oEPA
Unittd State*
Environmental Protection
Agency
Off ice of
Solid Waste and
Emergency Reaponae
DIRECTIVE NUMBER: 9230.0-3A
TITLE": Community Relations-1 rt:Sujjejr.fUnd:^A: Handbook
APPROVAL DATE: Transmitta^ memo, signed March 5,, 198
EFFECTIVE DATE: See below
ORIGINATING OFFICE: Superfund
D FINAL
D DRAFT
STATUS: This is a draft version. The final handbook
will-be completed in fall of 1985 and will supercede
both interim version (9230.0-3) and this draft (9230.0-3A)
'Jse 9230".0-3"r^Community ReTatiWs^ifrSirperfund: A
REFERENCE (other documents):
Handbook, Interim Versiori!1 until issuance of final this
fall.
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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vvEPA
United Stales Environmental Protection Agency
Washington. OC 20460
OSWER Directive initiation Request
Interim Directive Number
9230.0-3A
Originator Information
ame of Contact Person
Anne Fenn
Mail Code
WH-548A
Telephone Number
382-2464
ead Office
53 OERR
CD OSW
D OUST
D OWP6
O AA-OSWER
Signature of Off/e Director Hglfory/IyDngest
^JOu>y
roved for Review
5St )l
Jx.
itle f\
Community Relations in Superfund:' A Handbook
Summary of Directive
The Handbook was first printed in September 1983 as an interim
version. The Superfund Community Relations office is now in the
process of revising and finalizing this Handbook. A draft^ version'
will be distributed for internal Agency review this Winter and
the public for-comment th-tsSprlng- and Summer. -TTiflrixf inal Handbook
will be completed in the fall of 1986^^1^ u/zZ/cfco 6m.
&4 Uwi£
Type of Directive (Manual, Policy Directive. Announcement, etc.)
Manual
Status
O Draft
D Final
D New
UU Revision
Does this Directive Supersede Previous Oirective(s)? Mft Yes VI No Does It Supplement Previous Directive^)?( J Yes
Jrj^ __ *^J _
if "Yes" to Either Question. What Directive (number, title) Community Relations in Superfund: A Handbook -
Interim Version September 1983 (HW-6) tftW>D~3 " M/ZU* MvrfL>£ Hfryifrp&fe'U)
N
Review Plan
O AA-OSWER
Q OERR
D OSW
D OUST
ED OWPE
UU Regions
LU OECM
H OGC
D OPPE
D
Other (Specify)
This Request Meets OSWER Directives System Format
Signature of Lead Office Directives Officer
Signature of OSwER Directives Qf/'cer
Ou'>^
/
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
-'" WASHINGTON. D.C. 20460
Region 111 Library
Emrfronmental Protection Agency
U*O C Mfe
rtn w BQD
OFFICE OF
SOLID WASTE ANO EMERGENCY RESPONSE
OSWER Directive Number
9230.0-3A
MEMORANDUM
SUBJECT: Revised Superfund Community ReJat^Jbns Handbook
FROM: Henry Longest II, Director
Office of Emergency and
TO: Addressees
Attached is a draft of the revised version of "Community
Relations in Superfund: A Handbook." This draft Handbook is
being circulated for internal Agency review. The Handbook, first
issued in 1983* has now been thoroughly revised to reflect the >
additional experience we have gained in-conducting community
relatlo.n_3_a.t=jSuperfund sites...throughout the nation. The revised
Handbook places an increased emphasis on two-way communications
in community relations activities. In particular, it stresses
the need to identify early in the Superfund process how communities
would like to be Involved in site activities.
Based on our experiences during the last three years, this
draft Handbook Introduces new requirements and concepts in the
program. I would like to bring your attention to the following:
0 Information Repository Requirement; The draft Handbook
establishes as a program requirement the creation of at
least one Information repository at each NPL site where
remedial response actions are to commence and at sites
where a removal action Is expected to extend beyond 45
days. (These are the same sites for which a community
relations plan must be prepared.) For remedial sites,
the information repository must include the community
relations plan, the RI/FS workplan, the remedial investi-
gation report, the feasibility study, the responsiveness
summary, the signed record of decision (ROD), and the
remedial design. For removals lasting longer than
forty-five days, the information repository must include
the community relations plan.
0 New Community Relations Plan Format; The draft Handbook
recommends a new format for the Superfund community
relations plan. This'format emphasizes the description
and analysis of the community, rather than the technical
history of the site. In addition, the plan would include
site-specific objectives for community relations, rather
than repeating the overall goals of the community relations
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OSWER Directive Number -2-
9230.0-3A "'".
0 New Community Relations Techniques; The section which
provides Information on techniques has been considerably
expanded to Include several Innovative and successful
techniques for actively seeking community Involvement at
Superfund sites. Many of these techniques have been used
by Regional and State offices. Examples of these new
techniques Include the use of on-slte Information offices,
observation decks from which interested community members
can view site activities, and a Superfund briefing book
for the press. The applicability of potential techniques,
both established and new, has also been broadened to
include all phases of a Superfund response from
preliminary assessment through remedial action and operation
and maintenance.
Because the Superfund Community Relations Program is growing
and changing to reflect our increasing experience and community
needs, 'it Is inevitable that some of the discussion in this
Handbook cannot be considered as final. Pour sections of this
Handbook should be read with the awareness that changes or
additional guidance will be forthcoming and will be Incorporated'
into the final version:
(1) Reponslveness Summaries; An EPA Headquarters and
Regional work group recently met to discuss the purpose,
format, and timing of responsiveness summaries and how
they relate to other program documents, In particular,
the ROD/EDO and the enforcement "administrative record".
The guidance on responsiveness summaries In this draft
Handbook reflects the discussions of this work group,
although additional clarification on responsiveness
summaries will be Issued shortly from EPA Headquarters.
(2) Community Relations during Enforcement Actions; The
guidance in this Handbook relating to enforcement actions
(Chapter 6) should be supplemented by the Office of
Waste Program Enforcement (OWPE) clarification memo,
August 28, 1985, "Community Relations during Enforcement
Actions." In addition, OWPE Is developing policy to
guide enforcement actions in which a third-party (e.g.,
Clean Sites, Inc.) is facilitating a response. This
guidance will discuss community relations during such
third-party participation.
(3) Dispute Resolution as a Community Relations Technique;
A section has been reserved in this Handbook for the
discussion of dispute resolution as a technique for
addressing conflicts at controversial Superfund sites.
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OSWER Directive Number -3-
9230.0-3A .,...
A pilot program is currently being conducted by EPA
Headquarters to evaluate the effectiveness of this
technique at selected Superfund sites across the
country. The Handbook will be modified to reflect this
evaluation, once the pilot project is completed in the
Spring of 1986.
(4) Superfund Innovative Technology Evaluation Project
'(SITE) - Community relations plan guidance for sites
where innovative technology will be demonstrated is
currently under development.
As part of the revision process, this .draft Handbook will be
changed and improved by your review. We would like to have your
comments and suggestions on this draft, and encourage you to
submit a marked-up copy as soon as possible. Your comments
should be submitted by April 11, 1986, to Daphne Gemraill, Program
Manager, Superfund Community Relations Program (WH-548A), U.S.
Environmental Protection Agency, 401 M Street, S.W., Washington,
D.C. 20460.
/
After the Handbook is revised based on your comments, it
will be widely distributed to other government agencies, public
interest, labor, and industry groups for review. We also are
contemplating a series of Regional workshops to solicit public
comment during the spring and summer. The Handbook should be in
final by Pall 1986. We look forward to your contributions.
Attachment
ADDRESSEES;
Director, Office of Emergency & Remedial Response, Region II
Director, Hazardous Waste Management Division, Region III
Director, Air & Waste Management Division, Regions IV, VI, VII 4 VIII
Director, Waste Management Division, Regions I & V
Director, Toxics and Waste Management Division, Region IX
Director, Air & Waste Division, Region X
Superfund Community Relations Coordinators, Regions I-X
cc: (See Attached List)
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cc: Headquarters
Walter Kovallck
Christina Griffin
Timothy Fields
Russel Wyer
Stephen Llngle
James Lounsbury
James Makrls
Donald White
Thomas Scheckells
Sara Morekas
Paul Nadeau
Bob Burke
Mat White
John Cross
Pam Oarrow
Susan Bullard
Jerry Schwartz
Karen Clark
Daniel Berry
Andrew Caraker
Vanessa Musgrave
Kate Connors
Joan Warren
Region
Brooke Cook
Jim Marshall
Nancy Sinclair
Ray Germann
Janet Luffy
Michael Henderson
Prank Reed
Judy Beck
Margaret McCue
Art Gaslor
Jon Grand
Mava Elliot
Ellen Greeney
Rowena Michaels
Jane Russo
Doris Sanders
Patricia Post
Tim Vendllnskl
Sandra Carroll
Rob Stern
Sara Zlegler
Deanna Welman
Bob Jacobson
Phil Charles
Rosemary Henderson
Julie Winters
John Anderson
Tim Vendllnskl
Kate Connolly
Patty D1Andrea
Nancy Alvarado
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WMilngton DC 20460
M»^ B^«is^M4^sA Om
^i nwnvDiBV nv
Hw-a
Solid Waits and Emergency Response
Community Relations
in Superfund:
A Handbook
Interim Version
September 1983
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COMMUNITY RELATIONS IN SUPERFUND
A HANDBOOK
United States Environmental Protection Agency
Office of Emergency and Remedial Response
September 1983 Interim Version
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NOTE
This handbook was prepared by ICF Incorporated for the Office of Emergency
and Remedial Response, U.S. Environmental Protection Agency (EPA), under EPA
contract 68-02-3669. It was revised and approved through the EPA Peer and
Administrative Review Control System. Peer reviewers .were "Anthony Diecidue,
L. Michael Flaherty, Inez Artico, Marcia Carlson, and Richard Hoffman.
This handbook serves as program guidance for conducting community
relations activities in the Superfund program. It incorporates EPA policy on
community relations that is not expected to change, although details of the
handbook may be modified in the future to reflect experience with a developing
program. Questions and comments concerning this handbook should be addressed
to Daphne Gemmill, U.S. Environmental Protection Agency, 401 M Street, S.W.,
Office of Emergency, and Remedial Response (WH-548D), Washington, B.C. 20460.
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TABLE OF CONTENTS
PAGE
INTRODUCTION
CHAPTER 1 An Effective Community Relations Program.
1-1
CHAPTER 2 Community Relations During Immediate and
Planned Removals.
2-1
CHAPTER 3 Community Relations During Remedial Response 3-1
CHAPTER 4 Examples of Community Relations Techniques 4-1
CHAPTER 5 Administering a Community Relations Program 5-1
CHAPTER 6 Community Relations and Enforcement Actions
(reserved)
6-1
APPENDIX A Examples of Community Relations Plans A-1
APPENDIX B Community Relations Guidance for Evaluating Citizen
Concerns at Superfund Sites B-1
APPENDIX C Quarterly Report Format C-1
APPENDIX D Community Relations Program Staff. D-1
APPENDIX E Problem Situations.. (reserved) E-1
APPENDIX F Glossary of Terms and Acronyms F-1
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INTRODUCTION
The Superfund* community relations program encourages two-way
communication between communities affected by releases of hazardous substances
and agencies responsible for cleanup actions. The program attempts to provide
communities with accurate information about problems posed by releases of
hazardous substances; at the same time, it gives, local officials and citizens
the opportunity to comment on and provide input to technical solutions to site
problems. An effective community relations program must be an integral part
of every Superfund action.
Hazardous waste sites and other releases of hazardous substances have the
potential to create strong public concern about government action. The health
and environmental problems stemming from releases of hazardous substances are
inherently sensitive.
A community relations program can enable government staff to take
community concerns into account in planning a response and the result can be a
better response action. At the same time, it can ensure that citizens have
accurate information about the response. It is consequently an essential
component of a successful Superfund response action. '
This handbook offers specific guidance for EPA and state~₯ta~Ff on how-to
design and implement an effective community relations program. The handbook
presents guidelines for developing community relations programs for removal
actions (Chapter 2) and remedial actions (Chapter 3). Chapter 4 discusses the
advantages and disadvantages of various activities that may be included in a
community relations program. The handbook explains the administrative
requirements for the. program (Chapter 5). Chapter 6, which provides guidance
on managing community relations activities during enforcement actions, will be
added to the handbook at a later date. Appendix A discusses how to draft
community relations plans and presents examples of community relations plans
for removal and remedial actions. Appendix B provides guidance on how to
conduct on-site discussions with local officials and citizens and on how to
assess community concerns on the basis of these discussions. A community
relations program quarterly report format is contained in Appendix C.
Appendix D lists the EPA Headquarters and Regional Office staffs responsible
for community relations program management and implementation. At a later
"Superfund is the $1.6 billion fund created by the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) for
responding to releases or threats .of releases of hazardous substances. This
handbook also uses the term "Superfund" to describe the response program
established by the Environmental Protection Agency under CERCLA's authority.
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CHAPTER 1
AN EFFECTIVE COMMUNITY RELATIONS PROGRAM
This chapter describes the background and objectives of the Superfund
community relations program. First, it defines the program and describes how
EPA derived the guidelines" presented in this handbook. It then explains how
the program can enhance the ability of EPA and the states to implement
cost-effective removal and remedial actions.
A. PROGRAM DEFINITION
The Superfund community relations program is a site-specific information
and communications program that must be an integral part of every Superfund-
financed remedial or removal action. , When EPA (or a state under a cooperative
agreement with EPA) decides to fund a Superfund response action lasting longer
than a few days, it must develop a community relations plan (CRP) that details:
How citizen concern will be identified and assessed
at the site;
r
How accurate information on problems associated- with
the release of hazardous-subs-tanecs wi-1-1be _
distributed and explained to the community;
How 'citizens will have an opportunity to comment on
and provide input to ongoing and proposed site work;
and
How the technical alternatives and the proposed
technical solution will be explained to the community.
Specific activities listed in the CRP for soliciting citizen input and
distributing information vary from site to site, depending upon the level of
citizen concern and the nature of the site's technical problems. The
responsible agency (either EPA or the state) implements the plan, in close
coordination with other interested agencies.
All site-specific activities that encourage communication between
communities affected by releases of hazardous substances and agencies
responsible for cleanup together constitute EPA's- Superfund community
relations program. The program's evolution and objectives are described below.
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"i-3
for responding to releases or threatened releases of hazardous substances,
pollutants, or contaminants from vessels or facilities. Although the $1.6
billion response fund (Superfund) created by CERCLA seems large, the cost of
responding to releases is also large and there are many problems in need of
attention. Thus, for remedial actions, the National Contingency Plan requires
the lead agency for any site action to choose the most cost-effective remedial
alternative to address the site's problems. It may be necessary, therefore,
to explain to a community that a balance must be struck between the need to
protect public health, welfare, and the environment at any one site, and the
need to conserve the Fund for responding to problems at other sites.
A successful community relations program is a preventive effort. EPA has
found that a measure of prevention is critical to implementing a cleanup of a
hazardous substance release. Every site action has the potential to become
difficult to manage if communication is poor between EPA or the state
government, local governments, interest groups, and citizens. People who are
worried about releases of hazardous substances and believe that the government
has not considered their concerns may press for additional -- and more costly
-- relief. Regardless of the technical adequacy of a proposed response, it
may prove unacceptable to the local public. The best way to lessen the
chance that citizens might reject a cost-effective solution is to identify
citizen concerns, take these concerns into consideration when fashioning a
solution, and explain the rationale behind the course of action chosen.
The community relations guidelines outlined in this handbook should
enhance EPA's and states' abilities to implement cost-effective removal and
remedial actions in communities across the nation. A community relations
program can ensure that the concerns and questions of citizens are not
neglected, but are incorporated into the decisionmaking process. It can
lessen the chances for the spread of rumors or misconceptions about the nature
of the threat at the site.
The objectives of the Superfund community relations program, consequently,
are as follows:
Gather information about the community in which a site is
located. A community relations program provides a vehicle for
exchanges between EPA, the state, the public, and local"
government. It enables EPA and state staff to identify citizen
leaders, public concerns, and a site's social and political
history. Sometimes it can also yield technical data useful in
planning a solution to the site's problems -- or information
useful in an enforcement case against a responsible party.
Inform the public of planned or ongoing actions. The program
should inform the public of the nature of the environmental
problem, the remedies under consideration, and the progress
already made.
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CHAPTER 2
COMMUNITY RELATIONS DURING IMMEDIATE AND PLANNED REMOVALS
This chapter provides a brief guide to the kinds of community relations
activities that can be undertaken during immediate and planned removals.
Whether the technical problems encountered during a removal action are simple
or complex, the social, political, economic, and psychological effects of the
action on the community can be dramatic. Citizens will want information about
the effects of exposure to hazardous substances upon their health and
environment. In addition, citizens must be given the opportunity to express
opinions and concerns about a removal action in their community. Finally,
citizens should be informed about the restrictions CERCLA and the National
Contingency Plan place on removal actions.
The purposes of the communications techniques discussed in this chapter
are to: (1) help EPA identify and assess citizens' perceptions of the health .
and environmental threat; (2) give citizens an opportunity to comment on and
provide input to the selection of a response action, when feasible; and (3)
help community relations staff choose effective methods for distributing and
explaining information on removal actions. Readers should consult Chapter ^
for detailed explanations of the techniques suggested in this chapter.
Chapter 5 describes community reiaTTiohs"planning requirements for removal
actions, and Appendix A provides formats for planning documents.
A. IMMEDIATE REMOVAL ACTIONS
1. Need for Communication
EPA may decide to undertake an immediate removal action in those
situations where immediate action will prevent or mitigate immediate and
significant risk of harm to human life or health, or to the environment. (See
Section 300.65 of the National Contingency Plan for a definition of immediate
removal actions.) The On-Scene Coordinator's (OSC's) principal responsibility
in an immediate removal is to protect public health and property until the
emergency is abated. During such an incident, the primary community relations
activity is to inform the community about response actions and their effects
on the community.
The specific types of community relations activities during immediate
removals are likely to include responding to inquiries from the media,
providing local officials with the knowledge necessary to handle the questions
of their constituents, and giving information directly to concerned citizens.
By channeling community inquiries to the appropriate agency or official, the
community relations program can ensure that the community receives the vital
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2-3
3. Suggested Community Relations Activities
Community relations programs for immediate removals should take into
consideration that the immediate removal may be only the beginning of a
lengthy presence in the community. It is possible that a planned removal or
remedial action will follow at a site. Thus, the OSC's actions during an
immediate removal may have long-term consequences for EPA or state
effectiveness during future operations at the site.
To ensure that the'community is given accurate information in a timely and
efficient way during an immediate removal, OSCs and Regional OPA staff should
work with other Superfund program and state staff to:
Designate a single contact to handle all public
inquiries.
Provide sufficient telephone lines and staff to
support the designated public contact and publicize
the phone number in the local media.
Contact immediately local officials, the Governor's
Off-ice, and interested Congressional officials;
provide these officials with information about the ,
release and the immediate removal action.
If sufficient interest exists, hold a news
conference or briefing to explain problems caused by
the release and the plans for the immediate removal
action. Also, establish a repository for site
information at a local library, health office, or
community center with approved technical reports,
official phone numbers, and the immediate removal CRP.
If sufficient time exists, periodically hold small
meetings with local officials and groups of interested
citizens as early in the response action as possible.
There will be times when an immediate removal is taken at a site that -has
long been a recognized problem and that is familiar to community relations
staff. For example, an immediate removal can be preceded by an assessment
period, or it can be taken midway through a remedial action. In such cases,
some of the preparatory work for a community relations program may already
have been accomplished. Local officials and citizens will be aware of the
need for action and may have a good idea of what to expect when work begins at
the site. Similarly, community relations staff may be well acquainted with
the special concerns of.people living near the site. In these cases, the
community relations program can concentrate on public consultations and
briefings and news conference updates..
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2-5
the purpose of the action is to provide a permanent remedy to the problem, one
that will involve the removal of all hazardous substances from the site. If
they are allowed to generate such expectations, they will be frustrated if the
planned removal is only a provisional response. At an early stage, therefore,
it is critical to prevent the development of unrealistic expectations. Early
on-site discussions can be a-key factor in developing accurate expectations.
2. Assess the nature of citizen concern.
After completing the on-site discussions, community relations staff must
assess the nature and level of citizen concern at the site. Such an
assessment allows staff to match communications activities both to the
technical schedule of the response action and to citizens' information needs
and concerns. One method of assessing citizen concern is detailed in Chapter
4 and explained further in Appendix B.
3. Describe citizen concerns, community relations activities, timing,
and resource needs in a CRP.
In addition to a thorough assessment of citizen concerns, the CRP must
include: a description of specific objectives for the program; a list of all
communications activities planned for the site; a detailed workplan and
budget; a staffing plan; a schedule of activities; a list of interested '
citizens; and a list of technical and community relations staff responsible
for the site.
Chapter 4 describes a number of communications techniques that can be used
in a community relations program at a planned removal or remedial action
site. Given the limited nature of a planned removal, however, many of these
techniques may not be needed or appropriate. Community relations staff should
use discretion in determining which activities would be effective at a
particular site. In general, the following activities are suggested for a
planned removal:
Briefings for local officials and the media.
Briefings on the planned removal action are essential
at an early point in the'action. They are useful for
providing information about any health or
environmental problems posed by the site and for
informing the public about the proposed response
action.
Public meetings and workshops. In general,
meetings-and workshops should be small and informal.
They should be held as early in the response action as
possible, and should be used both to identify citizen
concerns and to solicit citizen comments on the
response action. Investigations of community
involvement at sites in every EPA Region suggest that
small meetings and workshops are very effective for
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^V~V^^r7?^ ;.. TV;'^y^"^
~~~"^7" ~-~
5. Prepare a responsiveness summary.
When the planned removal is concluded, a final report or "responsiveness
summary" must be prepared and should be submitted to the Office of Policy and
Program Management in the Office of Emergency and Remedial Response, EPA
Headquarters. This in-house report must describe the community relations
activities conducted and the major issues that arose at the site. In
addition, it must evaluate the effectiveness of the community relations
program at the site. The purpose of the report is to document EPA and state
actions, to assist in community relations planning in the event that long term
remedial response occurs at the site, and to help plan for subsequent
community relations programs at other sites. The summary may be used to help
document for the public record how EPA responded to key community concerns and
issues.
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CHAPTER 3
COMMUNITY RELATIONS DURING REMEDIAL RESPONSE
This chapter provides guidelines for conducting community relations
activities during remedial actions. Remedial actions are those responses to
releases on the National Priorities List that require longer term and possibly
more expensive efforts to prevent or mitigate the migration of releases of
hazardous substances. (See the definition of remedial response in Section
300.68 in the National Contingency Plan.) A community relations program is a
key part of EPA and state activities during a remedial action. As pointed
out in Chapter 1 of this handbook, without a program of ongoing communication
between the community affected by the release of hazardous substances and the
agency responsible for cleanup, EPA and the state cannot provide accurate,
understandable information to the community about site problems and cannot
incorporate community concerns into decisions about response actions.
When the federal government has lead responsibility for a remedial action,
the U.S. Army Corps of Engineers will usually be responsible for management of
remedial construction. Community relations, however, will continue to be the
responsibility of EPA during all stages of the response; the state may play a
supporting role. When the state has the lead responsibility for the.^remedial
action, EPA staff will review state programs and may participate in- community
relations activities, as specified in the cooperative agreement.' Therefore,
community relations during a remedial response may involve the efforts of
three or more agencies: EPA or state staff will manage the program, and in
certain cases, the Corps of Engineers will provide technical assistance. In
addition, other federal or state agencies may be responsible for certain
aspects of a response, with corresponding responsibilities for community
relations. The Federal Emergency Management Agency, for example, manages
Superfund-financed relocations of residents and businesses, when necessary.
The blueprint for community relations programs at remedial action sites
is the community relations plan (CRP). This chapter discusses communications
activities that could be incorporated into a CRP for a remedial action.*
These activities or techniques, suggested here as general guidelines,
correspond to each of the technical stages of a remedial response. In
practice, however, a remedial action may not be as neatly structured as this
'''Staff responsible for community relations .planning should also consult
Chapter 5 and Appendix A for a detailed summary of remedial action planning
requirements.
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.."._; ~_'_i"i. . ^._
3-3
of future events. Staff should emphasize the tentative nature of any plans
and should stress that the inspection should not be viewed as evidence of a
serious contamination problem. Community relations staff should inform the
community through a brief fact sheet that the site inspection is limited in
scope, and is intended primarily to gather any data needed for ranking on the
National Priorities List.
3. Priority Listing and First Notification of
Proposed Course of Action
Community relations efforts become critical once EPA has. set
priorities and evaluated a site for remedial action. At this.point, EPA or
state staff must conduct on-site discussions with local officials and
citizens, evaluate the nature and level of citizen concern, and determine how
the remedial investigation and feasibility study may affect citizen
concerns. The on-site discussions and the assessment of citizen concern will
become the foundation of the CRP for the site. These activities are described
below.
3.1 On-Site Community Discussions
Site problems go beyond the physically measurable, technical problems
of hazardous waste releases. The community setting of the hazardous substance
.problem must also be understood before investigating the problem and proposing
a technical solution. Community relations staff should, therefore^ conduct" a
series of short on-site discussions with the*state and local officials
involved with the site, citizen leaders representing interest groups, business
leaders, environmentalists, members of other community groups such as the
League of Women Voters, and any other interested citizens. The information
gleaned from these discussions may enhance the technical understanding of the
site if local officials and residents know of past dumping practices. In
addition,-these discussions can provide valuable information about local
attitudes toward the site and past government actions. Thus, these
discussions provide an opportunity for public input to the planning process.
They also enable community relations staff to identify the best means to
provide information to the community during the response action.
3.2' Assessment of Citizen Concern
On the basis of these community discussions, community relations
staff should assess the nature and level of citizen concern about the site.
(See Chapter 4, Assessment of Citizen Concern: A Procedure and Appendix B.)
An evaluation of the following factors can help staff determine how the level
of citizen concern at a site compares to concern at other sites, and whether
concern is likely to increase or decrease over the course of the action:
Whether families in a community believe their
children's health may be affected by the release;
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3-5
The analyses of how the level of technical complexity and the proposed timing
of response actions affect the selection of communications activities for the
site should also be described briefly in the CRP.
3.4 Preparation of the CRP
Having completed the on-site discussions and the assessments of citizen
concern and technical complexity, the community relations staff must then
prepare a draft CRP. The draft CRP must be submitted with the draft Action
Memorandum for federal-lead sites or with the draft cooperative agreement for
state-lead sites. It must include:
A description of the site's background and the
background and history of community involvement at the
site;
Community relations objectives for the site during
the remedial investigation and feasibility study;
Any immediate community relations activities
recommended prior to approval of the complete CRP;
A list of affected and- interested groups and individ- '
uals, their affiliations, addresses, and telephone
numbers;
A schedule for completing the CRP; and
The date the draft CRP was prepared.
The draft CRP will form the basis of the complete CRP which must be
submitted: (1) for federal-lead sites, within four weeks of the submission of
the draft Action Memorandum or prior to the initiation of the remedial
investigation, whichever comes first;-or (2) for state-lead sites, with the
final cooperative agreement package. The complete CRP must include:
The information presented in the draft CRP, updated
if necessary;
A specification that the pub-lie will be given a
minimum three week comment period to review the
feasibility study prior to the selection of the
recommended alternative and an explanation of how this
comment period will be structured;'1'
'At the time the CRP is drafted, staff may know that an initial remedial
measure (IRM) will be needed at the site. Where an IRM will be needed, the
CRP must address how the community will receive prior notification of any
action. In addition, the CRP must state that citizens will have an
opportunity to comment on any recommended complex IRM at the conclusion of a
limited feasibility study, and must explain how a minimum two week comment
period w^ll be implemented. See Section 5 of this chapter for further detail.
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1 . ..._._ .. _._._ - . .. . ..;._
3-7
tools is to designate a Superfund community relations coordinator for the site
to channel both citizen and intergovernmental contact. Diplomatic skills on
the part of the coordinator are very important; being a good engineer or
program manager alone is not enough for this sensitive position. The
coordinator must be available to hold meetings and be interviewed after office
hours, when residents may likely be available. It is not necessary that the
community relations coordinator be present at the site everyday; however, the
coordinator's schedule should be well-publicized.
Useful forms of citizen-agency interaction during the remedial
investigation stage that should be specified in the CRP include:
Informal meetings for distributing significant test
results or other information about the response action;
. Meetings with individual citizens or groups of
citizens affected by any results of health studies;
Briefings of local officials and state and federal
legislators;
Public consultations and workshops, where community
relations staff meet with small groups of citizens to
keep abreast of community concerns _and pass on
information;
Progress reports, fact sheets and news conferences;
A repository for site information at the local
library, health office, or community center that
contains approved technical documents, official phone '
numbers, and the CRP;
Site visits.
The use of an information repository is encouraged and should be established
as soon as the state contract or cooperative agreement is signed.
It is possible that local citizens will not want to become involved in and
extensively informed about the problem of hazardous substances at this stage
Alternatively, some citizen groups will make early and possibly large demands
for resources on any agency that indicates an interest in helping the
community. The coordinator should frequently assess the changing information
needs of the community, and if necessary, modify the CRP to reflect these
changing needs.
5. Feasibility Study: Development and
Selection of Alternatives
A major community relations effort must accompany the development of
cleanup alternatives during the feasibility study and the selection of the
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3-9
the availability of the feasibility study and request written comments on the
remedial alternatives. During the comment period, the coordinator should
review with the community the advantages and disadvantages of the alternatives
under consideration.' Notice should be given of where written comments should
be sent and the deadline for submission. The CRP must detail how the public
will be provided opportunity to comment.
The comment period policy for initial remedial measures (IRMs), or those
actions that can be taken quickly to limit exposure or threat of exposure to a
significant health or environmental hazard during remedial planning, is
similar: EPA must provide the affected community with information about the
action and must elicit community views and concerns. When the needed action
consists of simple IRMs,* no comment period is required but EPA must provide
advance notification of the action to the community. Community relations
staff should identify the most effective way(s) to inform the community of the
action and to respond to citizen concerns. News conferences or news releases,
combined with door-to-door contacts, phone conversations, or small group
meetings, could be effective ways for providing information and for
identifying community iss-ues.
When a complex IRM is recommended following an expedited remedial
investigation and feasibility study, the community relations staff must not
only notify the community of the recommended action, but must also provide a
minimum two week comment period. This comment period may be lengthened if
the community requests an extension as long as the extension does not
exacerbate threats to public health, welfare, or the environment at the site.
During this comment period, community relations and technical response staff
should hold small group meetings or workshops, provide fact sheets, or engage
in other activities that explain the conclusions of the limited feasibility
study to the community.
The alternative remedies for nonexpedited or expedited feasibility studies
may be presented and reviewed at a public meeting or a formal hearing where
public comment is invited. As noted above, large public meetings or formal
hearings are not necessarily encouraged; small informal meetings and the
other communications techniques listed above are encouraged instead because
they are more effective in most situations. If community relations staff
determine that a public meeting or hearing is necessary at this stage
-Simple IRMs include: staging/overpacking drums; runon/runoff controls;
site security measures; dike/berm stabilization; fences; temporary covers;
drum/tank sealing; and temporary relocation.
"'''Complex IRMs include: measures such as off-site transport or disposal
of drums/tanks; off-site transport or disposal of lagoon liquids; sludges and
highly contaminated soils; leachate treatment; and temporary water supplies.
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3-11
Public service announcements on radio or TV;
News releases;
Fact sheets and progress reports; and
A continuation of the local information repository.
The purpose of these activities is to expla.in to local officials and
citizens the activities that will take place during engineering design, and
once design is completed, .to explain in understandable terms the design
conclusions and construction proposal.
7. Construction
During site construction, the community relations coordinator should
continue to inform area residents and businesses of the progress of
construction, any health hazards that may be caused by construction, suitable
hazard precautions, economic effects, new findings, and the reasons for any
delays in the cleanup. To ensure that the local public is adequately
informed, the community relations coordinator must provide site information to
local officials and citizen leaders on a frequent basis. Appropriate
techniques at this stage continue as before: '
^ News releases"," fact sheets, and progress, reports ; -
. ' Briefings for officials;
Public consultations and small informal meetings;
Site tours; and
A continuation of the local information repository.
Community relations staff must also make sure local residents understand
that cleanup of the site may not resolve all problems. Meetings with small
groups of citizens and officials to explain the likely results of the remedial
action may again be the most effective communications' technique during this
stage of the response action.
8. Post Cleanup Documentation
Upon completion of the cleanup, the EPA staff must evaluate EPA's and
the state s interaction with the local government, interest groups, and
citizens. This includes the preparation of a responsiveness summary that
should be submitted within one month of the completion of the response action
to EPA Headquarters. A responsiveness summary may help prevent problems at
other sites; it will also suggest ways to continue public awareness at the
completed site.
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3-13
EXHIBIT 3-1
REMEDIAL RESPONSE AND COMMUNITY RELATIONS ACTIVITIES*
Step
Preliminary Assessment
Site Inspection
Priority Listing and First
Notification of Proposed Action
Remedial Investigation
Feasibility Study
Remedial Design
Remedial Construction
Post Cleanup Documentation
Community Relations Activities
Telephone contacts, telephone
discussions with officials and key
citizens
Brief fact sheet
On-site community information
discussions
Assessment of citizen concern
Fact sheet, progress report
Briefings, workshops, and public
information meetings
News conferences
Information repository
News release ,
Fact sheet, progress report
Public consultations
Briefings, workshops, and public
information meetings
Information repository
Comment period
Fact sheet, progress report, or
briefing
News releases
Small meetings, workshops
Information repository
News releases
Fact sheet, progress report
Briefings
Site tours
Information repository
Small meetings and briefings
-The community relations activities listed are examples of techniques that
may be effective at Superfund sites. Community relations staff should select
communications techniques that are consistent with the nature of community
concern and the technical response schedule.
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CHAPTER 4
EXAMPLES OF COMMUNITY RELATIONS TECHNIQUES
This chapter describes the purposes, benefits, and limitations of the
community relations techniques that may be used in a Superfund response. It
supplements Chapters 2 and 3, which explain when these techniques should be
used during a removal or remedial action. The following techniques are
discussed:
1. Telephone Contacts
2. On-Site Discussions
3. Assessment of Citizen Concern: Procedure
4. Briefings
5. Citizen Group Meetings
6. Exhibits ,
7. Fact Sheets/Progress Reports
8. Formal Public Hearing
9. Media Appearances
10. Presentations
11. News Conferences '
___12... News- Releases
13. Site Tours
14. Public Consultations/Small Group Meetings
15. Public Inquiry Responses
16. Public Meetings
17. Workshops
18. Information Repository/Project File
As emphasized in Chapters 2 and 3, the key to a successful community
relations program is targeting activities to the distinctive needs of the
community. Therefore, not all of the techniques described in this chapter
are appropriate for every response action. Appendix A describes further the
importance of selecting the appropriate mix of techniques in the development
of a site-specific- community relations plan (CRP).
This chapter does not present an exhaustive discussion of public
participation techniques. Readers should consult public participation
manuals, such as the manuals prepared for EPA's water programs, for detailed
information.
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4-3
1. TELEPHONE CONTACTS (continued)
TECHNIQUE State health departments: Health officials may
(continued) have received complaints from citizens concerning
the safety of a site. They may also know about
active community groups that have addressed the
hazardous substance problems' in the state.
Moreover, these officials will know about any
state sponsored health effects studies or
monitoring conducted at the site.
State environmental or pollution control
agency (and equivalent offices at the city and
county level): Contacting state or local
pollution control officials can be most effective
for finding out about concerned citizens. Often,
local resident and community groups have
contacted officials at this level seeking answers
to questions about potential hazards, etc. These
officials can also provide impressions of citizen
expectations.
Local elected officials (mayors , city
managers, etc.): They can explain not only what
the citizens want, but also what steps, if any,
have been taken to satisfy citizen demands.
These officials can often put citizen concerns in
perspective, identifying how important or
unimportant the hazardous substance problem is to
the community as a whole.
BENEFITS Telephone calls can be an inexpensive and expedient method
of acquiring initial information about the site. During
immediate removals, the telephone contacts can help the OSC
identify and deal with community concern when time for more
thorough community relations activities is not available.
In remedial response actions, telephone interviews will
often be useful for establishing a network of contacts to
be used later during on-site community discussions.
LIMITATIONS The information received through telephone calls may not be
accurate. The public may not know much about the site
except what has been circulated in rumors or newspaper
articles.
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4-5
2. COMMUNITY INFORMATION DISCUSSIONS (continued)
TECHNIQUES Meeting with local government officials: Interviews with
(continued) government officials should include a brief introduction
explaining why they are being interviewed and what kind of
information is needed (site his.tory, government activity at
the site, a political perspective on citizen's
expectations, etc.).
Meeting with residents and community groups: Interviews
involving local residents or community groups are likely to
require more time. Be prepared with a discussion guide --
questionnaires are too formal and are likely to elicit curt
responses. Be sensitive to the residents' needs but remind
them that the purpose of the interview is to gather
preliminary information to be used in planning response
actions and appropriate citizen participation programs. In
this way, unrealistic expectations are not raised.
In many cases, the interviewee will ask questions and
express_concerns about the site. With adequate
preparation, the interviewer can thus acquire information
useful for later planning, as well as respond to initial
citizen concern w'ith accurate information and allay
unwarranted fears.
Confidentiality: At the beginning of each discussion,
explain that the report will be presented to EPA or state
officials and other interested persons. If the interviewee
would like'to remain anonymous, explain that the
information will be used to understand community concerns
and that a record of the contact will, be made, but EPA or
the state will not attribute any specific statements or
information to the interviewee.
Other possible contacts: During the discussions, ask for
names and phone numbers of persons who could provide
additional information on the site.
Information on citizen participation activities: Ask
whether the interviewee would like to receive any fact
sheets or other printed information as the response action
continues. Also, for future reference, keep a list of
persons interested in attending public consultations and
public meetings.
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4-7
3. ASSESSMENT OF CITIZEN CONCERN: PROCEDURE
ACTIVITY
PURPOSE
TECHNIQUE
An assessment of citizen concern about the release of
hazardous substances. Information derived from this
procedure can assist officials in estimating the level of
effort to devote to community relations at the site.
To provide additional information on the level of community
concern. This procedure may be useful in:"
Assessing local concerns where no previous
contacts with the community have been made;
Confirming the judgments of field personnel on
the level of concern in. a community; or
Reassessing preliminary judgment's about citizen
concern.
This procedure is best used after the completion of the
community information discussions, performed by community
relations staff or a contractor. These onrsite discussions
provide background information and indicate future
directions of local concern. If initial assessments of
citizen concern have already been made, an accurate
assessment of concern may require follow-up telephone calls
to local officials and citizen leaders to update the
information about the community.
Superfund officials may assess whether community concern at
a site is high, medium, or low by determining the presence
or absence of six characteristics after interviewing
members of the local community. An analysis of citizen
concerns at hazardous waste sites has shown that some of
these characteristics are more important than others in
determining the level of concern in a site community. The
characteristics are:
Children's health -- whether families in the
community believe their children's health may be
affected by the hazardous substances;
Economic loss -- whether local homeowners or
businesses believe that the' site has caused them
or will cause them economic loss;
Agency credibility -- whether the performance
and statements of EPA and the state are viewed by
the public as competent and credible;
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4. BRIEFINGS
ACTIVITY Sessions held with local government officials, often before
a news conference. Should precede meetings and workshops
held with local citizens.
PURPOSE Removal Action: To notify officials of the nature and
reasons for the action and to keep them informed of recent
developments at the site.
Remedial Responses: To inform officials and other
interested parties about recent developments at the site,
to provide them with background material on the technical
studies, results of the field investigations and
engineering design, and to report to them on proposals and
planning for remedial Action.
TECHNIQUE Inform local officials or other attendees, generally 2 weeks
before a scheduled briefing, that a briefing concerning
recent activities at the site or other related topics will
occur. It is usually best to hold the initial, briefing in
- the office of the officials or at a local meeting room.
Subsequent briefings should be held at a convenient time
and location.
Present a short, official statement about the preliminary
findings from the site activities (inspections,
investigations, engineering design, etc.) and the EPA/state
decision process, and announce future steps in the process.
Answer questions from local officials and other attendees
about the statement. Anticipate questions; be prepared to
answer them without getting involved in minor details and
subjective judgments.
BENEFITS Because briefings are often held in conjunction with news
conferences, they are useful in educating the local
officials and other interested parties about the topics of
the upcoming news conference.
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 these
persons, or otherwise to convey an impression of favoritism
towards other interested parties.
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6. EXHIBITS
ACTIVITY
PURPOSE
TECHNIQUE
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.
To illustrate issues associated with hazardous substance
problems in a creative and informative display.
Identify the target audience and the message to convey.
Possible audiences:
BENEFITS
General public
Concerned citizens
Environmental groups
The media
Public officials
Possible messages:
Description of the site -
Historical background
Proposed remedies
Health and safety effects associated with the site
Determine where the exhibit will be set up. For example,
if the general public is the target audience, assemble the
exhibit in a highly visible location, say a public library,
convention hall, or a shopping center. On the other hand,
if concerned citizens are the target, set up an exhibit
perhaps at a public meeting. An exhibit could even be as
simple as a bulletin board at the site or trailer if this
is a convenient communications location.
Design the exhibit and its scale according to the message
to be transmitted. Include photos or illustrations. Use
text sparingly.
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.
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4-13
7. FACT SHEETS/PROGRESS REPORTS
PURPOSE
TECHNIQUE
ACTIVITY A brief progress report on an issue of concern to the
community. Includes summaries of past site work and
details of upcoming activities. Must be distributed to
government agencies with an interest in the site, area
residents, citizen groups, the media, and other interested
parties on a regular basis (at least monthly when there is
a high level of citizen concern at a site) .
To ensure public understanding of the issues involved in
the response program and to present information on the
progress and results of the removal or remedial action.
Identify information to be transmitted. The fact sheet may
include the location of the site, the types or quantities
of substances known to be at the site, the potential
problems at the site, or an explanation of what EPA or the
state intends to do about the site. Address recurring
questions or issues of apparent concern in the fact sheet.
. Select a simple format for transmitting progress reports
and maintain consistency with that format. The fact sheet
may simply state the facts or present the message using a
question-and-answer format. Avoid using bureaucratic
jargon or highly technical language because the audience is
likely to be made up of individuals with widely-varying
backgrounds.
Be concise. The purpose of the fact sheet is to provide
facts, not opinions. Fact sheets are not the only way to
keep the community informed of technical developments.
Include names and phones numbers of the person or office
issuing the fact sheet and of other persons to contact for
further information. Date .the fact sheet to accommodate
future references (e.g., for changes or updates).
BENEFITS The fact sheet provides interested persons with a brief
summary of facts and issues involved in the cleanup
operations.
LIMITATIONS If not well-written, a fact sheet, with its brief format,
could be misleading or confusing. Such problems could cost
much in time and resources.
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9. MEDIA APPEARANCES
ACTIVITY
PURPOSE
TECHNIQUE
BENEFITS
Live or taped interviews, or discussions held with local or
national television or radio personnel.
To keep the public informed of what EPA or the state is
doing about the release of hazardous substances.
The need for participating in a media event should be
carefully evaluated. Do not draw attention to a problem
that seems insignificant to most citizens, especially if
the community is already sensitive about the attention it
is getting.
On the other hand, if the community is unaware of or
confused about the magnitude of the situation, broadcasts
can reach a wide audience.
Plan exactly what to say ahead of time. Live interviews
leave no room for mistakes or statements that might need to
be. retracted later. '
A media appearance reaches a wide audience -and permits only'
the most important issues to be covered.
LIMITATIONS A media appearance can unintentionally turn into a
regrettable 'event if critical facts are misstated or the
impression is conveyed that EPA or the state is not
concerned about issues important to the community.
Another limitation is that media appearances, -although they
allow response to a reporter's inquiries, do not allow a
response to individual citizen concerns; there is no
immediate feedback from the audience. This limitation can
be mitigated somewhat by reviewing, prior to the media
appearance, previous assessments of citizen concerns.
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10. PRESENTATIONS (continued)
BENEFITS Because the presentation is delivered in person, the
audience has a chance to ask questions, and EPA or the
state has an opportunity to gauge citizens concerns.
Another benefit is that a group1, of people is reached at one
time, alleviating the need for responding to individual
inquiries.
LIMITATIONS It may be difficult to deviate from the format of the
presentation to accommodate different concerns of the
audience. These concerns will have to be addressed during
a question-and-answer period after the presentation.
If a presentation is top long or not understandable to an
audience, the audience may lose interest and become
frustrated by an inability to obtain needed information in
an efficient way.
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4-19
11. NEWS CONFERENCES (continued)
TECHNIQUE
(continued)
BENEFITS
Do not overuse news conferences. Other forms
of communication, such as news releases, fact sheets, and
public consultations and meetings will be used to report
the results of the site inspection, field investigation,
and EPA or state decisions. Drawing attention to
preliminary results of technical studies may fuel
unnecessary citizen fears or unreasonable citizen demands.
Gear the news conference to the magnitude of the problem
at the site.
News conferences provide a public forum for EPA and the
state to announce plans and developments. They provide
media coverage and are an inexpensive way to reach large
numbers of citizens. By preparing a written statement,
officials can help ensure that the facts are presented
accurately to the media. During the question period, the
EPA or state spokesperson can demonstrate knowledge of the
site and may be able to improve media relations by
providing thorough, informative answers to all questions.
LIMITATIONS There are three major risks associated with news
conferences. One risk is that a news conference can focus
a high degree of attention on the situation, potentially
causing unnecessary local concern. Consider using news
releases, or other, lower-profile means of disseminating
information if such distortion is likely. Second, the
presiding official may say something that is inaccurate or
that should not be quoted to the media. Another risk is
that the official's comments could be taken out of context
by the media"and create false impressions among the
public. This risk is heightened when the conference is not
properly structured according to rules of order or protocol"
and unanticipated questions result.
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4-21
12. NEWS RELEASES (continued)
TECHNIQUES Be brief. Limit the news release to essential facts and
(continued) issues.
Use simple language and avoid the use of professional
jargon and overly technical words.
Identify the issuer of the news release. The .top of the
sheet should include the following:
Name and addresses of the issuing agency;
Release time (For Immediate Release or Please
Observe Embargo Until), and date;
Name and phone number of a staff person to reach for
further information; and
A headline summarizing the action taken.
BENEFITS A news release, if used by. the local media, can quickly and
inexpensively reach a large audience. News releases can
. inform citizens of activities at the site, and give them an
opportunity to raise questions about the findings or the
alternative remedies.
LIMITATIONS Because news releases usually can contain only the most
. important information, minor details that the public may be
more interested in are often excluded. Thus, a news
release alone cannot address all citizen concerns; it must
be issued in conjunction with other methods of
communication where more attention to detail is permitted.
When announcing controversial results, it may be useful to
attach a fact sheet that contains more detailed information.
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4-23
13. SITE TOURS (continued)
Ensure that the tour complies with the safety plan for the
site.
BENEFITS The media, local officials, and citizens become familiar with
the site, the difficulties of solving the problem, as well as
the individuals involved in cleanup operations. The result
could be better understanding and more accurate reporting.
LIMITATIONS An arranged tour may lead people to believe that the problem is
larger than it really is, particularly if technical aspects of
the removal or remedial action are not explained clearly, in
terms understandable to a lay audience.
Another limitation is that the public may attempt to engage EPA
or state community relations staff in a heated, unproductive
debate in the presence of media representatives.
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4-25
14-r- PUBLIC CONSULTATIONS/SMALL GROUP MEETINGS (continued)
TECHNIQUE
(continued)
BENEFITS
Gear the discussion to the audience. Avoid discussing the
release problems in highly technical terms unless citizens
are knowledgeable about the topic.
\
Listen. Find out what the citizens want done. Some
concerns may be met by making minor changes in the selected
remedy. Other citizens' objections to the planned work
would require revisions that change the cost and scope of
work of the permanent remedy. Work out a possible
compromise or explain the reasons why citizen proposed
remedies appear to be unworkable or contradict program or '
statutory requirements.
Follow-up on.any major^citizen concerns, stay in touch with
the groups, and contact any new groups that have formed.
The primary benefit of public consultations is that they
allow two-way interaction between citizens and EPA and the
state. Not only will the citizens be informed about the
propos.ed response, but the citizens will have the
opportunity to ask questions and to express their thoughts
on the issue.
Another attractive feature of public consultations is that
they add a personal dimension to what could otherwise be
treated as a purely technical problem. Familiarity with
the considerations involved in selecting the remedy can
relieve citizen apprehension about the hazardous substance
problem.
LIMITATIONS To be effective, attendance should be restricted to about 5
to 10 individuals. In situations where more than 10
citizens would like to be included, additional
consultations or a single large public meeting may be
required. Public consultations, however, use EPA or state
staff resources intensively, requiring upwards of a
half-day of staff time to reach a limited number of
citizens.
Another limitation is that some citizens or environmental
groups may perceive restricting the number of attendees as
a ploy to "water down" the influence large groups may have
on potential actions.
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4-27
15. PUBLIC INQUIRY RESPONSE
PURPOSE
TECHNIQUE
ACTIVITY Answering questions for the public and providing
information when requested.
To keep the public informed of EPA and state activities
throughout the response program.
Staff should consider establishing a toll-free "Superfund
hotline" or should publicize local telephone numbers that
citizens can use to obtain information.
Requests for information should be handled promptly.
Telephone calls and personal visits leave little time to
prepare a response; however, answer questions as thoroughly
as possible without making the caller wait. If you are on
a tight schedule, set up a more convenient time to answer
the inquiry.
Make sure the caller's needs are. understood, and state
exactly what information will be sent in response to the
inquiry. Take the opportunity to inform the caller about
o'ther sources of information.
Written inquiries allow more time to formulate clear,
detailed answers, but it is important not to delay the
response more than a few days.
BENEFITS Responding to public inquiries should setve two important
purposes: to keep the public informed of response actions,
and to demonstrate the desire to provide timely responses
to citizen concerns.
LIMITATIONS It is difficult to-judge whether or not citizen's questions
have been adequately answered, or whether response's have
been misinterpreted.
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>' ' __'.._. _r...
4-29
16. PUBLIC MEETING (continued)
Present the issues concerning the site, preliminary
findings, and proposed course of action. Allocate some
time for citizens to express their concerns and ask
questions. Establish a time limit for each citizen; this
avoids lengthy presentations which could generate
impatience and disrupt the meeting. Meetings may last from
an hour to no more than three hours.
BENEFITS Public meetings provide the public with an opportunity to
express their concerns to EPA, state, or local government
officials. Meetings also provide an opportunity for EPA
and the state to present information and a proposed course
of action. Public meetings also provide one setting for
the resolution of differences between the government and
the community.
LIMITATIONS Public meetings may not be the best way to obtain, citizen
input. If controversy surrounding the site has escalated,
a public meeting could provide an opportunity to intensify
conflicts rather than resolve them. Evaluate the
possibility of a public meeting getting out of hand by
reviewing the site''s history and level of citizen
involvement in this and similar controversies. In
addition, if citizens in the area view public meetings as
distractions from the issues or if public meetings have
been failures in the past, then use an alternative method,
such as small public consultations, to transmit information
and obtain feedback. Or, schedule, a public hearing that is
highly structured.
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17. WORKSHOPS (continued)
BENEFITS Workshops provide more, information to the public than is
possible through fact sheets. They also allow for two-way
communication between the public and the persons who are
running the workshops, thereby answering many of the
citizens' concerns and questions. For this reason,
workshops are particularly good for reaching opinion
leaders, interest group leaders, and the most affected
public.
LIMITATIONS Workshops reach only a small segment of the population
unless a number of them take place.
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-4-33-
18. LOCAL REPOSITORY/PROJECT FILE (continued)
TECHNIQUE Make sure the file is kept up-to-date. Timely replacement
of dated information helps avoid unnecessary
misunderstandings.
BENEFITS An information repository provides local officials,
citizens, and the media with easy access to accurate,
detailed, and current background data about the site. It
demonstrates that officials are responsive to citizens'
needs for comprehensive site information.
LIMITATIONS A project file requires diligent maintenance to avoid
misunderstandings based on dated information.' Also, there
is always a risk that information contained in the file may
be used out of context.
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v'-v^
CHAPTER 5
ADMINISTERING A COMMUNITY RELATIONS PROGRAM
Chapters 2 through 4 describe techniques community relations staff can use
to develop an effective community relations program for removal and remedial
actions. This chapter provides guidelines on program administrative
requirements for planning, reporting, and personnel. It first examines the
development, contents, and format for a community relations plan (CRP) -- the
key program planning, management, and budget tool. It then describes the
requirement to submit program status reports to EPA Headquarters. Finally, i't
explains the division of responsibility for community relations between
Headquarters and EPA Regional Offices, and discusses how to use contractor
support appropriately. The guidelines on developing CRPs apply either to EPA
staff or state agencies taking the lead on Superfund community relations
activities.
A. PROGRAM PLANNING
This section describes EPA requirements for the development of CRPs.
Staff responsible for developing community relations programs should consult
Appendix A to review suggested formats for community relations planning '
documents.
1. Development of a Community Relations Plan
The CRP is the planning, management, and budget document that guides
the community relations program at Superfund sites. CRPs must be developed
for all Superfund planned removal and remedial actions. In addition, a
profile of community concerns and a short version plan must be developed for
certain kinds of immediate removal actions. Specific planning requirements
for each type of Superfund action are described below.
1.1 Immediate Removals
Chapter 2 describes a two-step planning process for immediate removal
community relations programs:
A community relations profile must be prepared for
immediate removal actions that last longer than 5
days. It must contain a brief analysis of the nature
of citizen concern, the key site issues, and program
objectives. The profile should explain how community
relations staff intend to plan for and implement
community relations activities at the site. It must
be submitted with the Immediate Removal Request (the
"10 Point Document").
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5-3
The complete CRP for the site must be prepared either I) within four
weeks of the submission of the draft Action Memorandum or prior to the
initiation of the remedial investigation, whichever comes first for
federal-lead sites; or 2) with the final cooperative agreement package for
state-lead sites. The complete CRP includes:
The information presented in the draft CRP, updated
if necessary.
A list of communications activities to be conducted
at the site, an explanation of how these activities
will be conducted, and a description of how these
activities relate to the technical response schedule.
A budget, schedule, and workplan.
A list of technical and community relations staff
responsible for site wo,rk.
The plan should clearly identify the roles and responsibilities of all
federal agencies that may be involved in the response action (e.g., the
Federal Emergency Management _Agency_ or the Army^C^rp^s^o^Engineers) . There
should be a provision for coordinating the activities of different federal, as
well as state and local, agencies. The division of responsibility among
various federal agencies -for community relations during Superfuhd response
actions is outlined in interagency agreements or memoranda of understanding.
The complete plan must specify that the community will have an opportunity
to comment on the feasibility study prior to the selection of site remedy, and
must describe how community relations staff will implement the required
comment periods for nonexpedited and expedited remedial actions. (See the
comment period discussion on pp. 3-8 and 3-9 of this handbook.) The plan must
be sufficiently flexible to permit an extension of the review period where an
extension is warranted. At sites where there is significant public interest,
the plan should also provide for monthly fact sheets or progress reports on
technical and community relations work. In all cases, the plan should provide
that the community must receive advance notification of any action at the site.
EPA or state staff should revise the plan any time a major change takes
place in the community's needs for information or in the technical schedule.
The CRP, however, must be revised when the feasibility study is completed to
incorporate communications activities planned for the design and construction
'phases of the action. The budget, schedule, and workplan should be revised at
this point as necessary. The revised CRP should be submitted two weeks after
the submission of the draft Record of Decision for federal-lead sites or with
'the draft amended cooperative agreement application for state-lead sites.
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:^%.?^S=^S&S5^s^tr:^^^=^^'^'^-'^r:~~' . ""--
3. Appropriate Tasks for Contractors
The community relations programs at individual sites will include
many activities for which it is appropriate to make use of contractor staff.
Some activities will be routine; others will involve behind-the-scenes
preparation; still others may require special expertise. Contractors are
especially useful for ensuring that technical information is accurate and
comprehensible.
Exhibit 5-1 illustrates the appropriate responsibilities of
contractor staff for a number of standard community relations activities. The
amount of contractor assistance asked for, and the division of responsibility
between EPA and contractor staff, will vary from site to site. The
preparation and distribution of any written materials, as well as all
appearances- before the news media, must conform to EPA policy on such matters.
Technical contracting firms and their employees may be inexperienced
in assisting with community relations activities. The following section
discusses the capabilities that contractor staff assigned to community
relations should possess, and suggests how to evaluate contractors'
performance in this area.
4. Evaluating Contractors
a. Staff Qualifications
The most important contractor qualification is a clearunderstanding
of the specific communications and technical problems at a site. Without such
an understanding, it is difficult to speak straightforwardly and informatively
to interested citizens and officials, as a good community relations program
requires. Because the community relations" program is a two-way communications
program, one-way public -relations skills are not sufficient. Instead, the
following qualifications should be looked for in the contractor staff assigned
to community relations activities:
Strong interpersonal skills: the ability to listen
well, to speak clearly, to know how to answer a
question in a way that will not frustrate or anger
someone very concerned about a sensitive issue.
The demonstrated ability to write clearly and to
distill detailed information into a form suitable for
a news release or a fact sheet.
The willingness and ability to learn the technical
complexities of a site's geohydrology, the
engineering measures conducted in response, and the
potential effects of the substances at the site on
human health.
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EXHIBIT 5-1 i
SAMPLE TASKS FOR CONTRACTORS IN A,COMMUNITY RELATIONS PROGRAM*
Ac t i v i ty
I
Contractor Responsibilities
EPA or State ResponsibiIi t ies
Community .information
interviews
Community relations plan
Telephone contacts
News releases
Public consultations
Fact sheets
Briefings and news
conferences
Workshops on hazardous
waste
Formal public meeting
or public hearing
Pub Iic inqui ry
responses
Graphics
Conduct interviews, analyse socio-
political environment, prepare
report on site history arid actors,
brief EPA <
Develop and draft plan
Make follow-up calls, set interview
dates, develop community mailing
I ist
Research text of releases
Arrange small meeting wit
and EPA staff, prepare ag
i citizens
enda
Research fact sheet;
distribute sheets
reprpduce and
t
I
Arrange time and location; brief
EPA staff on how to answer diffi-
cult questions, etc; arrange any
written handouts
Design and conduct workshops in
interested communities; arrange all
logistics and support
i
Arrange time and location, prepare.
public notice, advise and prepare
EPA speakers, prepare agenda and any
support materials (including audio-
vi suaIs )
Prepare routine responses for EPA
approval, aid in researching more
involved responses
Prepare graphics for presentations or
briefings
Clear up any questions by inter-
viewees, attend briefing
Review and approve plan
Make initial calls to all elected,
appointed, and citizen leaders
Draft, edit, and release
Meet with citizens and answer
quest ions
Draft, edit and approve fact
sheet
Invite officials or reporters,
practice answers with contractor
staff, edit and approve handouts,
prepare opening statement, answer
all questions (contractors do not
pa rt ic ipate)
Make available technical staff to
discuss testing techniques, alterna-
tive solutions, etc. for workshop
Conduct hearing. Discuss site
problems and progress, roles of
EPA, state, other agencies, etc.;
answer questions
Read all letters, divide into
routine and involved answers, write
involved answers; handle all phone
inquiries; approve all responses
Review and approve all graphics
*The EPA Regional Office or the state response agency d-irects all contractor work. The support
activities listed on this exhibit are performed at the discretion of the staff with responsibility for the
community relations program.
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CHAPTER 6
COMMUNITY RELATIONS AND ENFORCEMENT ACTIONS
(Reserved)
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^^is-^jfej^r^r^^
APPENDIX A
COMMUNITY RELATIONS PLANNING DOCUMENTS
INTRODUCTION
To encourage the design and implementation of effective community
relations programs at Superfund sites, community relations planning begins
early in the response action and is generally completed before site work is
initiated. This appendix describes how to prepare the community relations
documents that are an integral part of the Superfund program: the community
relations profile (immediate removals); and the community relations plan
(immediate removals, planned removals, and remedial actions).
Chapters 2 and. 3 of the handbook generally discuss these documents and
suggest activities that might be included in community relations plans
(CRPs). Chapter 5 explains EPA planning requirements in greater detail. The
sample formats and plans that are presented below should further help EPA and
state community relations staff to determine the scope and contents of these
planning documents.
A. THE COMMUNITY RELATIONS PROFILE
The community relations profile -- a shor-t form CRP -- must be prepared
for-an-yi-mmediax.e_ removal action.-.that lasts longer than 5 days. It must be
submitted with the Immediate Removal Request (the "10 Point Document") and can
later be incorporated into any immediate removal CRP. To ensure that the
profile briefly explains how EPA intends to plan for and implement community
relations activities at the site, community relations staff should use the
profile format presented in Exhibit A-l. .In preparing the profile, staff
should answer the relevant questions,, listed in Exhibit A-2.
B. THE COMMUNITY RELATIONS PLAN
Community relations plans must be prepared for all Superfund-financed
immediate removals lasting longer than 45 days and for all planned removal and
remedial actions.
As described in Chapter 5, CRP requirements differ slightly, depending
upon the nature of the response action. For example, as soon as it is evident
that a removal action may last longer than 45 days, an immediate removal CRP
must be prepared for the site. This CRP is less detailed than the CRP
prepared for planned removal and remedial actions and is not necessarily based
upon on-site discussions.
While the structure and contents of CRPs for planned removals and remedial
actions are similar, the development process differs. A CRP covering the
entire planned removal action must be submitted along with the "14 Point
Contractual Document." For remedial actions, draft CRPs must be submitted
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engineering OT science teachers would be very different from a presentation to
a taxpayers organization. The local groups (to be identified in the community
information interviews and/or telephone contacts) may include:
Neighbors of the site;
Local elected officials, political candidates,
county or municipal boards, county health departments;
Federal or state representatives and their staffs;
Groups organized around the issues of the site;
Existing civic groups: League of Women Voters,
Kiwanis Club service clubs, church groups, taxpayer
groups, farm organizations, senior citizen groups,
minority groups;
Local business groups ,, Chamber of Commerce, real
estate groups;
' Environmental groups, Audubon Society, Sierra Club;
Health' organizations , local American Cancer Society
Officials or interest groups from nearby communities;
Local industries and business;
Labor unions ; and
Newspaper, radio, and television reporters, editors,
talk show hosts.
Once the interested groups in a community and their concerns about the site
are identified through on-site discussions and/or telephone contacts, the plan
can be drafted.
The CRP includes the following elements that detail the community
relations program at the site:
Background and history of community involvement at the site:
Site history
Community involvement
Key issues;
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A-S
Provide accurate, timely information about the response to the
community; and
Allow citizens to express their concerns to EPA and the state.
The purpose of this section of the CRP is to list specific objectives tailored
to the technical response timing and the level of citizen concern at the
site. Included in these objectives are the specific points that EPA and the
state want to communicate to the community at certain points in the technical
response,- and the specific decisions on which local input is essential.
The community relations techniques section lists the communications .
activities to be conducted in each phase of the response and specific
objectives. The section should explain how the community relations
activities selected for the site are tied to the technical response workplan
and schedule. The types of techniques that can be used in Superfund
community .relations programs are described in Chapter 4, but other techniques
may be used as well, particularly activities that fit into ongoing local
arrangements. As noted in Chapter 5, the CRP must specify that the community .
will have an opportunity to comment on.the feasibility study prior to the
selection of a site remedy. This section of the CRP must specify how a three
week comment period will be implemented for nonexpedited remedial actions.
For any' initial remedial measures (IRMs), the plan must also (1) address how
the community will receive prior notification of any site action and (2) state
that a minimum two week comment period will be provided for any complex IRM
recommended by a limited feasibility study. It should note that if there is a
reasonable request for a comment period extension (e.g., because of delays in
providing documents to citizens), community relations staff should extend the
review period, as long as the delay does not exacerbate any threat to public
health, welfare, or the environment.
/
This section should also detail how staff will keep citizens informed
of past site activities and upcoming events on a regular basis. Where there
is significant public interest, CRPs should provide for monthly fact sheets or
progress reports on technical and community relations work. There should be
provision for coordinating the community relations responsibilities of the
federal, state, and local agencies, in addition to EPA, involved in the
response.
The last two sections, the workplan and schedule, and the budget and
staffing plan, consist of charts. The workplan and schedule display
technical milestones and community relations activities along a time line.
The time line may be altered over the course of the Superfund response because
most activities will correspond to technical milestones, not dates. The
community relations activities should include a period for lead time to draft,
circulate, review, and approve written materials and activity plans before the
date of the activity. The budget and staffing plan details the EPA, other
federal, and state agency staff responsible for each community relations
activity. The staffing list should differentiate preparatory staff -- those
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A-7
EXHIBIT A-1
SUGGESTED FORMAT -- COMMUNITY RELATIONS PROFILE
FOR IMMEDIATE REMOVALS
DATE PROFILE PREPARED:
A. BACKGROUND
1. Release information
Date and location of release and substances released:
Nature of the threat to public health, welfare, and the environment:
Response actions, if any, taken to date:
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Brief description of any actions taken by community members, or any
meetings that have already been held by EPA or the state, elected
officials, or citizens:
B. OBJECTIVES OF THE COMMUNITY RELATIONS PROGRAM
List of specific objectives for the site and why these are selected:
Brief description of activities considered for the site (staff's
preliminary view of what would constitute an effective program for
the site) and how these activities would be tied 'into the technical
response:
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A-ll
EXHIBIT A-3
SUGGESTED FORMAT -- COMMUNITY RELATIONS PLANS
FOR IMMEDIATE REMOVALS
DATE PLAN PREPARED:
A. BACKGROUND OF RELEASE
1. -Date of release and substances released
2. Nature of the threat to public health, welfare, and the environment
3. Response actions, if any, taken to date
B. KEY COMMUNITY CONCERNS AND ISSUES
/
1. Concerns and issues identified-by local officials and citizens
2. Identification-of interested local officials, citizens, and groups,
their affiliation, addresses, and phone numbers
3. Brief description of any media coverage; media coverage date;
identification of media contacts:
4. Description of actions taken by the community
C. OBJECTIVES FOR THE COMMUNITY RELATIONS PROGRAM
1. List of specific program objectives (e.g., to provide accurate,
understandable information, to prepare the community for further
action, to allay community concerns)
2. Explanation of why objectives have been selected (e.g., their targets,
their relationship to the response a'ction)
D. COMMUNITY RELATIONS ACTIVITIES
1. List of communication activities to be performed at the site;
description of how they relate to program objectives; explanation of
how community relations activities relate to the technical response
schedule
2. Brief schedule of activities (specify date, activity, objective,
staff, workhours)
E. STAFF
1. List of staff responsible for program implementation and their
assignments
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-.,.--
COMMUNITY DELATIONS PLAN SAMPLE CRP
Residence/Dial Services Manufacturing Company
Ueveiana, Qmo '. "
This comnunity relations plan outlines activities to be conducted during a
Superfund planned removal action at the Skiljan residence and the Dial Services
Manufacturing Company, both being located in Cleveland, Ohio. Subject to
finalization of the cooperative agreement between Ohio EPA and U.S. EPA, the Ohio
Department of Health will have the lead responsibility working in close
cooperation with U.S. EPA, Region V and Ohio EPA. This community relations plan
can be updated and revised in response to events affecting the progress of the
planned removal and/or citizens needs or concerns.
A. BACKGROUND AND KEY ISSUES
1. Site History
a. Skiljan residence
13028 Notti.nghan Road
Cleveland, Ohio
On April 30, 1982, Mr. Eugene Skiljan discovered, in the course of
demolishing a barbeque pit in his backyard,-several hundred vials
labeled "U.S. Radium" and "poison". Investigation by the Ohio
Department of Health (ODH) Radiological Health Program, led to
identification of the vials as spent containers possibly from Dial
Services Manufacturing, a radium dial painting company founded by the
former owner of Mr. Skiljan's residence, Mr. Walter Issel. Subsequent
surveying identified several regions of radioactivity in the backyard
and on an adjoining property, seepage off the property showing
elevated radium-226 in the water and contamination in the basement of
the home.
During the week of May 25-28, the Center for Applied Isotope Studies
(CAIS) at the University of Georgia surveyed the property more fully
for the State of Ohio and identified, in addition to the barbeque pit,
nine areas requiring excavation to remove radium-226 contaminated
soils.
b. Dial Services Manufacturing Company
1741 Rockwell Avenue
Cleveland, Ohio
Subsequent to the discovery of radium contamination on the Skiljan
property, an investigation was conducted by the ODH, Radiological
Health Program, of the building in downtown Cleveland, Ohio, where
Dial Services Manufacturing formerly painted radium dials. The firm
still exists but.no longer utilizes radioactive materials. Less than
a dozen employees are engaged to teflon coat small parts. The
radioactive survey established that gamma and beta radiation levels
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A-15
SBMPIE CRP
B. OBJECTIVES OF THE COMMUNITY RELATIONS PLAN
The objectives of the community relations program are:
1. To keep Dial Services Manufacturing, the Skiljans and immediate property
owners apprised of the plan and time table for clean up.
2. To insure that citv officials especially interested in the sites be
informed of plans, progress and any problems which may develop.
3. To keep interested state and Congressional legislators and state officials
Informed of plans and progress.
4. To insure that accurate information is disseminated to the media.
C. COMMUNITY RELATIONS TECHNIQUES
The following techniques are suggested to meet the objectives of this
community relations plan:
Objective
1. Meetings with Dial -Services Mfg.
the Skiljans and immediate
- property owners.
2. Meetings with city officials.
3. Briefings for state and
Congressional legislators and state
officials.
4. Media conference.
Technique
To keep them informed of plans
and progress. These can be
one to- one meetings rather
than group meetings. As clean
up starts, these will likely
be on a day to day basis.
To inform interested city
officials of the plans and
progress. These should
include meetings as
preliminary plans are made,
when the schedule is set, as
any problems develop and when
work is completed.
To keep these interested
individuals informed of
progress. These briefings can
be oral or written.
To provide all concerned media
with accurate information, an
opportunity to tour the sites
and question the contractor,
state officials and city
officials.
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Site tours
Media releases
Concluding report
F. OFflCIALS, CITIZENS, MEDIA
Local Officials
A-17 " .
Paul Massa (ODH)
Bob Quillin (ODH)
Ken Meckstrotn. (ODH)
Lorey Roggenkamp (OEPA)
SAMPLE CRP
3
3
10
10
Federal Officials
'State Officials
Concerned Citizens and Property Owners
Medi a
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jsgp^SasaSS
^^^S^g^^^^^^s-z^v.^....^., \"..^'^7j^g^:^»fsf^-rjg^faa^s^^^^i^^>>--T^S:';
COMMUNITY RELATIONS PLAN-
FOR REMEDIAL ACTION
AT THE IMPERIAL SITES
IMPERIAL, MISSOURI
This Stage I community relations plan otxtlin.es the activi-
ties to be conducted during a Superfund remedial action at
the Imperial sites in Jefferson County, Missouri. U.S. EPA
Region VII has the lead responsibility for managing the re-
medial action, which consists of initial remedial measures,
a remedial investigation, and a feasibility study. This
plan was prepared in February 1983 and revised in June 1983.
I. BACKGROUND AND HISTORY
A. SITE HISTORY
Imperial, Missouri, a suburb of St. Louis, is an unin-
corporated town of about 6,000 middle-income families.
The dioxin sites located in Imperial are nestled in a
hilly, wooded area that is still being developed.
In February 1971, a salvage oil company owned by a
Mr. Russell Bliss began hauling dioxin wastes from the
now defunct Northeastern Pharmaceutical and Chemical
Company (NEPACCO) in Verona, Missouri. The type of
dioxin, scientifically named 2,3,7,8-tetrachlorodi-
benzo-p-dioxin (TCDD) , is an unwanted byproduct re-
sulting from the manufacture of trichlorophenol, which
was produced by NEPACCO as an intermediate in the manu- .
facture of hexachlorophene.
The dioxin-contaminated wastes were mixed with waste
oils and used to spray at least three horse arenas for
weed and dust control. One of these arenas was at
Bubbling Springs Ranch in Jefferson County. It was
sprayed with contaminated oil in June and July 1971.
Early in 1972, two horses died, and Later in the year
four more died. At the time, the cause of death was
undetermined. As a precaution, however, 850 yards of
arena soil was excavated in March 1973.
The excavated soil from Bubbling Springs Ranch was used
as residential fill at the Minker residence and the
Stout site (named after the contractor who did the exc-
avation and who owned the property at the time) . Approxi-
mately 20 truckloads of the soil were used to fill a
steep ravine on the south end of the Minker house. The
property is located on a ridge at the head of the water-
shed, and the fill area has mostly washed out into
Romaine Creek. The Stout property is on the side of a
ridge, and the contaminated soil was used to level off
an area underneath two house trailers..
PD951.001
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October 6 and 7, 1982; EPA staff toured the area and
visited four households near the Minker site (staff
could not contact two other households near the site)
and one household near the Stout site.
October 6, 1982; A phone line to EPA was opened; from
October to the present, approximately 30 residents have
called EPA.
October 14, 1982; A public meeting was held at Mermac
Heights Elementary School. Approximately 150 households
in the vicinity of the sites were invited. About 175 per-
sons attended. There was heavy press coverage and
attendance by local and state officials. A fact sheet
was distributed.
November 5, 1982; Dioxin Update No. 1 (stating the
status of October sampling) was sent to approximately
150 households in the vicinity.
December 1, 1982; EPA and CDC made personal visits to
the six households identified for relocation. Dioxin
Update #2 was distributed door-to-door to approximately
150 families. This included October sampling results,
maps of the sites that were sampled, action options,
future plans, and notice of a public inquiry center.
December 8, 1982; A public inquiry center was opened
at a nearby hotel for 5 days, 9 a.m. to 9 p.m. A press
conference and news release presented the findings-from
the October sampling.
January 20, 1983; A spokesman for concerned citizens
near the Minker site requested a meeting between resi-
dents and responsible officials. Forty-two citizens
attended, as well as representatives from EPA, CDC,
Missouri Division of Health, Missouri Department of
Natural Resources, and a State of Missouri attorney.
There was no press attendance. Remedial actions and
citizen concerns were discussed. Handouts included a
fact sheet, dioxin questions and answers, and a summary
sheet of proposed actions..
January 29, 1983; A public hearing was held at Jeffer-
son College in Hillsboro, called by Congressman Robert
Gephardt. This was a general meeting concerning pos-
sible dioxin sites throughout Missouri. Meeting par-
ticipants included: Regional and Headquarters EPA
officials; FEMA; CDC; Missouri DNR and Health Division;
State Senator Harriet Woods; State Representative Bob
Feigenbaum; Dr. Ellen Silbergeld (Environmental Defense
Fund); and representatives from the Minker site, Stout
PD951.001 3
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f.. James Haeger householdtwo adults. Next door
neighbors to Minkers on W. Rock Creek Road.
g. Joseph Korenak householdfirst house south of
Minker residence, on west side of Rock Creek Road.
h. Albert Edwards householdlocated immediately adjacent
to Romaine Creek, approximately 1/3 mile north of
the Minker site.
Personal contact will be maintained with ±a»fe house-
holds adjacent to the seven identified for relocation:
Crismon
Davis
Abramson
Henderson
Webb
5. Three households near the Stout site have been
offered relocation:
Martin Hutchison (next door to site;
have already temporarily relocated)
James Cisco (2 doors down from site; '
have already temporarily relocated)
Edward Baczynski (-across street; have
already temporarily relocated)
6. Personal contact will be maintained with two house-
holds near the Stout site that have expressed concerns
Jack Sutton (owns trailer house on Stout
site; is the developerNHI Development
Companyof Country Club Manor subdivi-
sion)
Peter Vogt (owns part of Stout site;
lives further up the road)
7. Other areawide groups that are involved in the
dioxin situation in Missouri are:
Coalition for the Environment (based in
St. Louis; present at January 29 meeting)
Missourians against Hazardous Waste (based
in Excello, Missouri)
Environmental Defense Group (based in
Washington, D.C.; Dr. Ellen Silbergeld
attended January 29 meeting)
PD951.001
-------
taminated soil be contained onsite or removed?
What will the restoration and close-out procedures
be? There is a strong feeling by some people that
containing and securing the site is not an ade-
quate cleanup measure; if this solution is "chosen,
they will insist on being bought out on the basis
of lowered property values and future health
risks. If soil is removed, will the truck traffic
cause road deterioration? What traffic controls
will be provided? How will equipment used during
the cleanup be decontaminated? How will residents
be protected from dust? Can downwind residents be
relocated during on-site action?
It should be emphasized that people's two main concerns
are health effects and economic loss. It is perhaps
relevant to note that in August 1982, a Federal court
awarded over $58 million in damages to workers whose
health was affected by exposure to dioxin during the
cleanup of a 1979 train derailment in Sturgeon, Mis-
souri. Several residents in the Imperial area have
filed suit for damages, and more litigation is
expected.
Based on the issues, concerns, and citizen participation
and perceptions that have been identified, the_ level__of _
community concern at the Imperial sites should be as-
sessed as high.
E. PROPOSED REMEDIAL ACTIONS AND SCHEDULE
The activities described below will be conducted pur-
suant to a written contract between EPA and the State
of Missouri. That contract defines the responsibili-
ties of EPA and the State and provides for funding of
the proposed actions. EPA is the lead agency and will
be responsible for performing all activities at the
site other than the relocation of the residents.
Initial Remedial Measures - Temporary relocation
will be offered to affected residents by the State
of Missouri. EPA contractors will post warning
signs around the Minker and Stout residential
areas and along Romaine Creek. Before the posting,
access agreements will be obtained from property
owners and surveys of the area will be conducted.
Remedial Investigations - Additional data will be
collected. Aerial photographs of the area will be
taken to prepare topographic maps. Additional
soil samples from the Stout residential area will
be collected and analyzed to accurately define the
contaminated area. A hydrogeological study of
PD95;! 001
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III. TECHNIQUES TO BE USED TO MEET OBJECTIVES
The following community relations techniques fulfill
the objectives listed above. The purpose of each tech-
nique and its application at certain stages of the tech-
nical work are discussed. The workplan and schedule
shown in Section IV shows -these community relations
techniques in relation to technical milestones.
Technique
Objectives
1. Personal contact with
residents
Door-to-door or by telephone. To inform
target residents (relocatees; spokesper-
sons for two community groups; closest
neighbors) of major findings, activities,
and decisions. Should occur before fact
sheets or other public information is
released.
2. Briefing of local and
state officials
In person or by telephone. Inform
appropriate officials of plans and
developments on continuing basis. CIGL
will maintain liaison with public officials,
3, Public consultations
Informal discussions with small groups
of concerned citizens (two identified
groups and any others that arise) to re-
view issues and answer questions. Pro-
vide medical experts or other experts as
appropriate. Schedule during the feasi-
bility study to present the alternatives
and solicit input; also schedule upon
request.
,001
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A-28
Technique
Objectives
8. EPA toll-free telephone
line (Office of Public
Affairs, EPA Region VII,
Kansas City)
(Office To provide a direct line of
communication for Inquiries and con-
cerns. Number should be Included in.
fact sheets or otherwise be made known
to local residents and officials.
9. Onsite inquiry office
(optional)
10. Regional information of-
fice (optional, for St.
Louis region)
To provide an onsite source of informa-
tion when controversial findings are re-
leased or when a great deal of public
interest is anticipated.
To provide information about this and
other dioxin sites; to provide personal,
easily accessible, and consistent contact,
to concerned citizens.
11. Summary of public concerns For use by EPA staff during feasibility
study; public concerns are to be used as
one criterion for the evaluation of
alternatives.
12. Interim report
To provide EPA Headquarters with a sum-
mary of public inquiries and concerns,
the responses provided, and the community
relations activities conducted.
PD951.001
11
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-A-3C
V. BUDGET AND STAFFING PLAN
(To be provided by EPA)
APPENDIX: NOTIFICATION LIST (Available upon request)
A. Local officials
B. Interested or affected parties and organizations
C.' Media
PD951.001 13
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APPENDIX B
COMMUNITY RELATIONS GUIDANCE FOR EVALUATING
CITIZEN CONCERNS AT SUPERFUND SITES
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* *~ - - --..- . ...
B-2
2. PLANNING AND PREPARATION
This section of the guidance discusses the planning and preparation that
should precede discussions with citizens and local officials at the site. The
work effort required for the activities described will vary from site to site,
depending on the level of citizen concern and the site's technical
complexity. On the average, however, planning and preparation for on-site
discussions should require three days of work effort.
Prior to conducting the on-site discussions, the community relations staff
should plan: (1) how to acquire information about the site and identify
interested public officials and members of the local community; (2) how to
contact interested officials, citizens, and organized groups; and (3) how to
elicit information from these individuals and groups. These three phases of
the planning process are discussed separately below.
A. Acquiring Site Information and Identifying Interested Officials,
Community Members, and Groups
_ ?
To ensure that key individuals are contacted and that site issues are.
understood, certain steps should be performed to acquire necessary background
information, including the following:
(1) Meeting with regional EPA and state technical staff to
discuss- known or suspected site problems, to identify
interested officials and citizens, and to obtain other
background information;
(2) Reviewing EPA regional office, headquarters and state
files to obtain relevant memos, documents, and
correspondence;
(3) Researching local newpaper articles for the names of
community leaders and for a preliminary indication of
major site issues;
(4) If EPA clearance has been obtained, contacting
Congressional offices in Washington or the state,
either by telephone or in person, to obtain additional
background information, as well as to inform the
offices that EPA or state staff or contractors will
soon visit the site. Congressional staff can identify
the most involved citizens and the major site issues on
the basis of inquiries to their office. It is
essential to obtain EPA clearance, however, before
making such contact. (Staff in the local or district
Congressional office nearest to the site may be
included routinely among those with whom on-site
discussions are held, as noted below.)
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those persons on the contact list, staff should explain that the purpose of
the discussions is solely to obtain the views of community members on site
problems and to explore the concerns and issues identified by citizens and
local officials. Staff should stress that the discussions will not. be used
to provide information to the public about site problems or possible future
site actions, but instead, that the purpose of the discussions is to assess
the level and nature of community concerns, so that community relations
activities appropriate to those concerns can; be conducted and so that
community concerns can be taken, into account in planning response actions.
The purpose of the discussions will usually be easily understood. Citizens
and officials will generally not object to speaking to government staff who
cannot provide them with findings on possible effects or a firm schedule for
cleanup, although they may be disappointed not to receive such information.
Rather, citizens and local officials are generally appreciative that someone
from the government is willing to meet with them and listen to their views.
They regard the discussions as an opportunity to voice their concerns and,
perhaps, to have some effect on government decisions.
If possible, all meetings should,be scheduled over a period of no more
than five days.
C. Eliciting Information from Individuals and Groups
The final phase of the planning process is to draw up a brief and informal
list of questions to guide the discussions with local officials and citizens.
Such a list may help to ensure that the discussions are efficient yet
comprehensive. These questions may serve as a reminder of the areas that
should be covered in the discussions, the kinds of information that should be
elicited, and any specific points that must be addressed. Because the on-site
discussions should not be conducted as a survey, the questions listed in
advance while planning the discussions need not be asked explicitly during
discussions. Exhibit 1 presents examples of questions that may be useful in
conducting on-site discussions.
In addition to preparing questions, community relations staff should
determine whether there are any special matters that should not be publicly
disclosed (for example, specific findings from enforcement investigations or
preliminary cost estimates for cleanup). Program and enforcement staff should
be consulted on this point before the on-site discussions are held.
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B-6
3. CONDUCTING ON-SITE DISCUSSIONS
This section presents procedures that may be useful to EPA, the state, or
contractor support staff in conducting on-site discussions with citizens and
local officials. If possible, all discussions related to a specific site
should be conducted within a five day period';
Unce the discussions have begun, staff should try to:
Make all appointments as scheduled;
Arrange a follow-up conversation if additional time
is needed with any official or citizen;
Assure citizens and officials that all interviews
will be held confidential, and that no specific
statements will be attributed to any person without
prior clearance;
.»
Have two community relations staffers present during
the discussion,-when pqss_ible_,_so that one can 'take
notes while the other leads the discussion.
About 45 minutes to one hour- should be allowed for a discussion with an
individual. Less time will usually be required once the community relations
staff have become familiar with the background of community involvement
through previous discussions. If asked, staff should not hesitate to identify'
some of the other citizens or officials with whom discussions are being held.
Local reporters may, on occasion, ask to attend discussions between .
community relations staff and community leaders or officials. The attendance
of reporters at these discussions should be discouraged, as it might inhibit a
frank and open conversation. Reporters should be asked, instead, to meet
separately with community relations staff. If they do attend discussions with
officials, they should be included in the meeting and asked for their views
and comments, which are valuable.
At the outset of any discussion with reporters, community relations staff
should repeat that the purpose of the discussion is to collect information,
not to answer questions, and that the community relations staff are not in a
position, in any event, to provide new information on site problems or
response plans.
Community relations staff must take special care to avoid making
subjective comments about the site during the discussions and avoid conveying
specific information that may raise citizens' or officials' expectations
about response activities.
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B-8
4. EVALUATING DISCUSSIONS
Based upon the discussion summaries and the notes from each meeting,
community relations staff should evaluate the nature and level of citizen
concern at the site. This evaluation will be incorporated into the CRP.
Community relations staff may assess whether community concern is high,
medium, or low by considering the presence or absence of the following six
characteristics, which have been found to be important indicators of community
involvement and concern in past on-site investigations conducted by EPA:
(1) Children's health -- whether families in the community
believe their children's health may be affected by
hazardous substances;
(2) Economic loss -- whether local homeowners or ,
businesses believe that, the site has caused or will
cause them economic loss;
r
(3) Agency credibility -- whether the performance and <
statements of EPA and the state are viewed by the
public as competent and credible;
O) Involvement -- whether an active, vocal group leader
(or leaders) has emerged from the community and whether
the group leader has a substantial local following;
(5) Media -- whether events at the site have received
substantial coverage by local, state, regional, or
national media; and
(6) Number affected -- whether more than three or four
households perceive themselves as affected by the site.
Some of these characteristics are more important than others in
determining the level of community Concern. For example, a perceived threat
to children's health is a particularly strong indicator of a potentially high
level of citizen concern at a site. If several of the above characteristics
describe the affected community, the community relations staff have grounds
for considering that the level of community concern at the site may be medium
to high or has the potential to become medium to high.
In writing CRPs, following completion of these on-site discussions, it is
important to maintain objectivity. Consideration should be given to the
feelings of any citizens or officials mentioned. These plans will be
circulated among the state and federal agencies involved in the response.
They may also be read by members of the general public in the site community.
Allegations or opinions expressed by those with whom discussions
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APPENDIX C
THE QUARTERLY REPORT
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QUARTERLY REPORT QUESTIONNAIRE
*
1. Site/location: '
2. Describe any changes in site issues (economic, social, technical,
scientific, political) that have occurred since the preparation of the
last quarterly report:
3. Describe the community relations activities undertaken during the previous
quarter, their effects, and the concerns that arose. What issues remain?
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.-_.. ._:... ..,-,_. :... /.:
7. Does the CRP currently address these issues? Do you plan to revise the
CRP?
8. Explain any deviations from the CRP -for the site during the past
quarter?
9. Would you like OPPM community relations staff or contractors to assist you
in meeting certain needs during the next quarter or in resolving
particular issues?
SITE REPORT PREPARED BY:
DATE':
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APPENDIX D
Super-fund Coordinators
Superfund Community Relations Coordinators
(September 1983)
Region One
John Hackler, Superfund Coordinator
Waste Management Division
EPA - Region T
John F. Kennedy Federal Building
Boston, Massachusetts 02203
FTS 8-223-5709 or (617) 223-5709
David Pickman, Superfund
Community Relations Coordinator
Office of Public Affairs
EPA - Region I
John-F. Kennedy Federal Building
Boston, Massachusetts 02203
FTS 8-223-5752 or (617) 223-5752'
Region Two
Robert Ogg, Superfund Coordinator
Air and Waste Management Division
EPA - Region II
26 Federal Plaza
Mew York, New York 10278
FTS 8-264-2647 or (212) 264-2647
Lillian Johnson, Superfund
Community Relations Coordinator
Office of Public Affairs
EPA - Region II
26 Federal Plaza
New York, New York 10278
FTS 8-264-4534 or (212) 264-4534
Region Three
Ed Skernolis, Superfund Coordinator
Air and Waste Management Division
EPA - Region III
Curtis Building
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
FTS 8-597-9100 or (215) 597-9100
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/ ;
fc^y_ 'lJ"*, ' " ^^ '-*'---?
Region Six
William Hathaway, Superfund Coordinator
Deputy, Air and Waste Management Division
EPA - Region VI
First International Building
1201 Elm Street
Dallas, Texas 752.70
FTS 8-729-9709 or (214) 767-9709
Betty Williamson, Superfund
Community Relations Coordinator
Congressional and Intergovernmental Liaison
EPA - Region VI
First International Building
1201 Elm Street
Dallas, Texas 75270
FTS 8-729-9986 or (214) 767-9986
Region Seven
David Wagoner, Director/Superfund Coordinator
.A.ir_.and Waste Management Division
EPA - Region VII
324 East llth Street
Kansas City, Missouri 64106
FTS 8-758-6529 or (816) 374-6529
Rowena Michaels, Director
Office of Public Affairs
EPA - Region VII
324 East llth Street
Kansas City, Missouri 64106
FTS 8-758-5894 or (816) 374-5894
Steve Wurtz, Superfund
Community Relations Coordinator
Office of Public Affairs
EPA - Region VII
324 East llth Street
Kansas City, Missouri 64106
FTS 8-758-5894 or (816) 374-5894
Region Eight
John Wardell, Superfund Coordinator
Air and Waste Management Division
EPA - Region VIII
1860 Lincoln Street
Denver, Colorado 8CW95
FTS 8-327-6238 or (303) 837-6238 .
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Headquarters Superfund Community Relations Staff
(September 1983)
Daphne Gemmill
Community Relations Coordinator
Office of Emergency and Remedial Response
EPA Headquarters' (WH-548D)
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2441 or (202) 382-2441
Anne Fenn
Assistant Community Relations Coordinator (Regions V - X)
Office of Emergency and Remedial Response
EPA Headquarters (WH-548D)
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2464 or (202) 382-2464
Allen Naples
Assistant Community Relations Coordinator (Regions I - IV)
Office of Emergency and Remedial Response
EPA Headquarters.(WH-548D)
401.M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2461 or (202) 382-2461
Michael Flaherty, Removal Actions Contact
Emergency Response Division (WH-548B)
Office of Emergency and Remedial Response
EPA Headquarters
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2196 or (202) 382-2196
Tony Diecidue, Remedial Actions Contact
Hazardous Site Control Division (WH-548E)
Office of Emergency and Remedial Response
EPA Headquarters
401 M Street, S.W.
Washington, D.C. 20460
FTS 8-382-2454 or (202) 382-2454
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APPENDIX E
PROBLEM SITUATIONS
(reserved)
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APPENDIX F
GLOSSARY OF TERMS AND ACRONYMS
This glossary presents brief descriptions of terms used in the community
relations handbook. The terms are organized alphabetically by broad
categories: community relations program; Superfund response actions; program
documents and requirements; and program offices and officials. The acronyms
that are applicable to program terms are listed at the end of.the glossary.
Detailed definitions of these terms are provided in this handbook.
COMMUNITY RELATIONS PROGRAM
Community Relations Program. The community relations program is a
two-way communications program, designed to provide communities with
accurate, understandable information about Superfund sites and
proposed response actions, to elicit community concerns, and to
provide communities with an opportunity to comment on proposed
response actions.
Public Relations Program. A public relations program is an
information program that exists primarily to provide information to
the public about an agency and its programs. It differs from a
community relations program in that it does not necessarily promote
two-way communication.
The Superfund Response Program. The Superfund program is the
response program established by the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) to respond to
releases or threatened releases of hazardous substances, pollutants,
or contaminants from vessels or facilities. (See CERCLA and the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFR Part 300.)
SUPERFUND RESPONSE ACTIONS
Response Actions. Superfund response actions are those removal or
remedial actions undertaken in accordance with Section 104 of
CERCLA. The three types of response actions that may be taken under
CERCLA are described below.
Immediate Removals (IR). These are actions taken to prevent or
mitigate immediate and significant risk of harm to human life or
health or to the environment. They are subject to timing and
monetary limitations. (See Section 300.65 of the NCP.)
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F-3
Superfund planned removal and remedial actions. In addition, a less
detailed plan must be developed for immediate removals that are
anticipated to last longer than 45 days. The plan contains: an
assessment of citizen concern; a list of communications activities to
be conducted at the site, a budget estimate, schedule, and workplan,
and a list of technical and community relations staff responsible for
site work.
Community Relations Profile. The profilea short form CRP--is a
brief analysis of the nature of citizen concern, the key site issues,
and program objectives that must be prepared for immediate removal
actions lasting longer than 5 days.
Cooperative Agreement (CA). The cooperative agreement is the
agreement that outlines the responsibilities of the federal and state
governments for removal or remedial actions at state-lead Superfund
sites. (See "Guidance-Cooperative Agreement and Contracts with
States under CERCLA (P.L. 96-510)," U.S. EPA, OERR, March 1982.
Feasibility Study (FS). The feasibility study is conducted to
develop and analyze remedial alternatives, to recommend the
appropriate cost-effective remedial action, to prepare an
environmental assessment, and to develop a conceptual design for_ the
recommended action.
Fourteen Point Document. This planned removal document, prepared
by On-Scene Coordinators for EPA-lead actions, describes general site
information, explains the threat presented by the site, and provides
information regarding the proposed response action. (See the EPA
Contracts Management Manual for the required contents of the
document.)
National Contingency Plan (NCP). The NCP is the regulatory
document that guides response actions taken pursuant to CER'CLA and
Section 311 of the Clean Water Act. (See the National Oil and
Hazardous Substances Pollution Contingency Plan, 40 CFR 300.)
National Priorities List (NPL). The NPL is a list of over 400
hazardous waste sites targeted for cleanup by federal and state
governments under CERCLA. Sites on the list are candidates for
remedial or enforcement action. Decisions on the type and extent of
action to be taken at the site are made on a case by case basis
according to guidelines specified in the NCP.
Quarterly Report. This is a brief summary of community relations
activities for each Superfund response in the Region. Prepared by
the Regional Superfund community relations coordinator, the report is
submitted to Headquarters where it is used to analyze community
relations programs and to identify potential communications problems
at sites.
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F-5
The Office of Emergency and Remedial Response (OERR). This is the
EPA office responsible for establishing Superfund policies, for
implementing the Superfund Program, and for evaluating program
effectiveness.
The Office of Policy and Program Management (OPPM). This is the
office within OERR that is responsible for developing community
relations policies, reviewing and approving community relations
plans, tracking communications activities at sites, and conducting
program evaluations and resource analysis.
The Regional Office of Public Affairs (OPA) . Staff in the
Regional Office of Public Affairs are responsible for helping' to
design and implement a community relations program at each site where
Superfund monies have been obligated. The office works closely with
the technical staff at the site and in the Regional Office in
conducting community relations programs.
On-Scene Coordinator (OSC). This is the federal or state official
that coordinates and directs the Superfund technical response at the
site. The OSC works closely with the community relations staff to
establish site-specific community relations programs.
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/
ACKNOWLEDGEMENT
This handbook is a product of the combined efforts of ICF Incorporated,
EPA's Office of Emergency and Remedial Response, and EPA Regional and State
Superfund and public affairs staff concerned about citizen involvement in
responding to hazardous substances problems.
Daphne Gemmill and Barry Jordan served as EPA's project officers. Their
guidance and direction in developing the handbook benefitted from the
contributions of Anthony Diecidue, Anne Fenn, L. Michael Flaherty, and Allen
Maples from EPA Headquarters. The ICF staff for this project include James R.
Janis, Project Manager, Carol Andress, Edwin Berk, Bradley Brockbank,. Margo .
Brown, James Bunchuck, Carole Francis, Sara Nielsen, Robin Sandenburgh, Mary
Sexton, Corliss Wallingford, Zella Williams, and Dana tfohlford. The initial
guidance of Dr. Steven Cohen of Columbia University is also very much
appreciated.
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