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
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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
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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.
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OSWER Directive 9230.0-02
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(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
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• 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.
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OSWER Directive 9230.0-02
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• 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
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OSWER Directive 9230.0-02
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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.
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