United States Environmental Protection Agency Office of Solid Waste and Emergency Response SEPA DIRECTIVE NUMBER: 9230.0-02 TITLE: Superfund Community Relations Policy APPROVAL DATE: May 9, 1983 EFFECTIVE DATE: May 9, 1983 ORIGINATING OFFICE: OERR/HSCD Q FINAL D DRAFT STATUS: REFERENCE (other documents): OSWER OSWER OSWER 'E DIRECTIVE DIRECTIVE Dl ------- 03/19/87 United State Environmental Protection Agency Washington, D.C. 20460 EPA OSWER Directive Initiation Request 2. Originator Information Name of Contact Person Mil Code Office //i?5{> GEMMILL OERR/«PO» 3. Title SUPERFUND COMMUNITY RELATIONS POLICY 1. Directive Number 9230.0-02 Telephone Number 382-2460 4. Summary of Directive (Include brief statement of purpose) General policy on the conduct of community relations in Superfund. (5/83, 5 pp) U,§ SPA Headquarters Library Mail code 3404T 1200 Pennsylvania Avenue NW Washington, DC 20460 202-566-0556 5. Keywords SUPERFUND, CERCLA, COMMUNITY RELATIONS 6a. Does this Directive Superosde Previous Dlrectlvs(8)?| X | yes | j No What directive (number, title) 1 1 1 1 9230-°-1 b. Does It Supplement Previous Directives^)? | | yes 1 XI No What directive (number, tttle) 7. Draft Level 1 A-SlgnedbyAA/DAA I 1 B - Stgnsd by Offtee Director 1 C- For Review 6 Tiki** RnMiiMAfr **——*•— f^ftiUFWt ^* — -~*SrAA ^Sratam s^fc**M*4 This Request Meets OSwen Dncuves Astern rormat B. Signature of Lead Offtee Olrecttves Coordinator 9. Name and Title of Approving Official HEDEMAN i Comment In Development Date Date 05/09/83 OSWER OSWER OSWER DIRECTIVE DIRECTIVE ------- OSWER Directive 9230.0-02 SUPERFUND COMMUNITY RELATIONS POLICY MAY 9, 1983 Community relations must be an integral part of every Superfund-financed remedial or removal action. This section provides overall policy on the conduct of community relations in Superfund. Community Relations in Superfund: A Handbook supplements this section with background material and more detailed procedural guidance on planning and implementing effective community relations programs. A. Program Objectives The objectives of the Superfund community relations program are as follows: • To gather information about the community in which a site or incident is located; • To inform the public of planned or ongoing actions; • To give the public the opportunity to be involved in decision making; • To focus and resolve controversy. B. Program Design In meeting the objectives of the Superfund community relations program, five general principles must be stressed. • (1) The community relations effort at a particular site must be tailored to the distinctive and.individual characteristics of the sice and the surrounding community. * (2) The5 design of a community relations program for a site should take into account both the technical complexity o€ jthe problem and the level of citizen concern. A more intensive program is required for situations that either are technically complicated or have generated a high level of local citizen concern. (3) Up-front community relations planning is essential to an effective Superfund response. The key to proper planning is a knowledge of community concerns at the site and the scheduled technical action. ------- OSWER Directive 9230.0-02 - 2 - (4) In most cases, small-scale, informal communication techniques should be used, rather than large-scale, forma,! techniques (such as public hearings). (5) Adequate opportunity must be given for the public to comment on proposed remedial cleanup actions prior to final EPA decisions. C. Program Implementation Community Relations Plans. EPA regional offices are responsible for developing community relations plans for Superfund-financed actions. These plans must be submitted to EPA Headquarters for review. They are submitted together with the 14-point contractual document, for planned removals, or as part of the cooperative agreement or state Superfund contract, for remedial actions, as explained below; plans for immediate removals are submitted independently. Headquarters may recommend modifications to a plan on the basis of its review. Approval of the 14-point document, cooperative agreement, or state contract constitutes approval of the community relations plan. Funding for an action might be withheld if a plan is unacceptable. The requirement to submit community relations plans to headquarters for review may be suspended if an EPA region has demonstrated that it is able to plan and implement effective community relations programs. The region will then be entrusted with full responsibility for community relations. At the request of the region, however, headquarters staff may still assist the region by reviewing CRPs and other planning documents, offering recommendations, and otherwise supporting the implementation of community relations programs. A community relations plan is a management and planning tool which outlines the specific communications activities to be used during a Superfund response and the integration of these activities with the technical work at a site. The plan must include an assessment of community interests and concerns. This assessment must be based on on-site discussions with local officials, civic leaders, and community residents in order to gauge their concerns and to determine the level of community relations effort that will be necessary during the action. Each plan must contain the following elements: • Background and history of community involvement at the site: -*• Site history -• - Local activity and interest -- Key issues • Specific objectives of the community relations program • Community relations techniques to be used to meet specific objectives, including progress reports on site work and reports on upcoming activities ------- • 3 • OSWER Directive 9230.0-02 • Vorkplan and schedule • Budget and staffing plan • List of affected and interested groups and individuals and a list of EPA, other federal, and state technical and community relations officials Removal Actions. Immediate removals under the National Contingency Plan are taken to "prevent or mitigate immediate and significant risk or harm to human life or health or to the environment" (40 CFR 300.65(a)). The on-scene coordinator's principal responsibility is to protect public health and the environment until the immediate removal is completed. During such an incident, the primary community relations responsibility is to inform the community about response actions and their effects on the community. For those immediate removals requiring headquarters' funding approval, a brief community relations plan must be prepared and submitted to headquarters for review. The "short form" community relations plan can be used as a model. Planned removal actions usually allow more time than immediate removals for planning and consultation with the local community. The draft action memorandum requesting approval for a planned removal will include an assessment of community interest and concerns. A community relations plan, covering the entire action, must be prepared and submitted to headquarters for review along with the "14 point" contractual document. At the conclusion of the planned removal, a responsiveness summary must be prepared. This summary should include a list of community relations activities conducted, an account of the issues that arose, and an explanation of how citizen concerns were dealt with during the response. Remedial Actions. A community relations program is a key requirement of federal and state activities during a remedial action. Community relations plans must be developed for all Superfund-financed remedial actions. The following steps must be taken to meet this requirement: 1. The Remedial Action Master Plan (RAMP) must include an assessment section which provides background information on community involvement at the site. The on-site community relations discussions must provide the basis for this section of the RAMP. The section should include: • Background and history of community involvement at the site (site history, local activity and interest, and key issues). • Specific objectives of the community relations program. ------- OSWER Directive 9230.0-02 - 4 - • Any immediate community relations activities recommended prior to submission of the community relations plan. • List of affected and interested groups and individuals. -• Schedule for completion of community relations plan. 2. A community relations plan must be prepared and submitted to headquarters as part of the cooperative agreement application or the state Superfund contract. This plan includes: • The community relations assessment from the RAMP. • A list of community relations activities to be conducted at the site. • Budget estimate. • Tentative implementation schedule and workplan. 3. The community relations plan must be completed by including a detailed workplan and budget, a staffing plan, and a schedule. Funding for a remedial action might be withheld if this complete community relations plan is not acceptable. 4. When the feasibility study is completed, the community relations plan must be revised to include communications activities during the design and construction phases. The public must be given a three week minimum comment period to review the feasibility study prior to selection of a remedial alternative. In some cases, components of projects may proceed prior to completion of the full feasibility study. In such cases, opportunity for public review still must be provided. In the case of simple remedial measures, such as fencing, storing drums, site security, etc., the public should be informed through the public meeting on the RAMP. For components of remedial actions (such as moving drums off-site), for which expedited feasibility studies are completed prior to the final feasibility study, the public comment period may be shortened, but the public still m^ust be given at least two weeks to review this draft feasibility study. The Regions may extend any comment period if there is a reasonable request for an extension (e.g., if citizens had insufficient time to review the feasibility study because of delays in receiving copies), as long as the extension does not exacerbate threats to public health, welfare, or the environment at the site. At the conclusion of any public comment period, a responsiveness summary will be prepared. This document will include a summary of the public ------- OSWER Directive 9230.0-02 - 5 - comments, the Agency's response to those comments, and a list of community relations activities conducted. Chapter 3 of the Handbook provides further guidance on community relations during remedial actions; Chapter 2 discusses removal actions. D. Administering the Community Relations Program * EPA headquarters is responsible for policy development, review of community relations plans, and overall program monitoring and evaluation. Headquarters also provides informational materials on Superfund and overall contract management. • For federal-lead responses, EPA regional offices are responsible for the development, implementation, and revision of community relations plans in conformance with this policy, supervision of contractors providing regional community relations support, and coordination with states. For state-lead responses, the state is responsible for the development, implementation, and revision of community relations plans in conformance with this policy and the supervision of contractors providing state community relations support, and coordination with the EPA regions. For all remedial responses, EPA regions are generally responsible for preparing the RAMP community relations assessment. i Contractors can be used to perform the preparatory work needed for community relations activities. Contractors, however, must; never represent (or appear to represent) EPA before the public. Refer to: Community Relations in Superfund: A Handbook, U.S. Environmental. Protection Agency, 1983. ------- |