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

                                  -  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

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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

                                  -  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

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                        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.

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