forum in which all affected and inter-
ested parties in a community would have a voice and could participate actively in the Super-
fund process.
Efforts to encourage members of the community to serve as CAG members began on (date). These
efforts included direct communication with individuals and organizations in the community (be spe-
cific in terms of the outreach effort) as well as a public meeting in which the purpose of the CAG
and the roles and responsibilities of CAG members were discussed.
Despite these efforts, members of the community have not expressed enough interest so far to ensure
full participation by all segments of the community. Since these efforts to stimulate interest in a
CAG in (name of community), have not been successful, EPA will not continue to encourage a CAG
to form at (name of site). If in the future, community members express an interest in forming a
CAG, EPA may reconsider this decision.
If You Have Any Questions Contact: (local contact name, address, and telephone number).
27
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APPENDIX E: List of Community Involvement Managers Nationwide
Region I CT. ME. MA. NH. Rl. VT
US EPA - Region I (RPS-74)
John F Kennedy Federal Bldg.
Boston, MA 02203-0001
I -888 EPA-REGI (I -888-372-7341 )*
617-565-4592
Region 2 NJ. NY. Puerto Rico. & Virgin Islands
US EPA - Region 2 (26-OEP)
290 Broadway, 26th Floor
New York, NY 10007
212-637-3673
Region 3 DE. DC. MD. PA. VA. VW
US EPA-Region 3 (3 HS43)
I 650 Arch Street
Philadelphia, PA 19103-2029
1-800-553-2509*
215-814-5131
Region 4 AL FL GA. MS. KY. NC. SC. TN
US EPA - Region 4
Waste Management Division
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA 30303
AL, FL, GA, MS: 1-800-435-9234
KY NC, SC, TN: 1-800-435-9233
Region 5 IL IN. Ml. MN. OH. Wl
US EPA - Region 5 (PS 19-J)
Metcalfe Federal Bldg.- 19th floor
77W.Jackson Blvd.
Chicago, IL 60604-3507
I-800-621-8431 *
312-353-2072
Region 6 AR. LA. MN. OK. TX
US EPA - Region 6 (6 SF-P)
Wells Fargo Bank
1445 RossAve., Suite 1200
Dallas, TX 75202-2733
1-800-533-3508*
214-665-8157
Region 7 IA. KS. MO. NE
US EPA - Region 7
726 Minnesota Ave.
Kansas City, KS 66101
I -800-223-0425*
913-551-7003
Region 8 CO. MT. ND. SD. UT. WY
US EPA-Region 8 (8-OC)
Office of Communications
999 18th St., Suite 500
Denver, CO 80202-2466
1-800-227-8917*
303-312-6312
Region 9 AZ. CA. HI. NV & U.S. Territories
US EPA - Region 9 (SFD-3)
Office of Community Relations
75 Hawthorne Street
San Francisco, CA 94105
I -800-231-3075*
Region I OAK. ID. OR. WA
US EPA-Region 10 (ECO-081)
Community Relations & Outreach Unit
1200 6th Ave.
Seattle, WA 98101
I -800-424-4372*
206-553-1272
29
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Headquarters
Community Involvement and Outreach Center
Office of Emergency and Remedial Response
USEPA(5204G)
401 MSt.,SW
Washington DC 20460
Suzanne Wells
703-603-8863
Leslie Leahy
703-603-9929
*800 & 888 numbers only work within the
Region
30
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