PA/540/G-88/002
United States j'j
Environmental Protectlipn
Agency jj
Superfund "
Office of Emergency and
Remedial Response
Washington DC 20460
EPA/540/G-88/002
OSWER Directive 9230 0-3B
June 1988
-------
United States environmental Protection Agency
Washington. DC 20460 "
OSWER Directive Initiation Request
Directive Numoer
9230.0-03B
2. Originator Information
Name of Contact Person
Vanessa Musgrave
Mail Code
VH-548E
Office
OERR
Telepnone Code
(FTS) 202/382-2464
3 Title
Conmunity Relations In Superfund: A Handbook
4 Summary of Directive imciuce brief statement o/ purpose) Program guidance for Regional and State staff In
conducting community relations activities in the Superfund program. Includes both re-
quirements and recommendations for community relations activities for CERCLA and
SARA in the remedial, removal and enforcement programs, SITE demonstrations, listing
and delisting sites. Discusses interagency coordination and administrative issues.
Appendices present sample documents, guidance for conducting activities, a glossary,
5. Keywords Super fund , CERCLA, SARA
Community Relats, Removal, Remed Proposed Plan,
6a. Does This Directive Supersede Previous Directive(s)?
Community Relations in Superfund: A
b. Does It Supplement Previous Directive(s)?
7 Draft Level
A - Signed by AA/DAA
No
Handbook
JJNo
B - Signed by Office Director
references and Key Regional contacts™
Adminis Record, SITE program, NCP
)S Yes What directive (number, title) 9230. 0-3A
Yes What directive (number, title)
C - For Review & Comment
D - In Development
8. Document to be distributed to States by Headquarters?
Yes
X No
System Format Standards.
9. Signature of Lead Office Directives Coordinator
10. Name and Title of Approving Official
J. Winston Porter
Assistant Administrator
, Office of Solid Waste & Emergency Resp
Date
Date
EPA Form 1315-17 (Rev. 5-87) Previous editions are obsolete.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
-------
oEPA
StctM
Environment*!
Agency
Sot'd
*nd
DIRECTIVE NUMBER: 9230.0-03B
TITLE: Conmunity Relatioos inSuperfund: A Handbook
•v
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE:
C FINAL
6/88
6/88
DDRAFT
STATUS:
A- Pending OMB approval
B- Pending AA-OSWER approval
j C- For review &/or comment
] D- In development or circulating
REFERENCE (Othtf dOCUm«ntl): headquarters
DIRECTIVE DIRECTIVE L
-------
EPA/540/G-88/002
OSWER Directive 9230.0-3B
June 1988
Community Relations in Superfund:
A Handbook
Interim Version
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, DC 20460
-------
NOTICE
The information in this document has been funded, wholly or in
part, by the United States Environmental Protection Agency under
Contract No. 68-01-7389 to ICF Incorporated. It has been subject to
the Agency's peer and administrative review and has been approved
for publication as an EPA document.
111
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PREFACE
The U.S. Environmental Protection Agency (EPA) is issuing this handbook
as policy and guidance for community relations in the Superfund program. It
is applicable to all response actions conducted under authority of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), whether conducted by EPA, other Federal agencies, or State
governments. The objective of community relations efforts is to involve the
public in activities and decisions made about Superfund sites where past
activities have led to hazardous release problems. EPA also has developed a
public involvement program for community residents living near facilities that
currently treat, store, or dispose hazardous wastes, and are therefore
regulated under Subtitle C of the Resource Conservation and Recovery Act
(RCRA) of 1976. These two programs -- Superfund community relations and RCRA
public involvement -- share similar objectives in keeping communities informed
about and involved in hazardous waste issues.
The purpose of the handbook is to provide (1) policy requirements for
coordinating community relations activities at Superfund sites and (2)
additional techniques and guidance that can be used to. supplement and enhance
the basic requirements for community relations. As such, the present handbook
is a thorough revision of an interim version issued in September 1983. New
material has been added, and existing material has been rewritten to
incorporate new public participation requirements of SARA, and EPA policies
issued since 1983. The overall aim has been to reflect additional years of
experience in conducting community relations activities at Superfund sites
throughout the nation. While this experience has confirmed the value of the
Superfund community relations program, it also has provided considerable
insight, often based on trial-and-error, about which approaches and activities
are more useful, and which may be less so. This handbook incorporates these
lessons of experience.
The handbook continues to emphasize two-way communication in the planning
and implementation of community relations programs. This approach has
consistently demonstrated the value of incorporating public input into the
decision-making process. The handbook also stresses the importance of
integration of technical, community relations, and legal staff in carrying out
coordinated community relations activities.
In addition, since the September 1983 interim version of this handbook
was issued, community relations efforts have increasingly become standard for
EPA and State agencies responsible for Superfund actions. Regional and State
staff committed to conducting effective community relations efforts are
growing in number, and necessary resources are increasingly available. The
primary emphasis of this revised handbook, therefore, is on practical guidance
for planning and implementing community relations activities, with secondary
emphasis on the rationale for such activities.
IV
-------
It is important to note this edition of the handbook, once again, is an
interim version. New and additionally required public participation
activities specified in SARA are included in this edition, but it does not
include further guidance and policy expected to be promulgated in the revised
National Oil and Hazardous Substances Pollution Contingency Plan (NCP) which
is to be issued in mid-1988. Two chapters of this edition are reserved
pending development of these policies. Also, this handbook is supplemented by
EPA guidance on contract management for community relations, as well as by EPA
policy and guidance on community relations during particular phases of
Superfund response actions. Other guidance will be developed to supplement
this handbook. In particular, guidance will be forthcoming on the technical
assistance program and on community relations during removal actions. EPA
expects this interim edition of the handbook and supplemental guidance to be
in effect until the Agency issues the final version of the handbook soon after
the revised NCP is issued.
Although prepared by EPA, this handbook is intended to be equally useful
to staff in other Federal agencies, as well as to staff in State agencies, who
are responsible for implementing community relations programs during Superfund
responses. The neutral term "agency" is used in this document to refer to
either EPA, another Federal agency, or a State agency with lead responsibility
for Superfund actions.
Community relations is a team effort, involving the collaboration of
technical staff and enforcement staff, as well as staff with special expertise
in community relations or public affairs. Therefore, this handbook is
intended for a broad audience of all those individuals involved in any way in
community relations activities. The term "staff" is used in this handbook as
a neutral term to apply to anyone involved in a community relations program,
not just staff whose sole or principal responsibility is to plan and
administer community relations programs. One point stressed throughout this
handbook is that an effective community relations program requires the
attention and commitment of everyone involved in a Superfund response,
regardless of job title. This requires that technical and enforcement staff
familiarize themselves with community relations requirements and issues of
community concern at a site while community relations staff understand the
technical and legal issues at a site. This guidance can help to coordinate
the contributions of staff throughout an agency and ensure an effective
community relations program.
Chapter 6 is undergoing a revision. The revised chapter will be issued
at a later date.
v
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TABLE OF CONTENTS
Page
NOTICE ii
PREFACE iv
ACKNOWLEDGEMENTS x
CHAPTER 1: INTRODUCTION: COMMUNITY RELATIONS IN SUPERFUND 1-1
1.1 The Program and Its Objectives 1-1
1. 2 Background 1-2
1.3 How to Use this Handbook 1-3
CHAPTER 2: COMMUNITY RELATIONS REQUIREMENTS AND POLICIES 2-1
2.1 Requirements for Removal Actions 2-2
2.2 Requirements for Remedial Responses 2-10
2.3 Requirements for Additions of Sites to the
National Priorities List (NPL) 2-14
2.4 Requirements for Deletion of Sites from the
National Priorities List (NPL) 2-14
2.5 Requirements for the Superfund Innovative
Technology Evaluation (SITE) Program 2-15
CHAPTER 3: CONDUCTING COMMUNITY INTERVIEWS AND DESIGNING
COMMUNITY RELATIONS PROGRAMS FOR REMEDIAL RESPONSES 3-1
3.1 Planning and Conducting Community Interviews 3-1
3.2 Designing Community Relations Programs 3-7
3.3 Community Relations for SITE Demonstration
Proj ects 3-14
CHAPTER 4: CONDUCTING COMMUNITY RELATIONS PROGRAMS DURING
REMEDIAL RESPONSES 4-1
4.1 Community Relations Before Remedial Investigation 4-1
4.2 Community Relations During Remedial Investigation/
Feasibility Study (RI/FS) 4-5
4.3 Community Relations at the Conclusion of Feasibility
Study 4-7
4.4 Community Relations Before and During Remedial Design ... 4-13
4.5 Community Relations During Remedial Action 4-14
4.6 Community Relations During Operation and Maintenance .... 4-15
4.7 Community Relations During the National Priorities
List (NPL) Deletion Process 4-16
4.8 Coping with Unanticipated Developments 4-17
4.9 Summary 4-18
CHAPTER 5: COMMUNITY RELATIONS DURING REMOVAL ACTIONS (Reserved) 5-1
vi
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TABLE OF CONTENTS
(continued)
Page
CHAPTER 6: COMMUNITY RELATIONS REGARDING ADMINISTRATIVE
RECORDS AND ENFORCEMENT ACTIONS (Reserved) 6-1
CHAPTER 7: TECHNICAL ASSISTANCE (Reserved) 7-1
CHAPTER 8: INTERAGENCY COORDINATION 8-1
8.1 Federal, State, and Local Agency Roles in Superfund 8-2
8.2 Federally-Owned Facilities 8-3
8.3 Interagency Coordination at Federal-Lead Sites 8-4
8.4 Interagency Coordination at State-Lead Sites 8-5
8.5 Interagency Coordination at Enforcement Sites 8-5
CHAPTER 9: ADMINISTRATION OF COMMUNITY RELATIONS PROGRAMS 9-1
9.1 The Role of Headquarters and Regional Offices 9-1
9.2 Appropriate Tasks for Contractors 9-1
9.3 Managing Contractor Support 9-2
APPENDIX A: EXAMPLES OF COMMUNITY RELATIONS ACTIVITIES A-l
A. 1 Briefings A-3
A.2 Community Interviews A-5
A. 3 Contact Person A-9
A.4 Door-to-Door Canvassing A-ll
A. 5 Exhibits A-13
A.6 Fact Sheets A-15
A. 7 Formal Public Hearings A-17
A.8 Information Respository A-19
A. 9 News Conferences A-22
A. 10 News Releases A-24
A. 11 Observation Deck A-27
A.12 On-Scene Information Office A-29
A. 13 Open Houses A-31
A. 14 Presentations A-33
A. 15 Public Comment Period •. A-35
A. 16 Public Meetings A-37
A. 17 Public Notices A-40
A.18 Responsiveness Summaries A-42
A.19 Revision of Community Relations Plans A-43
A. 20 Site Tours A-44
A. 21 Small Group Meetings A-46
A.22 Superfund Briefing Book A-49
A. 23 Technical Advisor A-51
A. 24 Telephone Contacts A-52
A.25 Telephone Hotline A-55
A. 26 Telephone Network/Phone Tree A-57
VII
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TABLE OF CONTENTS
(continued)
A.27 Translations A-59
A.28 Using Existing Groups/Publications A-62
A.29 Workshops A-64
APPENDIX B: SUGGESTED FORMAT FOR AND SAMPLE COMMUNITY RELATIONS
PLAN B-l
I. Suggested Format B-l
II. Sample Plan B-4
APPENDIX C: SUGGESTED FORMAT FOR AND SAMPLE RESPONSIVENESS
SUMMARIES C-l
I. Suggested Format C-l
II. Sample Responsiveness Summary C-2
APPENDIX D: GLOSSARY D-l
APPENDIX E: REFERENCES E-l
APPENDIX F: KEY CONTACTS FOR THE SUPERFUND COMMUNITY RELATIONS
PROGRAM F-l
APPENDIX G: PROPOSED COMMUNITY RELATIONS AND ADMINISTRATIVE RECORD
REQUIREMENTS FOR REMOVALS G-l
viii
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ACKNOWLEDGEMENTS
This handbook serves as guidance for conducting community relations
activities in the Superfund program. It incorporates U.S. Environmental
Protection Agency (EPA) policy and guidance on community relations. Certain
details of the handbook may be modified in the future to reflect experience
and future additional guidance with a developing program. The handbook was
prepared for the EPA, Office of Emergency and Remedial Response (OERR) and
Office of Waste Programs Enforcement (OWPE) by IGF Incorporated, under EPA
contract 68-01-7389.
Comments on drafts of this handbook were sought from the following:
o EPA Regional and Headquarters Superfund staff;
o State environmental agencies;
o Other Federal agencies;
o Environmental groups;
o Government associations; and
o Industry representatives.
The Superfund Community Relations staff would like to thank all those who
submitted their comments. Many valuable suggestions for improving and
expanding this handbook were received, and have been incorporated in this
edition.
Questions and comments concerning this handbook should be addressed to:
U.S. Environmental Protection Agency, Office of Emergency and Remedial
Response (WH-548E), 401 M Street, S.W., Washington, D.C. 20460.
IX
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CHAPTER 1
INTRODUCTION: COMMUNITY RELATIONS IN SUPERFUND
The Superfund community relations effort promotes two-way communication
between members of the public, including PRPs, and the lead government agency
responsible for response actions. The community relations activities
discussed in this Handbook provide the opportunity for interested persons to
comment on, and provide input to, decisions about response actions. These
activities ensure that the local public is provided with accurate and timely
information about response plans and progress and that their concerns about
planned actions are heard by the lead agency. A site-specific and
well-planned community relations effort is an integral part of every Superfund
response.
This handbook offers policy and guidance on planning and conducting
Superfund community relations programs. It emphasizes the approaches and
activities that have proven successful in years of experience with community
relations in Superfund. This introductory chapter describes the Superfund
community relations program and its objectives, presents some background on
the program, and explains how the handbook should be used.
1.1 THE PROGRAM AND ITS OBJECTIVES
The Superfund community relations program, as a whole, consists of all
those activities conducted throughout the planning and implementation of
Superfund responses to encourage communication between government staff and
the local public, as well as the planning, coordination, and administration of
such activities.
The overall objectives of Superfund community relations are as follows:
o Give the public the opportunity to comment: on and
provide input to technical decisions. An ongoing
community relations effort should encourage and
assist the local public to contribute to agency
decisions that will have long-term effects on their
community.
This guidance is oriented primarily to a particular segment of the
local public in the vicinity of a Superfund site. It recognizes that members
of the local public other than PRPs and State officials may have different
concerns and interests. The guidance helps EPA and State staff coordinate
with these special groups and individuals. The guidance is not intended to
describe our relationships with other members of the local public; namely PRPs
and State 'officials. However, because this guidance is a comprehensive
statement on EPA's public participation program, it will necessarily include
outreach with PRPs. Finally, the terms: local public, communities, citizens,
and interested parties are interchangeable. They all represent the universe
of affected and interested public, including PRPs.
1-1
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o Inform the public of planned or ongoing actions.
Community relations activities should inform the
local public of the nature of the environmental
problem, the threat it may pose, the responses under
consideration, and the progress being made.
o Focus and resolve conflict. Conflict may be
unavoidable in some circumstances, but it can be
constructive if it brings into the open alternative
viewpoints based upon sound reasons for criticism or
dissent. An effective community relations effort
channels conflict into a forum where it can serve a
useful purpose.
These objectives guide the planning and implementation of community
relations efforts in each Superfund response.
1.2 BACKGROUND
Experience with the Superfund program since 1980 has yielded some general
conclusions about the nature of public involvement in hazardous waste problems
and, in turn, about the most helpful approaches to community relations in
Superfund. These conclusions are the basis for the objectives listed above,
and underlie the specific recommendations in the following chapters of this
handbook.
EPA has found that its decision-making ability is enhanced by actively
soliciting comments and information from the public. Public input can be
useful in two ways:
1. Communities are able to provide valuable information
on local history, citizen involvement, and site
conditions; and
2. Identifying the public's concerns enables EPA to
fashion a response that is more responsive to
community needs.
The people who are the most concerned about a site or release are usually
those who consider themselves to be directly affected, believing their health
to be endangered, or perceiving possible economic loss. Community relations
efforts must focus on these people.
EPA has found that there can be no set formulas for a community relations
program. Each community is different. The issues of importance to the
public, the level of concern, the history of public involvement, and the
social structure of the community will vary from site to site. Community
relations efforts must therefore be tailored to the distinctive needs of each
community as stated by that community. They also must be tied to the
technical response schedule.
Nonetheless, the best way to reach concerned citizens is usually through
1-2
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informal activities initiated early in the response and continued to its
completion. Informal interviews in a living room, face-to-face discussions
with a remedial project manager, or frequent telephone calls are the preferred
means of ensuring open and candid communication. When large public meetings
are needed, they must be very carefully planned to enhance productive
communication.
Finally, there are no guaranteed results, even from the most carefully
planned community relations effort. Keeping the community well-informed and
actively soliciting information and ideas from the community is critical for
the decision-making process. However, this proccess will not guarantee that
the community will be entirely satisfied with the remedial or removal action
selected for the site. Nevertheless, the level of anger and frustration is
almost certain to be higher in a community that has been "shut out" or ignored
than a community that has had a voice in the process. A community relations
program should, therefore, not try to quell controversy, but rather strive to
anticipate, identify, and acknowledge areas of conflict so that decisions can
be made with full understanding of community views.
1.3 HOW TO USE THIS HANDBOOK
This handbook has been organized to be as useful as possible to the staff
responsible for planning Superfund community relations programs and conducting
community relations activities. It contains nine chapters.
Chapter 1: Introduction: Community Relations in Superfund.
Chapter 2: Community Relations Requirements and Policies is a concise
summary of all requirements for community relations in Superfund. Certain
requirements for a community relations program are specified in the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP)(8)^, the
Superfund Amendments and Reauthorization Act of 1986(12), and other EPA
policy. This chapter identifies clearly, at the outset, those required
community relations activities for each response, as distinguished from
supplemental activities that are recommended in EPA guidance and this
handbook.
Chapter 3: Conducting Community Interviews and Designing Community
Relations Programs for Remedial Responses explains in detail the two critical
steps in planning a community relations program for a Superfund remedial
action; that is, a response consistent with permanent remedy at a site listed
on the National Priorities List (NPL):
(1) Conducting the community interviews (or on-site
discussions) used to identify key members of the
affected public, their concerns, and the best means
to involve and communicate with the public; and
Bold face numbers appearing in parentheses refer to the bibliographical
in Appendix E, "References".
entries in Appendix E
1-3
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(2) Developing a site-specific community relations plan
(CRP), based on the needs expressed by the community
during community interviews, that specifies the types
of community relations activities to be conducted in
the remedial action.
Additionally, this chapter describes community relations as it is to be
conducted for the Superfund Innovative Technology Evaluation (SITE)(35)(36)
demonstration program.
Chapter 4: Conducting Community Relations Programs During Remedial
Responses provides guidance for conducting community relations activities
during especially critical points in a remedial response: before NPL listing;
during the remedial investigation and feasibility study; during the remedial
design and action stages; and during operation and maintenance. It also
discusses how to adapt community relations activities to unanticipated
developments.
Chapter 5: Community Relations During Removal Actions is currently
reserved for guidance on conducting community relations activities during
removal actions.
Chapter 6: Community Relations During Enforcement Actions is currently
reserved for guidance on conducting community relations when an enforcement
action is initiated or ongoing at an Enforcement- or PRP-lead site.
Chapter 7: Technical Assistance is currently reserved for guidance on
the use of technical advisors to community groups at Superfund sites.
Chapter 8: Interagency Coordination is an overview of the respective
roles and responsibilities for community relations of the various government
agencies that may be involved in managing a Superfund response: EPA, the
Department of Defense, the Department of Energy, other Federal agencies, and
State agencies.
Chapter 9: Administration of Community Relations Programs focuses on
roles and responsibilities for administering community relations, and, in
particular, the functions that may be handled by contractors.
There are six appendices to this handbook. The first three appendices
relate to specific community relations program elements. Appendix A briefly
discusses a number of activities that may be used in a community relations
program. Appendix B presents a format for community relations plans and a
model plan illustrating that format. Appendix C presents a format for
responsiveness summaries and a model responsiveness summary illustrating that
format.
The final three appendices contain helpful reference and resource
information. Appendix D provides a glossary to key program and technical
terms and acronyms that are commonly used in the Superfund process. Appendix
E lists all bibliographical information for EPA regulatory and policy
documents referred to in the body of the handbook. These documents are listed
alphabetically in the Appendix. Appendix F is a list of Headquarters
1-4
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Superfund Community Relations staff, Regional Superfund Community Relations
Coordinators, and Regional Public Health Advisors from the Centers for Disease
Control.
This handbook need not be read from cover to cover. For an adequate
understanding of all phases of the program, however, it is suggested that this
handbook be read first in its entirety. This handbook is intended to serve as
a convenient and helpful reference to guide those responsible for planning and
implementing community relations programs. The handbook has therefore been
written to enable users to find the guidance they need quickly and
efficiently, and without the need to consult several chapters at once. For
example, a reader interested in a specific community relations technique could
go directly to Appendix A for a full discussion of this technique. Another
reader interested in suggested activities for remedial actions would refer to
Chapter 4. To find guidance for a particular type of action, or any special
situation, the reader is referred first to the Table of Contents.
1-5
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CHAFFER. 2
COMMUNITY RELATIONS REQUIREMENTS AND POLICIES
This chapter summarizes the requirements for community relations at
Superfund sites. Its purpose is to identify clearly, at the outset, those
community relations activities that are required, in Contrast to those that
are recommended, suggested, or otherwise discretionary. These requirements
are applicable to all sites -- EPA and State-lead --at which a Superfund
response is being undertaken.
The requirements discussed in this chapter are set forth in the 1985
National Oil and Hazardous Substances Pollution Contingency Plan (NCP) in the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and in EPA policy
documents referred to in this chapter. These documents are listed
alphabetically in Appendix E. This chapter does not include additional
community relations requirements expected to take effect with the 1988
revision of the NCP and EPA policy which will implement those regulations.
These requirements are presently under development but have not yet been
promulgated. Therefore, they are omitted from this chapter, but, where known,
they are included in other sections of this interim edition of the handbook.
A final edition of the handbook is expected soon after the revised NCP is
issued.
EPA also recognizes that Federal agencies may have their own community
relations programs and guidance. However, SARA §120(a)(2) states that EPA
guidelines, rules, regulations, and criteria are applicable to Federal
agencies, and that Federal agencies may not adopt or utilize any guidelines,
rules, regulations, or criteria which are inconsistent with those established
by the EPA Administrator under CERCLA. This handbook provides Federal
agencies with the guidance to more closely coordinate community relations
efforts in the planning and implementation of their community relations
programs to be consistent with CERCLA, the NCP, and EPA policies. EPA
Regional offices should have close interaction with other Federal agencies to
ensure that guidance is provided on a site-by-site basis.
This chapter first discusses community relations requirements for removal
actions. Section 2.2 then addresses requirements pertaining to the following
activities during a remedial response:
o Community interviews;
o Community relations plan;
o Information repositories and administrative records;
o Proposed plan and RI/FS completion;
o Public comment period and opportunity for public meeting on
proposed plan, administrative order on consent, consent decree;
o Responsiveness summary;
^Proposed plan, as used in the handbook, refers to a proposed remedial
action plan.
2-1
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o Explanation of differences;
o Public notice of selection of remedy;
o Revision of the community relations plan, if necessary, for
remedial design/remedial action (RD/RA); and
o Fact sheet and notification on engineering design.
Sections 2.3 and 2.4 explain requirements and procedures for adding and
deleting sites from the National Priorities List (NPL). Section 2.5 discusses
community relations activities in the SITE program. Exhibit 2-1 is a matrix
summarizing these requirements, their source in statute, regulation, and EPA
policy documents, and their applicability to various phases in a Superfund
response.
It should be emphasized that while this chapter addresses requirenents,
merely fulfilling these requirements will not necessarily result in adequate
community relations efforts. Rather, these requirements are the foundation
for more comprehensive and effective activities described in the following
chapters. The requirements have been kept to a minimum to allow for a
flexible community relations approach that can take into account the needs of
different communities.
2.1 REQUIREMENTS FOR REMOVAL ACTIONS
In defining removal actions, the NCP §300.65(b) stipulates that if a lead
agency determines that "there is a threat to public health, welfare or the
environment ... the lead agency may take any appropriate action to abate,
stabilize, mitigate or eliminate the release or threat of release". Such
actions may last only a few days, or may require longer-term measures.
Removal actions may be taken at sites that have not been ranked on the NPL, as
well as at NPL sites.
The NCP stipulates that the lead agency must designate a spokesperson at
removal sites, who will inform the community of actions taken, respond to
inquiries, and provide information concerning the release.
As soon as it appears that a removal action may last longer than 45 days,
the NCP requires that a community relations plan be prepared. (The proposed
NCP will make this 120 days.) This plan must be based on community interviews
conducted, at a minimum, with community leaders and concerned, affected
citizens. The community relations plan must specify the communications
activities which will be undertaken during the response. In addition, an
information repository should be established for removals that last longer
than 45 days. The community relations plan prepared for the site should be
placed in this repository.
SARA requires several other public participation activities pursuant to
§113 and consistent with §117. §113 requires that an administrative record
file must be established and made available to the public. EPA is also
charged with developing procedures for appropriate participation by the public
in the development of the administrative record. The proposed NCP will
contain suggestions for those procedures which include notifications, comment
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EXHIBIT 2-1
CERCLA COMMUNITY RELATIONS REQUIREMENTS2
Technical Phase:
Site Activity
Requirement(s)
Requirement Source(s)
Agency Spokes-
person
Community
Relations Plan
(CRP)
Administrative
Record
REMOVAL ACTIONS
The lead agency must
designate a spokes-
person to inform the
public about the
release and actions
taken, to respond to
questions, and provide
information.
A CRP, based on
community interviews,
must be prepared
for removals longer
than 45 days.
The Agency must estab-
lish an administrative
record upon which selec-
tion of a response
action shall be based
and make the administra-
tive record available to
the public at or near
the site and at a central
location.
The National Oil and Hazard-
ous Substances Pollution Con-
trol Contingency Plan (NCP)
§300.67(b); Superfund
Community Relations Policy
Memorandum of 1983 (Superfund
Community Relations Policy,
1983)(34).
NCP §300.67(b); Superfund
Community Relations Policy,
1983; Superfund Removal
Procedures, Revision No. 2,
(OSWER) (August 20, 1984).
CERCLA §113(k), CERCLA
Reauthorization Transition
Guidance (October 24, 1986).
rt
Community relations requirements apply to both Fund-financed and
enforcement sites.
2-3
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EXHIBIT 2-1 (continued)
CERCLA COMMONITY RELATIONS REQUIREMENTS
Technical Phase:
Site Activity
Requirement( s )
Requirement Source(s)
REMEDIAL RESPONSES
Prior to Remedial Investigation (RI):
Community
Interviews
Community
Relations Plan
(CRP)
Information
Repository
Administrative
Record
On-site discussions must
be held with local
officials and community
members in order to
assess their concerns and
determine appropriate
community relations
activities.
A complete CRP based on
community interviews must
be developed and approved
before remedial investi-
gation field activities
start.
An information repository
must be established which
includes each item
developed, received,
published, or made
available pursuant to
§117. These items must
be made available for
public inspection and
copying at or near
facility.
The Agency must establish
an administrative record
upon which the Agency
shall base the selection
of a response action.
The Agency must provide
for participation of
interested persons in
the development of the
administrative record.
Superfund Community
Relations Policy, 1983,
NCP §300.67(c); Superfund
Community Relations Policy,
1983.
SARA §117(d)
SARA §113(k)
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EXHIBIT 2-1 (continued)
CERCIA COMMUNITY RELATIONS REQUIREMENTS
Technical Phase:
Site Activity
Requirement ( s )
Requirement Source(s)
Feasibility Study (FS)/
Proposed Plan:
Notice and Anal-
ysis of the RI/FS
and Proposed Plan
Public Comment
Period on RI/FS
and Proposed
Plan
Public Comment
Period on Consent
Decrees
An RI/FS and proposed
plan must be developed.
Notice of the availabil-
ity of the RI/FS and pro-
posed plan, including a
brief summary of the pro-
posed plan, must be pub-
lished in a major local
newspaper of general circu-
lation. The notice must
also announce the public
comment period.
The RI/FS and proposed
plan must be provided to
the public for review
and comment for a period
of not fewer than 21
calendar days. Both
oral and written
comments must be
considered.
For enforcement sites:
Proposed cleanup agree-
ment consent decrees must
be filed with the court at
least 30 days before a final
judgment is entered into.
A 30-day comment period
must be provided to persons
not named as parties to the
action to comment on the
proposed judgment before
its entry by the court as
a final judgment. Written
comments, views, or allegations
relating to the proposed
judgment shall be considered
and filed with the court.
SARA §117(a) and (d)
SARA §117(a)(2); NCP
§300.67(d); Superfund
Community Relations Policy,
1983.
SARA §122(d) and (i); NCP
§300.67(g); 28 CFR 50.7.
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EXHIBIT 2-1 (continued)
CERCIA COMMUNITY RELATIONS REQUIREMENTS
Technical Phase:
Site Activity
Requirement(s)
Requirement Source(s)
Opportunity for
Public Meeting
Pre-ROD Signifi-
cant Changes
Responsiveness
Summary
Before adoption of
any remedial action
plan, an opportunity for
a public meeting at or
near the facility at
issue must be provided.
A meeting transcript
must be prepared and
made available to the
public.
The final remedial action SARA §117(b).
plan or ROD shall be accom-
panied by a discussion of
any significant changes
(and the reasons for such
changes) in the proposed
plan and a response to
each of the significant
comments, criticisms, and
new data submitted in
written or oral presenta-
tions . Refer to the Guidance
on Preparing Superfund
Decision Documents: The
Proposed Plan and Record
of Decision for further
information.
SARA §113 and §117(a)(2);
NCP §300.67(d); Superfund
Community Relations Policy,
1983.
A response to each of the
significant comments,
criticisms, and new data
submitted on the proposed
plan and RI/FS must be
prepared and must accom-
pany the ROD.
SARA §113 and §117(b); NCP
§300.67(e); Superfund
Community Relations
Policy, 1983.
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EXHIBIT 2-1 (continued)
CERCLA COMMUNITY RELATIONS REQUIREMENTS
Technical Phase:
Site Activity
Requirement ( s )
Requirement Source(s)
Public Notice
After Selection
of Alternative
Notice and Comment
Period on Settle-
ment Actions
After ROD Is Signed:
Revision of
the CRP
The final remedial ac-
tion plan or ROD must be
made available to the
public and a notice which
states the basis and pur-
pose of the selected
action must be published
after the Agency selects
a remedy and before
commencement of any
remedial action. At a
minimum, the notice
must be published in a
major local newspaper
of general circula-
tion.
A notice of the proposed
settlement must be pub-
blished in the Federal
Register at least 30 days
prior to the date any de
minimis or cost recovery
settlement becomes effec-
tive. Persons who are not
parties to the proposed
settlements must be pro-
vided an opportunity to
file written comments for
a period of 30 days.
SARA §113(k)(2)(B) and
§117(b) and (d).
CERCLA §122(i).
During remedial design,
the CRP should be re-
vised, if necessary,
based on community con-
cerns discovered during
interviews and other
Superfund Community
Relations Policy, 1983.
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EXHIBIT 2-1 (continued)
CERCIA COMMUNITY RELATIONS REQUIREMENTS
Technical Phase:
Site Activity
Requirement(s)
RequirClient Source (s)
Explanation of
Differences
Remedial Design:
Fact Sheet on
Engineering
Design-*
activities as pertains to
the remedial design and
construction phase.
After adoption of a
final remedial action
plan, if any remedial
action is taken, or any
enforcement action under
§106 is taken, or if any
settlement or consent decree
under §106 or §122 is entered
into, and if such action,
settlement, or decree differs
in any significant respects
from the final plan, the
lead agency shall publish
an explanation of the signi-
ficant differences and the
reasons such changes were
made. See Guidance on
Preparing Superfund Decision
Documents: The Proposed Plan
and Record of Decision for
further information.
SARA §117(c)
A fact sheet must be
prepared explaining the
final engineering design
and should be made
available to the public.
Policy on CERCLA Compliance
with Other Environmental
Statutes(16).
3 This activity is currently under review as part of the proposed NCP.
, Guidance will be issued once the NCP requirements are finalized.
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EXHIBIT 2-1 (continued)
CERCIA COMMUNITY RELATIONS REQUIREMENTS
Technical Phase:
Site Activity
Requirement(s)
Requirement Source(s)
NFL Additions and Deletions:
Publication of
Proposed Rules
And Notification
Of Public Comment
Period
Publication of
Final Rules
Proposed addition and
deletion rules must be
published in the Fed-
eral Register and in a
local newspaper of
general circulation with
request for comments.
Publication of the
final rules must be
made not less than
30 days before their
effective date.
Administrative Procedure
Act, 5 USCA §553(b) and (c)
(1).
Administrative Procedure
Act, 5 USCA §553(d).
SITE PROGRAM
Site Demonstration Phase:
Selection of
Demonstration
Site
A public notice and
public comment period
are required prior to
final selection of demon-
stration site for
innovative technologies.
SARA §311(b)(5)(E).
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periods, and responsiveness summaries. Interim guidance will be issued in the
future. Until this time, refer to Appendix G for a list of recommended
community relations activities for different types of removal actions.
2.2 REQUIREMENTS FOR REMEDIAL RESPONSES4
2.2.1 Community Interviews
EPA policy requires that a community relations effort accompany any
Superfund remedial investigation and response, whether it be Federal-,
State- , or enforcement-lead. Once the lead agency has set priorities and
evaluated a site for remedial response, community relations efforts become an
integral part of site activities. At the beginning of the remedial
investigation and feasibility study (RI/FS) stage, before RI field work
begins, EPA or State staff must conduct interviews with affected residents and
community leaders to determine their level of interest in the site, major
concerns and issues, and information needs. Chapter III provides additional
information on conducting interviews.
2.2.2 Conmunity Relations Plan
Based upon the community interviews, a community relations plan must be
prepared and should include a description of the site background, history of
community involvement at the site, community relations strategies, a schedule
of community relations activities, and a list of affected and interested
groups and individuals. This plan must be completed before RI field
activities begin. See Chapter 3 and Appendix B for more information about
preparation of the CRP.
2.2.3 Information Repository and Administrative Record
SARA requires that an administrative record for selection of a response
action be established at or near the facility at issue. The administrative
record shall include documents which EPA considered or relied on in selecting
a response action.
EPA requires that an information repository be established at or near the
site to comply with §117(d) of SARA, which states that each item developed,
received, published, or made available to the public under §117(d) must be
available for public inspection and copying at or near the facility at issue.
The information repository and administrative record may be housed in the
same location, and may be established at approximately the same time. The
administrative record for remedial actions will be established when the
remedial investigation phase begins, e.g., when the final RI/FS work plan or
CRP is available. At that time, a notice should be published in a local
4 These requirements also apply to operable units. (See Glossary.)
5 Only CERCLA-funded State-lead sites must comply with these requirements.
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newspaper indicating the availability of the administrative record, and, if
applicable, the information repository.
Note that the materials in the information repository may overlap with
the administrative record. The information repository maintained by the
community relations coordinator may contain additional information which is of
interest to the public but which does not form a basis for the response
selection decision. Examples of such information include newspaper articles,
press releases, and fact sheets.
2.2.4 Notification and Analysis of the Proposed Plan and Remedial
Investigation/Feasibility Study
SARA §117(a) and (d) require that the public be notified of the
availability of the proposed plan. The public notice must identify the lead
agency's preferred remedy, the other alternatives which were analyzed, the
location where the administrative record can be reviewed and copied, community
involvement opportunities, and the name of an agency contact. According to
SARA, this notice must, at a minimum, be published in a major local newspaper
of general circulation.
The proposed plan can be prepared in the form of a fact sheet or a
separate document. It must clearly summarize:
alternatives analyzed in the detailed analysis of the
feasibility study;
preferred remedy and rationale for that preference;
any proposed waivers to §121(d)(4) cleanup standards; and
position of the support agency on the proposed plan and
preferred alternative.
Public comment must be solicited on all alternatives, not just the preferred
alternative, and the information that supports the alternatives. Also, the
proposed plan should clearly state that it is not the sole document on which
the public should rely for information on the alternatives, and refer the
reader to the information in the administrative record and repositories.
Response to releases of hazardous substances is often affected by
floodplain and wetland issues. Under the EPA document entitled "Policy on
Floodplain and Wetlands Assessments for CERCLA Actions" (August 6, 1985),
Superfund actions must meet the substantive requirements of the Floodplain
Management Executive Order (E.O. 11988), the Protection of Wetlands Executive
Order (E.O. 11990), and Appendix A of 40 CFR Part 6, entitled Statement of
Procedures on Floodplain Management and Wetland Protection. The purpose of
Appendix A of 40 CFR Part 6 is to set forth EPA's policy and guidance for
carrying out the provisions of Executive Orders 11988 and 11990.
These documents outline certain public involvement activities that may
apply if a potential agency action for a site impacts a floodplain or wetland.
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Lead agency staff should consult the policy and orders to ensure all public
involvement requirements are fulfilled. Further guidance on the application
of these orders and policies for the community relations program will be
forthcoming.
2.2.5 Public Comment Period and Public Meeting
The NCP requires for all remedial actions at NPL sites -- including Fund-
financed and enforcement actions - - that the RI/FS and proposed plan be
provided to the public for its review and comment for a period of at least 21
days. SARA §117(a)(2) also requires that the agency provide a "reasonable
opportunity for submission of written and oral comments and an opportunity for
a public meeting at or near the facility." A transcript of the meeting
conducted during the public comment period (pursuant to §117a), must be made
available to the public and must be part of the administrative record. It is
also recommended that the transcript be placed in the information
repositories.
2.2.6 Public Comment Period on the Administrative Order on
Consent or Consent Decree (AOC/CD)
All consent decrees, whether for removal actions, for RI/FS work or for
RD/RA, require public notice in the Federal Register and public comment
opportunities. This is pursuant to CERCLA §122(d) and follows U.S. Department
of Justice policy established under 28 CFR 50.7. A notice of the consent
decree must be published 30 days prior to filing in court as a final judgment.
Comments received during the public comment period must be considered and
filed with the court by the U.S. DOJ. At the conclusion of the public comment
period the U.S. DOJ will recommend that the decree either go unchanged or be
modified, based upon public comments.
Administrative orders may be used for removal actions, RI/FS work or for
settlements under CERCLA §122(g) or (h). Administrative orders used for
removal actions and for RI/FS work do not normally require public comment
opportunities. However, once these documents become final, they should be
made available for public review. Administrative orders on consent for
settlements under §122(g) and (h) require a notice in the Federal Register of
the proposed settlement, an opportunity for public comment, consideration by
the lead Agency of the comments and a determination by the lead Agency either
that the order go unchanged or be modified.
2.2.7 Responsiveness Summary
At the conclusion of the comment period, SARA and the NCP require that a
response to significant comments, criticisms, and new data submitted in
written or oral form during the comment period be prepared, and that it
accompany the final remedial action plan, or other decision document. This
has routinely been accomplished in the form of a responsiveness summary. For
further guidance on preparing responsiveness summaries, see Chapter 4 and
Appendix A.
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2.2.8 Addressing Significant Changes Prior to Adoption of Final
Remedial Action Plan
Before preparing the ROD, SARA §117(b) requires the lead agency to
analyze the final selected remedy against the alternatives described in the
RI/FS and proposed plan, to determine whether any "significant changes" have
been made to the selected alternative as it was presented for public review
and comment. What constitutes a "significant change" will be a site-specific
determination based on the contents of the RI/FS and proposed plan. If
significant changes have been made, these changes must be documented in the
decision summary section of the ROD. Significant changes may require
additional public involvement opportunities under SARA §117(a). See Section
4.3.4 of this Handbook and Guidance on Preparing Superfund Decision Documents:
The Proposed Plan and Record of Decision for guidance on required activities
in these instances.
2.2.9 Public Notice
Under SARA §117(b) and (d), the public must be informed through a public
notice in a major local newspaper of general circulation when the agency has
issued the proposed plan and later when the final remedial action plan or ROD
is adopted. The final plan must be made available to the public before
remedial action begins. Refer to Chapter 4 and Appendix A for further
information on preparing public notices.
2.2.10 Revision of the Community Relations Plan
Prior to remedial design, the community relations plan must be revised,
if necessary, to account for the needs and concerns of the community during
remedial design and remedial action. Community interviews or other activities
may be conducted to gather these concerns. Chapter III has additional
information about conducting interviews and developing a community relations
plan.
2.2.11 Addressing Post-ROD Significant Changes (Explanation of
Differences)
SARA §117(c) requires an explanation of significant differences after the
adoption of a final remedial action plan or ROD if:
any remedial action is taken;
any enforcement action under Section 106 is taken; or
any settlement or consent decree under Section 106 or Section
112 is entered into
and if such action, settlement or decree differs in any significant respects
from the final plan or ROD, the lead agency must publish an explanation of the
significant differences and the reasons such changes were made. Refer to the
Guidance on Preparing Superfund Decision Documents: The Proposed Plan and
Record of Decision for further guidance on requirements in these
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circumstances.
2.2.12 Fact Sheet and Notice on the Remedial Engineering Design
Consistent with EPA's "Policy on CERCLA Compliance with Other
Environmental Statutes", a fact sheet on the engineering design of the
remedial action must be prepared and made available to the public prior to
completion of the final engineering design.** The public should be notified of
the availability of the fact sheet. The notification should briefly explain
the design. This may be accomplished through a general mailing of the fact
sheet to all individuals on the site mailing list; by placing an ad in a local
newspaper of general circulation; or other means of communication deemed
appropriate. Nonsignificant changes that occur during the design phase may be
summarized in the design fact sheet for further public information. See
Guidance on Preparing Superfund Decision Documents: The Proposed Plan and
Record of Decision for further guidance on this issue.
2.3 REQUIREMENTS FOR ADDITIONS OF SITES TO THE NATIONAL PRIORITIES LIST (NFL)
Under the NCP, EPA is required to revise the NPL at least annually. The
NCP sets forth three mechanisms for establishing and amending the NPL: the
Hazard Ranking System (HRS); designation by States of their top priority
releases; and determination that a site poses a significant threat to public
health, welfare, or the environment. Once EPA has decided to add a site to
the NPL, the Agency has elected to use the procedure for rule-making specified
in the Administrative Procedure Act. Under this Act, EPA is required to
publish the proposed rule in the Federal Register, with an invitation to
interested parties to make comments. EPA must then consider these comments in
making revisions to the rule. The final rule is published in the Federal
Register.
2.4 REQUIREMENTS FOR DELETION OF SITES FROM THE NATIONAL PRIORITIES LIST
(NPL)
A site can be deleted from the NPL either because a remedial action has
been completed or because it has been determined that remedial action is
unnecessary. The NCP lists three criteria of which one must be met to delete
a site:
1. EPA determines that responsible parties have
completed all appropriate response actions;
2, EPA determines that all appropriate Fund-financed
response has been completed, and that no further
cleanup by responsible parties is needed; or
6 This activity is currently under review as part of the proposed NCP.
Guidance will be issued once the NCP requirements are finalized.
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3. Based on a remedial investigation, EPA determines
that the site poses no significant threat to public
health, welfare, or the environment and, therefore,
construction of remedial measures is not appropriate.
Procedures for site deletion from the NPL are similar to the rule-making
procedures for NPL site additions described in 2.3. §553(b) and (c) of the
Administrative Procedure Act requires the following steps for deleting a site
from the NPL:
o A Notice of Intent to Delete prepared by Regional
staff must be published concurrently in the Federal
Register and appropriate local publications;
o The Notice of Intent to Delete must include
notification of a 30-day comment period on the
proposed rule;
o The final rule must be published not less than 30
days before the effective date.
Public notification statements are prepared by Regional staff. The
Notice of Intent to Delete must appear in the Federal Register and appropriate
local publications.
2.5 REQUIREMENTS FOR THE SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION (SITE)
PROGRAM
The Superfund Innovative Technology Evaluation (SITE) program is designed
to enhance the development and use of innovative technologies for hazardous
waste remedial and removal actions. Under this program a wide range of waste
types will be screened and specific sites will be selected as candidates for a
demonstration project. SARA §311(b)(5)(E) requires an opportunity for a
public notice and public comment period prior to the final selection of a
demonstration site. It is suggested that Community Relations Coordinators and
Remedial Project Managers coordinate closely to ensure this public comment
opportunity is implemented. Important additional guidance on community
relations during SITE projects can be found in Section 3.3 of this handbook.
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CHAPTER 3
CONDUCTING COMMUNITY INTERVIEWS AND DESIGNING COMMUNITY
RELATIONS PROGRAMS FOR REMEDIAL RESPONSES
This chapter presents guidance for planning and designing community
relations programs for remedial responses. Planning and designing a community
relations program for a remedial response requires:
o Conducting community interviews; and
o Developing a community relations plan.
The information gathered during community interviews provides the basis for
the development of site-specific community relations plans. By designing a
plan targeted to a particular community and offering regular opportunities for
public involvement in response decisions, EPA and State agencies can obtain
very valuable information, and encourage those most affected by the decision
to participate in the process. Often, remedial investigation workplans have
been changed based on information gathered during community interviews.
This chapter is divided into three major sections. Section 3.1 provides
guidance for community relations planning, including recommendations for
conducting community interviews. Section 3.2 discusses the design of a
community relations program, with guidance on how to select activities,
structure a program, and prep.are community relations plans. Section 3.3
describes community relations activities for SITE demonstration projects.
Guidance for implementing the community relations effort outlined in the plan,
with details on selecting the types of activities most appropriate for
different phases of a remedial response, is presented in Chapter 4.
3.1 PLANNING AND CONDUCTING COMMUNITY INTERVIEWS
The success of community relations planning depends first and foremost on
community interviews. Community interviews are discussions with State and
local officials, community leaders, media representatives, potentially
responsible parties, and/or interested citizens which take place in informal
settings such as homes and offices in the community. To be most successful,
it is important that these interviews be face-to-face discussions to determine
public concern and learn how and when the public want to be involved in site
response activities. If individuals conducting the community interviews
actively seek information about public concerns and informational needs, the
communication activities will be better targeted to the specific needs of the
people in the community. Before conducting community interviews, staff need
to:
o Confer with the Remedial Project Manager and other
Regional and State staff to acquire information about
the site;
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o Identify interested officials, citizens, and
organized groups; and
o Schedule interviews with these individuals.
Once these preparatory tasks have been completed, the interviews can be
conducted. It is suggested that interviews be conducted by the Remedial
Project Manager, community relations staff, perhaps enforcement staff, and
possibly contractors.
Some situations may occur where only a few selected interviews or
informal discussions may need to be conducted to complete the information
necessary to develop a successful CRP. This may occur when revising the CRP
to address the public's concerns during RD/RA, if there has been a great deal
of current interaction with the community through the ROD process. In such
cases, it may be necessary to conduct only a few, informal discussions by
telephone or in person with selected, well-informed individuals who clearly
represent the community to provide a sufficient basis for the development of a
revised CRP. These are site-specific decisions that must be made by the lead
agency with input from the support agency to decide which discussions and how
many are appropriate to develop a CRP that will address the public's concerns
and enhance the response action.
Community interviews frequently set the tone for the agency's future
contacts with the public. Those conducting the community interviews should
ask the public what mechanisms for communication will enhance their ability to
make their opinions and questions known. This initial exchange of information
should take place through individual discussions, rather than through large
public meetings or news media.
3.1.1 Background Review Prior to Community Interviews
Staff preparing for community interviews should first become familiar
with the technical and legal issues at the site and attempt to identify those
aspects of the contamination problem that are of relevance to the local
community. To acquire the necessary background information, including names,
maps, and documents, certain steps should be performed, including:
o Meeting with EPA or State technical, legal, and
enforcement staff;
o Reviewing agency files; and
o Researching local newspaper articles.
When reviewing background information, staff should remember that
numerous factors could influence public perceptions of the site problem, such
as:
o Nearness of area residences to the site;
o Nearness of schools or playgrounds to the site;
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o Visibility of the site;
o Presence of livestock, crops, or other vegetation
near the site;
o Location of a public water supply;
o Location of nearby recreational lakes, ponds, rivers,
streams, and parks;
o Measures to control or limit site access;
o Presence of other hazardous waste or Superfund sites
in the area;
o Activity of local interest groups or press; and
o Role of responsible parties within the community
(e.g., are responsible parties major employers in the
area?).
This kind of technical review does not establish the level or focus of public
concern; rather, it provides an initial opportunity for staff to become
familiar with technical issues associated with the site and to understand the
site from the community's perspective.
3.1.2 Developing a Contact List for Community Interviews
Community relations staff next should consult with agency officials to
identify interested citizens and local officials who should be contacted
during the community interviews. In addition, staff should review agency
files to identify individuals who have expressed concern about the site and
research local newspaper articles for the names of community leaders.
Additional names also may be collected during the interview process,
particularly those of individuals whose knowledge of the community may not be
obvious to the nonresident (e.g., a visiting nurse who comes once a month, but
who knows the community well). Individuals and groups that typically are
interviewed include:
o State agency staff, such as officials from health,
environmental, or natural resources departments;
o Local agency staff and elected officials, such as
county health department officials, county
commissioners, mayor or township administrator, and
officials serving on environmental commissions, local
advisory committees, and planning boards;
o Representatives of citizens' groups organized to
address site issues;
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o Area residents and individuals not affiliated with
any group;
o Local business representatives (e.g., from the
Chamber of Commerce or the Council of Governments);
o Local civic groups and neighborhood associations;
o Local chapters of public interest groups (e.g.,
Sierra Club, Wilderness Society, League of Women
Voters); and
o Potentially responsible parties.
At sites where community interest is high, it may not be possible to meet
with all interested parties. In these situations, staff should determine
which individuals are likely to provide the greatest variety of perspectives
about the site. A broad range of interviewees is particularly important at
sites where citizens' groups or other ad hoc organizations have formed. Staff
should always speak to more than one group representative (since different
viewpoints and constituencies may be represented within a group) and never
limit conversations to the most visible groups or individuals.
3.1.3 Scheduling Community Interviews
Community interviews typically can be scheduled over 2 to 3 days,
although at some sites extra time may be necessary for additional unplanned
interviews and follow-up conversations. It is advisable that the number of
individuals interviewed at any one meeting be limited to one or two persons,
and that meetings be arranged at a time and place convenient to the
interviewee. Some individuals may feel most comfortable being interviewed at
home, while others may prefer to meet at a local meeting hall, library, or
restaurant.
When contacting individuals to schedule interviews, community relations
staff should explain briefly and clearly the purpose of the interviews.
Specifically, staff should state that they will be talking with area residents
and local officials about community concerns regarding the site. Explain that
community interviews are a planning activity held before the RI begins so that
a community relations plan relevant to community needs can be prepared;
individuals contacted should understand that staff cannot provide detailed
technical information about site problems or future site actions. While
community members may be more or less willing to participate in the
interviews, generally most citizens, including PRPs, will perceive the
discussions as a significant opportunity to express their concerns in a
productive manner. Staff should speak first with State and local officials to
obtain background information and to let these people know that area residents
will also be interviewed. Officials have an understandable interest in agency
activities that affect their constituents. However, these discussions with
elected officials cannot in themselves generate enough information to develop
an adequate community relations plan. Special efforts must be made to
interview local residents, particularly those who are not affiliated with any
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group. As a simple matter of courtesy, staff might send letters to each of
the individuals that will be interviewed to confirm the date and time of the
interview, and the place in which the interview is scheduled to take place, as
well as to restate that the interview is for agency planning purposes.
3.1.4 Conducting Conmmity Interviews
Community relations staff should begin community interviews by
reiterating the purpose of the discussions and providing general information
about community relations and the Superfund process. Officials and community
members usually appreciate brief and simple explanations about what happens
during the Superfund response, and when public input will be sought. Staff
should refer requests for site-specific information to appropriate program
staff. Alternatively, staff should get back to community members with the
information they have requested, or have specialists contact the community
members directly. Discussions about specific technical or enforcement issues
at the site should not dominate the community interviews. Staff conducting
the interviews should also make clear that while the purpose of these
interviews is to identify community attitudes and concerns, the plan prepared
from the interviews will not use direct quotations without approval of the
individual to be quoted. Even the use of indirect quotation, or attribution
of attitudes or ideas to individuals, should be used with discretion.
Some staff may feel more comfortable if they prepare questions in advance
of the community interviews. Questions that would be appropriate at most
sites include:
o When did you first become aware of problems at the
site? What is your understanding of the history of
the site?
o Have you had any problems on your property that you
think are attributable to the site?
o What contacts have you had with government officials
about the site? Do you feel these officials have
been responsive to your concerns?
o Are you aware of the history of site operations?
o Do you know of any parties who were involved with
these site operations?
o What are your current concerns about the site?
o Have you participated in activities concerning the
site?
•o How would you like to be involved in future
activities?
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o How can EPA or the State best provide you information
concerning response activities?
o What kinds of information do you need?
o How do you want to get that information and how
frequently?
o Can you suggest other individuals or groups that
should be contacted for additional information?
Developing a list of questions frequently helps identify those viewpoints
that are most widely held in the community. Conflicting responses can be as
revealing as consensus because they indicate which issues are likely to be
most controversial during cleanup activities. Staff should investigate
differing interpretations of a situation, particularly when officials and
residents disagree about the seriousness of a problem. At the same time, it
is important to anticipate what kinds of information are to be sought from
which individuals, and to pose different questions accordingly. For example,
while a local health department official would be a good source of information
about response actions at a site, he or she might not be able to discuss
objectively how the local community has perceived health department efforts.
Similarly, the leader of a citizens' group may comment extensively on the
group's concerns, but might not be able to discuss area-wide environmental
issues and concerns.
In the final analysis, the best questions are usually those that arise
spontaneously during a discussion. As is the case with any community
relations activity, it is never fully possible to anticipate how the public
and local officials will respond. Some community members may discuss their
concerns fully and openly, without any focused questioning. Others may be
more reserved. Similarly, many officials will welcome the agency's presence
at the site and even offer to help provide information to the local community,
while other officials will resent the intrusion of agency officials. If
citizens or officials appear uninterested, ask questions that address why
concern is limited and where any emerging concern is likely to focus. In
these situations, questions about the community at large are often helpful:
o How sensitive is the public in the area to
environmental issues?
o How does the public typically perceive the presence
of Federal or State officials in the locality?
o What kinds of issues have attracted the most public
attention?
At all times, interviewers should listen carefully, realizing that they
represent their agency and are establishing the basis for later meetings
between the agency and community members. This is especially true if
officials or community members are antagonistic towards or critical of the
agency. In such cases, understanding why these individuals hold these
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attitudes is important. Perhaps previous response efforts have fallen short
of their expectations. Perhaps people think their concerns have been ignored.
Citizen displeasure or hostility should not be viewed as a personal affront;
frequently, angry individuals are a valuable source of information about what
has gone wrong in the past and which issues are most sensitive. In such
situations, staff should acknowledge the individual's complaint, and thank him
or her for the contribution, without either endorsing or rejecting the basis
for the complaint.
Another potentially difficult situation is the appearance of reporters
during community interviews. If possible, discourage their attendance
beforehand, as it might inhibit a frank and open conversation. Reporters
should be asked, instead, to meet separately with community relations staff.
If reporters nevertheless appear during community interviews, ensure that they
understand that the purpose of the discussion is to gather information about
the community, and not to answer questions about the problems at the site or
the government's plan for remedial response. The reporter should also be
asked for his/her views and comments.
At the end of each community interview, staff should ask if the citizen
or official knows of other people who have expressed interest or concern about
the site. Staff should encourage citizens and officials to contact them later
if they feel they did not have the opportunity to discuss any current concerns
or if they have problems or concerns in the future. Staff should provide the
names and telephone numbers of the agency's community relations coordinator
and the remedial project manager. Finally, as a suggested follow-up to
community interviews, the coordinator responsible for the site might send a
brief letter to all individuals interviewed, thanking them for their time and
contribution and explaining when the CRP will be completed and how a copy may
be obtained.
3.2 DESIGNING COMMUNITY RELATIONS PROGRAMS
The design of a community relations program for a remedial action depends
substantially on the extent and quality of information obtained during the
community interviews. Design largely involves formalizing and putting into a
planning document the analysis conducted during the planning stages.
Activities and approaches recommended for the community relations program
should always be based on specific findings from the community interviews and
supplemented with findings from file searches.
3.2.1 Identifying Citizen Concerns
In designing a community relations program, staff should first focus on
distinctive features of the site and community in question. Think about how
the community could be described best to a person unfamiliar with the area.
What constitutes the affected community? What makes the site unique? What
are the key characteristics of the community? What issues are of most concern
to the community and officials? Does the level of public concern reflect the
technical complexity of the problems at the site? Individuals interviewed
should be asked to consider what community relations activities and approaches
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will be most appropriate for their community. Staff should also identify
existing methods by which government communicates with the local public and
determine which officials are regarded as useful sources of information within
the community. This kind of information contributes substantially to
determining appropriate community relations activities and approaches for a
site. If local officials are uncomfortable about the presence of the agency
in the community, staff should indicate their willingness to cooperate with
local officials by including these individuals in community relations
activities. In communities undergoing substantial development activity or
economic growth, community relations staff should be sensitive to the fears of
local officials that the notoriety associated with being on the NPL may
adversely affect growth in the area.
The design of the program depends greatly on the level and nature of
community concern as expressed by residents during community interviews.
Questions that have been found to influence the extent of community
involvement include the following:
o Do residents in the community believe their health,
or their children's health, may be affected by
hazardous substances?
o Do residents consider the site contamination as part
of a larger area-wide hazardous waste problem?
o Do homeowners and businesses believe the site has
caused or will cause them economic loss?
o Are agency officials perceived as credible and
responsive to public problems?
o Have site problems and events been covered by local,
State, regional, or national media?
o Has an active, vocal group leader (or leaders)
emerged in the community?
If "yes" is the answer to several of these questions, community involvement at
the site is likely to be high. Remember, however, that the seemingly quiet
community may also demand staff attention. Silence should not automatically
be equated with lack of interest. It is entirely possible that a silent
community is unaware of how to voice its concerns or is unsure if its concerns
may be legitimately raised. Limited community concern at the time of the
community interviews does not eliminate the need for monitoring community
concerns, because numerous factors can increase concern at any point during
the remedial process. Experience has shown that community interest generally
peaks when a decision is made concerning the remedial action to be conducted
at a site. Another event that commonly triggers community concern is the
arrival of technical crews at the site when the RI/FS begins. The knowledge
and experience of those conducting community relations will therefore be very
important in judging how much effort may be required to monitor a community
where there is little apparent interest in site activities.
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3.2.2 Selecting Techniques and Approaches
Community relations techniques and approaches should be selected
primarily on the basis of information gathered during community interviews.
To the extent possible, the public's preferences for how they would like to be
involved should be taken into consideration. The number and complexity of
community relations activities should reflect stated community needs. For
example, while news releases are typically issued to announce site findings,
community relations staff might also prepare statements to be included in
State environmental agency newsletters, area environmental group publications,
and citizen group bulletins if interest in the site is widespread. Similarly,
while public meetings are most commonly held when the draft FS is completed,
meetings, workshops, or informal sessions with community members may be
scheduled at other points in the response process.
At sites where the contamination problem is technically complex and will,
in all likelihood, require a correspondingly complicated response, staff might
provide information more frequently about the site and eventual cleanup
efforts. These activities also may be desirable in some cases where the
contamination problem is not technically complex, but where the community
members are eager to educate themselves about hazardous waste issues.
Workshops, seminars, or panel discussions on hazardous waste treatment and
disposal, ground-water issues, and the Superfund program also may be
appropriate at these sites. Alternatively, staff should consider activities
to monitor community concern at sites where interest appears limited.
Periodic telephone calls to local officials and key citizen leaders, reviews
of local newspapers, and informal contacts with community residents,
particularly those neighboring the site, are efficient ways to find out about
shifts in the level of community concern during the RI/FS. Keeping in touch
is particularly important when activity is intense at a site, especially if
heavy equipment or protective clothing will be used.
Technical, community relations, and enforcement staff are strongly
encouraged to seek public input throughout the remedial process in addition to
the required public comment period. Studies conducted by the agency during
the RI are frequently of great interest, particularly because the data
gathered are later used to identify cleanup alternatives for the site. Staff
also may find it beneficial to provide information to the public for their
review during the development of a workplan for the RI and planning stages of
the FS. For example, the local community who has actually witnessed the
dumping of hazardous materials have made suggestions as to where samples
should be taken. Throughout the remedial process, the agency should be
willing to hold informal meetings and workshops where possible to provide the
public with the opportunity to review technical decisions and to offer
opinions.
Finally, when selecting techniques and approaches for the community
relations program at a site, staff should always consider the overall context
of remedial activities. Are there other hazardous waste sites or facilities
in the area? Is the site regulated under other environmental regulatory
programs (e.g., the Resource Conservation and Recovery Act (RCRA)(11) or the
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Clean Water Act(2)?) The community relations program at a site that is one of
several sites in a town or county might include a presentation on hazardous
waste problems. For example, in some communities, information sessions on
toxicology have been conducted with the help of local university experts. In
areas where environmental issues are particularly visible, community relations
staff should anticipate greater media attention to site developments and the
possibility that regional or national environmental groups may become
interested in the site. At all sites, community relations efforts will be
more effective if community-specific strategies of this kind are incorporated
during program design.
Finally, community relations activities should be scheduled in relation
to milestones for the Fund-financed response and/or enforcement action.
Chapter 4 provides guidance on selecting activities for key points in the
remedial process. Chapter 6 (reserved) will provide guidance on selecting
activities for key points in the enforcement process. Appendix A provides
descriptions of these activities, their purpose, benefits, and limitations.
3.2.3 Community Relations Plans
The NCP requires a community relations plan for all remedial response
actions, and for all removals longer than 45 days. For remedial actions, the
plan must be prepared before the RI/FS begins and outline community relations
activities to be held during the RI/FS. The plan also should project
activities that are required during remedial design and action (such as the
preparation of a fact sheet after the engineering design is complete). A
revised plan that projects additional activities during remedial design and
remedial construction should be prepared before remedial design begins. If
prepared by an EPA Regional Office, the initial community relations plan
should be submitted with the RI/FS workplan. The State may request funds for
the development of the CRP in the cooperative agreement application. If the
CRP is not part of the cooperative agreement application, it must be
incorporated into the State's annual workplan. Also, in that case, the final
CRP must be submitted with the RI/FS workplan. An informational copy should
be sent by the Regional Office or the State to EPA Headquarters Superfund
community relations staff. If the plan is given to any one individual outside
of EPA for review, it generally should be available to all who wish to review
it at the same time. Even with public review, however, the Regions have the
final decision on the contents of the plan.
Community relations plans document the community's concerns identified
during community interviews and provide a detailed description of the
community relations activities selected on the basis of these interviews.
Community relations plans should not discuss generic program goals, but focus
instead on site-specific community relations techniques and approaches.
As planning documents, the best community relations plans generally will
be those that convey a working knowledge of the local community and its
concerns, while providing a framework for addressing community concerns during
the remedial response. In addition, however, it is important that the
community relations program outlined in each plan include sufficient
flexibility to adjust to changes either in community attitudes or in the
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schedule for technical activities at a site. Guidance for implementing such a
program is presented in the next chapter.
While plan format can be varied to reflect the unique characteristics of
a specific program, the recommended format consists of five sections and two
appendices:
o Section 1: Overview of Community Relations Plan
o Section 2: Capsule Site Description
o Section 3: Community Background
o Section 4: Highlights of the Community Relations Program
o Section 5: Community Relations Activities and Timing
o Appendix A: Contact List of Key Community Leaders
and Interested Parties (Note: names and addresses
of private citizens should not be included in the
copy of the community relations plan that is made
available to the public.)
o Appendix B: Suggested Locations for Meetings and
Information Repositories
These sections and appendices are described in greater detail below. Appendix
B to this handbook provides a model plan in this format.
1. Overview of Conmunity Relations Flan. This section should outline
the purpose of the community relations plan and the distinctive or central
features of the community relations effort for this site. Any special
characteristics of the community and the site should also be introduced. This
overview, which should be only a few paragraphs in length, should not merely
restate the general goals of community relations in Superfund; rather, it
should identify objectives specific to community relations during this
remedial response and special circumstances that the plan will address.
2. Capsule Site Description. This brief section should provide readers
unfamiliar with the site with the basic historical, geographical, and
technical details necessary to understand why the site is listed on the NPL.
Topics that should be covered include:
o Site location and relationship to homes, schools,
playgrounds, businesses, lakes, streams, and parks;
o History of site use and ownership;
o Type of hazardous substances at the site, if known;
o Nature of threat and potential threat to public
health and the environment, if known;
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o History of inspections and studies conducted at the
site; and
o Lead agency responsible for the site.
Maps showing the location of the site within the State and locality also are
helpful.
3. Connunity Background. The community background section will usually
be divided into three parts:
(1) Community profile, which should familiarize the
reader with the community and analyze key local
issues and interests.
(2) Chronology of community involvement, which should
identify how the community has reacted to the site in
the past. What actions, if any, has the public taken
to resolve problems at the site? How did the public
view previous response efforts at the site? How does
the public perceive various levels of the
government's involvement at the site? Are PRPs
associated with the site or past site operations?
(3) Description of key community concerns, which should
analyze the major public concerns regarding the site and
the remedial process proposed to deal with those concerns.
Throughout the community background section, but particularly during the
analysis of community concerns, focus on the community's perceptions of the
events and problems at the site, not on the technical history of the site.
This section, which may vary from three to seven pages, will contain much of
the information obtained during the community interviews.
4. Highlights of the Community Relations Program. This section should
summarize the design for the community relations program at the site. The
approaches described should be site-specific and follow directly and logically
from the preceding discussion of the community, including PRPs, and its
perceptions of the problems posed by the site. Topics that will be covered in
this section, usually two to four pages, include:
o Site-specific methods of communication, or activities
and techniques;
o Resources to be used in the community relations
program (e.g. local organizations, meeting places);
o Key individuals or organizations that are expected to
play a role in community relations activities; and
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o Areas of special sensitivity that must be considered
during community relations and remedial activities.
5. Community Relations Activities and Timing. This section specifies
the types of community relations activities, both required and recommended, to
be conducted at the site and when they will be conducted. This section also
should identify additional activities that might be appropriate at the site if
concern increases or shifts, or if PRPs are present and the site is classified
as a federal enforcement site. This section could include a matrix that
relates the timing of community relations activities to technical and/or
enforcement milestones for the site. Another useful planning tool,
particularly where several agencies are involved, is a budget staffing plan.
Appendix A: Contact List of Key Community Leaders and Interested
Parties. The names, addresses, and telephone numbers of all officials and
group representatives contacted during the community interviews, along with
others who will receive information about site developments, are listed in
this appendix. However, the names, addresses, and telephone numbers of
private citizens contacted for interviews should not be included as a part of
the plan that is made public. These names, addresses, and telephone numbers
should, however, be included in the mailing list compiled for the site. The
contacts identified in the Appendix should include:
o Federal elected officials;
o State elected officials;
o Local elected officials (e.g., county and city or
township);
o Potentially Responsible Parties;
o Environmental groups and citizens' groups;
o EPA Regional officials (e.g., Superfund community
relations coordinator, remedial project manager);
o State environmental and health department officials;
o Local health department, safety officials (e.g.,
fire, police), and township officials; and
o Press contacts (television, radio, newspapers).
Appendix B: Suggested Locations of Meetings and Information
Repositories. The community relations plan should identify locations for the
information repository and for public meetings. Facilities recommended for
holding public meetings include school gyms, town halls, and library meeting
rooms. The locations selected for public meetings should be accessible to
handicapped individuals. Typical locations of information repositories
include local libraries, town or city halls, and county offices. Hours that
the information repositories will be accessible should be included, along with
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the names of contacts for getting into the buildings. The size or capacity of
meeting rooms is a particularly helpful detail for later planning.
3.3 COMMUNITY RELATIONS FOR SITE DEMONSTRATION PROJECTS
The Superfund Innovative Technology Evaluation (SITE) Program is designed
to enhance the development and use of innovative technologies for Superfund
remedial and removal actions. The SITE program is a joint effort being
conducted by the Office of Research and Development (ORD) and the Office of
Solid Waste and Emergency Response (OSWER).
Under the SITE program, proposals from technology developers are
evaluated to determine technologies which are ready for demonstration at
Superfund sites. A wide range of Superfund waste and site types will be
screened, and specific sites will be selected as candidates for a
demonstration project. SARA §311(b)(5)(E) requires an opportunity for a
public notice and public comment period prior to the final selection of a
demonstration site. The criteria for selecting sites will be established by
OSWER, with the objective of selecting sites that are representative of high
priority waste problems and allow the demonstration of the capability of the
technologies. The sites will then be tentatively "matched" with appropriate
technologies identified by ORD. Approximately ten demonstration projects per
year will be selected, and the developer or vendor of the new technology will
conduct the demonstration. The duration and scale of the project will be
decided by EPA on a case-by-case basis. Demonstration locations can be EPA
testing and evaluation facilities, a selected NPL site, a removal action site,
a State-lead hazardous waste site, or a privately-owned treatment facility.
The results of the demonstration will be evaluated by EPA using a set of
predetermined criteria including performance, cost, and reliability relative
to conventional technologies.
Community relations activities typically will be conducted during all
phases of a SITE demonstration project. Demonstration projects will usually
take place at locations where the Regional Superfund Community Relations
Coordinator has already conducted community interviews, completed a site
specific community relations plan, and established an information
repository(ies) in the local community.
When a site is being screened for a SITE technology demonstration, but
before a tentative selection has been made, the Community Relations
Coordinator should assess the likely community concerns to help the Remedial
Project Manager determine the potential feasibility. Prior to tentative site
selection there should be no discussion of the possible demonstration with
members of the community.
Once a tentative match has been made between a site and a technology, the
lead agency should solicit public comment on the match. The requirements for
this are identical to public comment opportunities on the remedial action,
feasibility study and proposed plan. A site-specific demonstration fact sheet
should be distributed to the information repository and site mailing list, and
a notice published in a major local newspaper. At least one information
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briefing/public meeting for the community is strongly suggested after
tentative site selection and/or during the comment period. If such meeting(s)
occur during the comment period, transcripts of comments submitted at the
meeting should be made. After comments have been received, the Community
Relations Coordinator and On-Scene Coordinator/Remedial Project Manager
(OSC/RPM) should prepare a responsiveness summary addressing each comment and
the agency's response. On the basis of the responsiveness summary and the
Region's recommendations, OSWER and ORD will make a decision on whether to
proceed with the demonstration.
A demonstration plan will be prepared for each site which addresses all
aspects of the demonstration. Once this plan is completed, the Community
Relations Coordinator should coordinate with the OSC/RPM to determine whether
a second public notice and an opportunity for a meeting and public comment
period should be held. This step is optional but should be considered in
cases with mixed community acceptance.
During the demonstration itself staff should be prepared for a likely
increase in community interest. Activities such as workshops, briefings,
community meetings, site tours, observation deck, on-scene information office,
or an open house may be useful.
Once the demonstration at the site has been completed in accordance with
the plan and schedule for the individual project, a complete evaluation of the
innovative technology will be conducted by ORD. ORD will then prepare a final
report and summary of the demonstration results. A public notice and/or a
fact sheet will be prepared by the appropriate Regional office announcing the
completion of the evaluation report and its availability in the information
repository(ies). This public notice will be published in a local newspaper
and mailed to individuals on the local mailing list for the site. Copies of
the public notice, a summary of the demonstration results, and the final
evaluation report must be placed in the information repository.
Alternative technologies may sometimes be used at sites that are not part
of the formal SITE program. A SITE demonstration project could occur as part
of the regular RI/FS process. In such cases, community relations requirements
for remedial responses must be employed (see Chapter 2, Section 2.2).
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CHAPTER 4
CONDUCTING COMMUNITY RELATIONS
PROGRAMS DURING REMEDIAL RESPONSES
This chapter provides guidance on conducting community relations programs
during remedial responses. It covers all phases of a Superfund remedial
response -- from the preliminary assessment and site investigation of a site
to the post-cleanup phase when the remedial technology is operated and
maintained. By explaining how to select activities for key points during
remedial planning and remedial action, this chapter also serves as additional
guidance for program design, as discussed in Chapter 3.
The remedial response can be a long, and sometimes complex process,
particularly as the roles and responsibilities of various government agencies
change throughout the response. Open and consistent communication with the
community assures the public that their concerns have not been lost sight of,
even as site responsibilities are transferred from one agency or work team to
another. Open communication also helps the agency to move more quickly toward
its goals of protecting human health and the environment. There are fewer
"surprises" in a well-conducted community relations program, and, as a result,
fewer delays in site remediation, as compared to a site where the agency and
the community are not freely and frequently exchanging information.
This chapter is organized according to the following phases or milestones
of a remedial action:
o Pre-Remedial Activities: Preliminary Assessment, Site
Inspection, and the NPL Process;
o Remedial Investigation;
o Feasibility Study;
o End of Feasibility Study;
o Remedial Design;
o Remedial Action;
o Operation and Maintenance; and
o Deletion from NPL.
The chapter concludes with a discussion of accommodating plans for community
relations to unanticipated developments. In discussing each phase, the
chapter considers the types of issues and concerns likely to arise and
suggests approaches or activities that may be useful. The various types of
community relations activities recommended in this chapter are described
individually in greater detail in Appendix A. Suggestions for community
relations programs during enforcement actions are presented in Chapter 6.
4.1 COMMUNITY RELATIONS BEFORE REMEDIAL INVESTIGATION
Community concern about a hazardous waste site may exist long before the
nature and extent of contamination are known and the site is on the NPL, and
hence eligible for a remedial action. In some cases, the community may
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initiate the remedial process by alerting local, State, or Federal officials
to problems at a nearby site. In other cases, the community may be unaware of
the potential risks posed by a site, or the reasons why the State or EPA is
gathering information about the site.
Ultimately, the kinds of community relations activities that are
conducted at sites before a remedial investigation will depend on the nature
of the site problem, available resources, and other competing claims for these
resources. Staff should therefore consider carefully whether organized
community relations activities are warranted at a pre-remedial site. As a
general rule of thumb, resources are appropriately directed to sites where
risk to the population is suspected to be high, and/or where public interest
is already demonstrated. Similarly, calls or letters from local officials may
be taken as another indication that community relations resources may be
productively directed to the site.
4.1.1 Comunity Relations During Preliminary Assessment
EPA, often with contractor assistance, or the State, conducts the
preliminary assessment of a site. Preliminary assessments are limited in
scope, generally involving a review of site records, permits, pathway and
target data, or titles to establish past activities at the site (e.g., wastes
produced or disposed) and the need for further investigation. A preliminary
assessment does not usually require an on-site visit or sampling. As a
result, there is little need for organized community relations activities, or
large-scale efforts to inform the community of the government's interest in
the site. Formal activities are, in fact, not recommended at this stage,
because they can generate unrealistic expectations in the community about the
government's future involvement at the site.
It is nevertheless important during this phase for staff to become aware
of community attitudes toward the site. At this stage in the remedial
process, the people most likely to be aware of potential site problems and
interested in eventual government response actions are local officials: the
mayor, city council members, the public health chief, the public works chief,
and members of local planning boards. Therefore, one of the first actions
staff could take is to telephone State and local officials, the office of the
area Congressman, and key citizens who can provide information about the scope
and history of the problem. If technical staff will be gathering information
directly from local officials or the community, community relations staff may
wish to inform them beforehand of the purpose of any calls or visits from
government officials. Community relations staff could also advise technical
staff on how best to obtain the most pertinent information from these initial
contacts with the community. If the preliminary assessment involves an
on-site visit, it may be helpful for a community relations specialist to
accompany the field investigator to the site. In all cases, staff should
ensure that any local individuals contacted understand the purpose and
possible outcomes of the preliminary assessment. Such explanations are best
provided informally and directly, through telephone calls to the appropriate
individuals.
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Staff should also keep informed about the results of the preliminary
assessment, in order to plan any follow-up contacts with the community. If
the results of the preliminary assessment indicate that there is no need for a
site inspection, key community officials should be so informed. If, on the
other hand, a site inspection is planned, local officials should be advised
that the site is slated for further government investigation and the
approximate schedule.
4.1.2 Community Relations During Site Inspection
Site inspections, by definition, involve one or more visits to a site by
State or EPA field teams to evaluate the hazards posed by the site. The
purpose of the site inspection is to gather further information to determine
if the site should be placed on the NPL or a removal action should be taken.
Because a site receiving an inspection is one step closer to a possible
NPL listing and remedial investigation, community interest in the site may
increase. It may be advisable to step up community relations efforts
accordingly or initiate community relations activities if not yet begun.
Staff responsible for community relations should obtain the schedule of all
field activities to be conducted by EPA contractors (e.g., the Field
Investigation Team, the Technical Assistance Team, and the Technical
Enforcement Support Team). In coordination with technical staff, they may
want to prepare the community beforehand for any on-site visits by technical
work teams. The individuals who might be contacted include:
o Local officials;
o Heads of community organizations;
o Citizens who have indicated concerns to local, State
or Federal officials;
o People who live closest to the site;
o Principals of schools near the site;
o Local businesses near the site; and
o Potentially responsible parties.
Such advance notice can help to prevent alarm about the appearance of
government officials and contractor teams at the site.
It is particularly important, however, to keep communication with the
community low-key and direct during the site inspection. The local community
and officials should be made to understand that the site inspection is not
itself evidence of a confirmed problem, but rather an information-gathering
effort. A brief generic fact sheet is one way to provide the community with
this information. The fact sheet could explain the purpose of the site
inspection and its possible outcomes: i.e., proposal of the site for the NPL,
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placement of the site in a "no further remedial action planned" category, or
deferral of the site to another program to address concerns.
Without raising the community's expectations of long-term government
action at the site, community relations staff might nevertheless consider ways
to lay the groundwork for later site activities. A few simple steps, taken
during the site inspection phase, can go a long way in building community
trust, and can save considerable time in developing a community relations
program for the site, should an RI/FS be scheduled. Such steps might include:
o Identifying key community leaders and organizations
that should be contacted during community interviews;
o Developing a mailing list of concerned citizens; and
o Designating an agency contact person who can answer
questions from the community.
Community relations staff should follow-up with the community after the
site inspection has been completed to explain the results of the site
inspection. In many cases, the results of site sampling and scoring take many
months to process; the time lag between the site inspection and the decision
to proceed with an RI may lead to considerable uncertainty and frustration.
Letters, or periodic phone calls, may help reassure local officials and the
public that their site has not been lost in bureaucratic processing. In all
circumstances, the community should be notified when a decision is made about
further investigation of the site. Local officials and interested public
should hear such news directly from the agency, rather than through the media.
4.1.3 Community Relations During the NPL Listing Process
The NCP sets forth three mechanisms for establishing priorities among
releases and potential releases for purposes of the NPL: the Hazard Ranking
System (HRS); designation by the States of their top priority releases; and
determination that a site poses a significant threat to public health or
welfare. Once EPA has identified a site or sites to be included on the NPL,
the Agency proposes in the Federal Register to place the site(s) on the NPL
and requests public comment for a period of 60 days. After consideration of
all public comments, revisions are made, and the final rule is published in
the Federal Register, not less than 30 days prior to its effective date.
Staff should anticipate increased community concern or interest when a
site is placed on the NPL. To meet this increased need, staff might
distribute a fact sheet that describes the site, outlines the NPL process, and
explains the time frame for a site proposed for the NPL to be added to the
final NPL. The fact sheet should also describe how the interested public can
submit comments on the proposed listing. In addition, a public meeting might
be held to provide the community with the opportunity to comment orally. The
formal rule-making also attracts the media's attention; thus, it may be useful
to prepare a press release to accompany fact sheets distributed to the media.
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4.2 COMMUNITY RELATIONS DURING REMEDIAL INVESTIGATION/
FEASIBILITY STUDY
Community relations efforts become critical once a site is scheduled for
a long-term RI/FS. From the time that a workplan is prepared for the RI/FS,
to its completion, staff should schedule regular activities to:
o Obtain information from and learn the community's
perspective on site problems and hazards;
o Ensure that the community is kept up-to-date about
the activities, progress, and results of the RI/FS;
and
o Provide the community with any background information
or technical explanations necessary to understand the
significance of the RI results and FS analysis.
4.2.1 Community Relations During Remedial Investigation
Once RI/FS work on a site has been scheduled, staff should prepare a site
mailing list and designate an agency contact, if these steps have not already
been taken during the pre-remedial phase. Community interviews, should be
conducted as described in Chapter 3. These interviews are held primarily to
gather information on the public's past and current involvement with the site
to prepare a CRP. It is appropriate to assure interviewees that they will
hear of future site activities as soon as agency plans are made, and to ask
them how they would like to be involved in the process.
During community interviews, staff should establish information
repositories where site documents will be made available to the public and
identify locations for public meetings. When an information repository is
established, it is advisable to inform the public in some way of the location
and availability of the documents. When an administrative record is
established, a public notice must be placed in a major, local newspaper of
general circulation. These notifications may be done together. Meetings may
be held and information repositories set-up in centrally-located public
buildings; libraries, schools, community centers, or municipal buildings are
often convenient and accessible locations. Staff should consider the accessi-
bility and convenience of these locations to the physically-handicapped: Are
there ramps for wheelchairs? Are the rooms well-lighted for the visually
impaired?
When the draft RI workplan and community relations plan is completed, a
public briefing or other forum is often scheduled to explain the plans. At
sites where interest is limited, a press release could be issued, including
information on where copies of the workplan (and subsequent site documents)
can be obtained. "Kick-off" fact sheets can be distributed early in the RI to
describe technical activities planned during the RI/FS, announce the location
of the information repositories, and inform the public of the community
relations plan. If plans for site activities change or schedules are delayed
during the RI, local officials and the community should be notified.
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Throughout the RI/FS process, efforts should be made to seek and use the
public's input. Staff might want to hold small workshops during the RI/FS to
solicit public opinion on technical issues. When the RI is completed and
placed in the administrative record file, staff should arrange informal
meetings with community members and local officials to discuss RI findings and
progress on the FS. Briefings and workshops should be scheduled if high
levels of concern are anticipated.
To a certain extent, the structure of a community relations program (e.g.
the timing and schedule for activities) will always be dictated by the
technical progress at the site, because information becomes available and
opportunities for public input are often greatest when the various technical
phases are completed. Nevertheless, the content of a program should be
determined at all times by the nature of community concern. Community
interest does not necessarily proceed in step with technical progress. Often
there are demands for discussion and information before all the technical
issues are resolved.
4.2.2 Community Relations During Feasibility Study
Public concern commonly intensifies during the RI/FS stage of the
remedial process. The public will be anxious to review the alternatives for
cleaning up the site, and will generally have strong opinions about the
technical adequacy of various alternatives. In some cases, the strength of
their opinions will not have been anticipated by their earlier involvement at
the site. Because of the large potential for conflict at this time, it is
vital for a strong community relations effort to accompany the development of
cleanup alternatives during the RI/FS and the selection of alternatives.
Among the community relations activities and techniques suggested during
the development of the RI/FS are:
o Informal meetings with the public, local officials,
or PRPs before and during the development of the
RI/FS, along with briefings and workshops;
o News releases, fact sheets, and publicly available
progress reports that explain the progress and
conclusions of the RI/FS;
o Updates of materials in the information repository
and/or administrative record; and
o Open house to listen informally to public concerns
and answer individual questions.
Staff will need to make the decision as to which of these or other suggested
activities are appropriate during the RI/FS.
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4.3 COMMUNITY RELATIONS AT THE COMPLETION OF REMEDIAL INVESTIGATION/
FEASIBILITY STUDY
The decision-making process following the lead agency's release of the
remedial investigation/feasibility study and proposed plan is a point of
intensive community relations activity. The preceding community relations
efforts prepare a community for their involvement in this step. It is
critical for the lead agency to actively reach out to inform the local public
and receive comments on all remedial alternatives under consideration in the
detailed analysis of the RI/FS, the agency's preferred alternative, the
rationale for that preference, and any proposed waivers to §121(d) to cleanup
standards. These activities should occur throughout the public comment
period.
SARA §113 and §117 have specific public participation requirements at
this point. Other activities are under discussion at this time. Please refer
to Guidance on Preparing Superfund Decision Documents: The Proposed Plan and
Record of Decision for further guidance. Activities include at a minimum:
o Developing a proposed plan, a document prepared for
public comment which summarizes the remedial
alternatives presented in the detailed analysis of
the RI/FS, identifies the preferred alternative,
provides the rationale for that preferred
alternative, identifies any proposed waivers to
cleanup standards and the support agency's comments.
o Publication of a public notice of the availability of
the proposed plan and remedial investigation/
feasibility study, a brief summary of the proposed
plan and announcement of a comment period. This
should be done preferably through a display
advertisement purchased in a major local newspaper of
general circulation.
o Providing the opportunity for submission of both oral
and written comments. The 1985 NCP requires this
formal comment period to be not less than 21 days.
The proposed revisions to the NCP may suggest
extending this to not less than 30 calendar days.
o Providing the opportunity for a public meeting. The
agency must provide a transcript of all formal public
meetings held pursuant to §117(a) of CERCLA during
the public comment period. The transcripts must be
kept and made available to the public in the
administrative record, and may also be distributed in
repositories and on request.
o Preparing a responsiveness summary, which summarizes
significant public comments and the agency's response
which becomes a part of the ROD. It also documents
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how the agency considered public comments throughout
the decision-making process.
o Publication of a newspaper notice which informs the
public that the ROD is signed and of the availability
of the final remedial action plan selected by the
agency. This notice, preferably a display ad, must
be placed in a major local newspaper of general
circulation after the remedy has been selected and
the ROD signed, but before commencement of any
remedial action.
While it is not required, distribution of the proposed plan (and FS fact
sheet, if applicable) to the entire site mailing list and any other interested
parties is highly recommended. In addition, all items developed, received,
published, or made available to the public pursuant to §117 of CERCLA must be
made part of the administrative record for the site. It is also recommended
that copies be placed in information repositories at or near the site.
4.3.1 Proposed Plan
The proposed plan, as required in §117(a), is a critical part of remedy
selection and the administrative record, which should reflect the decision-
making by the lead and support agencies. Staff should consult Guidance on
Preparing Superfund Decision Documents: The Proposed Plan and Record of
Decision (ROD Guidance) for information concerning the proper development of
proposed plans. The following section will provide a brief summary of the
discussion contained in the ROD Guidance.
The proposed plan can be presented in different formats. The formats are
discussed in the guidance mentioned above. It is important to remember that,
whatever form is used, it is a document whose purpose is to inform the public
and should be written in a clear and concise style. Illustrations and figures
should be used where appropriate to better summarize the information in the
RI/FS.
It is recommended that preparation of the proposed plan be a joint effort
of the site team. The Remedial Project Manager, Community Relations
Coordinator and Regional Counsel should coordinate to ensure that the proposed
plan is technically accurate, satisfies statutory requirements, and provides
the public with all necessary information in a clear and concise style for the
lay reader.
In addition to clearly summarizing the alternatives from the detailed
analysis in the RI/FS, the proposed plan must specify the preferred
alternative. It is also important to clearly discuss the rationale for the
preference utilizing the evaluation criteria, as identified in the ROD
Guidance. The proposed plan should notify the public of all opportunities to
obtain additional information and submit comments (e.g. information
repositories/administrative record, RI/FS report, public meetings, contact
person, etc.).
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The proposed plan is a key part of remedial selection which should
reflect the decision-making by the lead and support agencies. The lead agency
will seek the support agency's comments on the proposed plan prior to it being
made available to the public (§121(f)(g)). The proposed plan should include a
discussion of whether the support agency agrees with the proposed plan; or,
when the support agency does not agree, a discussion of the support agency's
comments on the preferred alternative should be summarized.
Another requirement of the proposed plan is to present a discussion of
any waivers [SARA §121(d)(4)] of applicable or relevant and appropriate
requirements that would be invoked if the preferred alternative (or other
alternative) was implemented.
The presentation of the preferred alternative should make clear that the
agency has not made a decision in regard to the preferred alternative and is
open to suggestions on how the preferred alternative or the other alternatives
might be modified to better satisfy the remedial objectives of the site. In
other words, the proposed plan should make clear that public comments are
encouraged on all alternatives, not just the preferred alternative. It is
important to note that changes to the preferred alternative or a shift from
the preferred alternative to another may be made if public comments and/or
additional data indicate that these modifications are warranted.
4.3.2 Newspaper Notice
The advertisement published in the newspaper should include sufficient
information to provide a brief summary of the proposed plan and inform the
public of their opportunity to comment on the RI/FS and proposed plan. The
notice should describe the alternatives analyzed and identify the preferred
alternative. It should also tell how to submit oral and written comments,
provide the location of the information repositories and administrative
record, name a contact person and how to reach him or her, and provide the
opportunity for a public meeting or state the time and place of a public
meeting. It is suggested that the announcement should occur at least two
weeks prior to the beginning of the public comment period so that the public
have sufficient time to obtain and read the document. (See ROD Guidance for
more information and a sample notice.)
In keeping with the objectives of SARA and to reach as broad an audience
as possible, it is suggested that the advertisement should be a display and
designed to attract attention and engage the reader. The agency should
consider purchasing ad space in the most widely read section of the newspaper.
4.3.3 Public Comment Period
The public comment period offers special community relations challenges
and opportunities. It can also make a large contribution to the quality of
the selected remedial alternative. Community relations staff, in coordination
with technical and/or enforcement personnel, should maintain communication
with local officials and interested community members, explain the remedial
alternatives in understandable terms, and solicit public input. If this is
effectively done, concerned groups and individuals can see that their
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interests are receiving serious consideration. This should make a significant
difference in the acceptability of the final remedy. It may be appropriate to
extend the public comment period beyond the three-week minimum in response to
citizen requests. In fact, EPA expects to propose extending the comment
period to no less than 30 calendar days in the 1988 revision of the NCP.
The lead agency is required to provide an opportunity for a public
meeting at or near the site regarding the RI/FS and proposed plan. The
community relations staff may also choose to conduct a formal public hearing,
although this is neither required nor always encouraged. Public hearings, in
which concerned individuals formally state their comments but no agency
response is given, are primarily a vehicle for the public to get comments on
the record, rather than establishing a dialogue with the community. If a
request for a hearing is received, staff should inquire as to why the hearing
has been requested. It may be that the public's needs can be met in a more
informal, productive and less resource-intensive manner. It is preferable to
use hearings in conjunction with small informal meetings and the other
communications techniques mentioned above.
SARA also requires the lead agency to provide a reasonable opportunity
for submission of written and oral comments. The lead agency must keep a
transcript of the public meeting conducted during the public comment period,
pursuant to §117(a) and make the transcripts part of the administrative record
placed at a site information repository available for review and copying.
Such transcripts serve as records for consideration of oral comments received
during meetings. Further substantive discussions regarding the proposed plan,
RI/FS and proposed waivers received by other means such as telephone calls or
meetings with individuals during the public comment period, should also be
documented. This may be done through a record of communication, tapes, or
notes which must be placed in the administrative record. Agency
representatives should also urge commenters to put their thoughts in writing
to ensure they are fully reflected in the record.
4.3.4 Addressing Significant Changes Prior to Adoption of the Final
Remedial Action Plan
After issuance of the proposed plan and prior to the adoption of the
final remedy in the ROD, if new information is made available that
significantly changes the basic features of the remedy as originally presented
in the RI/FS and proposed plan with respect to the scope, performance, and
cost, the lead agency shall be required to document those changes in the ROD.
SARA §117(a) requires additional public comment if those changes are not
reasonable extensions of the information presented in the RI/FS and proposed
plan. Please consult the Guidance on Preparing Superfund Decision Documents:
The Proposed Plan and Record of Decision for further guidance on the community
relations requirements and recommendations in this circumstance.
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4.3.5 Addressing Post-ROD Significant Changes
After adoption of a final remedial action plan or ROD, if any remedial
action is taken, or any enforcement action under §106 is taken, or if any
settlement or consent decree under §106 or §122 is entered into, and if such
action, settlement, or decree differs in any significant respects from the
final plan, the lead agency shall publish an explanation of differences and
the reasons such changes were made. Refer to the Guidance on Preparing
Superfund Decision Documents: The Proposed Plan and Record of Decision for
guidance on the community relations activities that will be required and
recommended in such circumstances.
4.3.6 Responsiveness Summaries
At the end of the public comment period, the lead agency's staff must
prepare a responsiveness summary. The responsiveness summary is submitted as
part of the ROD package that is reviewed and signed by Agency decision-makers.
Once the ROD has been signed, the responsiveness summary is made available to
the public as part of the ROD.
The responsiveness summary serves two functions: first, to provide the
decision-maker with information about the views of the community and
potentially responsible parties regarding the proposed remedial action and any
alternatives. Secondly, it documents how public comments have been considered
during the decision-making process and provides answers to major comments
raised.
A responsiveness summary, in order to serve these purposes, should be a
concise and complete summary of significant comments from the public including
the potentially responsible parties and the agency's response to these
comments. It should be simple, straightforward and readable. It should
include, by way of summary categories, references to all significant comments,
criticisms, and new data received and the agency's position on each issue. It
should not be a point-by-point recitation of each comment. For example,
potentially responsible parties and other members of the public may submit
very detailed and technical comments that require lengthy responses. It may
be advisable to prepare those responses in one document which is placed in the
administrative record and repository(ies), then summarize those responses in
the responsiveness summary. The responsiveness summary also should state
where the detailed response is available for public review. Each written or
documented comment is included in the administrative record and, in this way,
available for public review.
As discussed in the ROD guidance, it is recommended that the
responsiveness summary be divided into four sections:
1. Overview. The first section should describe the
selected remedy and any changes as compared to the
alternatives presented in the proposed plan, feasibility
study, and any new alternatives suggested by the public
which the agency had not previously considered. The level
of community support for the agency's preferred
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alternative should be discussed and compared with the
level of support for other alternatives.
2. Background on Community Involvement. The second
section should provide a brief history of community
interest in the site and should identify key public
issues. Major modifications in the preceding
investigation, operable units, or removal actions which
were the result of public comment and concern should be
noted. A listing of community relations activities
conducted to date may be included as an attachment to the
responsiveness summary.
3. Summary of Comments Received and Agency Responses.
This section should include a summary of comments received
from all interested parties, including citizens' groups or
individuals in the community, the community's technical
advisors, potentially responsible parties, and local
officials. Included within each category of comments
should be the lead agency's response. Possible categories
or subsections might include technical comments, concerns
regarding alternative remedies, public participation
process, cost, etc. Comments received during the public
comment period, as well as significant concerns raised
over the course of the site history relating to the remedy
selection should be included. Substantive comments
received after the close of the comment period also should
be included to the extent practicable. Significant
community concerns which will not, and can not, be
addressed by an agency because of lack of jurisdiction or
other aspects which would make any agency action
inappropriate, should be noted with an explanation of why
no agency action will occur.
4. Remedial Design/Remedial Action Concerns. This final
section should describe public concerns raised during the
RI/FS and public comment period, (e.g. air monitoring
during construction) which have to do with the remedial
action. This will keep EPA alert to community concerns
during this stage of the process.
The responsiveness summary is part of the ROD. However, it should be
written as an independent section which can stand alone to document public
concerns and how they are addressed. The responsiveness summary will be
submitted to the lead and support agency decision-makers for consideration,
and, after ROD approval, to the public. The ROD (with the responsiveness
summary) will be placed in the administrative record file and other
information repositories. In addition, the responsiveness summary may be
distributed to all those who commented and to the entire site mailing list.
The lead agency receives comments from the public throughout the remedial
process. The agency has no obligation to respond to these comments before the
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public comment period on the RI/FS and proposed plan, it is agency practice to
respond to them as quickly as possible. These comments should be documented
in some way such as a record of communication and placed in the administrative
record file. The agency should also incorporate such significant comments
into the responsiveness summary on the RI/FS and proposed plan.
Because of the wide-ranging nature of comments, addressing technical,
legal, financial, and public or private due process concerns, preparation of
the responsiveness summary is a team effort under the direction of the RPM.
The lead agency community relations staff is usually given responsibility for
coordinating this effort because the responsiveness summary is the primary
means of documenting community involvement in the decision-making process.
Therefore, contractor support for the responsiveness summary is normally a
community relations activity in the SCAP. However, with growing technical
sophistication of the community, technical advisors, and technical comments
from the PRPs, these efforts also require substantial additional funding in
the SCAP for the technical support contractor, and may require further
involvement of the technical and legal staff to respond to questions.
4.4 COMMUNITY RELATIONS BEFORE AND DURING REMEDIAL DESIGN
Moving from the FS to remedial design is a major step in the remedial
response. The focus in site activity shifts from remedial planning to actual
cleanup. Roles and responsibilities at the site also change, as the Army
Corps of Engineers or PRPs may take the lead on actual site work.
Furthermore, responsibility for the site may shift from EPA to the State.
Given these major changes, the community may need assurance that its concerns
will continue to be addressed in the subsequent phases of the remedial action.
In the early stages of remedial design, the community relations plan
should be revised to address any new or changing community concerns since the
RI/FS. If local concerns have remained relatively unaltered, the revision may
be limited to providing a new section on future community relations activities
and schedule, with minor changes or updates in other sections. These
additions may be based on a few informal discussions either by telephone or in
person with selected, informed individuals who clearly represent the
community. If community attitudes towards the remedial action have changed
considerably, the plan may need to be substantially rewritten. In such cases,
it is suggested that community interviews be held prior to the revision of the
plan. Interviews may range from formal question and answer formats conducted
with several citizens about many aspects of the site to informal discussions.
These are site-specific decisions that must be made by the lead agency, with
input by the support agency, using its judgment as to what types and number of
discussions are appropriate to develop a CRP that will enhance the response
action.
One objective of revising the plan is to evaluate community relations
efforts to that point. Staff therefore should review all community relations
activities held during the RI/FS and consider which activities were effective
and which were not. Based on this evaluation, the revised plan should project
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community relations activities for remedial action and design that have
already been demonstrated to be successful at a particular site.
In revising the plan, staff also should be alert to particular issues
that might emerge during the remedial design and action. Even though the
public has had the opportunity to comment on the FS, some members of the
public may not agree with the selected remedial action. It is important to be
sensitive to such disagreements and to identify ways in which these and other
public concerns can best be addressed during the remedial design. Community
involvement at this stage also can help staff design factors such as the
construction of traffic routes and work schedules to minimize impact on the
community.
During the RI/FS many changes may have occurred; there may have been
resignations, elections, deaths, arrivals, and departures in the community.
Therefore, all lists of names, addresses, and telephone numbers of local
citizens, officials, and institutions should be updated when the plan is
revised.
When the final engineering design is near completion, EPA policy provides
that staff notify the public. At this point, staff should prepare a fact
sheet explaining the engineering design. Notification of the design fact
sheet may be accomplished with a notice in a local newspaper, mailing the fact
sheet to those on the mailing list, or other technique best suited to the
affected community and interested parties.
At this stage, the public might be surprised to learn how long the
cleanup will take. Moreover, after a lengthy RI/FS and the promise of an
extended cleanup process, the public may anticipate that the site will
ultimately be restored to its original condition. Some may expect that all
risks at the site will be eliminated. Staff can help the public appreciate
that while full cleanup is the exception rather than the rule, the site will
be cleaned up to levels that are considered safe and are consistent with
applicable or relevant and appropriate requirements of other Federal and State
environmental laws(28). .A review of Superfund objectives and constraints at
this stage could be very useful.
4.5 COMMUNITY RELATIONS DURING REMEDIAL ACTION
With the remedial action, site activity increases as construction of the
selected remedy begins. Although the engineering design should have been
explained in a fact sheet distributed to the community before the remedial
action, residents may still have questions about the actual construction. If
site conditions permit, site tours can be conducted to enable community
members to better understand the nature of the problem at the site and the
response action under construction. If site access is restricted, a pictorial
display posted at a local library or in the information repository allows the
community'to view the progress at the site.
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While there are no formal community relations requirements during the
remedial action, staff should ensure that the community is kept informed of
the schedule of site activities, changes in the remedial action schedule, and
any new findings at the site. Effective tools for keeping the public and
local officials informed include periodic updates to describe progress at the
site, press releases announcing site developments or changes in the schedule
of events, and informal meetings or public availability sessions to allow the
community to meet with agency staff to discuss site issues.
4.6 COMMUNITY RELATIONS DURING OPERATION AND MAINTENANCE
Under CERCLA, States are responsible for operating and maintaining site
remedies once the remedial action has been completed. Thus, at this point in
the remedial process, all Fund-lead sites effectively become State-lead sites.
However, according to EPA's guidance on "State Participation in the Superfund
Remedial Program"(33) and the March 26, 1986 "Draft Addendum to January 17,
1986 Guidance, CERCLA Funding of State Oversight of Potentially Responsible
Parties (PRPs)"(21), the State may obtain EPA funding and assistance for up to
one year after remedial action to ensure that the remedy is operational and
functional through a cooperative agreement. These agreements also establish
lead responsibility for community relations activities. After this one year
period, States have responsibility for community relations activities for both
State-lead and Fund-lead sites for the duration of operation and maintenance
(O&M).
Community relations efforts during the O&M phase are likely to be less
intense than in the earlier phases of a remedial response when public concerns
were more strongly felt and expressed. However, public concerns do not
necessarily vanish with the signing of the ROD. The public may continue to
have health concerns, or questions about site safety or long-term use of the
site. Hence, those responsible for community relations at the site should
continue efforts to monitor community concerns, exchange information, and,
where appropriate, meet with community residents to discuss their concerns.
When the remedial response shifts from remedial action to O&M, certain
events can be anticipated:
o Planned and unplanned shutdowns. Planned shutdowns
will occur whenever it is necessary to clean and
adjust equipment. To prevent the public from
becoming alarmed that a new danger has been
discovered at the site, they should be informed well
in advance concerning maintenance shut-down
schedules. Unplanned shutdowns due to equipment
failure and extraneous events such as a labor strike
will be especially dismaying to those living near the
site. They may fear a new danger at the site.
Again, the public should be immediately informed by
the lead agency what is happening.
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Changes in the appearance of the work site due to
weather conditions. If, for example, the weather
suddenly becomes much cooler, the water vapor above
an air stripping tower may condense into a visible
plume. Some citizens may fear that an explosion has
occurred. To prevent or allay these fears, it is
advisable to tell people in advance what to expect.
Increased civic awareness that the site will not
always be a Superfund site, but may be restored to
other uses within the community. To some citizens,
the departure of agency staff and contractors from
the site may be as upsetting as their arrival. Staff
should therefore ensure that the community
understands the long-term plans for the site and
knows which State and local officials will be
ultimately responsible.
4.7 COMMUNITY RELATIONS DURING THE NATIONAL PRIORITIES LIST (NFL) DELETION
PROCESS
A site can be deleted from the NPL by meeting one of three criteria, as
discussed in 2.4. Procedures for site deletion from the NPL are similar to
rule-making for NPL site additions. According to draft "Guidance on Deletion
of Sites from the National Priorities List (NPL)"(25), Regional staff should
prepare a deletion docket containing all pertinent information supporting the
deletion recommendation before a deletion recommendation is transmitted to
Headquarters. The Regional public docket and local information repositories
should contain complete copies of all supporting information prior to
publication of public notification statements announcing EPA's intent to
propose a site deletion.
Public notification statements are prepared by Regional staff. The
Notice of Intent to Delete will appear in the Federal Register and appropriate
local publications. Additional information provided in the notice should
include:
o Summary of EPA deletion criteria and how the site
meets the criteria;
o Location of Regional dockets;
o Location of local information repositories containing
relevant documents for community review;
o Name and address of a Regional contact where comments
may be sent;
o Brief site history (including location, former use,
type of contaminants, and date of inclusion on the
NPL);
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o Description of all response actions taken at the site
(including scope of RI, if applicable, general
results, and conclusions);
o Specification of cleanup standards and criteria and
results of all confirmatory sampling;
o Summary of Superfund community relations activities;
o Description of EPA's close-out plan for the site,
explaining operation and maintenance procedures and
the monitoring program that will be implemented;
o Acknowledgement of State concurrence to delete the
site; and
o Statement indicating that EPA retains the authority
to spend money on a deleted site if future conditions
warrant such actions.
A responsiveness summary that documents comments received on the Notice
of Intent to Delete and EPA responses to the comments should be prepared to
support a deletion recommendation. This responsiveness summary should
describe:
o Community relations activities conducted during the
remedial planning and action stages of the cleanup;
o Comments received during the comment periods;
o Comments received during public meetings (if held);
o Comments from settlement-related comment periods (if
appropriate);
o EPA responses to national and local public comments;
and
o Justification for proceeding with the deletion (if
public comments indicate strong disagreement with the
recommendation).
Following approval of the Regional Administrator, a copy of the
responsiveness summary should be included in the Regional docket and published
as part of the final rule.
4.8 COPING WITH UNANTICIPATED DEVELOPMENTS
Ideally, community relations plans would anticipate all likely community
concerns and identify appropriate community relations activities accordingly.
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In reality, unanticipated developments commonly occur. The effectiveness of
the community relations program at each site will defend on how well such
unforeseen occurrences are managed. While by definition it is not possible to
plan directly for unanticipated developments, each community relations program
should have sufficient resources and flexibility to respond to these
situations. For example, if an environmental group suddenly begins picketing
at a site where there has been no prior community involvement, agency
officials may want to meet with representatives of the group and demonstrate
the agency's willingness to consider community concerns. Similarly, if agency
officials discover significantly greater contamination than anticipated at a
site, community relations and/or technical staff should meet with affected
citizens, prepare statements, hold informal meetings concerning the new
findings, and conduct press briefings.
As these examples suggest, agency efforts to address unanticipated
developments will be most effective if community relations and technical staff
respond as soon as possible. Good crisis management is crucial to the
effectiveness of any public involvement program. Staff confronted with
unanticipated developments should seek vigorously to pursue general community
relations program goals: listen to and consider community concerns, and keep
citizen and local officials accurately informed about site activities.
4.9 SUMMARY
Exhibit 4-1 summarizes community relations activities that are suggested
for each stage of a remedial response. (Exhibit 2-1 in Chapter 2 displays
required activities during remedial response.) These suggested activities .may
or may not be useful at any given site. The decision whether to conduct any,
some, or all of these activities will depend ultimately on site-specific
factors such as level of technical activity, or perceived or real degree of
risk present at the site. Some sites may not require extensive briefings or
numerous public meetings, while others may require regular consultation with
community members and frequent releases of information. Each community
relations program should be site-specific and reflect the needs and
suggestions of individual communities. Appendix A describes in more detail
the activities recommended in this chapter.
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EXHIBIT 4-1
SUGGESTED COMMUNITY RELATIONS
ACTIVITIES DURING REMEDIAL RESPONSE1
Technical Phase
Suggested Activities
1) Preliminary Assessment
2) Site Inspection
3) Before RI
4) During the RI
o Technical staff brief community
relations staff on the site
o Community relations staff brief
technical staff on community issues
o Telephone local officials and concerned
community members
o Telephone local officials and
concerned community members
o Hold small, informal meetings with
community members
o Distribute fact sheet describing site
inspection procedures and possible
outcomes
o Prepare mailing list
o Designate an agency contact
o Notify public of availability of
information repository
o Technical staff brief community rela-
tions staff on scope of RI work plan
o Hold public meeting to present the
Superfund process and the final RI/FS
work plan
o Community relations staff brief
technical staff on information gathered
during community interviews
o Distribute a "kickoff" fact sheet
o Maintain telephone contact with key
community representatives
o Conduct workshop on the Superfund
program
o Notify interested parties of delays or
lags in site activity
o Hold meetings with the community to
discuss RI findings
Suggested activities should be undertaken in conjunction with
requirements specified in Exhibit 2-1.
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EXHIBIT 4-1 (continued)
SUGGESTED COMMUNITY RELATIONS
ACTIVITIES DURING REMEDIAL ACTIONS
Technical Phase
Suggested Activities
5) During the FS
6) Completion of the FS and
Proposed Plan
7) Remedial Design
8) Remedial Action
9) Operation and Maintenance
(O&M)
o Maintain telephone contact with key
community representatives
o Solicit public comments on criteria for
evaluating and screening FS alternatives
o Distribute fact sheet and/or letters
to the community on the CRP mailing list
o Issue news releases
o Inform those on mailing list that the
RI/FS and proposed plan are available
for public review and comment
o Evaluate effectiveness of past
community relations activities
o Distribute fact sheets explaining
remedial design
o Brief Corps of Engineers on community
relations
o Hold small meetings or open houses
to explain the remedial technology
o Conduct site tours
o Prepare an exhibit showing a pictorial
history of the site
o Publish maintenance schedules
o Prepare fact sheets explaining O&M
procedures
o Hold meetings with the interested public
to encourage local responsibility for
the site
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CHAPTER 5
COMMUNITY RELATIONS DURING REMOVAL ACTIONS
(Reserved)
This chapter is reserved for discussion of community relations activities
during removal actions. The National Contingency Plan requires community
relations activities at a removal site if the action extends or is anticipated
to extend beyond 45 days. The proposed NCP may state this will be changed to
120 days. The Emergency Response Division (ERD) and community relations
personnel at EPA Headquarters are examining the specific community relations
needs for removals. Appendix G summarizes the proposed NCP requirements for
community relations.
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CHAPTER 6
COMMUNITY RELATIONS REGARDING ADMINISTRATIVE
RECORDS AND ENFORCEMENT ACTIVITIES
This chapter is being revised to reflect procedures for compiling
administrative records. The revised chapter will be circulated for Regional
comment in June 1988.
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CHAPTER 7
TECHNICAL ASSISTANCE
(Reserved)
Superfund reauthorization legislation provides for technical assistance
grants to citizen groups at Superfund sites. These grants will enable
affected citizens to obtain expert advice in reviewing and assessing
technical information produced during work at a remedial site. Once EPA
develops guidance and regulations for the implementation of technical
assistance grants, this chapter will be completed.
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CHAPTER 8
INTERAGENCY COORDINATION
Superfund response actions commonly require the participation of several
government agencies at the Federal, State, and local levels. Depending on
site-specific factors, EPA, another Federal agency, or a designated State
environmental agency, may be responsible for managing the response. Other
Federal agencies, such as the Department of Health and Human Services, the
U.S. Army Corps of Engineers, the Federal Emergency Management Agency, or the
Department of Justice, and their State counterparts, may also be vital
contributors by providing legal, technical, and engineering support. An
important community relations task at any Superfund site is the coordination
by the lead agency of the community relations activities of these various
agencies. The lead agency, as defined in §300.6 and §300.33 of the NCP is
responsible for conducting community relations activities and ensuring that
the requirements specified in Chapter 2 of this handbook are met. Effective
coordination of community relations activities is vital to ensuring that:
o Public input is properly channeled to the appropriate
government decision-makers; and
o The community receives accurate, timely, and
consistent information, even when that information
must come from a variety of sources.
This chapter discusses the roles and responsibilities of Federal, State,
and local agencies for community relations at Superfund sites. These roles
and responsibilities vary depending on site ownership and response status.
This chapter focuses on the assignment of lead responsibility for community
relations activities and on contributing roles. The discussion in previous
chapters on recommended community relations activities for remedial and
removal actions are generally applicable regardless of which agency has lead
responsibility for community relations.
Lead responsibility for Superfund response efforts resides primarily with
EPA. EPA may, however, work with another Federal agency through an
interagency agreement (IAG), or a State through a State memorandum of
agreement (SMOA) to conduct a remedial action. Through such agreements, EPA
may delegate lead responsibility for a response at a particular site to a
State or another agency, but still retain final authority over remedial action
at that NPL site. CERCLA establishes a process by which States may enter into
cooperative agreements or contracts with EPA and authorizes EPA to prescribe
the terms and conditions of such agreements. SARA §120(e)(6) also authorizes
EPA to enter into agreements with potentially responsible parties (PRPs) under
§122 and using consent decrees to conduct RI/FSs or remedial actions at sites
they leased on Federal facilities if EPA determines that such actions will be
done properly and within the required deadlines.
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8.1 FEDERAL, STATE, AND LOCAL AGENCY ROLES IN SUPERFUND
Many Federal agencies may provide valuable scientific, technical, and
managerial assistance to the lead agency in undertaking response efforts. For
example:
o The Department of Agriculture (USDA) can provide
expertise in managing agricultural, forest, and
wilderness areas. Through the Soil Conservation
Service, USDA can predict the effects of pollutants
on soil and their movements over and through soil.
o The Department of Commerce (DOC), through the
National Oceanographic and Atmospheric Administration
(NOAA), can provide scientific expertise on marine
resources and habitats for which it is responsible;
information on actual and predicted meteorological,
hydrologic, ice, and oceanographic conditions for
marine, coastal, and inland waters; and prediction of
movement and dispersion of pollutants through
trajectory modeling.
o The Department of Defense (DOD) provides assistance
in responding to releases from DOD vessels or
facilities and in managing Fund-lead remedial
actions. Specifically, DOD officials serve as
On-Scene Coordinators (OSCs) for removal actions and
as Remedial Project Managers (RPMs) for remedial
actions resulting from releases of hazardous
substances, pollutants, or contaminants from DOD
vessels and facilities. In addition, the U.S. Army
Corps of Engineers (COE) manages the remedial design
and action phases of Fund-lead remedial actions.
o The Department of Energy (DOE) can help in
identifying the source and extent of radioactive
releases and in the removal and disposal of
radioactive contamination.
o The Department of Health and Human Services (DHHS) is
responsible for providing assistance on all matters
related to the assessment of health hazards at a
response and for the protection of the health of both
response workers and the public.
o The Federal Emergency Management Agency (FEMA)
provides assistance on civil emergency planning (and
may, in fact, assume the lead in managing a response
when evacuation or relocation of residents and
businesses is required).
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o The Department of the Interior (DOI) offers
expertise, through its several bureaus and offices,
on the impacts of hazardous releases on wildlife,
soils, vegetation, and surface and ground water.
o The Department of Justice (DOJ) represents the
Federal government, including its agencies, in
litigation.
o The Department of Transportation (DOT) provides
expertise on all modes of transporting oil and
hazardous substances. Through the United States
Coast Guard (USCG), DOT offers support in responding
to releases into coastal navigable waters of the U.S.
At State- and Federal-lead sites, the State counterparts of many of these
Federal agencies also may provide valuable technical and managerial expertise
such as providing information on ARARs as required by SARA. According to
Appendix F of EPA guidance on "State Participation in the Superfund Remedial
Program," (33) the coordination of the various State participants in a
response action is a State responsibility. Therefore, a State, in its
cooperative agreement, is expected to identify those agencies or entities that
will participate in the response action, briefly describe the role of each,
and agree to oversee their participation in close coordination with EPA.
Federal and State agencies have an additional role in the Superfund
process as trustees of natural resources. For purposes of CERCLA, trustees
are Federal or State governmental agencies and Indian tribes that have
authority over the natural resource, and would include DOI, USDA, DOC, and
State natural resource agencies.
Under SARA, EPA is required to notify trustees of potential natural
resource damages resulting from releases and to coordinate with such trustees
in performing assessments, investigations, and planning. (See NCP for further
information.) Community.relations staff should remain alert to the potential
active involvement of trustee agencies in the response process so they can
thoroughly explain the extent and purpose of such involvement to community
residents.
Local governments may play an active role in community relations
activities. In addition to being the recipients of information from Federal
or State agencies, they may assist in distributing fact sheets and other
community relations documents for public review. In addition, local officials
are expected to provide input during the decision-making process.
8.2 FEDERALLY-OWNED FACILITIES
Several Federal agencies also own facilities at which hazardous wastes
are or were disposed. Many Federally-owned facilities have been proposed for
and placed on the NPL. While responses at these facilities are subject to
CERCLA and NCP requirements, SARA further defines the process by which Federal
agencies are to undertake remedial actions and provides for joint selection of
8-3
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the remedy by EPA and other Federal agencies. If there is disagreement, EPA
must make the determination. SARA also notes that "No department, agency, or
instrumentality of the United States may adopt or utilize any such guidelines,
rules, regulations, or criteria which are inconsistent with the guidelines,
rules, regulations, and criteria established by the Administrator under this
Act" (§120(a)(2)). While Federal facilities may offer alternative methods for
meeting community relations requirements, EPA must make the determination
whether these alternatives are consistent with these rules, regulations,
guidelines, and criteria.
Response actions at Federal facilities are to be conducted according to
site-specific interagency agreements (lAGs) between EPA and the department,
agency, or instrumentality that owns or operates the facility. In addition,
the State is often involved in site-specific lAGs. The content and scope of
such lAGs will be determined on a site-specific basis and the agreements will
designate responsibility for community relations activities. Accordingly, it
is possible that Federal agencies other than EPA will conduct community
relations activities for response actions at Federal facilities. For non-NPL
Federal facilities, State law applies to response actions; accordingly,
community relations activities must be undertaken as required by State law.
(More information on Federal facilities will appear in the final draft of this
handbook.)
EPA also recognizes that Federal agencies may have their own community
relations programs and guidance. However, SARA §120(a)(2) states that EPA
guidelines, rules, regulations, and criteria are applicable to Federal
agencies, and that Federal agencies may not adopt or utilize any guidelines,
rules, regulations, or criteria which are inconsistent with those established
by the EPA Administrator under CERCLA. This handbook provides Federal
agencies with the guidance to more closely coordinate community relations
efforts in the planning and implementation of their community relations
programs to be consistent with CERCLA, the NCP, and EPA policies. EPA
Regional offices should have close interaction with other Federal agencies to
ensure that guidance is provided on a site-by-site basis.
8.3 INTERAGENCY COORDINATION AT FEDERAL-LEAD SITES
Other Federal and State agency staff may participate in community
relations activities during a Federal-lead response. States may receive funds
under a cooperative agreement for certain coordinating activities at
Federal-lead sites, including community relations. The Regional community
relations coordinator is responsible for coordination and oversight of
community relations activities conducted by State or other agencies. (§300.39
of the NCP requires that any public information activities be approved by the
on-scene coordinator or remedial project manager.) Two Federal agencies that
may frequently contribute to Federal-lead responses, and therefore merit
special attention in this context, are the U.S. Army Corps of Engineers (COE)
and the Agency for Toxic Substances and Disease Registry (ATSDR) of the
Department of Health and Human Services.
The U.S. Army Corps of Engineers is usually responsible for managing the
remedial design and action phases of a Federal-lead remedial response and may
8-4
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also provide technical assistance to EPA during the RI/FS. Under the
"Interagency Agreement Between the U.S. Army Corps of Engineers and the U.S.
Environmental Protection Agency in Executing CERCLA"(4), however, EPA retains
the lead responsibility for community relations and for interagency
coordination at sites where COE is involved.
Under SARA, ATSDR is required to perform a health assessment at every
site on the NPL. ATSDR also may perform health assessments on non-NPL sites
in response to citizen petitions or under other circumstances. A health
assessment combines site-specific risk assessment information developed by EPA
during the RI/FS, with health data on people possibly affected by the site.
In addition, ATSDR may issue health advisories at sites where ATSDR has
determined that a significant threat to public health exists and may provide
health-related assistance and technical advice to EPA when requested. ATSDR
may jointly conduct some of its activities with other participating agencies
of the Public Health Service and with State health departments. EPA retains
the lead in conducting community relations activities at Superfund sites, but
ATSDR may, at EPA's request, help conduct these activities.
8.4 INTERAGENCY COORDINATION AT STATE-LEAD SITES
The procedures for coordinating community relations activities at
State-lead sites are analogous to those at Federal-lead sites. The State and
its designated agencies have lead responsibility for planning and implementing
the required community relations activities. EPA maintains oversight over
State activities and, where there is a cooperative agreement, may provide
assistance including actually conducting community relations activities. The
State may submit a final CRP to EPA for review and approval. The State also
may request funds for the development of a CRP in the cooperative agreement
application. The State must prepare the CRP and have it approved by EPA
before remedial investigation work begins.
CERCLA assigns States the responsibility for operating and maintaining
site remedies after remedial action is completed. Thus, all Federal-lead
sites effectively become State-lead sites following completion of remedial
action. (On ground-water issues, see §104(c)(6) of SARA.) EPA's directive
entitled "State Participation in the Superfund Remedial Program," however,
allows for the State to request EPA funding and assistance for the first year
of O&M through a cooperative agreement. During this initial period, lead
responsibility for community relations activities at Federal-lead sites will
be designated in the cooperative agreement for the site. States will maintain
lead responsibility for community relations at State-lead sites during the
initial O&M period and at all State-lead and Federal-lead sites for the
duration of O&M.
8.5 INTERAGENCY COORDINATION AT ENFORCEMENT SITES
Cooperative agreements may also be established between EPA and the State
at enforcement-lead sites. In general, if EPA negotiates the order with
responsible parties, then EPA is designated as the lead agency for community
relations. If the State negotiates the order, then the State will have the
lead for community relations if there is an IAG. In this situation, EPA will
8-5
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provide oversight and States will be required to follow EPA community
relations requirements outlined in Chapters 2 and 6. See "CERCLA Funding of
State Oversight of Potentially Responsible Parties (PRPs)"(17) and "Draft
Addendum to January 17, 1986 Guidance, CERCLA Funding of State Oversight of
Potentially Responsible Parties (PRPs)."(21)
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CHAPTER 9
ADMINISTRATION OF COMMUNITY RELATIONS PROGRAMS
This chapter identifies the respective roles and responsibilities of EPA
Headquarters, Regional Offices, and contractors in community relations
activities. The suggestions in this chapter also are intended to aid staff in
other Federal and State agencies determine responsibilities and identify areas
where contractor support is appropriate. Supplemental guidance on management
of community relations contractor support is currently being prepared. Until
such guidance becomes available, staff are encouraged to call EPA Headquarters
Remedial Planning and Response Branch with questions on contractor management.
9.1 THE ROLE OF HEADQUARTERS AND REGIONAL OFFICES
EPA Headquarters and Regional Office staff have distinct responsibilities
for planning and implementation of a community relations program at a site.
Headquarters is responsible for developing policy, guidance, and training
programs, overseeing community relations implementation, evaluating programs,
and analyzing resources. Further, Headquarters provides general informational
materials on the Superfund program, national contract management, and other
support for services that may be required in the field.
For EPA-lead responses, the Regional Offices are responsible for
developing community relations plans and programs, conducting community
interviews, developing site-specific public information materials, soliciting
citizen input, issuing press releases, managing and supervising contractor
support, and implementing community relations programs. The roles of EPA and
the State for community relations in State-lead responses are specified in the
cooperative agreement for a site or State memorandum of agreement (SMOA).
Regional Offices may play an advisory or oversight role in the development and
implementation of community relations, or may take full responsibility for the
site program where a cooperative agreement or IAG exists.
9.2 APPROPRIATE TASKS FOR CONTRACTORS
Community relations contractors can provide support services for program
activities in a number of situations. However, one principle must be
maintained throughout the program: contractors must never represent, or
appear to speak for, the lead agency on policy issues before the public, other
government officials, or the media.
The community relations programs at individual sites will include many
activities that can be supported by contractor staff. Some activities will
involve routine assistance in daily or on-going site work; others will involve
behind-the-scenes preparation; and still others may require specific
expertise, such as presenting sampling results or discussing engineering
plans. Contractors have been widely used for conducting community interviews
9-1
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and preparing community relations plans. Contractors are very useful for
ensuring that technical information is accurate and understandable.
The amount of contractor assistance required, and the division of
responsibility between the lead agency and contractor staff, will vary
significantly from site to site. Staff needs to work closely with the
contracts officer in delegating tasks to contractors regardless of the
particular type or level of contractor support at a given site. Exhibit 9-1
illustrates appropriate responsibilities of contractor staff for several
community relations activities.
9.3 MANAGING CONTRACTOR SUPPORT
For the community relations program at each site, the lead agency needs
to determine the level of effort to apply and the corresponding financial
resources. Factors used to determine the LOE include site priority, available
time of contractor, balancing CRC workload and schedule for all community
relations site activities. Accordingly, the extent of contractor support at a
site will depend on the resources available as well as the level of community
interest and the response action chosen.
Some factors to consider in determining contractor resource needs are:
o The number of contractor hours necessary to complete
a task (including internal review);
o The extent of site-related administrative and
management tasks (e.g., time sheets, monthly
reports);
o Whether the task involves travel (i.e., airfare,
local transport, and per diem costs); and
o Other direct costs, such as typesetting and printing
of fact sheets and other reports; graphics;
transcripts of meetings; newspaper advertisements;
mailings to interested community members; express
mailing costs; telephone services; and any temporary
staff exclusive of typing support.
Because these factors will vary from site to site, the community relations
coordinator and technical staff should meet early in the planning process to
determine the appropriate level of contractor support for the particular site.
The contracting agency evaluates contractors based on their performance.
The evaluations assess the contractor's ability to identify and focus on
issues critical to the site, the innovativeness of their technical approach,
the quality and timeliness of their work, and whether the work was completed
within the established budget.
9-2
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APPENDIX A
EXAMPLES OF COMMUNITY RELATIONS ACTIVITIES
This appendix discusses many of the community relations activities
mentioned in the preceding chapters. It is intended as a reference to be
consulted when a decision must be made on whether and when to conduct a
certain type of community relations activity. The discussion of each activity
includes:
o A description of the activity;
o Its purpose;
o Techniques for conducting the activity (key points to
remember);
o When to conduct such an activity in a Superfund response;
o Other activities that can be conducted in conjunction with this
activity;
o Benefits of the activity; and
o Limitations to its effectiveness.
The following activities are discussed:
A.I Briefings
A.2 Community Interviews
A.3 Contact Person
A.4 Door-to-Door Canvassing
A.5 Exhibits
A.6 Fact Sheets
A.7 Formal Public Hearings
A.8 Information Repository
A.9 News Conferences
A.10 News Releases
A.11 Observation Deck
A.12 On-Scene Information Office
A.13 Open Houses
A.14 Presentations
A.15 Public Comment Period
A.16 Public Meetings
A.17 Public Notices
A.18 Responsiveness Summaries
A.19 Revision of Community Relations Plans
A.20 Site Tours
A.21 Small Group Meetings
A.22 Superfund Briefing Book
A.23 Technical Advisor
A.24 Telephone Contacts
A. 25 Telephone Hotline
A.26 Telephone Network/Phone Tree
A.27 Translations
A.28 Using Existing Groups/Publications
A.29 Workshops
A-l
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As Chapters 3 and 4 emphasized, the key to a successful community
relations program is targeting activities to the distinctive needs of the
community. Therefore, not all of the activities described in this appendix
are appropriate for every response action.
All activities discussed in this appendix could be conducted during the
RI/FS phase of a remedial action. Most could also be conducted during the
remedial design, remedial action, and operation and maintenance phases.
Several are activities that would even be appropriate during the preliminary
assessment/site investigation phases. This appendix identifies the specific
type and phases of a response action where a community relations activity may
be appropriate. The applicability of specific activities will also depend on
the characteristics and needs of the community and the availability of agency
resources.
This appendix does not exhaustively discuss techniques for conducting
public participation activities. Instead, it calls attention to key points to
remember in conducting such activities in the context of a Superfund response
action. Readers should consult public participation manuals, such as the
manual prepared for EPA's water programs, for additional information. A few
of these manuals are listed in the bibliography at the end of the handbook.
A-2
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A.I BRIEFINGS
Description of Activity
Brief sessions held with key State and local officials and citizens to
inform them of the status of site activities. Agency staff conduct these
sessions in person, and the briefings usually precede release of
information to the media.
Purpose
Removal Action: To notify key officials and citizens of the nature and
reasons for the action, and to inform them of recent developments at the
site.
Remedial Response: To inform key officials and citizens about recent
developments at the site; to provide them with background material on
technical studies, results of the field investigations, and engineering
design; and to report to them on remedial action planning and progress.
Technique
To schedule and hold briefings:
Inform key State and local officials, citizens, and other interested
parties ahead of time of a briefing concerning recent activities at the
site or other related topics. It is usually best to hold the initial
briefing in a small public room, such as a. hotel meeting room or a
conference room. Where relationships are antagonistic, it may be best to
hold the briefing in a neutral location.
Present a short, official statement about the response plans or
preliminary findings from the site activities (such as inspections,
investigations, and engineering design). Describe the EPA or State
decision process, and announce future steps in the process.
Answer questions about the statement. Anticipate questions and be
prepared to answer them simply and directly.
When to Conduct
Briefings are appropriate when State or local officials or citizens have
expressed a moderate to high level of concern about the site.
Briefings are recommended at any point during the RI/FS, remedial design,
remedial action, and O&M phases of a remedial action. If local officials
or citizens have expressed concern during the preliminary assessment or
site investigation phases, a briefing may be appropriate to explain the
Superfund program and the technical activities that are scheduled for the
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A.I BRIEFINGS (Continued)
site. Briefings are also useful when unexpected events or delays occur
at the site.
Acconpanying Activities
Briefings usually precede news conferences, news releases, small group
meetings, or public meetings.
Benefits
Briefings allow State and local officials and citizens to question the
agency directly about any activity prior to public release of information
regarding that activity. By doing so, officials and citizen leaders will
be prepared to answer questions from their constituents when the
information becomes public. Briefings also allow for the exchange of
information and concerns.
Limitations
Bad feelings or bad publicity could result if some individuals who
believe they should be invited to the briefings are not. Care must be
taken not to exclude such persons, or otherwise to convey an impression
of favoritism towards certain interested parties.
Although briefings can be effective, they should not be the only means of
communicating with Superfund site communities. Briefings for State and
local officials and citizens should always be complemented by activities
to inform the general public, such as small group meetings or public
meetings.
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A. 2 COMMUNITY INTERVIEWS
Description
Informal face-to-face interviews held with selected local residents,
government officials, community groups, media representatives,
potentially responsible parties, and other individuals interested in site
activities. (This activity was called "on-site discussions" in the 1983
interim version of the handbook.)(19)
Purpose
To obtain first-hand information about the community near a Superfund
site. To gain an understanding of the site's history, the community's
involvement with the site, and the political climate in the area. To
identify credible sources and disseminators of information. To learn how
the community would like to be involved in the Superfund process. To lay
the groundwork for developing an effective community relations plan for
the site.
Technique
Conduct community interviews before the community relations plan (CRP) is
prepared.
Identify contact people: Begin by contacting the project officer for the
site, and staff from appropriate State or local environmental agencies.
These people should be able to provide some background information about
the site and the names of key people to contact.
Prepare for the interviews: Before conducting the interviews, learn as
much as possible about community concerns regarding the site. Review any
available agency files that contain news clippings, documents, letters,
and other sources of information relevant to the site. Identify local
residents, key State and local officials, and citizen organizations that
have been involved with or expressed concern about the site. While it
may not be possible to meet with all interested parties, staff should
determine which individuals are most likely to provide the greatest
variety of perspectives about the site. Prepare a list of questions that
can serve as a general guide when speaking with residents and local
officials.
Arrange the interviews: Telephone the contact people and arrange a
convenient time and place to meet. Ideally, the meeting place should
promote candid discussions. While government and media representatives
are likely to prefer meeting in their offices during business hours,
local residents and community groups may be available only in
non-business hours. Meetings at their homes may be most convenient.
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A. 2 COMMUNITY INTERVIEWS (Continued)
Meet with local government officials: Interview government officials.
Include a brief introduction explaining why they are being interviewed
and what kind of information is needed.
Meet with residents and conmunity groups: Be sensitive to residents'
needs and remind them that the purpose of the interview is to gather
preliminary information for planning an appropriate program for citizen
participation. This reminder should prevent raising unrealistic
expectations (for instance, about how quickly a site will be cleaned up).
With adequate preparation, the interviewer can acquire information useful
for developing the CRP, as well as respond to initial citizen concerns
about the site. It must be emphasized, however, that the primary purpose
of community interviews is to collect, rather than disseminate,
information.
Assure interviewees that their statements will remain confidential: At
the beginning of each interview, explain that the CRP will be presented
to agency officials and other interested persons, and will be placed in
an information repository established at the site. Explain that the
information will be used to understand community concerns and that a
record of the contact will be made, but the agency will not attribute any
specific statements or information to any individual without his or her
permission. Ask interviewees if they would like their names, addresses,
and phone numbers on the contract list, which is appended to the CRP.
Identify other possible contacts: During the discussions, ask for names
and phone numbers of persons who could provide additional information on
the site, such as district health officials or local ministers. Add
these names to the list of interested citizens.
Gather information on past citizen participation activities: Ask the
interviewees how they perceive the agency's past efforts in providing the
community with information about the site, and whether they would like to
receive any fact sheets or other printed information as the response
action continues. Keep a list of persons interested in being kept
informed.
Assess how citizens would like to be involved in the Superfund process:
Briefly explain the Superfund process and ask the interviewees how they
would like to be involved and informed of site activities.
Identify citizens' concerns: When identifying concerns, consider the
following factors:
o Threat to health --Do community residents believe their health
is or has been affected by the hazardous substances at the
site?
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A.2 COMMUNITY INTERVIEWS (Continued)
o Economic loss --Do local homeowners or businesses believe that
the site has caused them or will cause them economic loss?
o Agency credibility -- Does the public have confidence in the
performance of the agency responsible for the remedial or
removal action?
o Involvement -- Has a group leader been vocal in the community?
Has this group leader gained substantial local following? What
has been the working relationship between the group leader and
agency officials? What has been the working relationship
between the group leader and other groups?
o Media -- Have events at the site received substantial coverage
by local, State, or national media? Do local residents believe
that media coverage accurately reflects the nature and
intensity of their concerns?
o Number affected -- How many households or businesses perceive
themselves as affected by the site?
When to Conduct
As a basic requirement of the Superfund community relations program,
community interviews must be conducted before a CRP is developed.
Ideally, community interviews should also be conducted before revising a
CRP, because months, or perhaps years, may have elapsed since the first
round of interviews, and therefore community sentiment may have changed.
If there has been much interaction with the community and interested
parties, agency information on citizen concerns may be current and
active. In such situations, it may be necessary to conduct only a few
informal discussions in person or by telephone with selected, informed
individuals who clearly represent the community. This small amount of
input would verify, update, or round out the information already
available to the lead agency and provide sufficient basis for the
development of a GRP. The lead agency, with the input of the support
agency, will decide which interviews and how many are appropriate to
accomplish the objective of obtaining sufficient information about
community needs and concerns to develop an effective CRP. The revised
CRP is prepared prior to the remedial design stage.
Accompanying Activities
Because community interviews are held to determine an appropriate
community relations strategy for the site, these interviews will
generally precede, rather than be accompanied by, other community
relations activities. Nevertheless, community interviews will involve
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A. 2 COMMUNITY INTERVIEWS (Continued)
making some initial telephone contacts and identifiying appropriate
locations for information repositories and public meetings.
Benefits
The views of citizens and government officials are often not stated in
the media. Community interviews, however, are excellent sources of
opinions, expectations, and concerns regarding a response action. In
addition, these interviews may lead to additional information sources.
Furthermore, face-to-face interviews can lay the groundwork for building
an open, honest, and positive relationship between the community and
officials responsible for the response.
Limitations
Individuals may have legitimately different perceptions of the same set
of events. As a result, each interviewee may have a different story to
tell. Those responsible for conducting the interviews should be
particularly sensitive to various points of view, and not dismiss one
account as being less factual or accurate than another.
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A. 3 CONTACT PERSON
Description
Designation of one staff member as a contact person who assumes
responsibility for addressing citizens' concerns, answering their
questions individually, and responding to inquiries from the media.
Purpose
To help build trust between the agency and citizens.
Technique
Designate a contact person for each removal or remedial action to respond
to citizens' requests for information, answer their questions, and
address their concerns on any aspect of the cleanup process. If citizens
are able to interact with the same staff person throughout the response
action, they may gradually develop more trust and confidence in agency
actions.
When a contact person is assigned to a site:
Send out a news release announcing the contact person to all local
newspapers, radio stations, and television stations. Include the contact
person's telephone number and mailing address in all news releases, fact
sheets, and mailings.
Inform all agency staff members who may be involved with the site--and
consequently, may be approached by the contact person for information--of
the new contact. Specify the role the contact person is to play at the
site.
Keep a log book of all citizen requests and comments received by the
contact person, and how each one was handled. This will help to assure
that incoming requests are not filed and forgotten.
When to Conduct
A contact person should be designated for each site when the response
action begins--that is, before the RI for remedial actions and any field
activity for removals.
Accompanying Activities
Designation of the contact person should be announced in news releases
and fact sheets. If a contact person has been designated during the
RI/FS process, the record of citizen requests and comments received by
the contact can later be incorporated into the responsiveness summary.
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A. 3 CONTACT PERSON (Continued)
The contact person should also be responsible for making sure that all
relevant material is filed in the site's infornation repository.
Benefits
A contact person can assure citizens that the agency is actively
listening to their concerns and can provide the community with consistent
information.
Limitations
The contact person may not have the authority to resolve all of the
concerns raised by citizens; his or her role may be limited to providing
information and facilitating communication between agency staff and
citizens. If, for any reason, the identity of the contact person
changes, it is important to ensure that the community is well-informed
about this change.
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A.4 DOOR-TO-DOOR CANVASSING
Description
Gathering information by calling on individuals door-to-door.
Purpose
To meet with community members individually and directly to discuss site
problems or gather needed information.
Technique
A door-to-door canvass involves training staff to gather information,
answer questions, and deal with a possibly irate or suspicious public.
Procedures to follow in preparing a door-to-door canvass include:
Identify the area where canvassing is necessary or desirable. Determine
the area where special information must be given or collected. This area
may range from just a few streets to several neighborhoods.
Send a letter to the residents in the designated area announcing that
staff members will be calling door-to-door in the area and explaining the
purpose of the canvassing program. Advance notice will reduce the
suspicions of residents and encourage their cooperation.
Provide canvassers with the information they will need to know to respond
to questions. Residents will want to know what is happening at the site
and may have many questions about, for example, possible health effects
of various contaminants. Distinguish between the types of questions that
a canvasser may answer (i.e., questions concerning soil or water testing)
and the types of questions that should be referred to an agency
specialist (e.g., highly technical questions concerning the site, or
agency policies).
Canvass the designated area. Note the name, address, and telephone
number of residents requesting more information. Note also the names of
those who were especially helpful in giving information. Be prepared to
tell residents when they will next be contacted and how (i.e., by
telephone, by letter, or in person).
Send a thank-you letter after the canvass to all residents in the
canvassed area. If possible, provide information concerning recent site
developments and any results or pertinent information gathered by the
canvass. Respond to special requests for information either in the
thank-you letter or by telephone.
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A.4 DOOR-TO-DOOR CANVASSING (Continued)
When to Conduct
This activity is best used when information is needed from a specific
group of individuals. For example, canvassing can be used to gather
signatures to gain access to residential property for soil and water
testing. Where the goal is to convey rather than to collect information,
a more appropriate approach may be to send a letter with the relevant
information and the name of the staff contact person. This letter should
be followed up with a telephone call.
Accompanying Activities
Telephone contacts and conmunity interviews may help to identify
appropriate areas for canvassing efforts. Canvassers should add to the
nailing list names of individuals who either requested additional
information or provided particularly useful information.
Benefits
This activity involves face-to-face contact, thereby ensuring that
citizens' questions can be directly and individually answered.
Limitations
This technique is very time-consuming and costly, even in a small area.
Furthermore, trained people that can answer questions at the necessary
level of detail are not typically available for this activity. Thus,
this activity is not recommended for the dissemination of information
except in an emergency.
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A. 5 EXHIBITS
Description of Activity
Setting up visual displays of maps, charts, diagrams, or photographs.
These may be accompanied by a brief text explaining the displays and the
purpose of the exhibit.
Purpose
To illustrate issues and proposed cleanup actions associated with
hazardous substance problems in a creative and informative display. To
make technical information more accessible and understandable.
Technique
To develop and display an exhibit:
Identify the target audience and the message. Possible audiences
include:
o General public;
o Concerned citizens;
o Environmental groups;
o Media representatives; and
o Public officials.
Possible messages include:
o Description of the site;
o Historical background;
o Community relations activities;
o Proposed remedies; and
o Health and safety effects associated with the site.
Determine where the exhibit will be set up. If the general public is the
target audience, for example, assemble the exhibit in a highly visible
location, such as a public library, convention hall, or a shopping
center. If concerned citizens are the target audience, set up a
temporary exhibit at a public meeting. An exhibit could even be as
simple as a bulletin board at the site or staff trailer.
Design the exhibit and its scale according to the message to be
transmitted. Include photos or illustrations. Use text sparingly.
When to Conduct
This activity can be used during any phase of a response action.
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A. 5 EXHIBITS (Continued)
Accompanying Activities
Exhibits are useful to display at public meetings or public hearings. If
an observation deck is installed at a site, a nearby exhibit could
explain response activities underway.
Benefits
Exhibits tend to stimulate public interest and understanding. While a
news clipping may be glanced at and easily forgotten, exhibits have a
visual impact and leave a lasting impression.
Limitations
Although exhibits inform the public, they are a one-way communication
tool. One solution to this drawback is to attach blank postcards to the
exhibit, encouraging viewers to comment or submit inquiries by mail to
the agency. Another approach is to leave the phone number of the contact
who can answer questions during working hours. These requests must be
answered, however, or citizens may perceive the agency as unresponsive to
their concerns.
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A. 6 FACT SHEETS
Description
A brief report summarizing current or proposed activities of the cleanup
program. The fact sheet presents technical and/or enforcement
information in a clear and understandable format.
Purpose
To help ensure that the public is informed of the status and findings of
cleanup actions, and that citizens understand the issues associated with
the response program.
Technique
To develop fact sheets:
Identify phases during the cleanup program where fact sheets would be
useful. For instance, fact sheets have proven helpful:
o At the beginning of the RI;
o At the end of the RI;
o When the FS is released; and
o When the ROD is released.
Fact sheets may also be appropriate during the preliminary
assessment/site investigation, remedial design, remedial action, and O&M
phases of a cleanup action.
For each fact sheet, identify the information to be transmitted. Types
of information might include:
o A brief background on the site;
o The legal justification or triggering event for the proposed
action(s);
o A timetable for the proposed action(s);
o A description of the issues or problems associated with the
site;
o A description of the remedial alternatives being considered;
o A description of public participation opportunities during the
cleanup process;
o The name, address, and phone number of an agency contact person
who will provide additional information on request; and
o The location of information repositories where material is
available to the public for review.
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A.6 FACT SHEETS (Continued)
Select a simple fornat for presenting the information. Avoid using
bureaucratic jargon or highly technical language in the text.
Be concise.
When to Conduct
Fact sheets are appropriate whenever new information is available, and
whenever a public comment period is required during the response action.
In addition to the various stages of the RI/FS, fact sheets can be
written to explain the site inspection, remedial design, remedial action,
O&M, and the enforcement process.
Additional fact sheets may be prepared after the agency selects a
remedial alternative and before the final engineering design of the
remedial action is complete.
Accompanying Activities
Community relations staff at Superfund sites have found that fact sheets
can be a particularly useful technique if distributed at a public meeting
or public hearing. Fact sheets can provide background information which
is then elaborated on at the public meeting or hearing. A public notice
should be provided whenever a fact sheet becomes available. Fact sheets
should always include the name of a contact person, who can provide
further information. If a general fact sheet is available when community
interviews are conducted, it may be distributed to community members
interviewed for the community relations plan.
Benefits
Fact sheets are effective in briefly summarizing facts and issues
involved in the cleanup process.
Limitations
Fact sheets take time and require careful coordination between technical
and community relations staff. A poorly written fact sheet can be
misleading or confusing. Fact sheets are also a one-way communication
tool, and therefore should always provide the name and number of a
contact person.
Fact sheets should look professional. People will be less likely to read
fact sheets consisting of a solid sheet of typed text than a fact sheet
that has been typeset with clear, easy-to-read illustrations. Moreover,
a well-designed fact sheet suggests that the agency is taking its
community relations program seriously.
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A. 7 FORMAL PUBLIC HEARINGS
Description
Formal hearings organized by the agency that are open to the public.
Purpose
To provide an opportunity for formal comment and testimony on proposed
actions, without necessarily answering questions or engaging in dialogue
with the audience. All testimony received becomes part of the public
record.
Technique
To conduct public hearings:
Anticipate the audience and the issues of concern. The public may not
become actively involved in hazardous substance issues until a cleanup
alternative is proposed or selected. Meet citizens' needs for
information before a formal hearing, with, for example, fact sheets,
small-group meetings, and briefings.
Schedule the hearing location and time so that citizens (particularly
handicapped individuals) have easy access. Identify and follow any
procedures established by the local and State governments for public
hearings. Ensure the availability of sufficient seating, microphones,
lighting, and recorders. Consider holding the hearing in the evening or
on a weekend to accommodate the majority of concerned citizens.
Announce the public hearing at least 2 weeks before the hearing date.
Provide notice of the hearing in local newspapers and mailings to
interested citizens.. Make a follow-up phone calls to major participants
to ensure that the notice has been received.
Provide an opportunity for local officials and citizens to submit written
comments. Not all individuals will want to provide oral testimony.
Publicize where written comments can be submitted and how they will be
reviewed.
Provide a transcript of all oral and written comments. Announce where
the transcript will be available for public review.
When to Conduct
The most appropriate time to hold a public hearing is when the draft FS
report is released. Schedule the hearing some time during the 3-week
public comment period. Public hearings may also be appropriate during
the remedial design.
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A. 7 FORMAL PUBLIC HEARINGS (Continued)
Accompanying Activities
Fact sheets providing background information and an update of site
activities can be distributed at public hearings. If held to solicit
comments on the proposed plan, the hearing will shortly be followed by a
responsiveness summary, which documents all public comments submitted and
agency responses to these comments. For Superfund sites where residents
have exhibited high levels of concern, or where citizens are not very
familiar with the Superfund program, an educational workshop may be
helpful 1 or 2 weeks before the public hearing. The workshop could
provide detailed information on the Superfund program, explain the
technical aspects of the issues at the site, and describe how citizens'
input will be incorporated into the remedial action. Transcripts of all
public hearings should be placed at the information repository and in the
administrative record.
Benefits
The major benefit of a formal public hearing is that it allows citizens
an opportunity to present formally their concerns and ideas to the agency
and provides clear documentation of community concerns.
Limitations
Communication during the hearing tends to be formal and one-way, flowing
from the public to the agency, and often creates an atmosphere of "us
versus them." Citizens usually have little opportunity to have their
questions answered, which may be frustrating to some. Holding a
question-and-answer session at the end of the presentations may help
solve this problem.
A high level of citizen concern may precipitate a disorderly public
hearing, where citizen groups attempt to gain support for their
positions. The hearing can easily become an adversarial confrontation.
One way to avoid hostility or confrontation is to make sure the community
residents have had an opportunity to express their concerns in a less
formal setting (for instance, in small meetings or open houses). More
frequent contact with concerned citizens before a formal public meeting
decreases the chance of confrontations.
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A. 8 INFORMATION REPOSITORY
Description
The information repository is a project file or repository containing
site information, documents on site activities, and general information
about the Superfund program. EPA now requires an information repository
at all remedial action sites and any removal action sites likely to
extend beyond 45 days.
Purpose
To allow open and convenient public access to all site-related documents
approved by the agency for public disclosure.
Technique
To establish an information repository:
Determine a location early in the response action. With remedial
actions, one or more locations could be identified during community
interviews. Typical locations might be local public libraries, town
halls, or public health offices. Ensure that there are copying
facilities available.
Depending on the level of community concerns, or the location of the site
relative to the surrounding communities, more than one repository may be
desirable. For example, if a county government seat is several miles
from the Superfund site, and county officials have expressed a strong
interest in the site, two repositories may be advisable: one in the
community closest to the site itself, and the other in the town where the
county government seat is based. At least one repository should be open
during evening hours and on weekends.
Select and deposit the materials to be included in the file. At minimum,
the repository for a remedial site should include copies of the
following:
o Draft and final FS report;
o Responsiveness summary;
o Signed ROD;
o Administrative order on consent or consent decree;
o CRP;
o RI/FS work plan;
o RI report; and
o Remedial design workplan.
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A. 8 INFORMATION REPOSITORY (Continued)
The following materials also are strongly suggested for the repository:
o Copies of CERCIA and RCRA;
o A copy of the NCP;
o A copy of the cooperative agreement, if a state-lead site;
o Documentation of site sampling results;
o Brochures, fact sheets, and other information about the
Superfund program and the specific site;
o Copies of press releases and newspaper clippings that refer to
the site; and
o Any other relevant material (for instance, published studies on
the potential risks associated with specific chemicals that
have been found at the site).
Clearly indicate hov individuals can conment on docunents in the
information repository. Place a cover note on documents (e.g., the CRP)
indicating who is to receive comments on the document and when.
Publicize the existence of the repository. Notify local government
officials, citizen groups, and the local media of the location of the
project file and hours of operation. Newsletters of local community
organizations and church groups are another means of notifying the
public.
Keep the file up-to-date. Timely replacement of dated information helps
avoid unnecessary misunderstandings.
When to Conduct
At least one repository must be established near each remedial site
before the RI/FS begins. Since repository locations are frequently
identified during community interviews, the repository should be
established as soon as the CRP has been approved and maintained
throughout the remedial action, including O&M. At a removal site
extending beyond 45 days, the repository should be established as soon as
the CRP has been approved.
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A. 8 INFORMATION REPOSITORY (Continued)
Accompanying Activities
The contact person should be responsible for making sure that all
relevant materials have been filed in the repository.
The administrative record, which is now required by SARA, may be included
in the same location as a repository at or near the site. The
administrative record is a legal file of documents upon which the lead
agency bases the selection of a response action and on which judicial
review of response actions will be based. It must be available to the
public at or near the facility. Duplicates may also be located at a
central docket, such as a Regional or State office. Refer to Draft
Interim Guidance on CERCIA Administrative Records for further
information.
Benefits
An information repository provides local officials, citizens, and the
media with easy access to accurate, detailed, and current data about the
site. It demonstrates that officials are responsive to citizens' needs
for comprehensive site information.
Limitations
A repository requires continual maintenance to avoid misunderstandings
based on dated information. Agency staff must check the repository
regularly, to ensure that all essential materials are available.
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A.9 NEWS CONFERENCES
Description
Information sessions or briefings held for representatives of the news
media, but also open to the general public.
Purpose
To provide the media with accurate information concerning important
developments during or after the action. To announce plans for any
future actions at the site.
Technique
To conduct news conferences:
Evaluate the need for a news conference. Because statements made during
a news conference may be misinterpreted by the media, use this technique
carefully.
Notify nembers of the local and regional media of the tine, location, and
topic of the news conference. Local officials may also be invited to
attend, either as observers or participants, depending upon their
interest. A news conference that includes local officials underscores
the agency's responsiveness and commitment to their interests and
concerns.
Plan exactly what to say ahead of time. Live conferences leave no room
for mistakes.
Anticipate reporters' questions and have your answers ready.
Present a short, official statement, both written and spoken, about
developments and findings. In addition, explain agency decisions to
proceed with a removal or remedial action and identify the next steps.
Open the conference to questions, to be answered by agency officials,
local officials, and any other experts present. Have technical staff on
hand to answer any technical questions. Decide ahead of time who will
answer what types of questions.
When to Conduct
News conferences should be used primarily to announce significant
findings at the site. Other community relations techniques such as fact
sheets, news releases, and public meetings may be more appropriate for
reporting the results of site inspections, sampling results, or other
preliminary information. A news conference announcing preliminary
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A.9 NEWS CONFERENCES (Continued)
results of technical studies may unnecessarily fuel public apprehensions
about the site.
News conferences can be used during any phase of an action, including
preliminary assessment, site inspection, RI/FS, remedial design, remedial
action, and O&M.
Accompanying Activities
News conferences can be made before or after formal public hearings or
public Meetings. They are accompanied by news releases.
Benefits
News conferences provide a public forum for the agency to announce plans
and developments. They are also an efficient way to reach a large
audience. A written news release can help ensure that the facts are
presented accurately to the media. During the question period, the
agency spokesperson can demonstrate knowledge of the site and may be able
to improve media relations by providing thorough, informative answers to
all questions.
Limitations
A news conference can focus considerable attention on the situation,
potentially causing unnecessary local concern. Residents may not welcome
the increased attention that such media coverage is apt to bring. News
releases or other lower-profile means of disseminating information should
be considered as alternatives.
A risk inherent in news conferences is that the media can take comments
out of context and create false impressions. This risk is heightened
when staff are unprepared or when the conference is not properly
structured or unanticipated questions are asked.
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A. 10 NEWS RELEASES
Description
Statements released to the news media that discuss on-site actions
proposed by the lead agency.
Purpose
To make an official statement at milestones in the response program, such
as selection of a remedial alternative, key project dates, and completion
of containment or cleanup actions.
Technique
News releases can effectively and quickly disseminate information to
large numbers of people. They may also be used to announce public
meetings, report the results of public meetings, and to describe how
citizen concerns were considered in the response action.
To prepare news releases:
Identify the relevant regional and local newspapers and broadcast media,
and learn their deadlines. Get to know the editor and environmental
reporter who might cover the issue.
Contact other involved agencies at the Federal, State, and local level to
ensure that all facts and procedures are coordinated and correct before
releasing any statement.
Select the information to be communicated. Place the most important and
newsworthy elements up front and present additional information in
descending order of importance. Enlist the aid of a public affairs
specialist in writing the release. When a draft FS is issued, for
example, the news release should contain the following facts:
o The findings of the investigation;
o A statement of what needs to be done;
o A statement of what will be accomplished by the alternatives
under consideration;
o Their costs and benefits; and
o The next steps.
Use supporting paragraphs to elaborate on findings, alternatives, and
other pertinent information. Mention any opportunities for citizen input
(public consultations, public meetings, etc.), and cite factors that
might contribute to earlier implementation or delays in the remedial
action. Note the location of the information repository (or other
sources for relevant documents).
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A. 10 NEWS RELEASES (Continued)
Be brief. Limit the news release to essential facts and issues.
Use simple language. Avoid the use of professional jargon and overly
technical words.
Identify the agency issuing the news release. The top of the sheet
should include:
o Name and address of the issuing agency;
o Release time ("For Immediate Release" or "Please Observe
Embargo Until") and date;
o Name and phone number of the contact person for further
information; and
o A headline summarizing the action taken.
Send copies of the release to local officials and citizen groups leaders
before the release is given to the press.
When to Conduct
News releases can be used when significant findings are discovered at the
site, when program milestones are reached, or when schedules are delayed.
Avoid, however, issuing a news release at times when it may be difficult
for citizens to get in touch with responsible officials (e.g., Friday
afternoons, or the day before a holiday).
Accompanying Activities
News releases can accompany any formal public hearings or public meetings
held by EPA or the State. They commonly accompany news conferences.
Benefits
A news release to the local media can reach a large audience quickly and
inexpensively. If the name, address, and phone number of a contact
person are included, reporters (and possibly interested citizens) can
raise questions about the information in the release.
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A. 10 NEWS RELEASES (Continued)
Limitations
Because news releases must be brief, they often exclude details that the
public may be interested in. A news release should therefore be used in
conjunction with other methods of communication that permit more
attention to detail. A news release is not an appropriate vehicle for
transmitting sensitive information. In some cases, a news release can
call unwarranted attention to a situation; a mailing to selected
individuals should be considered instead.
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A.11 OBSERVATION DECK
Description
An elevated deck on the site, near the area where remedial or removal
activities are in progress.
Purpose
To enable interested citizens to observe cleanup activities directly and
hence remove some of the mystique that surrounds cleanup actions.
Technique
The decision to establish an observation deck should be based on the
following criteria:
o The community's understanding of site activities will be
enhanced by direct observation;
o There will be sufficient activity at the site to promote the
community's interest;
o Staff are available to supervise, during all hours of
operation, public use of the observation deck; and
o It is physically possible to set up an observation deck in a
place where there is no danger to the public.
When to Conduct
An observation deck could be used at any point in the remedial process,
but is most appropriate to use during the construction phase of a
remedial action.
Accompanying Activities
An observation deck could complement periodic site tours. Citizens can
initially be educated about cleanup actions during the tours, then can
monitor the progress of these activities at their convenience from the
observation deck. Fact sheets or an informative exhibit placed near the
deck'could also explain site activities.
Benefits
An observation deck allows citizens and media representatives to observe
site activities without hindering the activities.
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A. 11 OBSERVATION DECK (Continued)
Limitations
An observation deck needs to be supplemented with an informational/
interpretive program, so that citizens understand what they see.
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A. 12 ON-SCENE INFORMATION OFFICE
Description
A trailer (or small building) near the site staffed by a full-time or
part-time person who responds to inquiries and prepares information
releases.
Purpose
To respond immediately to local questions and concerns.
Technique
To provide an on-scene information office:
o Rent a trailer, or designate space in a trailer used for other
purposes as well.
o Install a telephone to respond to inquiries and publicize the
number in local newspapers.
o Assign someone to staff the trailer. Establish regular hours,
including some during the weekend and weekday evenings.
Publicize the trailer's hours and the services it offers.
o Equip the trailer with the same materials normally contained in
an information repository.
When to Conduct
This activity is especially useful during removal actions, when a cleanup
at a site involves particularly complex technologies or processes, when
there is a very high level of risk to human health or the environment,
particularly when evacuation or longer term relocation of residents is
necessary, or when a significant amount of interaction between EPA and
community members is expected. An agency staff person should remain on
site until the removal or other appropriate action is completed.
However, where resources are limited, staff members may be on site only
at critical points in the cleanup process or during an emergency and
otherwise collect information requests from a telephone answering machine
or forward calls to the EPA regional office. All such inquiries must be
responded to promptly (within 24 hours).
An on-scene information office can also be used during remedial actions
where there is a continuous stream of citizen inquiries or for short
periods of time when important developments occur (e.g., the release of
long-awaited sampling results).
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A.12 ON-SCENE INFORMATION OFFICE (Continued)
Accompanying Activities
The on-site staff person can conduct meetings to inform citizens about
the status of the cleanup actions and prepare and distribute fact sheets
and weekly news updates to local residents.
Individuals staffing a community relations on-scene information office
for an extended period of time will necessarily have a special role in
the community. Involvement in other community relations activities may
represent a large part of their function. In addition to distributing
information to local residents, on-site staff will be responsible for
maintaining data bases of residents' addresses, the status of access to
property, daily technical reports, and a daily log of citizen inquiries.
It is important that on-site staff monitor public perceptions and
concerns daily (i.e., a "five-phone-calls-a-day" practice can help to
ensure the consistency of such perceptions). Finally and perhaps most
importantly, on-site staff members will frequently serve as a liaison
between the public and other agencies at the Federal, State, and county
levels, as well as contractors (e.g., staff members may be able to
provide sampling results over the telephone, if such information is
available, to concerned residents who are waiting for written results
from-another agency or contractor).
Benefits
An on-scene information office can be an effective activity for ensuring
that citizens are adequately informed about the agency's actions and that
their concerns are addressed immediately.
Limitations
An information office can be expensive, since it requires, at minimum, a
part-time staff person, trailer rental, and a telephone. Hence, it
should be used only when community concerns are high or may be in the
future.
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A.13 OPEN HOUSES
Description
An informal meeting in a public location where people can talk to agency
officials on a one-to-one basis.
Purpose
To allow citizens to ask questions and express their concerns directly to
community relations and technical staff.
Technique
To conduct an open house:
Select a date, tine, and location for the open house that encourages
attendance. Evening hours or weekends are preferable. The location
should be in an easily accessible building familiar to residents (such as
a public library or local meeting room).
Anticipate the number of attendees and plan accordingly. If a large
number of people is expected, consider the possibility of holding two
open houses to enable staff to greet and talk with each attendee.
Alternatively, increase (if possible) the number of staff who will host
the open house. As a general rule, planning for one staff member per
15-20 attendees should foster an informal atmosphere for conversation,
and thereby avoid the situation where a staff member has to speak to a
"crowd."
Publicize the open house at least 2 weeks ahead of time, if possible.
Send announcements to newspapers, television and radio stations, citizens
on the mailing list, and any interested community organizations that
publish newsletters.
Ensure that appropriate agency staff attend, so that citizens can meet
those who will be responsible for site activities. The staff present
should be able to answer both technical and policy questions.
When to Conduct
An open house is most appropriate when key milestones have been reached,
or major decisions made. For example, release of sampling results or
draft studies are appropriate times to hold open houses.
Accompanying Activities
Exhibits and fact sheets can provide background information that enables
citizens to ask more informed questions about the site during the open
house.
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A. 13 OPEN HOUSES (Continued)
Benefits
The one-to-one conversations during an open house can help build trust
and establish a rapport between citizens and agency staff.
Limitations
Planning and conducting an open house can require a significant amount of
staff time. A low turnout may not justify the effort. Hence, community
interest in the site should be significant before an open house is
planned.
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A. 14 PRESENTATIONS
Description
Speeches to clubs, civic or church organizations, school classes, or
similar local audiences.
Purpose
To improve public understanding of the problems associated with a site
and to explain how the agency will address them.
Technique
Develop procedures that can easily be changed to suit different
audiences:
Select a standard format such as the following:
o Describe the problems;
o Describe how the problems affect the public;
o Discuss what is being done about the problem; and
o Discuss how citizens can assist the agency in response efforts
and obtain additional information.
Adjust the tone and technical complexity to suit the audience's needs.
Set a time limit of 20 minutes. Consider having several staff members
deliver short segments of the presentation. Allow time for a
question-and-answer period.
Schedule presentation at convenient times, possibly evenings or weekends.
Select supporting materials -- slides, graphics, exhibits, etc. -- that
will hold the audience's attention but not distract from the speaker's
message. Conduct a trial run in front of colleagues and rehearse the
presentation as much as possible.
Contact groups that may be interested in learning about hazardous
substance problems. Announce the program through the media and in other
communications.
When to Conduct
Presentations are more effective if they focus on major milestones in the
response action, such as recommendation of a site for the NPL, or release
of the draft FS report. In addition, there should be at least moderate
interest in the site.
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A.14 PRESENTATIONS (Continued)
Accompanying Activities
Fact sheets should be distributed, if possible.
Benefits
Because the presentation is delivered in person, the audience has a
chance to ask questions, and the agency can gauge citizens' concerns.
Also, many people can be reached at one time, reducing individual
inquiries.
Limitations
Presentations require substantial effort to be effective. A
poorly-planned presentation can distort residents' views of the
situation.
Because the presentation is rehearsed, accommodating different or
unanticipated concerns of the audience can be difficult. Handle these
concerns during a question-and-answer period after the presentation.
If substantive issues or technical details cannot be handled in the time
allowed for the presentation, name a contact for further information.
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A.15 PUBLIC COMMENT PERIOD
Description
A designated time period where comments from citizens are formally
accepted by the agency responsible for the Superfund response.
Purpose
To allow citizens to review and comment on the agency's proposed course
of action.
Technique
To hold a public comment period:
Announce the public comment period at least 2 weeks in advance and again
just before the event. This announcement must be made in a major local
newspaper of general circulation. It may be included in the newspaper
notice of the proposed plan or other action. Identify where copies of
the pertinent documents can be found, and where all written comments
should be submitted.
Identify a contact person within the agency who will answer citizens'
questions regarding the public comment period. Publicize the name and
telephone number of this contact person.
Prepare a transcript of any public nestings which occur during the public
comment period on the proposed plan and RI/FS report. Insert the
transcript in the administrative record.
Document with a nemo to the file or Record of Communication any other
comments expressed that are not available in written form, which are of
significance to evaluation of any of the alternatives.
When to Conduct
A minimum 3-week public comment period must be held when the RI/FS and
proposed plan have been released for public review. (EPA plans to
propose extending this requirement in the revised NCP to no less than
30-calendar days.) In addition, when a negotiated settlement for
remedial action is reached at an enforcement site and embodied in either
an administrative order on consent or a consent decree, a public comment
period of at least 30 days (except under special circumstances) is
required. A 30 day comment period also is required for the ROD and
before the submission of the recommendation to EPA Headquarters to delete
a site from the NPL. Public comment periods of at least 3 weeks also may
be necessary before conducting an operable unit for which no FS was
prepared.
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A.15 PUBLIC COMMENT PERIOD (Continued)
Accompanying Activities
A public notice and opportunity for a public meeting must be provided
when a public comment period is held on the RI/FS and proposed plan. It
is recommended that public notices and an opportunity for a public
meeting be offered to the public during other comment periods. Comments
received during the public comment period must be discussed in a
responsiveness summary.
Benefits
Public comment periods allow citizens to comment on agency proposals and
to have their comments incorporated into the public record.
Limitations
Public comment periods only allow indirect communication between citizens
and agency officials because the formal responses to the comments may, in
some cases, not be provided for some time, and comments may, in some
cases, not be responded to individually. A community relations program
should provide other activities that allow dialogue between agency
officials and the community.
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A.16 PUBLIC MEETINGS
Description
A large meeting open to the public. Experts are available to present
information and answer questions. Citizens may ask questions and offer
comments.
Purpose
To inform citizens of ongoing response activities, and to discuss and
receive citizen feedback on the proposed course of action.
Technique
To hold public meetings:
Identify participants. In addition to agency staff, consider asking
informed local officials to make a short presentation and to respond to
questions.
Draw up an agenda detailing specific issues to be considered or specific
tasks that must be accomplished at the meeting. If possible, involve
citizens in developing the agenda.
Be sensitive to special needs of community members. For a foreign-
speaking community, consider the use of simultaneous translation during
the public meeting. For deaf participants, consider providing a sign
language translation.
Rehearse presentations in advance. Staff unaccustomed to speaking before
large audiences should practice their presentations, obtain criticism,
and improve their speaking style or content.
Announce the meeting in local newspapers and broadcast media 2 weeks in
advance of the scheduled date. Distribute flyers to citizens and groups
interested in attending. Before the meeting begins, review the agenda
with participants. Clarify that the meeting is not a formal public
hearing where testimony is received. Instead, it is a meeting to
exchange information and comments.
Hold a meeting in a comfortable setting. Make sure the location is
easily accessible, is well-lighted, and has adequate parking and seating,
especially to the handicapped.
Consider holding the meeting under the sponsorship of an existing
organization. For example, conduct the meeting as a portion of a
regularly scheduled city council meeting, or as a special presentation to
a group such as the Rotary Club or the League of Women Voters (if
sessions are open to the general public).
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A. 16 PUBLIC MEETINGS (Continued)
Begin the nee ting by stating the purpose, then outline the agenda and
the procedures for making statements.
Present the issues concerning the site, preliminary findings, and
proposed course of action. Keep agency presentations short (20 minutes)
to allow plenty of time for citizen testimony and a question-and-answer
session. Allocate a time period for citizens to express their concerns
and ask questions. Meetings may last from 1 hour to no more than 3.
Consider different formats for the meeting to encourage information
exchange. Not all meetings need to be run formally from a platform in
front of the room. Alternative formats -- such as having a moderator
circulating through the audience to solicit comments -- may encourage
greater participation in the meeting.
Prepare a transcript of the meeting that will be publicly available.
Announce at the end of the meeting how the transcript can be obtained.
When to Conduct
The agency must provide the opportunity for a public meeting before
adopting a plan for remedial action or ROD. Generally, this meeting
should take place during the public comment period on the RI/FS and
proposed plan. Other suitable times for a public meeting include when a
site has been placed on the NPL, when the remedial design has been
completed, or just before construction. Public meetings may also be used
to present the technical workplan to the community.
Accompanying Activities
A public notice may be used to announce public meetings. Fact sheets
should be distributed at public meetings, if possible. A transcript of
the public meeting held during the public comment period on the proposed
plan and RI/FS report must be made available to the public in the
administrative record.
Benefits
Public meetings allow the public to express its concerns to the agency or
to local government officials. Meetings also allow the agency to present
information on a proposed course of action. Public meetings can provide
a setting for the agency and community to resolve their differences.
Limitations
Public meetings may not be the best way to obtain citizen input. If
controversy surrounding the site has escalated, a public meeting can
intensify conflicts rather than resolve them. Evaluate the usefulness of
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A. 16 PUBLIC MEETINGS (Continued)
a public meeting by reviewing the site's history and level of citizen
involvement in this and similar controversies. If public meetings have
been failures in the past, then use an alternative method, such as small
group meetings, to transmit information and obtain feedback. Or,
schedule a public hearing that is highly structured.
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A. 17 PUBLIC NOTICES
Description
Advertisements, usually a display ad, published in major local
newspapers, broadcast via local radio stations, or sent as individual
mailings to announce agency decisions, major project milestones, public
meetings, or to solicit public comment on agency actions.
Purpose
To provide an official announcement of agency activities and plans and to
encourage public involvement in agency decisions.
Technique
To prepare a public notice:
Identify the community to be reached by the notice. In some cases, there
may be only a small group of people adjacent to the site that will need
to be informed of site activities. In such cases, a display ad in a
local or community newspaper or a mailing may be more appropriate than a
city-wide radio broadcast.
Identify the major media contacts. While there may be many newspapers,
newsletters, local radio stations, or even television stations serving a
particular area, use only one or two for the public notice. In general,
the newspaper with the widest circulation and greatest visibility will
reach the most people and elicit the greatest response.
Take into account publication schedules. Many local or community
newspapers are published on a weekly or bi-weekly basis. This may make
it difficult to coordinate the publication of the notice with the event.
In such a case, consider using a city-wide newspaper that is published
mo re fre quently.
Announce dates, times, and locations clearly in the public notice. When
scheduling an event, make sure that the date and time do not conflict
with other public meetings or holidays.
Provide ample notice. Provide at least one week's notice to ensure the
greatest level of participation possible. Two weeks notice is
recommended for public comment periods. Be sure to state the opening and
closing dates for the comment period.
Provide the name, address, and telephone number of the contact person for
more information. For notices that announce the beginning of an RI/FS,
include the location of the information repository. A clip-out coupon
may be added, allowing interested parties to send their names and
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A.17 PUBLIC NOTICES (Continued)
addresses to the agency to obtain a fact sheet and/or be placed on the
mailing list.
When to Conduct
A public notice mist be provided:
o When the RI/FS and proposed plan become available;
o When a public comment period is held on the RI/FS and proposed
plan;
o When the response action has been selected; and
o Whenever remedial action is taken or a settlement or consent
decree entered into that differs significantly from the final
remedial plan adopted by the agency.
In addition, a public notice may be used to announce:
o The beginning of the RI;
o Availability of the administrative record and information
repositories;
o Emergency response actions;
o The beginning of an operable unit;
o Enforcement actions involving PRPs;
o An RI/FS "kickoff" public meeting;
o The availability of an engineering design fact sheet; and
o Other public meetings.
Accompanying Activities
Public notices should announce the availability of fact sheets, as well
as the scheduling of public conraent periods and public meetings.
Benefits
Public notices are an efficient, simple means of alerting the public to
important events.
Limitations
Public notices should never substitute other activities that involve
direct communication with the public.
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A.18 RESPONSIVENESS SUMMARIES
Description
A summary of the written or oral comments made by the public, including
PRPs, on key agency documents and agency responses to those comments.
The responsiveness summary is required as a component of the ROD.
Purpose
To document any public concerns and issues and how the agency responded.
Technique
Refer to Chapters 2 and 4 of this handbook for discussion of a
responsiveness summary and to Appendix C for a model summary.
When to Conduct
EPA policy requires preparing a responsiveness summary for any response
action where a ROD is needed. Responsiveness summaries should be
prepared for NPL site addition or deletion submissions.
Accompanying Activities
Responsiveness summaries should document oral or written citizen input
submitted at public meetings, public hearings, or during public comment
periods, as well as major issues and concerns raised during a response
action.
Benefits
The agency responsible for the site response should have a clear record
of community concerns about the site so that this information can be
considered in selecting the appropriate response. The summary is also an
aid to evaluating past community relations efforts and planning for
subsequent activities during remedial design and remedial action.
Limitations
The responsiveness summary should not be viewed as a substitute for other
community relations techniques. In addition, it should not be a point-
by-point recitation of each comment: For example, potentially
responsible parties may submit very detailed and technical comments that
require lengthy responses. It may be advisable to prepare those
responses in one document which is placed in the administrative record
and repository(ies), then prepare a summary of those responses for the
responsiveness summary. Refer to Chapter 4 of this handbook for further
information.
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A. 19 REVISION OF COMMUNITY RELATIONS PLANS
Description
Revisions of all or parts of the CRP for a site to incorporate new
information,, reflect changes in community concern, or prepare for
community activities during remedial design and remedial action.
Purpose
To ensure that the CRP remains sensitive to citizens' concerns through
final phases of the remedial action. To evaluate which community
relations activities were effective, and which were not.
Technique
A CRP initially outlines the community relations program techniques for
the RI/FS phase of the remedial action. Once the ROD for a site is
completed, it is appropriate to re-assess the nature and extent of
community concerns and to develop a new schedule of community relations
activities for the design and construction phases of the remedial action.
Revisions needed will vary from site to site.
When to Conduct
CRPs should be revised before the remedial design begins if the RD/RA is
not already addressed in the CRP. If, after the plan has been prepared,
community concerns change focus or increase in intensity, the plan should
be revised accordingly.
Accompanying Activities
The responsiveness summary will provide some information to assess the
nature and extent of citizens' concerns after the RI/FS is completed.
Additional community interviews can provide further information for
revising the CRP. Chapter 3 provides additional, detailed information on
conducting interviews and developing plans.
Benefits
Revising the CRP will help to ensure that the agency continues to respond
to citizens' concerns during remedial design and action. Simple changes
can also help a community relations planner; for example, the contacts
list can incorporate changes in addresses, new telephone numbers, and the
names of new officials.
Limitations
Agency staff should make certain that there resources are available to
implement all activities identified in the revision.
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A.20 SITE TOURS
Description
Scheduled trips to the site for media representatives, local officials,
and citizens during which technical and community relations staff answer
questions.
Purpose
To,increase understanding of the nature of the problems at a site and the
response action proposed or underway.
Technique
To conduct site tours:
Draw up a list of individuals that night be interested in participating
in a tour, including:
o Individual citizens or nearby residents who have expressed
concern about the site;
o Representatives of public interest or environmental groups that
have expressed interest in the site;
o Interested local officials;
o Representatives of local citizen or service groups; and
o Representatives of local newspapers, television stations, and
radio stations.
Determine the ™a*ri*nm number that can he taken on site safely. Keep the
group small so that all who wish to ask questions may do so. Schedule
additional tours as needed.
Think of ways to involve tour participants. A "hands-on" demonstration
of how to read monitoring devices is one example.
Anticipate questions. Have someone available to answer technical
questions in non-technical terms.
Ensure that the tour complies with the safety plan for the site.
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A.20 SITE TOURS (Continued)
When to Conduct
Conditions permitting, tours can be conducted at any site where citizens
or local officials have expressed an interest. Site tours may be
particularly appropriate during or after the construction phase, so that
citizens can see a response action in progress.
If possible, arrange tours at nearby Superfund sites. Residents may
benefit from touring a site that has similar contamination problems or
where similar cleanup technologies have been applied. Touring a nearby
Superfund site can give residents a clearer perception of what to expect
at their own site.
Accompanying Activities
Fact sheets complementing presentations given on site tours can be
distributed to all tour participants. An observation deck near the site
would allow them to watch the progress of the cleanup activities on their
own.
Benefits
Site tours familiarize the media, local officials, and citizens with the
site and the individuals involved in cleanup operations. Unreasonable
fears about the risks of the site may be dispelled, as might suspicion of
remedial crews working at the site. The result could be better
understanding between the community and the agency.
Limitations
Site tours require considerable staff time to prepare the explanation of
site activities and to escort citizens through the site. Staff may have
difficulty gaining site access for non-agency people.
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A.21 SMALL GROUP MEETINGS
Description
Meetings of small groups held in private homes or in local meeting places
at which agency staff responsible for the site get first-hand information
from interested citizens and State and local officials.
Purpose
To inform citizens and State and local officials of site activities,
answer questions, and clear up any misconceptions or misunderstandings.
To develop agency sensitivity to citizen concerns and establish rapport
and a good working relationship with residents.
Technique
To conduct small group meetings:
Identify interested citizens and officials. Contact each citizen group
and local agency that is directly affected by site activities, or contact
individuals who have expressed great concern regarding site activities.
Offer to discuss cleanup plans at a convenient time. For a removal
action, schedule the meeting after emergency actions are completed or
after the agency has accurate information to share with the citizens.
For a remedial action, determine first when community concerns may be
highest and schedule meetings accordingly. For instance, when the draft
FS report is released may be an appropriate time to hold a small group
meeting.
Linit attendance. Restrict attendance to between 5 and 20 individuals.
The larger the group, the less likely that some people will candidly
express their concerns. Establishing rapport with individuals in a large
group is also more difficult. If a greater number of citizens and
officials are interested, schedule additional small meetings.
Select a meeting date, time, and place conducive to two-way interaction.
The meeting place should have chairs that can be arranged into a circle,
or some other informal setting. If citizens will not be able to meet
during working hours, schedule meetings in the evening. A private home
or public library meeting room may be more conducive to an exchange of
ideas than a large or formal public hall. When scheduling the meeting,
make sure that the date and time do not conflict with other public
meetings that citizens may want to attend (for example, town council
meetings), or with holidays or other special occasions. Be sure that the
meeting location does not conflict with State "sunshine laws." (For
instance, a State may require holding all meetings between agency
officials and the public in a public location.) In selecting a public
meeting place, be attentive to the special needs of handicapped
individuals (e.g., access ramps or elevators).
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A.21 SMALL GROUP MEETINGS (Continued)
Begin with an overview of current and future site activities. Keep it
brief (no more than a few minutes) and informal, to promote open
discussion. Cover such issues as:
o Extent of cleanup;
o Safety and health implications;
o Factors that might speed up or delay the cleanup; and
o How community concerns are considered in making decisions on
response actions.
Identify the major agencies and individuals responsible for the site
cleanup. Citizens will then know where to direct further questions or
voice new ideas or suggestions.
Gear the discussion to the audience. Discuss problems in technical terms
only if citizens are knowledgeable.
Listen. Find out what the citizens want done. Some concerns may be met
by making minor changes in the agency's proposed action. Discuss the
possibility for compromise or explain the reasons why citizen requests
appear to be unworkable or conflict with program or legal requirements.
Follow-up on any major concerns. Stay in touch with the groups and
contact any new groups that have formed, so that new or increasing
concerns can be dealt with before problems develop.
When to Conduct
Small group meetings can be used effectively during virtually all phases
of a Superfund remedial response: the RI/FS, remedial design, remedial
action, and O&M phases. (Community awareness or concern during
preliminary assessment and site investigation phases may not warrant
holding small group meetings. If community interest is expressed,
however, hold small group meetings.) These meetings can also provide a
forum for explaining how unexpected events may affect the project
schedule.
Small group meetings are also appropriate during removal actions.
Accompanying Activities
Community interviews usually precede these meetings, since it is during
these on-site interviews that concerned citizens groups are identified
and contacted. Possible meeting locations are also identified during the
community interviews.
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A. 21 SMALL GROUP MEETINGS (Continued)
Distributing fact sheets at these meetings may also be appropriate,
depending on when they are held.
Benefits
The primary benefit of small group meetings is that they allow two-way
interaction between citizens, local officials, and the agency. Not only
will citizens be informed about the proposed response, but officials
responsible for the site can learn how citizens view the site.
Small group meetings also add a personal dimension to what could
otherwise be treated as a purely technical problem. Familiarity with how
the remedy is selected can assist citizens in understanding the Superfund
process and promote their participation.
Limitations
Small group meetings may require a day or more of staff time to reach a
limited number of citizens.
One pitfall is that some citizens or environmental groups may perceive
the agency's efforts to restrict the number of attendees as a "divide and
conquer" tactic to prevent large groups from exerting influence on
potential actions and to exclude certain individuals or groups. One way
to prevent this perception is to hold additional small group meetings
with those organizations who express concern about being left out of the
process.
Irate groups or individuals may also accuse agency staff of telling
different stories to different groups at these small meetings. The
agency can avoid this criticism by inviting a cross-section of interests
to each small meeting. Alternatively, agency staff can keep a written
record of the small group discussions and make it available upon request.
A record of discussions is required for meetings during the public
comment period.
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A.22 SUPERFUND BRIEFING BOOK
Description
A notebook of information about a site and the Superfund program that is
distributed to the media. Included in the notebook might be a site
history, the RI report, the FS report, and Superfund fact sheets.
Purpose
To ensure that complete and accurate information about a Superfund site
and the Superfund program is available to the press. To minimize
inaccurate statements in the media.
Technique
To prepare a Superfund briefing book:
Compile site-specific information that could be used by reporters in
their stories about a site, including site history, extent of community
concern and involvement, and an up-to-date accounting of all site
samples, analyses conducted, and actions proposed.
Compile generic information including descriptions of CERCLA, the NPL,
and all steps in a Superfund cleanup process (from preliminary
assessment/site investigation through O&M). Include a separate
discussion of opportunities for public participation throughout the
Superfund cleanup process.
Much of this information will already be available in other public
documents - - for example, the CRP and technical workplans. To present
other information in a concise format (for instance, results of key
sampling studies), brief fact sheets may be appropriate.
When to Conduct:
Superfund briefing books should be compiled at the beginning of the
RI/FS, and updated throughout the life of the project. It is a good idea
to compile briefing books for all sites, even if community concern seems
low.
Accompanying Activities
Media representatives can be invited to review briefing books at the end
of news conferences. Announcements about the briefing books can be
included in news releases. A briefing book could be placed on reserve at
the information repository.
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A. 22 SUPERFUND BRIEFING BOOK (Continued)
Benefits
A Superfund briefing book will help to ensure that consistent and
accurate information is presented to the media. The briefing book can
also show willingness to cooperate, thereby helping to foster good
relations with the media.
Limitations
To be useful, the briefing book should be up-to-date and accurate. This
will require periodic reviews of the briefing book by agency staff.
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A.23 TECHNICAL ADVISOR
***** RESERVED *****
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A.24 TELEPHONE CONTACTS
Description
Initial telephone calls to State and local officials and concerned
citizens, informing them of the agency's interest in the site, finding
out which individuals or groups are involved with the site, and possibly
setting up personal interviews for a later date. Once site activities
are underway, follow-up telephone calls should be made to State and local
officials and key community groups and individuals to inform them of any
major findings and the progress of site activities. Telephone contacts
supplement, but do not replace, conmmity interviews as a way of
gathering information about the community.
Purpose
To understand community concern about a response action and gather
information for planning the response. To inform key officials and
community groups promptly about site activities.
Technique
In making telephone contacts:
Know exactly what information to request (e.g., additional references,
site specifics, background information) and tailor questions accordingly.
Information to solicit from these contacts might include:
o Background on the site and the problem;
o Recent government activities at the site;
o Nature and extent of citizen involvement;
o Names and telephone numbers of other possible contacts; and
o Addresses for compiling mailing lists.
Identify concerned citizens in the affected communities. State and local
government agencies are one source of such information. The media and
local chapters of environmental groups are another source.
These organizations may be contacted to obtain names and phone numbers of
concerned citizens and groups:
o State and local health'departments: Officials may have
received complaints from citizens concerning the safety of a
site. They may also know about community groups involved in
hazardous substance problems in the State.
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A.24 TELEPHONE CONTACTS (Continued)
o State and local environmental or pollution control agencies:
Often, local residents and community groups will have contacted
these offices seeking answers to questions about potential
health and safety effects of contaminants found at the site.
These officials can also assess citizen expectations.
o Local Congressional office: Staff may have received letters or
phone calls from concerned citizens regarding the site.
o State elected officials: Some may have been contacted by
concerned constituents.
o Local elected officials (mayors, city managers, etc.): These
officials can identify concerned citizens, and what steps, if
any, have been taken to satisfy their needs.
o Media: Reporters at local TV and radio stations and papers can
frequently identify community organizations or individuals
interested in the site.
o Environmental groups: Local chapters of environmental
organizations may have members who are monitoring site
activities.
Once concerned citizens have been identified, they should be telephoned.
If possible, agency staff should also arrange a personal interview to
discuss their concerns in detail.
When to Conduct
Initial telephone contacts should be used in the earliest phases of both
removal and remedial actions to identify key officials and citizens who
have a high interest in the site. After these initial contacts are made,
EPA may make telephone calls throughout the response action to inform
these individuals and to monitor the extent of community concerns.
Telephone contacts are also an appropriate activity for gathering
information during the preliminary assessment and site investigation
phases.
Accompanying Activities
Telephone contacts are usually made to arrange on-site community
interviews.
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A.24 TELEPHONE CONTACTS (Continued)
Benefits
Telephone calls can be an inexpensive and expedient method of acquiring
initial information about the site. During removals, the telephone
contacts can help the OSC identify and deal with community concern when
time is not available for more thorough community relations activities.
In remedial response actions, telephone interviews will often be useful
for establishing a network of contacts to be used later during community
interviews. Once the initial information has been gathered, telephone
contacts are a quick means of informing key people about site activities
and for monitoring any shifts in community concerns.
Linitations
Residents may initially feel uncomfortable discussing their concerns and
perceptions over the phone with a "faceless" questioner. Once residents
have met EPA staff in person, however, they may be more open and willing
to discuss their concerns during follow-up telephone calls.
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A. 25 TELEPHONE HOTLINE
Description
A toll-free telephone number in an agency office.
Purpose
To provide citizens with an opportunity to ask questions and obtain
information promptly about site activities.
Technique
To install a telephone hotline, either as a "permanent" fixture,
available throughout the cleanup action, or as a temporary measure,
installed at the time of major project milestones:
Assign one or more staff members to handle the hotline calls. Consider
installing more than one line to minimize citizens reaching a busy signal
when they call. If staff are not available throughout the day, install
an answering machine directing citizens to leave their name, number, and
brief statement of concern, and informing them that an agency official
will return their call promptly. Check the answering machine for
messages at least once a day. If the level of concern is high, check for
messages more frequently.
Announce the telephone hotline in news releases to local newspapers,
radio stations, and television stations.
Keep a written record of each question, when it was received, and how and
when it was answered.
When to Conduct
A telephone hotline would be useful during the RI, if concern is high
about the levels of contaminants at the site. A hotline is particularly
useful if any unexpected event, such as a fire or explosion, occurs at a
site. A hotline can also be effective during the construction phase,
when citizens may have complaints regarding environmental impacts such as
excessive dust or noise.
Accompanying Activities
One of the functions of the contact person might be to respond to
inquiries on the hotline.
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A. 25 TELEPHONE HOTLINE (Continued)
Benefits
A hotline can provide citizens with a relatively quick means of
expressing their concerns directly to the agency and getting their
questions answered. This quick response can help to reassure citizens
that the agency is listening to their concerns. A telephone hotline can
also help to monitor community concerns. A sudden increase in calls
could indicate that additional community relations efforts may be
warranted.
Limitations
Citizens calling the hotline must receive responses to their questions or
concerns quickly, or they may become frustrated with the agency. If the
number of calls is large, responding quickly to each inquiry could prove
burdensome to agency staff. Furthermore, hearing a recorded message on
the hotline could irritate or alienate some callers.
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A.26 TELEPHONE NETWORK/PHONE TREE
Description
A list of individuals responsible for calling a specified number of
people who, in turn, call an additional number of people to inform them
of site activities. A telephone network or "phone tree" may be a formal,
tiered system of contacting individuals about an upcoming event or a more
informal system of "spreading the word."
Purpose
To provide back-up information or reminder of plans already announced.
To reduce the number of calls made by individual staff members.
Technique
To set up a telephone tree:
Identify members of key groups or organizations willing to make telephone
calls (no more than ten calls per person) or, where there are no such
organizations, develop a list of independent individuals.
Assign each caller a specified number of names that he or she will be
responsible for calling.
Prepare a short written message that includes the necessary information
(date, time, place, etc.) and distribute it to the first tier of callers.
Be sure to include the name and telephone number of the staff contact
person who is available to answer questions.
When to Conduct
This activity is best used to provide follow-up information or to
reinforce information presented in a mailing or public announcement.
Calls should be made 1 week to 2 days before the event to remind
participants of an event or to estimate the level of attendance.
Accompanying Activities
Because this activity is intended to provide follow-up information, a
mailing list might be used to identify individuals who should be called.
Telephone networks generally should be used to reiterate announcements
made by a public notice or by a news release.
Benefits
This activity is an inexpensive and personal way to reach a large number
of people.
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A.26 TELEPHONE NETWORK/PHONE TREE (Continued)
Limitations
This activity may be time-consuming to coordinate, and unreliable if
there are too many tiers in the network. Information may become
distorted or confused, thus creating distrust of lead agency efforts in
general, and staff members in particular. Hence, a telephone network of
this type is recommended only as a back-up activity following a mailing,
advertisement (i.e., public notice), or other type of announcement. This
activity is not recommended as a general method of disseminating
information.
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A.27 TRANSLATIONS
Description
Providing written or verbal information in a foreign language to a
predominantly non-English speaking community. There are three types of
translations:
o A written translation of materials originally written in
English;
o A verbal translation of a public meeting or news conference by
translating each sentence after it is spoken (i.e., sentence by
sentence); and
o A simultaneous translation (i.e., word by word) of a public
meeting or news conference, usually with small headsets and a
radio transmitter.
Purpose
To ensure that all community members are informed about site activities
and have the opportunity to participate in the decision-making process.
Technique
To develop a successful translation:
Evaluate the need for a translation. Evaluate the demographic
characteristics of the community as well as the type of community
relations activities being planned. Consider whether citizens' ability
to take part in a community relations activity is limited by their
inability to speak or understand English.
Identify and evaluate translation services. A successful translation
depends on the skill of the translator. More problems may be created
than solved if inaccurate or imprecise information is given. Many
translators will not be familiar with the technical terms associated with
hazardous waste cleanup and few, if any, will be familiar with the
Superfund process. This problem may be further compounded in the case of
verbal translations (especially simultaneous translations) as there is no
time for review or quality control. Thus, it is necessary to contract
someone with experience in translating technical information. If
possible, arrange to have another person, preferably a staff member who
can speak or read the appropriate foreign language, check the
translator's work to ensure that the content and tone are in keeping with
the -agency' s intent.
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A. 27 TRANSLATIONS (Continued)
Avoid the use of jargon or highly technical terns. As a matter of
standard practice, a staff member should go over all technical and
Superfund terms that may cause problems with the translator in advance.
For verbal presentations, public meetings, and news conferences, plan
what to say ahead of time. If the translator has a prepared written
speech to work with in advance, there is more time to work out any
vocabulary "bugs" and thereby reduce the chances of faltering over
unfamiliar material or making inaccurate word choices. If possible,
practice with the translator before the actual meeting or presentation
date.
Anticipate questions from the audience and reporters, and have at least
the technical aspects (e.g., chemical names, statistics) of the answers
translated in advance.
When to Conduct
A translation is desirable where a large percentage of the community is
non-English speaking. A written translation should be provided for fact
sheets or letters, unless a presentation or public meeting would be more
appropriate (e.g., the literacy rate among the foreign-speaking community
is low). Verbal translations are recommended where there is considerable
concern over the site, extreme hostility, or suspicion of the lead
agency's efforts to communicate with the community members.
Accompanying Activities
In predominantly non-English speaking communities, translations may
accompany fact sheets, public notices, presentations, public meetings,
public hearings and news conferences.
Benefits
Written translations and use of translators ensure that a greater number
of community members can participate effectively in site activities and
therefore provide input to decisions concerning the cleanup process.
This effort assures the community of EPA's sincerity in providing
opportunity for public involvement.
Limitations
Translations are very costly, especially simultaneous translations of
public meetings. Sentence-by-sentence verbal translations frequently
double the length of public meetings, and may make information more
difficult to present effectively and smoothly. In addition, very few
translators are familiar with, much less trained in, the Superfund
process. For sites having highly volatile or sensitive problems, it may
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A.27 TRANSLATIONS (Continued)
be difficult to communicate the lead agency's position and involve
community members in a constructive dialogue.
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A.28 USING EXISTING GROUPS/PUBLICATIONS
Description
Using the publications and mailing lists of established local, civic or
community organizations as vehicles to inform a community of site
activities.
Purpose
To communicate with the public about site activities through existing
communication networks.
Technique
To use existing groups/publications:
Identify existing groups and publications. Groups that may help to
publish information to the community or in organizing meetings include:
o Local civic or environmental groups;
o Rotary clubs;
o Church organizations;
o Local trade associations, farmers' associations, and
cooperatives;
o The League of Woman Voters; and
o Local water companies or other independent agencies or
utilities.
Some types of appropriate publications may include:
o Newsletters, newspapers, magazines, or bulletins;
o Newsletters of homeowners' associations; and
o Local/community independent or commercial newspapers.
Contact groups/editors to determine if they are willing to provide
•ailing lists, publish site information, or organize meetings. As
important, determine whether such groups are appropriate for
communicating agency information. By publishing information through a
group that has a specific political interest or bias, the agency may be
perceived as endorsing these views. Groups that are "friendly" may also
be inappropriate if they appear to represent the agency's interests.
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A. 28 USING EXISTING GROUPS/PUBLICATIONS (Continued)
Make sure that the relationship between the agency and any group is
clearly understood by both the group itself and by the public.
When to Conduct
While this activity is most useful in the early stages of site activity
as a means of developing contacts within the community, it may also be
useful throughout the site cleanup process. Using existing organizations
and/or their publications ensures a regular and attentive audience.
Accompanying Activities
Existing groups and their publications may be useful for identifying
individuals for purposes of community interviews, mailing lists, and
door-to-door canvassing efforts.
Benefits
The principal benefit of using the mailing lists or publications of
existing organizations is that the agency has access to an established
communication network. Less time and expense will be needed to develop
mailing lists and to organize meetings.
Limitations
Working too closely with existing groups, or working exclusively with
just one group, may be misperceived by other groups within the community.
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A.29 WORKSHOPS
Description
Seminars or a series of meetings to discuss hazardous substance issues;
to allow citizens to comment on proposed response actions; and to provide
information on the technical issues associated with the site and the
Superfund program in general. Experts may be invited to explain the
problems associated with releases of hazardous substances and possible
remedies for these problems.
Purpose
To improve the public's understanding of the hazardous substance problem
at the site and to prevent or correct misconceptions. To enable agency
staff to identify citizen concerns and to receive citizen comments.
Technique
To conduct a workshop:
Plan the workshop. Decide ahead of time on a minimum and maximum number
of. participants. If there are too few, consider holding an informal
meeting and postpone the workshop until additional interest develops.
Identify a convenient location and time for the workshop, and set a date
that does not conflict with other important meetings or interests (for
example, town council meetings, high school basketball games).
Announce the workshop by publishing a notice well in advance (at least 3
weeks) in the local newspapers. Send notice of workshops with mailings
to all citizens on site mailing list and distribute posters around town.
Send out invitations and registration forms to concerned citizens.
Provide for multiple registrations on each form to accommodate friends
who might also be interested in the workshop. Emphasize that the number
of participants is limited, and provide a deadline for registration.
Cover the following topics:
o Nature of release problems;
o Methods of containing and cleaning up release, and monitoring
the cleanup;
o Identification of health or environmental problems; and/or
o Method and format for receiving citizen comments on the
proposed or ongoing response.
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A.29 WORKSHOPS (Continued)
When to Conduct
Workshops are appropriate for presenting technical information to
citizens, such as the draft FS. Workshops could also be useful when a
site is first proposed for the NPL; to inform citizens about the
Superfund cleanup process; and to increase their understanding of
potential risks associated with the site.
Accompanying Activities
Workshops can be conducted before fornal public hearings or during public
comnent periods to give citizens some ideas on developing and presenting
testimony. Fact sheets and exhibits can be used at workshops.
Benefits
Workshops provide more information to the public than is possible through
fact sheets or other written materials. Workshops have proven successful
in familiarizing citizens with key technical terms and concepts before a
public meeting. Workshops also allow two-way communication, making them
particularly good for reaching opinion leaders, interest group leaders,
and the affected public.
Limitations
Workshops can reach only a small segment of the affected population, if
only a limited number are held.
When planning a workshop, agency staff should make sure that it is
announced in local newspapers, to help ensure that it will be well-
attended. In addition, it may be helpful to specifically invite all
residents who have expressed an interest in the site.
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APPENDIX B
SUGGESTED FORMAT FOR AND SAMPLE COMMUNITY RELATIONS PLAN
I. SUGGESTED FORMAT
A. Overview of Community Relations Plan
Purpose: Provide a general introduction by briefly stating the purpose
of the community relations plan and the distinctive or central features
of the community relations program planned for this specific site. Also
note any special circumstances that the plan has been designed to
address. Do not repeat general program goals (e.g., "Keep the community
informed").
Length: One paragraph to several pages.
B. Capsule Site Description
Purpose: Provide the historical, geographical, and technical details
necessary to show why the site was put on the NPL.
Suggested topics:
o Site location and proximity to other landmarks;
o History of site use and ownership;
o Date and type of release;
o Nature of threat to public health and environment; and
o Responsibility for site (e.g., State- or Federal-lead).
Length: One page.
C. Community Background
Purpose: Describe the community and its involvement with the site.
Cover three topics:
1. Community Profile: the economic and political structure of the
community, and key community issues and interests.
2. Chronology of Community Involvement: how the community has reacted
to the site in the past, actions taken by citizens, and attitudes
toward government roles and responsibilities. Discuss actions taken
by any government agencies or government officials, such as public
meetings or news releases.
B-l
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3. Key Community Concerns: how the community regards the risks posed
by the site or the remedial process used to address those risks.
One approach: break down the analysis by community group or segment
(i.e., public environmental interest groups; nearby residents; and
elected officials).
In all three sections, but particularly in the last, focus on the
community's perceptions of the events and problems at the site, and not
on the technical history of the site.
Length: From three to seven pages, depending on the history and level of
community involvement in the site.
D. Highlights of Progran
Purpose: Provide concrete details on community relations approaches to
be taken, which should follow directly and logically from Section C's
discussion of the community and its perceptions of the problems posed by
the site. Do not restate the goals or objectives of conducting community
relations at Superfund sites. Instead, develop a strategy for
communicating with a specific community.
Suggested topics:
o Resources to be used in the community relations program (e.g.,
local organizations, meeting places);
o Key individuals or organizations that will play a role in
community relations activities;
o Areas of sensitivity that must be considered in conducting
community relations.
E. Techniques and Timing
Purpose: State what community relations activities will be conducted at
the site and when. Suggest additional techniques that might be used at
the site as the response action proceeds, and when they are likely to be
most effective.
Length: Two to three pages. Matrix format may be suitable.
B-2
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Appendices
o Mailing List of Interested Parties and Key Contacts*
o Suggested Locations of Meetings and Information Repositories
*(Names and addresses of individuals should not be included in the the
community relations plan that is made available in the information repository
for public review. Names and addresses should, however, be compiled for a
mailing list as part of the Community Relations Coordinator's files.)
B-3
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II. SAMPLE FLAN
The following community relations plan for the Sludge Pond site in
Woodbury, Connecticut is intended to illustrate the suggested format and
content of community relations plans, as discussed in Chapter 3 of this
handbook. While the plan is based on actual community interviews conducted
for a Superfund remedial site, names, locations, and technical details have
been changed so that the plan should be viewed as an illustration only.
********
COMMUNITY RELATIONS FLAN
SLUDGE POND SITE, WOODBURY, CONNECTICUT
A. OVERVIEW OF COMMUNITY RELATIONS PLAN
This community relations plan identifies issues of community concern
regarding the Sludge Pond Superfund site in Woodbury, Connecticut, and
outlines community relations activities to be conducted during the remedial
investigation and feasibility study (RI/FS) of the site. In general,
community concern about the site is low; having known for almost 40 years that
the site was a source of contamination, residents appear more or less resigned
to its presence in their community. The start of remedial activity at the
site, however, is likely to reawaken the concern of the community. An
effective community relations program for this site should, therefore, prepare
for this potential revival of community interest and attempt to educate,
without alarming, residents so that they can better understand the Superfund
remedial process. In particular, the community relations program for Sludge
Pond should enlist the support and cooperation of the town and county
officials of Woodbury. These individuals have a long-standing familiarity
with the area and its residents and hold visible positions of responsibility
within the community; therefore they should be considered as a key resource in
the effort to communicate openly and effectively with the people of Woodbury.
This draft community relations plan has been prepared to aid EPA in
developing a community relations program tailored to the needs of the
community affected by the Sludge Pond site. EPA conducts community relations
activities to ensure that the local public has input to decisions about
Superfund actions and is well-informed about the progress of those actions.
These sections follow:
o Capsule Site Description
o Community Background
o Highlights of Program
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o Techniques and Timing
o Attachments: List of Contacts and Interested Parties
and Locations for Information Repository and Public
Meeting
The information in this plan is based primarily on discussions conducted
in Litchfield County, Connecticut, in August 1985, with the District Health
Department, officials from the Litchfield County Office of the Connecticut
Department of Environmental Protection (DEP), the first selectman of Woodbury
Township, a Litchfield County Commissioner, and residents of Woodbury and
Watertown Townships. The "Preliminary Investigation Report/Lewis Iron Works
Site," prepared by contractors to Eastern Manufacturing Co., also provided
valuable information.^
The U.S. Environmental Protection Agency (EPA) Region I Office has lead
responsibility for managing this RI/FS; the EPA Region I Office of Public
Affairs will oversee all community relations activities at the site. The
Office of Community Involvement in the Ground Water Quality Division at DEP
will play a major role in implementing community relations activities.
B. CAPSULE SITE DESCRIPTION
The Sludge Pond site is located on a 40-acre tract of land in Litchfield
County, Connecticut, one mile south of Woodbury Township on Route 6.
(Exhibits 1 and 2 illustrate the location of the site within the state, and
surrounding geographical landmarks.) To the north is Tanner Lake, used for
fishing and swimming. The closest residences are approximately one-quarter
mile to the northwest and west across Route 6.
From 1886 to 1945, the site was used by Lewis Iron Works, a major
producer of charcoal, pig iron, and organic chemicals. Liquid tar residues
from chemical processing were discharged into a 2-acre depression on site,
giving to the area its current name of "Sludge Pond." Lewis Iron Works shut
down its chemical operations in early 1944, ceased operations entirely in
1945. Among the current owners of the site property are Eastern Manufacturing
Co., whose nearby plant produces automotive parts; the Wilson Lumber Co.; and
the township of Woodbury, which operated an 8-acre municipal landfill adjacent
to Sludge Pond from 1961 to 1969.
In the late 1940s, shortly after the closing of the Iron Works, residents
as far away as 3 miles from the site reported that their well water had a
"chemical taste and bad odor." Samples taken by the Connecticut Geological
This, as well as other technical reports (such as the RI/FS workplan),
will be made available at the information repository to be established in
Woodbury. These reports will give full details of the type and extent of the
problems at Sludge Pond.
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Exhibit 1
SITE LOCATION MAP
SLUDGE POND SITE
LITCHFIELD COUNTY, CONNECTICUT
v,
i
i
LITCHFIELD
T
,- HARTFORD I TOLLAND WINDHAM
NEW LONDON
B-6
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Exhibit 2
SLUDGE POND SITE VICINITY MAP
TAPAWINGO SKI AREA
TOWN OF
WOODBURY
SCALE IN MILES
B-7
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Study in 1949 indicated that phenol had contaminated eight private wells, to
the west and northwest of Sludge Pond. In the 1960s, the surface sludges on
site caught fire and burned out of control for several weeks.
Limited water sampling conducted since 1980 has confirmed the 1949
findings of phenol in the ground water. In addition, DEP found evidence of
heavy metals in Sludge Pond in 1980. Heavy metals, however, were not
confirmed by monitoring samples taken by EPA's Field Investigation Team in
1982, or by on-site testing conducted by Eastern Manufacturing in 1983. After
private wells were tested by DEP and the District Health Department in 1980,
residents were told that their water was drinkable.
Sludge Pond was proposed for the National Priorities List (NPL) in
December 1982. The site has recently been designated a Fund-lead site for the
RI/FS, although enforcement proceedings are underway against Eastern
Manufacturing.
C. COMMUNITY BACKGROUND
1. Comnmity Profile
The Township of Woodbury, named for the abundance of trees in the area,
developed in the 1820s as settlers journeyed to western Connecticut in search
of farmland. However, because of the town's fairly remote location, industry
did not begin to develop in the area until about a half-century later. In
1882, George Lewis - an area entrepreneur - erected a blast furnace to
manufacture charcoals, and the Lewis Iron Works soon became the area's largest
employer.
Several Woodbury residents interviewed for this plan recalled the days
when their relatives or neighbors worked at the Iron Works, and old
photographs of the company's vast lumber stocks and furnace can still be seen
in the local library and on the walls of the town office building.
Since the closing of the Iron Works, major sources of employment in the
area have included light industry and farming. Local craft industries dating
from the early nineteenth century continue to flourish in the area, as do
antique stores and clock shops. Dairy and poultry farms occupy a significant
portion of the land in Litchfield County and nearby Hartford county.
In general, however, Woodbury Township remains a quiet, rural area,
somewhat insulated from the industrial development to the south and east.
Judging from individuals interviewed for this plan, many town members have
been long-time residents in the area, and the township's small population
(7,000 reported in the 1980 Census) has meant that local officials know, and
are known by, most of the area's residents. A significant number of senior
citizens in the community; aging issues and facilities for the elderly have
been prominent concerns in the community, and according to the township clerk,
a central meeting place in the area is the Litchfield County Senior Center.
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2. Chronology of Comunlty Involvenent
Local officials have described community reaction to the proximity of an
NPL site as "quiet," particularly in the past year. The District Health
Department receives only infrequent inquiries about the safety of private well
water which, according to users, is a brownish-orange color and stains
bathroom fixtures and laundry. The last call was received at the beginning of
the summer of 1985 from a prospective home builder who was concerned about the
condition of the ground water directly south of Sludge Pond. Because ground
water flows west from the site -- and, in the opinion of some local officials,
is confined to a narrow finger of an aquifer -- the Health Department assured
the caller that his property was not threatened by contamination from the
site.
The level of community concern, while never high, reached a peak in the
early 1980s, when DEP analyzed sludges from Sludge Pond and water from a
number of private wells. Early in 1980, a local farmer with contaminated well
water wrote to the District Health Department after reading an article in the
Waterbury Republican about the suspected hazards at the site. She was
concerned because guests could not drink her water, though she herself was
accustomed to its distinctive taste. When interviewed, this same resident
stated that she and her husband knew about the problems with their well when
they purchased their house and farm, and in fact were able to buy the property
at a reduced price because of the discolored water.
Also in 1980, the Township of Woodbury took over and began rebuilding a
town water system from an independent water company. A major part of this
project, which was financed through loans and grants from the Farmers' Home
Administration, was the replacement of leaking wooden main pipes. Some
community members also attempted to obtain a Health Department grant to have
the water mains extended to the residents with private wells who had bad well
water. According to a County Commissioner, obtaining funds from the Health
Department for this extension required demonstrating that the water was not
fit for drinking. Because this was never done, the Township was unable to
finance an extended water system. While affected citizens could conceivably
put in their own pipes to connect to the town water system, this option
appears to be well beyond the means of individual residents.
Shortly after the site was listed on the NPL in December 1982, the
Litchfield County Herald ran an article identifying Sludge Pond as one of
"EPA's 400 Worst." Though several residents could recall the article, the
classification of Sludge Pond as a Superfund site did not particularly alarm
residents or motivate them to take organized action. No community groups have
been formed to participate in the investigation of the site, or to voice an
opinion as to how the site should or could be addressed. In general, affected
residents have dealt with the problem of contaminated well water in fairly
quiet and individual ways: some carry bottles of municipal water home for
drinking, and take extra measures (e.g., filtering and bleaching) to prevent
staining of laundry. From the point of view of local officials, a far more
urgent issue is the potential closure of the Litchfield-Berkshire municipal
landfill after DEP found contamination in monitoring wells at the landfill.
Because closure would mean that area waste would have to be transported
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further away, local officials are particularly concerned that some citizens
will resort to dumping refuse on back roads rather than paying the higher
transporting fees.
3. Key Gomunlty Concerns
Currently, as throughout the past 5 years, community concern about
contamination from Sludge Pond is fairly low, possibly because:
o Citizens have lived with the knowledge that Sludge
Pond was contaminated for a long period of time.
o Citizens view the contamination primarily as a
nuisance, but not as a public health hazard.
Residents rely on the fact that DEP and the Health
Department have never declared the water undrinkable.
o Only a few residents are affected, and their houses
are scattered over farmland about 2 miles northwest
from the site. In conversations with community
members, about 6 families were mentioned as having
had problems with their private wells. At least two
families have moved to homes on the municipal water
supply; another family had problems only when it
installed a well before being connected to the
municipal water system.
Current low level of community concern about Sludge Pond should not be
construed as lack of interest. Citizens are not indifferent to the
environmental problem posed by Sludge Pond; their attitude might be more
accurately characterized as resigned. In their view, the problem is
intractable. According to one resident, because such large quantities of
sludge were once deposited on site, it would literally take moving a small
mountain to eliminate the years' accumulation of waste. Furthermore, many
residents consider their community too rural and economically insignificant to
command Federal attention or funds for a cleanup.
The start of the Sludge Pond RI/FS is bound to change this attitude of
resignation. The arrival on site of investigation teams, and discussion of
alternatives during the FS may cause people to consider that perhaps the
problems at Sludge Pond can be solved and are worthy of being addressed. In
developing a community relations program for this site, it is important to
anticipate this potential for renewed community interest. The following kinds
of concern, voiced individually and in a low key manner during community
interviews, are likely to become more visible and pressing during the RI/FS:
o Property Values: Some residents have suffered losses
in the market value of their property as a result of
ground-water contamination in the area. When one
resident put his property up for sale, he was told by
the realtor that the listing had to carry a statement
that his well water was contaminated. He has been
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unable to sell his property, despite a substantial
decrease in his asking price, and has had to go into
debt to purchase a new home.
Inconvenience: Contaminated well water has
inconvenienced residents in a number of ways: they
must carry bottled water to their homes from the
homes of friends or relatives on municipal water, and
take extra measures with their laundry. There is
also the problem of the water having a bad odor. One
resident claims her plumbing has been affected by the
contaminants in her water. One resident complained
of a rash that did not heal while she was using
private well water, but in general it appears that
citizens regard the contamination of ground water as
a nuisance, rather than a health hazard.
Follow-up with community after site work: Over the
past 5 years, technical teams from EPA, DEP, the
District Health Department, and Eastern Manufacturing
have been in the area to sample monitoring wells and
private wells and fence the site. Some residents
complained that there was no adequate follow-up to
these visits, or explanation as to what had been the
purpose or results of testing. Owners of private
wells that were sampled did receive copies of
laboratory slips listing the levels of various
contaminants. However, they were not familiar with
the types of contaminants being tested, nor did they
understand how to interpret the levels detected.
Local officials were also irritated that they had not
been informed of the results of sampling activities.
Financing and conducting remedial work: At least one
local official and one resident wondered how the
investigation and possible cleanup of Sludge Pond
would be financed. The official's concern was that
the township could not afford remedial action at the
site; at the same time, he did not consider it fair
that Eastern Manufacturing, as a potentially
responsible party, might be liable for remedial costs
since the company had not created Sludge Pond. In
general, community members do not appear to be
knowledgeable about the Superfund remedial or
enforcement process, or its technical and legal
requirements. For example, one elected official who
had witnessed a technical crew on site found it
difficult to understand why sampling had to be
delayed until EPA-approved bottles were obtained. He
was also somewhat impatient that EPA would be
starting an RI of the site, when it had already been
investigated a number of times.
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D. HIGHLIGHTS
The community relations program at the Sludge Pond site should be
designed to allow the community to learn about and participate in the
Superfund remedial process, without disrupting the community's confidence that
the site poses no new or immediate hazards. To be effective, the community
relations program must be gauged according to the community's need for
information, and its interest and willingness to participate in the remedial
process.
The community relations program at the Sludge Pond site should take the
following approaches:
1. Enlist the support and participation of local officials in
coordinating community relations activities. Appropriate officials to involve
in a community relations program include the Town First Selectman; the County
Commissioner for Litchfield, and District Health Department officials. These
officials are visible and trusted leaders in the community, and are therefore
a valuable resource in EPA's effort to understand and monitor community
concern. To gain the support of local officials, inform them regularly and
fully of site activities, plans, findings, and developments.
2. Provide follow-up explanations about sampling and test results to
area residents. Concise and easily-understood information should be available
to all residents on the schedule of technical activities, their purpose, and
their outcome. Where information cannot be released to the public - - either
because of quality assurance requirements or the sensitivity of enforcement
proceedings -- explain clearly and simply why the information must be
withheld. Community relations staff should also, however, attempt to identify
special situations or concerns where more specialized information may be
required, or where certain types of information are needed by single
individuals or groups. In particular, owners of property where samples are
taken should receive follow-up explanations of what was done and found on
their land. Finally, to. ensure that inquiries from the community are handled
efficiently and consistently, a single EPA contact should be established for
the site.
3. Educate area residents and local officials about the procedures.
policies, and requirements of the Superfund program. To dispel some of the
current confusion about EPA's purpose and responsibilities at the site, make
an effort to circulate basic information to the community describing the
Superfund process. Questions asked by community members during on-site
discussions indicate that the following areas could receive special emphasis:
scoring and ranking of NPL sites, the schedule and stages of an RI/FS, and the
criteria used to select a cleanup alternative.
4. Let the people "set the pace" for the community relations program.
Be aware that federal involvement in local issues is not always well-regarded
by townspeople. Federal, and even State, programs are seen as excessively
bureaucratic and insensitive to the realities of local government budgets and
planning. Therefore, do not "overdo" or overplan community relations
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activities in a way that might discourage community participation. Large,
formal meetings will almost certainly be inappropriate for this community, as
will activities that are planned without consulting key local officials.
5. TECHNIQUES AND TIMING
The following activities are required for the Sludge Pond site community
relations program. Exhibit 3 illustrates the timing of each activity during
the remedial schedule for the site.
1. A public comment period on the draft FS report. A minimum 3-week
public comment period must be held to allow citizens to express their opinions
on EPA's preferred alternative for remedial action at Sludge Pond. Community
input should be encouraged at this point by informing citizens that EPA will
consider their opinions in the ultimate decision on remedial design and
remedial action.
2. Preparation of responsiveness summary. This document is required as
part of the record of decision (ROD) for the site. It should summarize public
concerns and issues raised during the public comment period on the draft FS.
In addition, the responsiveness summary documents responses made by EPA and
the State to these concerns.
3. Revision of Community Relations Plan. Once the ROD has been issued
for Sludge Pond, this community relations plan should be revised to outline
community relations activities appropriate to the remedial design and remedial
action (RD/RA) phase. The revision of the community relations plan should:
o Update facts and verify the information in this
community relations plan prepared for the RI/FS.
o Assess the community relations program to date and
indicate if the same or different approaches will be
taken during RD/RA.
o Develop a strategy for preparing the community for a
future role during RD/RA and ongoing operation and
maintenance.
Community interviews should be held before the Sludge Pond community relations
plan is revised.
In addition to these basic requirements for a community relations program
at Sludge Pond, a number of activities will be undertaken to ensure that the
community is well informed about site activities and has the opportunity to
express its concerns. Activities, and their approximate timing, are as
follows:
1. Establish and maintain information repositories: Fact sheets,
technical summaries, site reports (including the community relations plan),
and information on the Superfund program will be placed in the information
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repositories. An information respository will be located at the Woodbury
Public Library.
2. Establish an information contact: A technical or community relations
staff person will be designated to respond directly to public inquiries
regarding site activities. In contacts with the press, this person should
coordinate with EPA Community Relations staff and the DEP Community
Involvement staff.
3. Meet with local officials and telephone them periodically: The
County Commissioner and the town's First Selectman have indicated that they
want to be informed about site plans and findings. Meetings with local
officials should include both EPA and DEP officials and should be held at the
following technical milestones:
o Completion of the final work plan;
o Completion of the draft RI/FS report; and
o Before remedial action starts.
4. Conduct informal meetings with residents: A meeting with residents
is advisable prior to the RI, and before any on-site activities involving use
of earth-moving devices or other heavy machinery. The meeting should include
interested citizens, the EPA Remedial Project Manager, the DEP Community
Involvement Coordinator, and REM II technical and community relations
contractor assistance as necessary.
5. Prepare fact sheets and technical summaries: One fact sheet might be
released at the beginning of the RI to inform area residents and other
interested citizens about EPA's site plans and the procedures of the Superfund
program. Another fact sheet (including a technical summary) might be prepared
to explain the findings of the RI and to outline each of the remedial
alternatives considered for the Sludge Pond site. A detailed description of
EPA's preferred remedial alternative(s) should also be provided. In addition,
each fact sheet should list the location of information repositories where
information is available for public review.
6. Provide news releases to local media: Prepared statements might be
released to local papers, such as the Litchfield County Herald and the
Waterbury Republication. and to local radio and television stations to
announce discovery of any significant findings at the site during the RI/FS,
or to notify the community of any public meetings. Additional news releases
are advisable at the following milestones:
o When the draft FS report is completed; and
o Before remedial action starts.
Addresses and phone numbers of local newspapers are included in Appendix A.
7. Hold public meeting: A public meeting held during the public comment
period would provide an opportunity for EPA to answer questions directly and
to discuss the recommended remedial alternative. According to community
residents, as few as 20 or as many as 200 community residents might attend
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such a meeting. Planning should therefore be flexible. This meeting might be
held in the auditorium of one of Woodbury's public schools (Elementary, Middle
or High School.) The meeting should be coordinated with the Woodbury and
Watertown Township Officers.
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43 -a
SO 43
B
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43 C .
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ATTACHMENT
LIST OF CONTACTS AND INTERESTED PARTIES
A. Federal Elected Officials
(names and addresses) (phone)
B. State Elected Officials
(names and addresses) (phone)
C. Local Officials
(names and addresses) (phone)
D. U.S. EPA Region I Officials
(names and addresses) (phone)
E. State and Local Agencies
(names and addresses) (phone)
F. Community Organizations, Environmental Groups, and
Citizens' Groups*
(names and addresses) (phone)
6. Media
(name and address) (phone)
*Names and addresses of private citizens should not appear in the
community relations plan that is released to the public. These names should,
however, be placed on a mailing list that is compiled for the site. To protect
the privacy of individuals, this mailing list is compiled for the sole use of
the lead agency.
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ATTACHMENT
LOCATIONS FOR INFORMATION
REPOSITORY AND PUBLIC MEETING
Information Repository:
Woodbury Public Library (203) 246-4567
202 W. State Street
Woodbury, Connecticut 06798
Hours: Mon-Fri 9 am-9 pm
Sat 9 am-5 pm
Sun 12 noon-5 pm
Meeting:
Woodbury Public Schools (203) 246-1234
Elementary School
231 Chapel Street
Woodbury, Connecticut 06798
Middle School (203) 246-2468
105 E. Main Street
Woodbury, Connecticut 06798
High School (203) 246-1359
414 W. Main Street
Woodbury, Connecticut 06798
Woodbury Township Office (203) 246-4568
(basement of Woodbury Public Library)
202 W. State Street
Woodbury, Connecticut 06798
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APPENDIX C
SUGGESTED FORMAT FOR AND SAMPLE RESPONSIVENESS SUMMARY
I. SUGGESTED FORMAT
1. Overview
Purpose: Briefly state public reaction to the agency's preferred
alternative.
Length: One to two paragraphs.
2. Background on Community Involvement
Purpose: Briefly summarize major community concerns identified as part
of the community relations plan and during the RI/FS, and identify how
the agency addressed these concerns.
Length: Two to three pages.
3. Summary of Public Comments and Agency Responses
Purpose: Summarize the comments received by the agency during the public
comment period on the RI/FS and proposed plan. Include written and oral
comments from individual citizens, citizen groups, local officials, and
PRPs. Group comments into appropriate topics, such as public preferences
for remedial action and public comments on enforcement action.
Length: Varies with the number and types of comments received.
4. Remaining Concerns
Purpose: Identify any public concerns that the agency did not address
directly during the RI/FS, and how it proposes to handle these concerns
during remedial design and remedial action.
Length: One to two pages.
Attachment
List of community relations activities conducted at the site before and
during the public comment period.
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II. SAMPLE RESPONSIVENESS SUMMARY
The following responsiveness summary for the Mitchell Dump in Annapolis,
Maryland site is intended to illustrate the suggested format and content of
responsiveness summaries. This example was based on an actual responsiveness
summary prepared for a Superfund remedial site. Names, locations, and some
technical details have been changed so that this responsiveness summary should
be viewed as an illustration only.
MITCHELL DUMP, ANNAPOLIS, MARYLAND
RESPONSIVENESS SUMMARY
A. OVERVIEW
At the time of the public comment period, EPA had already selected a
preferred alternative for the Mitchell Dump in Annapolis, Maryland. EPA's
recommended alternative addressed the soil and ground-water contamination
problems at the site. The preferred alternative specified in the record of
decision (ROD) involved aeration to reduce soil contamination, and pumping and
treating the contaminated ground water. Treatment of ground water would
involve air stripping and carbon filtration. The treated ground water would
then be returned to the aquifer.
Judging from the comments received during the public comment period, the
residents and town council of Annapolis, and the Maryland Department of
Environmental Protection (DEP) would strongly support the pumping and
air-stripping alternative for ground-water contamination. The community, in
general, preferred soil treatment methods other than aeration (e.g., Citizens
for a Safe Environment preferred incineration, local officials preferred
capping, and DEP preferred excavation and removal of "hot spots"). The PRPs,
however, would not support any alternative that involved pumping and treatment
of ground water.
These sections follow:
o Background on Community Involvement.
o Summary of Comments Received during Public Comment Period and
Agency Responses.
o Remaining Concerns.
o Attachment: Community Relations Activities at Mitchell Dump.
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B. BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in the Mitchell Dump dates to 1973 when residents of
Annapolis reported odors in their well water and discoloration of laundry.
Since 1973, community concern and involvement have remained strong. Two
women, Jane Bethel and Karen Sweeney, have been particularly vocal in
expressing the concerns of the community to the Annapolis Town Council, DEP,
and EPA. They have been successful in focusing considerable media attention
on the site. The major concerns expressed during the remedial planning
activities at the Mitchell Dump focused on possible health effects from the
contamination at the site and the apparent delays in getting the site cleaned
up. These concerns and how EPA and the State addressed them are described
below:
1. Citizens for a Safe Environment and several residents expressed
concern that wells not originally included in the State's sampling
plan were contaminated.
EPA Response: EPA agreed to expand the sampling plan to include the
wells identified by the residents.
2. At two points during the RI, local officials and a few residents
complained that there was not adequate follow-up. Specifically,
they complained that sampling results and the status of negotiations
with PRPs were not made available.
EPA Response: Concerning the lack of sampling information, EPA
officials telephoned local officials and interested residents to
explain the sampling results as they became available.
EPA was unable to provide the community with information on the
status of PRP negotiations since this information is considered
confidential. EPA did acknowledge that PRP negotiations were
underway.
3. Citizens for a Safe Environment expressed a great deal of concern
about health effects from the site shortly after the ground-water
contamination was first discovered.
EPA Response: To provide the community with accurate, up-to-date
information on possible health effects from the Mitchell Dump, EPA
prepared and distributed a fact sheet.
4. One of the major concerns expressed by local officials and residents
regarded the perceived delays in the cleanup schedule.
EPA Response: EPA distributed a generic information pamphlet
describing the remedial process and the time required for remedial
activities.
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C. SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD
Comments raised during the Mitchell Dump public comment period on the
draft FS and proposed plan are summarized briefly below. The comment period
was held from February 27 to April 6, 1987. The comments are categorized by
relevant topics.
Remedial Alternative Preferences
Each of the major commentors on the draft FS expressed a preference for
specific alternatives:
1. DEP recommended controlling the source of contamination, possibly by
on-site aeration if first tested on a small scale. DEP also
recommended that EPA excavate the top few feet of soil in the "hot
spots" and dispose of soil off-site. DEP supports ground-water
pumping and treatment, but disagrees with EPA proposals. DEP
suggests that ground water be treated at the point of discharge
rather that at the point of origin.
EPA Response: After considering the tradeoffs between the
solutions, EPA decided on the on-site remedial action described in
the Record of Decision (ROD). This remedial action will involve
soil aeration on-site, covering the site with a synthetic cap, and
pumping and air-stripping/carbon filtration of ground water. For a
further explanation of the process for selecting the remedial
alternative, refer to the ROD. The ROD considers both the on-site
aeration alternative and treatment of ground water at the point of
discharge, and documents EPA's choice of cleanup method.
2. Citizens for a Safe Environment (speaking for a number of citizens
at the public hearing) recommended that ground water be pumped and
treated; however, they also expressed concern as to whether
air-stripping would remove heavy metals. The Citizens for a Safe
Environment and State Representative Bob Carter preferred source
control by incineration rather than soil aeration or capping the
site.
EPA Response: EPA seriously considered the preference of local
residents for pumping and treatment of ground water and eventually
selected it as the preferred alternative. EPA selected aeration
over incineration because of the potential air pollution from
incineration. Air-stripping is an effective treatment for volatile
organics, but not for heavy metals. To date, heavy-metal
contamination in off-site ground water has not been identified as an
environmental or public health concern. If this situation changes,
the proposed treatment system will be modified to ensure that levels
of heavy metals in the treated water will not adversely affect
public health or environment.
3. The Annapolis Town Council agreed that ground-water extraction and
treatment were critical. The town council was, however, split on
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capping versus incineration. The council preferred a clay cap
rather than a synthetic cap. The council opposed on-site aeration.
Other local officials, including the Annapolis Planning Board and
the Mitchell Dumping Site Evaluation Committee, endorsed capping as
the preferred method of source control.
EPA Response: EPA appreciates the efforts made to consider
seriously the tradeoffs involved in the source control options. EPA
has considered the advantages, disadvantages, and uncertainties
associated with each alternative considered in the FS. After
considering the effectiveness and cost of each alternative, EPA
decided on the aeration and air-stripping/carbon filtration
alternative described in the ROD. For a further explanation of the
process for selecting the remedial alternative, refer to the ROD.
4. All PRPs and their representatives recommended that the source of
contamination be controlled and that the ground water be allowed to
cleanse itself naturally. They opposed pumping and treating ground
water due to possible technical problems and questioned the
cost-effectiveness, since the water is not presently used to supply
drinking water.
EPA Response: As EPA explained to the PRPs, EPA's policy is that
applicable and relevant Federal laws be applied to Superfund
remedies to ensure adequate protection of public health, welfare,
and the environment. In this case, EPA applied Federal standards
from the Resource Conservation and Recovery Act (RCRA) to reach the
decision to pump and treat off-site contaminated ground water by the
air-stripping and carbon filtration methods. This cleanup will be
accomplished to levels adequate to protect human health based on
drinking water standards.
Technical Questions/Concerns Regarding Remedial Alternatives
1. DEP recommended that air monitoring be developed before any on-site
work that may result in emissions to the atmosphere.
EPA Response: Air quality will be monitored both on and off the
site during the soil aeration. If monitoring reveals air releases
in excess of EPA standards, aeration will be halted and one of the
other remedial alternatives will be substituted.
2. Citizens for a Safe Environment questioned the adequacy of the RI/FS
in explaining the effects of seasonal variation in the level and
movement of ground water. The group questioned whether testing done
in March was representative of the entire year.
EPA Response: The RI/FS provides sufficient information, including
information on depth of ground water, to make a decision on a site
remedy without further delays associated with additional studies.
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3. Most of the PRPs and several individuals questioned the
effectiveness and technical feasibility of the pumping/treating
alternative for ground water.
EPA Response: EPA considered state-of-the-art ground-water
restoration techniques in the RI/FS. Field tests during the
pre-design stage will be conducted to ensure that pumping/treating
is effective.
4. PRPs expressed concern that because the pumping alternative
necessitated construction on the site, an unattended structure would
be left on the site for many years and would attract vandals.
EPA Response: The treatment facility for the Mitchell Dump will be
designed to minimize the potential for vandalism.
5. Citizens for a Safe Environment and a local union leader expressed
concern that soil aeration may pose unacceptable risk to workers and
community, including children wandering onto the site.
EPA Response: Soil aeration will be completed as efficiently as
possible, but in accordance with a procedure which will not allow
airborne contaminants to exceed the safe limits established by EPA
for both workers and the public. EPA will require air monitoring
during soil aeration. If this monitoring reveals air releases in
excess of EPA standards, aeration will be halted and one of the
other remedial alternatives will be substituted. Measures will be
taken to prevent unauthorized people from entering the site,
6. DEP, Citizens for a Safe Environment, Representative Carter, and a
resident raised concerns regarding the long-term integrity of the
cap at the public hearing. They have argued that while a cap
provides cover, it does not eliminate contamination and eventually
contaminants will emerge. Citizens for a Safe Environment had a
number of questions concerning the capping alternative, including:
(1) How long will the cap last? (2) Will the cap be affected by
chemical vapors from the soil? (3) Will excessive water ponding on
top of the cap or running off the sides get into the soil? (4) Will
excess water be drained? (5) What effects will thawing have on the
cap?
EPA Response: The use of synthetic caps is relatively new (10-15
years old); therefore, predicting its effective life is difficult.
Manufacturers of the synthetic cap material claim that it can
withstand high concentrations of liquid volatile organics for 50
years or more. The cap at Mitchell will not come into contact with
liquids, but will come into contact with lower concentrations of
vapors. Therefore, EPA feels that a 50-year life span is realistic.
Tests of the cap have shown that the capping material will not be
affected by thawing.
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As for ponding - - the cap will act as an umbrella over the
contaminated soil. The site is naturally graded, so there should be
no ponding in the vicinity of the contaminated soils. Water will
naturally drain off the site.
8. PRPs questioned the application of RCRA since meeting the RCRA
requirements was not a stated objective in the FS.
EPA Response: To adequately protect public health and the
environment, EPA policy is that applicable and relevant Federal laws
be applied to Superfund remedies. In the case of the Mitchell Dump,
the applicable regulations are those found in RCRA that call for
cleaning up off-site contamination caused by the migration of
contaminants from a hazardous waste facility.
9. At the public meeting, one resident asked how aeration is to be
done.
EPA Response: As the Agency explained during the meeting, soil
would be turned over periodically with a rototiller to encourage
evaporation of volatile organics and monitored until levels of
contaminants in the soil are below detectable levels.
Public Participation Process
1. There were several complaints that not enough time was allowed
between the public meeting on March 17, when RI/FS was explained,
and the scheduled close of the public comment period on March 24.
(The draft FS was released on February 27). Specifically, the
following parties requested to have the public comment period
extended: Citizens for a Safe Environment, Annapolis Town Council,
residents, PRPs, and Representative Carter.
EPA Response: The public comment period started with the release of
the documents on February 27, 1985. During the comment period, EPA
held a meeting on March 17, 1985 to receive any questions on the FS.
The comment period initially allowed three weeks for comment, but
was extended on two occasions; with the extensions, the comment
period ended April 6, 1985.
Costs/Funding Issues
1. Several comments were received from DEP, residents, and
Representative Carter expressing concern that operation and
maintenance (O&M) costs could place a large burden on the State and
therefore the taxpayers. DEP was particularly concerned that O&M
costs would be an excessive burden on the State. Citizens for a
Safe Environment and citizens suggested that PRPs should pay for
O&M.
EPA Response: The Superfund law stipulates that, whenever possible,
PRPs pay for remedial actions at a Superfund site. PRPs can conduct
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the remedial action or EPA can take action following the cleanup to
recover monies for Superfund.
EPA will try to ensure that PRPs pay the costs of cleanup and the
O&M costs. In addition, further efforts will be made to minimize
the State's O&M costs without jeopardizing the effectiveness of the
remedial action.
2. Residents and Representative Carter stated that cost should not be a
criterion in deciding how to clean up a site.
EPA Response: The National Contingency Plan (NCP) specifies the
decision process for remedial actions at Superfund sites. EPA does
not compromise on the effectiveness of an alternative to meet the
cost-effectiveness criterion. However, among those alternatives
considered effective, EPA selects the least costly. This preserves
monies for other Superfund sites.
3. Representative Carter and the Citizens for a Safe Environment stated
that since the FY 1985 final Superfund Comprehensive Accomplishments
Plan (SCAP) allocated $5 million for cleanup of the Mitchell Dump,
EPA should not be constrained by costs in selecting alternatives.
EPA Response: The $5 million listed in the SCAP was an estimate
made in advance of the FS for budgeting purposes nationwide. It is
a gross estimate made before the appropriate actions could be
determined. The cost effective criterion in the NCP has been used
in making the decision for the Mitchell Dump. EPA believes this is
a more appropriate criterion than merely using an average figure
regardless of the circumstances pertaining to the site.
4. One resident questioned who would pay for the cleanup.
EPA Response: The remedial action at the site, if done by the
government. would use 90% Superfund money and 10% State funds. The
O&M costs, in this case, would have to be borne by the State. The
other option that exists at any Superfund site is that PRPs with
liabilities associated with the site may agree to come forth and do
the cleanup. They may agree to come forth and pay in advance for
the cleanup, or they may decline, in which case the government would
pay and then seek to recover the costs in court after the cleanup.
Enforcement:
1. PRPs questioned why EPA had not pursued other users of the Mitchell
Dump.
EPA Response: The question relates to EPA enforcement actions
against PRPs parties at the Mitchell Dump. The purpose of this
responsivness summary is not to comment on EPA enforcement strategy,
but rather to respond to comments on the RI/FS and its
recommendations.
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Decision Process
1. During the public hearing, a reporter with the Annapolis Journal
asked who decides how to clean up the site - EPA? DEP? EPA and DEP
in conjunction?
EPA Response: Under the Superfund law, EPA must make the decision
in consultation with the State. The law, however, also states that
before EPA can spend that money for the remedial action, EPA must
have a contract with the State assuring that it will pay 10% of the
cost and will assure O&M of the site. In effect, that gives the
State a veto, since it could refuse to sign a contract for
cost-sharing.
D. REMAINING CONCERNS
Issues and concerns that EPA was unable to address during remedial
planning activities include the following:
o How much of the cleanup will be paid by PRPs? EPA
was unable to address this since negotiations are
still unresolved.
o Will the pumping/treating alternative be 100%
effective? EPA was unable to address this concern
because this information will not be available until
details of the remedial design are established. EPA
will release this information as soon as it is
available.
The Citizens for a Safe Environment specifically requested an opportunity to
review and comment on the draft remedial design study before it is approved by
EPA. In response, EPA will hold a 30-day comment period and public meeting
after the workplan for remedial design is complete to allow the public to
question EPA, DEP, and contractor staff.
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ATTACHMENT
COMMUNITY RELATIONS ACTIVITIES
AT MITCHELL DUMP
Community relations activities conducted at the Mitchell Dump to date
have included:
o DEP conducted community interviews with local officials and
interested residents (April 1983).
o DEP prepared community relations plan (May 1983).
o DEP issued a press release announcing finalization of
cooperative agreement (June 1983).
o EPA established an information repository at the Annapolis
Library (June 1983).
o EPA prepared and distributed fact sheet on health-effects of
site contaminants (July 1983).
o DEP and EPA jointly issued two press releases to announce
findings of RI (Summer and Fall, 1983).
o DEP frequently telephoned the Annapolis City Council, Mayor and
the press (ongoing throughout RI/FS).
o EPA released the FS for public review and comment (February
1985).
o EPA held a public meeting at Stephenson Hall in Annapolis to
describe the RI/FS reports and to respond to citizens'
questions. Approximately 60 people attended, including
citizens, elected officials, and technical and legal
representatives of the PRPs (March 17, 1985). A transcript of
this meeting is available at the Annapolis Public Library.
o EPA held a public hearing at Stephenson Hall in Annapolis to
record comments by the public, including potentially
responsible parties (March 24, 1985). A transcript of this
hearing is available at the Annapolis Public Library.
o EPA allowed two extensions to the public comment period. The
comment period lasted from February 27 to April 6, 1985.
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APPENDIX D
GLOSSARY
This glossary defines terms often used by the U.S. Environmental
Protection Agency (EPA) staff when describing activities under the
Comprehensive Environmental Response, Compensation, and Liability Act (CERC1A,
commonly called Superfund), as amended in 1986. The definitions apply
specifically to the Superfund program and may have other meanings when used in
different circumstances. Underlined words included in various definitions are
defined separately in the glossary.
Administrative Order on Consent (AOC): A legal agreement between EPA and
potentially responsible parties (PRPs) whereby PRPs agree to perform or pay
the cost of a site cleanup. The agreement describes actions to be taken at a
site and may be subject to a public comment period. Unlike a consent decree.
an administrative order on consent does not have to be approved by a judge.
Administrative Record: A file which is maintained and contains all
information used by the lead agency to make its decision on the selection of a
response action under CERCLA. This file is to be available for public review
and a copy is to be established at or near the site, usually at one of the
information repositories. Also, a duplicate file is held in a central
location, such as a Regional or State office.
Air Stripping: A treatment system that removes, or "strips," volatile
organic compounds from contaminated ground water or surface water by forcing
an airstream through the water and causing the compounds to evaporate.
Aquifer: An underground rock formation composed of materials such as
sand, soil, or gravel that can store and supply ground water to wells and
springs. Most aquifers used in the United States are within a thousand feet
of the earth's surface.
Carcinogen: A substance that causes cancer.
Carbon Adsorption: A treatment system where contaminants are removed
from ground water or surface water when the water is forced through tanks
containing activated carbon, a specially treated material that attracts the
contaminants.
Cleanup: Actions taken to deal with a release or threatened release of
hazardous substances that could affect public health and/or the environment.
The term "cleanup" is often used broadly to describe various response actions
or phases of remedial responses such as the remedial investigation/
feasibility study.
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Coment Period: A time period during which the public can review and
comment on various documents and EPA actions. For example, a comment period
is provided when EPA proposes to add sites to the National Priorities List.
Also, a minimum 3-week comment period is held to allow community members to
review and comment on a draft RI/FS and proposed plan.
Comunity Relations (CR): EPA's program to inform and involve the public
in the Superfund process and respond to community concerns.
Connunity Relations Plan (CRT): Formal Plan for EPA community relations
activities at a Superfund site.
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA): A federal law passed in 1980 and modified in 1986 by the Superfund
Amendments and Reauthorization Act. The Acts created a special tax that goes
into a Trust Fund, commonly known as Superfund. to investigate and clean up
abandoned or uncontrolled hazardous waste sites. Under the program, EPA can
either:
o Pay for site cleanup when parties responsible for the
contamination cannot be located or are unwilling or
unable to perform the work; or
o Take legal action to force parties responsible for
site contamination to clean up the site or pay back
the Federal government for the cost of the cleanup.
Consent Decree (CD): A legal document, approved and issued by a judge,
that formalizes an agreement reached between EPA and potentially responsible
parties (PRPs) where PRPs will perform all or part of a Superfund site
cleanup. The consent decree describes actions that PRPs are required to
perform and is subject to a public comment period.
Contract Lab Program: Laboratories under contract to EPA which analyze
soil, water, and waste samples taken from areas at or near Superfund sites.
Cost-Effective Alternative: The cleanup alternative selected for a site
on the National Priorities List based on technical feasibility, permanence,
reliability, and cost. The selected alternative does not require EPA to
choose the least expensive alternative. It requires that if there are several
cleanup alternatives available that deal effectively with the problems at a
site, EPA must choose the remedy on the basis of permanence, reliability, and
cost.
Cost Recovery: A legal process where potentially responsible parties can
be required to pay back the Federal government for money it spends on any
cleanup actions.
Emergency: Those releases or threats of releases requiring initiation of
on-site activity within hours of the lead agency's determination that a
removal action is appropriate.
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Enforcement: EPA's efforts, through legal action if necessary, to force
potentially responsible parties to perform or pay for a Superfund site
cleanup.
Engineering Evaluation/Cost Analysis (EE/CA): An analysis of removal
alternatives for a site, similar to a remedial program feasibility study. The
EE/CA must be made available for a 30 calendar day public comment period prior
to the signing off of the Action Memorandum.
Environmental Response Team (ERT): EPA hazardous waste experts who
provide 24-hour technical assistance to EPA Regional Offices and States during
all types of emergencies involving releases at hazardous waste sites and
spills of hazardous substances.
Explanation of Differences: After adoption of a final remedial action
plan, if any remedial action is taken, or any enforcement action under Section
106 is taken, or if any settlement or consent decree under Sections 106 or 122
is entered into, and if such action, settlement, or decree differs in any
significant respects from the final plan, the lead agency is required to
publish an explanation of the significant differences and the reasons the
changes were made. See Guidance on Preparing Superfund Decision Documents:
the Proposed Plan and Record of Decision for further information.
Feasibility Study (FS): See Remedial Investigation/Feasibility Study.
Ground Water: Water found beneath the earth's surface that fills pores
between materials such as sand, soil, or gravel. In aquifers. ground water
occurs in sufficient quantities that it can be used for drinking water,
irrigation and other purposes.
Hazard Ranking System (HRS): A scoring system used to evaluate potential
relative risks to public health and the environment from releases or
threatened releases of hazardous substances. EPA and States use the HRS to
calculate a site score, from 0 to 100, based on the actual or potential
release of hazardous substances from a site through air, surface water, or
ground water to affect people. This score is the primary factor used to
decide if a hazardous waste site should be placed on the National Priorities
List.
Hazardous Substance: Any material that poses a threat to public health
and/or the environment. Typical hazardous substances are materials that are
toxic, corrosive, ignitable, explosive, or chemically reactive.
Hydrology: The science dealing with the properties, movement, and
effects of water on the earth's surface, in the soil and rocks below, and in
the atmopshere.
Incineration: Burning of certain types of solid, liquid, or gaseous
materials under controlled conditions to destroy hazardous waste.
Information Repository: A file containing current information, technical
reports, and reference documents regarding a Superfund site. The information
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repository is usually located in a public building that is convenient for
local residents -- such as a public school, city hall, or library.
Leachate: A contaminated liquid resulting when water percolates, or
trickles, through waste materials and collects components of those wastes.
Leaching may occur at landfills and may result in hazardous substances
entering soil, surface water, or ground water.
Monitoring Wells: Special wells drilled at specific locations on or off
a hazardous waste site where ground water can be sampled at selected depths
and studied to determine such things as the direction in which ground water
flows and the types and amounts of contaminants present.
National Oil and Hazardous Substances Pollution Contingency Flan (NCP):
The Federal regulation that guides the Superfund program.
National Priorities List (NPL): EPA's list of the most serious
uncontrolled or abandoned hazardous waste sites identified for possible long-
term remedial response using money from the Trust Fund. The list is based
primarily on the score a site receives on the Hazard Ranking System (HRS).
EPA is required to update the NPL at least once a year.
National Response Center (NRG): The center operated by the U.S. Coast
Guard that receives and evaluates reports of oil and hazardous substance
releases into the environment and notifies the appropriate agency(ies). The
NRC can be contacted 24-hours a day, toll-free at (800) 424-8802.
National Response Team (NRT): Representatives of twelve Federal agencies
that coordinate Federal responses to nationally significant pollution
incidents and provide advice and technical assistance to the responding
agency(ies).
Non-Time-Critical Removals: Those releases or threats of releases not
requiring initiation of on-site activity within 6 months after the lead
agency's determination, based on the site evaluation, that a removal action is
appropriate.
On-Scene Coordinator: The Federal official who coordinates and directs
Superfund removal actions.
Operable Unit: An action taken as one part of an overall site cleanup.
For example, a carbon absorbtion system could be installed to halt rapidly
spreading ground-water contaminants while a more comprehensive and long-term
remedial investigation/feasibility study is underway. A number of operable
units can be used in the course of a site cleanup.
Operation and Maintenance (O&M): Activities conducted at a site after a
response action occurs, to ensure that the cleanup or containment system is
functioning properly.
Parts Per Billion (ppb)/Parts per Million (ppm): Units commonly used to
express low concentrations of contaminants. For example, 1 ounce of
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trichloroethylene (TCE) in 1 million ounces of water is 1 ppm; 1 ounce of TCE
in 1 billion ounces of water is 1 ppb. If one drop of TCE is mixed in a
competition-size swimming pool, the water will contain about 1 ppb of TCE.
Potentially Responsible Party (PRP): An individual(s) or company(ies)
(such as owners, operators, transporters, or generators) potentially
responsible for, or contributing to, the contamination problems at a Superfund
site. Whenever possible, EPA requires PRPs, through administrative and legal
actions, to clean up hazardous waste sites they have contaminated.
Preliminary Assessment: The process of collecting and reviewing
available information about a known or suspected hazardous waste site or
release. EPA or States use this information to determine if the site requires
further study. If further study is needed, a site inspection is undertaken.
Proposed Plan: A public participation requirement of SARA in which EPA
summarizes for the public the preferred cleanup strategy, the rationale for
the preference, reviews the alternatives presented in the detailed analysis of
the remedial investigation/feasibility study, and presents any waivers to
cleanup standards of §121(d)(4) which may be proposed. This may be prepared
either as a fact sheet or as a separate document. In either case, it must
actively solicit public review and comment on all alternatives under Agency
consideration.
Quality Assurance/Quality Control (QA/QC): A system of procedures,
checks, audits, and corrective actions used to ensure that field work and
laboratory analysis during the investigation and cleanup of Superfund sites
meet established standards.
Record of Communication: A register of all verbal communications between
EPA and citizens regarding site concerns.
Record of Decision (ROD): A public document that explains which cleanup
alternative(s) will be used at National Priorities List sites. The record of
decision is based on information and technical analysis generated during the
remedial investigation/feasibility study and consideration of public comments
and community concerns.
Regional Response Team (RRT): Representatives of Federal, State, and
local agencies who may assist in coordination of activities at the request of
the On-Scene Coordinator or Remedial Project Manager before and during
response actions.
Remedial Action (RA): The actual construction or implementation phase
that follows the remedial design of the selected cleanup alternative at a site
on the National Priorities List.
Remedial Design (RD): An engineering phase that follows the record of
decision when technical drawings and specifications are developed for the
subsequent remedial action at a site on the National Priorities List.
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Remedial Investigation/Feasibility Study: Investigative and analytical
studies usually performed at the same time in an interactive, iterative
process, and together referred to as the "RI/FS." They are intended to:
o Gather the data necessary to determine the type and
extent of contamination at a Superfund site;
o Establish criteria for cleaning up the site;
o Identify and screen cleanup alternatives for remedial
action: and
o Analyze in detail the technology and costs of the
alternatives.
Remedial Project Manager (RPM): The EPA or State official responsible
for overseeing remedial response activities.
Remedial Response: A long-term action that stops or substantially
reduces a release or threatened release of hazardous substances that is
serious, but does not pose an immediate threat to public health and/or the
environment.
Removal Action: An immediate action taken over the short-term to address
a release or threatened release of hazardous substances.
Resource Conservation and Recovery Act (RCRA): A Federal law that
established a regulatory system to track hazardous substances from the time of
generation to disposal. The law requires safe and secure procedures to be
used in treating, transporting, storing, and disposing of hazardous
substances. RCRA is designed to prevent new, uncontrolled hazardous waste
sites.
Response Action: A CERCLA-authorized action at a Superfund site
involving either a short-term removal action or a long-term remedial response
that may include, but is not limited to, the following activities:
o Removing hazardous materials from a site to an EPA-
approved, licensed hazardous waste facility for
treatment, containment, or destruction.
o Containing the waste safely on-site to eliminate
further problems.
o Destroying or treating the waste on-site using
incineration or other technologies.
o Identifying and removing the source of ground water
contamination and halting further movement of the
contaminants.
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Responsiveness Summary: A summary of oral and/or written public comments
received by EPA during a comment period on key EPA documents, and EPA's
responses to those comments. The responsiveness summary is a key part of the
ROD, highlighting community concerns for EPA decision-makers.
Site Inspection (SI): A technical phase that follows a preliminary
assessment designed to collect more extensive information on a hazardous waste
site. The information is used to score the site with the Hazard Ranking
System to determine whether response action is needed.
Superfund: The common name used for the Comprehensive Environmental
Response. Compensation, and Liability Act, also referred to as the Trust Fund.
Superfund Amendments and Reauthorization Act (SARA): Modifications to
CERCLA enacted on October 17, 1986.
Surface Water: Bodies of water that are above ground, such as rivers,
lakes, and streams.
Time Critical Removals: Including emergencies lasting longer than 30
calendar days, those releases requiring initiation of on-site activity within
6 months of the lead agency's determination, based on the site evaluation that
a removal action is appropriate.
Treatment, Storage, and Disposal Facility (TSD Facility): Any building,
structure, or installation where a hazardous substance has been treated,
stored, or disposed. TSD facilities are regulated by EPA and States under the
Resource Conservation and Recovery Act.
Trust Fund: A Fund set up under the Comprehensive Environmental
Response. Compensation, and Liability Act to help pay for cleanup of hazardous
waste sites and to take legal action to force those responsible for the sites
to clean them up.
Volatile Organic Compound: An organic (carbon-containing) compound that
evaporates (volatizes) readily at room temperature.
Water Purveyor: A public utility mutual water company, county water
district, or municipality that delivers drinking water to customers.
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SUPERFUND ACRONYMS
AOC
ARARs
ATSDR
CD
CERCLA
COE
CR
CRP
DOC
DOD
DOE
DOI
ERA
ERT
FEMA
FS
HHS
HRS
lAGs
NCP
NOAA
NPL
NRC
NRT
Administrative Order on Consent
Applicable or Relevant and Appropriate Requirements
Agency for Toxic Substances Disease Registry
Consent Decree
Comprehensive Environmental Response, Compensation, and
Liability Act of 1980
U.S. Army Corps of Engineers
Community Relations
Community Relations Plan
Department of Commerce
Department of Defense
Department of Energy
Department of Interior
Expedited Removal Actions
Environmental Response Team
Federal Emergency Management Agency
Feasibility Study
Department of Health and Human Services
Hazard Ranking System
Interagency Agreements
National Oil and Hazardous Substances Contingency Plan
National Oceanic and Atmospheric Administration
National Priorities List
National Response Center
National Response Team
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osc
O&M
ppm/ppb
PRP
PA
QA/QC
ROD
RRT
RA
RD
RI
RPM
RCRA
SI
SARA
SMOAs
TSD
USCG
VOC
On-Scene Coordinator
Operation and Maintenance
parts per million/parts per billion
Potentially Responsible Party
Preliminary Assessment
Quality Assurance/Quality Control
Record of Decision
Regional Response Team
Remedial Action
Remedial Design
Remedial Investigation
Remedial Project Manager
Resource Conservation and Recovery Act of 1976
Site Inspection
Superfund Amendments and Reauthorization Act of 1986
State Memorandum of Agreements
Treatment, Storage, and Disposal Facility
United States Coast Guard
Volatile Organic Compound
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APPENDIX E
REFERENCES
1. Administrative Procedure Act, 5 U.S.C. §553, 1986.
2. Clean Water Act of 1977, 33 U.S.C. §§1251-1376.
3. Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA), P.L. 96-510.
4. Interagency Agreement Between the U.S. Army Corps of Engineers and
the U.S. Environmental Protection Agency in executing P.L. 96-510, The
Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA), July 3, 1982.
5. Memorandum of Understanding Between the Agency for Toxic Substances and
Disease Registry and the United States Environmental Protection
Agency, May 28, 1985.
6. Memorandum of Understanding Between the Department of Defense and the
Environmental Protection Agency for the Implementation of P.L. 96-510,
The Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), August 12, 1983.
7. National Environmental Policy Act (NEPA), P.L. 91-190.
8. "National Oil and Hazardous Substances Pollution Contingency Plan,"
Federal Register 50(224):47933-47934, 47973, November 20, 1985.
9. "Notice of Intent to Delete Sites from the National Priorities List,"
Federal Register 50(251): 53448-53449, December 31, 1985.
10. "Preamble to the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP)," Federal Register 50 (29):5881, February 12,
1985.
11. Resource Conservation and Recovery Act of 1976 (RCRA), P.L. 94-580.
12. Superfund Amendments and Reauthorization Act of 1986 (SARA), P.L. 99-499.
13. "Superfund; CERCLA Arbitration Procedures," Federal Register 50(46):
9586-9593, March 8, 1985.
14. "Superfund; CERCLA Natural Resource Claims Procedures," Federal Register
50(46):9593-9608, March 8, 1985.
15. U.S. Environmental Protection Agency, "Applicability of Section
103(2)(c) of the National Environmental Policy Act of 1969 to Response
Actions Under Section 104 of the Comprehensive Environmental
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Response, Compensation, and Liability Act of 1980," Memorandum from
Robert M. Perry to Rita M. Lavelle, September 1, 1982.
16. U.S. Environmental Protection Agency, "CERCLA Compliance with Other
Environmental Statutes," Memorandum from Lee M. Thomas to the Regional
Administrators, August 30, 1985.
17. U.S. Environmental Protection Agency, "CERCLA Funding of State Oversight
of Potentially Responsible Parties (PRPs)," Memorandum from J. Winston
Porter to Regional Administrators, January 17, 1986.
18. U.S. Environmental Protection Agency, "Community Relations Activities at
Superfund Enforcement Sites," Memorandum from Gene A. Lucero, August
28, 1985.
19. U.S. Environmental Protection Agency, "Community Relations in
Superfund: A Handbook," Interim Version, September, 1983.
20. U.S. Environmental Protection Agency, "Community Relations Requirements
for Operable Units," Memorandum from William N. Hedeman, Jr., to the
Regional Air and Hazardous Materials Division Directors and Regional
Superfund Community Relations Coordinators.
21. U.S. Environmental Protection Agency, "Draft Addendum to January 17,
1986 Guidance, CERCLA Funding of State Oversight of Potentially
Responsible Parties (PRPs)," Memorandum from Jack Stanton to Superfund
Branch Chiefs and Regional Counsels, March 26, 1986.
22. U.S. Environmental Protection Agency, "Draft Guidance on Preparation of a
Superfund Memorandum of Agreement (SMOA)," Memorandum from Henry L.
Longest, II, and Gene Lucero to Regional Offices, date unknown.
23. U.S. Environmental Protection Agency, "Drafting Consent Decrees in
Hazardous Waste Imminent Hazard Cases," Memorandum from Courtney M.
Price and Jack W. McGraw to the Regional Administrators, May 1, 1985.
24. U.S. Environmental Protection Agency, "Funding of State Enforcement-
Related Activities," Memorandum from Gene A. Lucero to Hazardous Waste
Management Division Directors, January 23, 1985.
25. U.S. Environmental Protection Agency, "Guidance on Deletion of Sites
from the National Priorities List (NPL)," Hazardous Site Control
Division, August 12, 1986, draft.
26. U.S. Environmental Protection Agency, "Guidance on Feasibility Studies
under CERCLA," Office of Emergency and Remedial Response and Office of
Waste Programs Enforcement, April 1985.
27. U.S. Environmental Protection Agency, "How to Write A Public Notice: A
Collection of Examples" (written for the Office of Water Programs
Operations by Barry H. Jordan), December 1979.
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28. U.S. Environmental Protection Agency, "Interim Guidance on Compliance
with Applicable or Relevant and Appropriate Requirements," Office of
Solid Waste and Emergency Response, Memorandum from J. Winston Porter
to Regional Administrators, July 9, 1987.
29. U.S. Environmental Protection Agency, "Participation of Potentially
Responsible Parties in Development of Remedial Investigations and
Feasibility Studies Under CERCLA," Memorandum from Lee M. Thomas and
Courtney Price, March 20, 1984.
30. U.S. Environmental Protection Agency, "Policy on Floodplains and Wetland
Assessments for CERCLA Actions," Memorandum from William N. Hedeman,
Jr., to the Superfund Coordinators, Regions I-X, November 24, 1984.
31. U.S. Environmental Protection Agency, "Preparation of Decision Documents
for Approving Fund-Financed and Potentially Responsible Party Remedial
Actions under CERCLA," Memorandum from Jack W. McGraw to the Regional
Administrators, February 27, 1985.
32. U.S. Environmental Protection Agency, "Releasing Identities of
Potentially Responsible Parties in Response to FOIA Requests,"
Memorandum from Gene A. Lucero and Kirk F. Sniff to Hazardous Waste
Management Division Directors and Regional Counsels, January 26, 1984.
33. U.S. Environmental Protection Agency, "State Participation in the
Superfund Remedial Program," Office of Emergency and Remedial
Response, February 1984, revised.
34. U.S. Environmental Protection Agency, "Superfund Community Relations
Policy," Office of Emergency and Remedial Response, May 1983.
35. U.S. Environmental Protection Agency, "Superfund Innovative Technology
Evaluation (SITE) Operations Plan," Office of Solid Waste and
Emergency Response, July 1987.
36. U.S. Environmental Protection Agency, "Superfund Innovative Technology
Evaluation (SITE) Strategy and Program Plan," Office of Solid Waste
and Emergency Response, December 1986.
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APPENDIX F
KEY CONTACTS FOR THE
SUPERFUND COMMUNITY RELATIONS PROGRAM
Headquarters Superfund Community Relations Staff
Steven Smagin
Acting Chief, Remedial Planning and Response Branch
Office of Emergency and Remedial Response
EPA Headquarters (WH-548E)
401 M Street, S.W.
Washington, D.C. 20460
FTS 382-2470 or (202) 382-2470
Vanessa Musgrave
Superfund Community Relations Coordinator
Office of Emergency and Remedial Response
EPA Headquarters (WH-548E)
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2464 or (202) 382-2464
Melissa Friedland Shapiro
Superfund Community Relations Coordinator
Office of Emergency and Remedial Response
EPA Headquarters (WH-548E)
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2461 or (202) 382-2461
Julie Klaas
Communications Strategies
Office of Waste Programs Enforcement
EPA Headquarters (WH-527)
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2990 or (202) 382-2990
Daphne Gemmill, Program Manager
Technical Assistance Grant Program
Office of Emergency and Remedial Response
EPA Headquarters
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2460 or (202) 382-2460
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Regional Superfund Comunity Relations Coordinators
Region 1
Patty D'Andrea
Superfund Community Relations Coordinator
Office of Public Affairs
EPA - Region 1
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Region 2
Lillian Johnson
Superfund Community Relations Coordinator
Office of Public Affairs
EPA - Region 2
26 Federal Plaza
New York, New York 10278
FTS 8-264-4534 or (202) 264-4534
Region 3
Ann Cardinal
Superfund Community Relations Coordinator
Office of Public Affairs
EPA - Region 3
841 Chestnut Street
Philadelphia, Pennsylvania 19107
FTS 8-597-9905 or (215) 597-9905
Region 4
Walton Jones
Superfund Community Relations Coordinators
Office of Public Affairs
EPA - Region 4
345 Courtland Street, N.E.
Atlanta, Georgia 30365
FTS 8-257-3004 or (404) 881-3004
Region 5
John Perrecone
Superfund Community Relations Coordinator
Office of Public Affairs
EPA - Region 5
230 South'Dearborn
Chicago, Illinois 60604
FTS 8-886-6874 or (312) 886-6685
F-2
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Region 6
Betty Williamson
Superfund Community Relations Coordinator
Congressional and Intergovernmental Liaison
EPA - Region 6
1445 Ross Avenue
Dallas, Texas 75202-2733
FTS 8-255-6705 or (214) 655-6705
Region 7
Steve Wurtz
Superfund Community Relations Coordinator
Office of Public Affairs
EPA - Region 7
726 Minnesota Avenue
Kansas City, Kansas 66101
FTS 8-758-5894 or (816) 374-5894
Region 8
Marilyn Null
Superfund Community Relations Coordinators
Office of Public Affairs
EPA - Region 8
1 Denver Place
999 18th Street, Suite 1300
Denver, Colorado 80202
FTS 8-327-5927 or (303) 837-5927
Region 9
Pam Cooper
Superfund Community Relations Coordinator
Toxics and Waste Management Division
EPA - Region 9
215 Fremont Street
San Francisco, California 94105
FTS 8-454-8445 or (415) 974-8445
Region 10
Tim Brincefield
Superfund Community Relations Coordinator
Hazardous Waste Division
EPA - Region 10
1200 6th Avenue
Seattle, Washington 98101
FTS 8-399-0455 or (206) 442-2870
F-3
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ATSDR Senior Superfund Public Health Advisors
Assigned to EPA Regional Offices
Ms. Marilyn DiSirio
EPA Superfund Office
Region 1 - Room 1903
John F. Kennedy Building
Boston, Massachusetts 02203
FTS 565-3639 or (617) 565-3639
Mr. William Q. Nelson
Emergency and Remedial Response, Room 737
EPA Region 2
26 Federal Plaza
New York, New York 10007
FTS 264-8676 or (212) 264-8676
Mr. Charles J. Walters
EPA Superfund Office
Region 3
841 Chestnut Street
Philadelphia, Pennsylvania 19107
FTS 597-7291 or (215) 597-7291
Mr. Casimer V, Pietrosewicz
Air and Waste Management Division
EPA Region 4
345 Courtland Street, NE
Atlanta, Georgia 30365
FTS 257-3931 or (404) 881-3931/2
Ms. Louise A. Fabinski
Emergency and Remedial Branch (5 HR)
EPA Region 5
230 S. Dearborn
Chicago, Illinois 60604
FTS 886-0398 or (312) 886-3005
Mr. Carl R. Hickam
EPA Superfund Office
Region 6
1445 Ross Avenue
Dallas, Texas 75202-2733
FTS 255-6725 or (214) 655-6725
Mr. Edward J. Skowronski
Waste Management Branch
EPA Region 7
726 Minnesota Avenue
Kansas City, Kansas 66101
FTS 757-2856 or (913) 236-2856
F-4
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Mr. Michael A. McGeehin
Air and Waste Management Division
EPA Region 8
1860 Lincoln Street
Denver, Colorado 80295
FTS 564-1526 or (303) 293-1526
Mr. Donald D. Hawkins
Toxics and Waste Management Division
EPA Region 9
215 Freemont Street
San Francisco, California 94105
FTS 454-7742 or (415) 974-7742
Mr. Joel D. Mulder
Hazardous Waste
EPA Region 10 (M/S 525)
1200 6th Avenue
Seattle, Washington 98101
FTS 399-2711 or (206) 442-2711
F-5
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