HI
RCRA CORRECTIVE ACTION
COMMUNITY RELATIONS GUIDE
FINAL
August 1990
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Final
August 1990
REGION III RCRA CORRECTIVE ACTION
COMMUNITY RELATIONS GUIDE
TABLE OF CONTENTS
Introduction i
Chapter I REGION III RCRA CORRECTIVE ACTION COMMUNITY RELATIONS 1-1
Objectives 1-1
Roles and Responsibilities , 1-1
Resource Requirements I-2
Level of Effort. I-2
Out-of-Pocket Expenses I-2
Chapter II REQUIREMENTS OF A BASIC COMMUNITY RELATIONS PROGRAM 11-1
The Community Relations Plan 11-1
Contents of the CRP II-2
Information Repository II-4
Preparing the Notice II-5
Publishing the Notice II-5
RFI Work Plan Fact Sheet II-5
Contents of the Fact Sheet II-6
RFI Wck-Off Meeting II-7
Meeting Objectives II-8
Public Meeting Components II-8
Public Notice of Proposed Corrective Action Measure II-9
Proposed Corrective Action Measure Fact Sheet II-9
Contents of the Fact Sheet 11-10
Public Comment Period 11-11
Response to Comments 11-11
Opportunity for a Public Meeting on the
Proposed Corrective Action Measure 11-11
Meeting Objectives 11-11
Public Meeting Components 11-12
Public Notice of Final Corrective Action Measure _. 11-12
Corrective Action Design Fact Sheet 11-12
Contents of the Fact Sheet 11-13
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Final
August 1990
Chapter III EXPANDED COMMUNITY RELATIONS 111-1
Community Interviews III-2
Briefings III-2
Door-to-Door Canvassing III-3
News Conferences III-3
Availability Sessions III-3
Revisions of Community Relations Plans III-3
Facility Tours III-4
Small Group Meetings '. HI-4
Additional Fact Sheets HI-4
Telephone Hotline HI-5
Translations HI-5
Workshops HI-5
Appendix A: Public Meeting Checklist
Appendix B: Pointers for Preparing Public Information Materials
Appendix C: Sample Response Card
Appendix D: Sample Notice of Public Meeting
Appendix E: Sample Information Repository Public Notice
Appendix F: Sample Public Notice of Proposed Corrective Action Measures
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INTRODUCTION TO THE REGION III RCRA CORRECTIVE ACTION
COMMUNITY RELATIONS GUIDE
Public involvement and participation is an important part of the Resource
Conservation and Recovery Act (RCRA) corrective action process. The U.S.
Environmental Protection Agency (EPA) and the facility undertaking a corrective action
are responsible for ensuring that opportunities for public involvement are provided
during corrective action activities.
The blueprint for such community relations activities is the Community Relations
Plan (CRP). The purpose of this Community Relations Guide is to provide guidance to
facilities undertaking a corrective action on how to develop a CRP. This guide
identifies the basic components of a CRP and recommends how these components
should be implemented. Recognizing that each facility and the surrounding community
is unique, this guide does not provide rigid standards. Rather, it focuses on the
appropriate procedures to be followed when performing community relations activities,
and the roles and responsibilities that both EPA and the facility have in every activity.
The guide is organized into three chapters:
• Chapter I: Region III RCRA Corrective Action Community Relations identifies
and explains objectives of a community relations program and the basic
resources needed.
• Chapter II: Requirements of a Ba^if; Community Relations Program describes
the basic community relations components for each facility undertaking work
pursuant to a RCRA 3008(h) order.
• Chapter III: An Expanded Community Relations Program focuses on additional
community relations activities that may be appropriate in communities where
citizen interest or concern is high.
In addition, appendices are included that provide a public meeting checklist guidelines
on preparing written materials for the public, and samples of various documents.
For more information on Region III corrective action community relations,
contact the RCRA Public Involvement Coordinator at:
US EPA, Region III
Office of Public Affairs (3EA20)
841 Chestnut Builidng
Philadelphia, PA 19107
(215) 597-9370
EPA guidance documents that provide additional useful information on public
involvement and community relations programs are:
Guidance for Public Involvement in RCRA Section 3QQ8(h) Actions (OSWER
Directive 990 1.3, May 1987)
Community Relations in Superfund: A Handbook (OSWER Directive 9230.0-
3B, June 1988)
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Guidance on Public Involvement in the RCRA Permitting Prnqmm (QSWER
Directive 9500.00-1 A, January 1986).
These documents are available by calling the RCRA/CERCLA hotline at 1-800-424-
9346 (in Washington, D.C., 382-3000).
This guide was prepared for EPA Region Ill's RCRA/UST Enforcement Branch,
Corrective Action RCRA Enforcement Section. The EPA Work Assignment Manager was
Dana J. Bamett, with technical direction provided by Joseph Kotlinski and Peter Bentley
(Office of Public Affairs). Review and input was also provided by Hal Yates of the Office
of Public Affairs. Contractor support was provided by COM Federal Programs
Corporation and Booz, Allen and Hamilton Inc., a subcontractor, under EPA Contract
68-W9-0004.
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CHAPTER I
REGION III RCRA CORRECTIVE ACTION COMMUNITY RELATIONS
Under a RCRA 3008(h) order, a facility is responsible for conducting a RCRA
Facility Investigation (RFI) to determine the nature, rate, and extent of on and off site
contamination, a corrective measures study (CMS) to investigate and evaluate various
remedial alternatives, and corrective measures implementation. As part of the RFI
Workplan, a facility must develop and implement a CRP to ensure that public
involvement opportunities exist for people who live or work in, or are otherwise
concerned with, the area surrounding a facility undertaking corrective actions.
The basic requirements for community relations during corrective action should
be developed in a way that is most appropriate to the circumstances at each facility. In
addition to these basic requirements, expanded Community Relations activities may be
necessary in specific situations (See Chapter III for more information).
OBJECTIVES
The RCRA corrective action community relations program is a partnership
between EPA and the facility performing corrective action. Together they formulate and
implement community relations programs that are responsive to the needs of the
community. Under RCRA 3008(h) corrective action orders, the objectives of the
program are:
To create communication channels that provide opportunities for public
involvement
To provide access to information
To integrate community concerns, interests and comments into all activities and
decisions, as appropriate
To create early and continuing opportunities for public participation in RCRA
corrective actions
To ensure Agency understanding of and responsiveness to public concerns
To anticipate conflicts and provide early means of resolution
To give the public the opportunity to comment on and provide input to technical
decisions
To inform the public of planned and ongoing actions.
A CRP should be developed that is responsive to the individual facility's situation, the
circumstances of the corrective action, and the community in the vicinity of the facility.
ROLES AND RESPONSIBILITIES
The major players in community relations planning are the EPA RCRA Project
Manager for the facility, EPA's RCRA Public Involvement Coordinator, and a contact at
the facility who will coordinate community relations activities with EPA,
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The facility must develop all written materials, such as the CRP, fact sheet, and
any handouts used at public meetings (described in Chapter 2) and submit these drafts
to EPA for review. These documents become "final" upon EPA approval. The facility is
then responsible for distributing the documents to the public.
When a public meeting is necessary, EPA will direct the facility to make all
arrangements regarding the location and time of the public meeting. It is left to the
discretion of EPA as to who will conduct the meetings, EPA or the facility.
Bimonthly progress reports are required pursuant to a RCRA 3008(h) order.
These should contain information concerning the status of the investigation and also all
public outreach efforts conducted by the facility during the reporting period. These
bimonthly reports give EPA an overview of the facility's entire public outreach effort and
will help coordinate overall communication efforts. The facility should inform EPA as
soon as possible, of any problems that arise in the planning and conducting of
community relations activities.
RESOURCE REQUIREMENTS
To conduct an effective community relations program, a facility must plan
ahead, prioritize its activities, and fund the program adequately. If a facility's responses
are reactive only, resources will be spent "putting out fires", and the community's
perception of the facility and the work being undertaken may be affected.
All required community relations activities can be conducted by available facility
personnel. The kinds of staff needed are as follows:
1. Professional staff person experienced in writing documents in non-
technical, concise language
2. Support staff member to coordinate with EPA
3. Contractors (optional) to conduct a portion or all of the community
relations activities.
Cost for conducting community relation activities will vary depending on the facility's
size, resources, and experience. The cost of completing the basic community relations
activities usually range from $5,000 to $30,000. This includes both "manpower" or
level of effort and "out-of-pocket" expenses.
LEVEL OF EFFORT
The level of effort Is the number of total hours it takes to complete all aspects of
an activity, including technical and support staff. Overall, community relations activities
require from approximately 250 to 350 hours. These hours are divided among public
affairs, technical, and support staff. Further detail on hours can be found throughout
Chapter II.
OUT-OF-POCKET EXPENSES
Cost incurred while conducting public outreach activities include out-of-pocket
expenses such as mailing and advertising costs, court reporter fees, and meeting room
charges. Each facility's actual costs will vary widely depending on the size of the
community, proximity to a large metropolitan area, and the cost of living of the area. If
costs become too high, EPA and the facility can work together on alternatives.
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CHAPTER II
REQUIREMENTS OF A COMMUNITY RELATIONS PROGRAM
The eleven activities that make up the Region III Corrective Action Basic
Community Relations Program correspond to steps in the corrective action process.
They are conducted to aid community involvement throughout the process and are
listed below in Exhibit 1.
EXHIBIT 1
Technical Phai
RCRA Facility
Investigation
Corrective Measures
Study
Corrective Measures
Implementation
Basic Community Relations
Community Relations Plan
Information Repository
RFI Work Plan Fact Sheet
RFI Work Plan Kick-Off Meeting
• Public Notice of the Final Corrective
Measure Alternative
• Fact Sheet on Corrective
Action Design
• Public Notice of Proposed Corrective
Measure Alternative
• Proposed Corrective Measure Alternative
Fact Sheet
• Public Comment Period
• Opportunity for a Public Meeting
• Response to Comment
THE COMMUNITY RELATIONS PLAN
The facility writes and submits the CRP to EPA along with the draft RFI work
plan. The CRP identifies the activities that the facility will conduct as part of the basic
program, and any expanded activities planned. The CRP contains informatiorv on the
background and regulatory history of the facility, as well as an assessment of the type
and level of community interest in the facility. Finally, it includes the mailing list of
interested parties and suggested locations for the information repository. The CRP is a
public document and should be written in clear, non-technical language. Development
of a CRP takes approximately 120 hours.
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Contents of the CRP
An outline of the recommended format for the CRP is included in Exhibit 2. The
following is a general description of each of the outline topics.
Overview of the CRP
The overview provides a general introduction to the document, briefly stating
the purpose of the CRP, the information it contains, and the features of the public
involvement effort planned for the community. It also includes a summary of the roles
and responsibilities of EPA and the facility.
Facility Description
The facility description identifies the facility's operations and the anticipated
scope of the corrective action. This brief description summarizes any historical,
geographical, or technical information necessary for the reader to understand why the
facility is undergoing a cleanup. The facility description includes:
Facility map(s) that show the facility's location and proximity to other
landmarks, the layout of facility grounds, and the areas targeted for
cleanup
A history of facility use and ownership
Date and type of known releases contributing to the contamination at the
facility
The threat or potential threat posed to public health or the environment
potentially posed by the facility.
Description of Local Community
The description of the local community focuses on the community's level of
interest in the facility and in corrective action. In general, this portion of a CRP contains
the following information:
Type of community (e.g., geographic and demographic information such
as urban, rural, industrial, or suburban; high, moderate, or low
population density; sizeable foreign-speaking population)
Type of local government
Level and nature of community interest in the facility (e.g., history of
community reaction to the facility and level of interest in facility
operations; information on any citizen groups organized to deal with the
facility)
Number of residences that border facility grounds
Source of area water supplies if groundwater contamination is an issue
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Number of persons employed by the facility and types of jobs held
History of community outreach or public affairs activities conducted by
the facility.
There are a variety of methods available to use in collecting this information. These
include reviewing facility documents and records, researching newspaper articles,
interviewing facility managers and public affairs staff with a historical knowledge of the
facility, and contacting the local planning commission, zoning commission, and
Chamber of Commerce.
A description of the steps taken to collect this information must be included
when the facility sends the draft CRP to EPA. This description should cite the books,
brochures, and records reviewed, as well as persons or organizations contacted.
CRP Activities
The CRP activities section contains all community relations activities that are
planned. In addition to all eleven basic activities that must be described, expanded
activities must also be listed if they are planned. Initially, it may not always be clear if
expanded activities will be necessary. If at any time expanded activities are planned,
the CRP should be updated to include them.
Schedule
The schedule gives a timeline of community relations activities that will occur
during the investigation and corrective action process. All planned events should be
included, with the projected month specified.
Locations for the Information Repository
This section of the CRP lists potential locations in the community where the
Information Repository may be housed and gives details about each location.
Locations should meet the requirements listed below:
Convenient location and hours of operation for the majority of citizens
Access for physically impaired citizens
Availability of photocopying facilities.
Locations that meet these requirements usually include a local library, the city or town
hall, or any other municipal building that has the available space to hold several files of
documents, and is open at least two weekday evenings or Saturdays. In general,
commercial establishments are not considered appropriate.
In listing the possible locations for the information repository, the draft CRP
should provide the following information for each location:
Address and phone number
Contact person
Hours of operation
Availability and cost of photocopying
Access for the physically impaired.
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EXHIBIT 2
RECOMMENDED FORMAT FOR THE COMMUNITY RELATIONS PLAN
A. Overview of Community Relations Plan
B. Facility Description
C. Description of Facility Community
D. Community Relations Plan Activities
E. Schedule
F. Locations for Information Repository
G. Locations for Public Meetings
H. Mailing List/Media Directory
1. Federal Elected Officials
(name, address, phone)
2. U.S. EPA Region III Officials
(name, address, phone)
3. State Elected Officials
(name, address, phone)
4. State and Local Agencies
(name, address, phone)
5. Local Officials
(name, address, phone)
6. Community Organizations, Environmental Groups, and Citizens' Groups
(name, address, phone)
7. Media
a. Newspapers
(name, address, phone, contact person, circulation, deadline for
advertisements, rate per column inch)
b. Television
(name, address, phone, contact person, deadline for public service
announcements)
c. Radio
(name, address, phone, contact person, deadline for public service
announcements)
8. Interested Individuals*
* EPA may choose to omit names and addresses of private citizens from the final community
relations plan that is released to the public. These names, however, should be included on the
mailing list that is compiled for the facility.
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If possible, two or three potential locations should be included in the draft CRP. EPA is
responsible for choosing the most suitable location(s) for the information repository and
will contact the appropriate person to set up the repository. The final CRP should only
list the location(s) of the information repository selected. Additional information
concerning the information repository is found in the section entitled, RFI Work Plan
Fact Sheet.
Locations for Public Meetings
The CRP also contains suggested locations for public meetings. Meetings are
generally not held on facility property. Like the information repository, public meetings
should be held in convenient locations that are accessible to the physically impaired.
Other information that should be included about the public meeting location is:
Name and address of suggested location
Contact person
Seating capacity and type of seating
Cost of rental for the meeting facility, if applicable
Charges for security or janitorial services
Advance notice required
Availability of audio-visual equipment and rental charge, if applicable
Availability of a public address system
Typical appropriate locations for public meetings include a library, school buildings,
city or town hall, fraternal lodges, fire stations, and church halls. As with the information
repository, EPA will review the information in the draft CRP and determine the public
meeting locations that are suitable. The final CRP will contain the list of public meeting
locations that EPA selected as the most appropriate.
Mailing List and Media Directory
A mailing list of appropriate Federal, state, and local officials, interested groups
and individuals who will receive information pertaining to the corrective action must be
developed and included in the CRP. Also included is a directory of local newspapers
and television and radio stations that can publish or air public service announcements
concerning community relations activities. All mailings should also be sent to these
media representatives. Exhibit 2 (which follows page 11-3) provides a format for the
mailing list and media directory.
To facilitate EPA review of the draft CRP, the facility should provide a brief list of
the sources for all entries in the mailing list/media directory. The facility should also
indicate other sources consulted, even if these sources did not result in an entry on the
mailing list/media directory.
INFORMATION REPOSITORY
The information repository is a public location that contains corrective action-
related documents. The repository is established following EPA approval of the draft
RFI work plan. EPA selects a location or locations from those suggested in the CRP.
EPA then contacts the location and begins procedures for establishing the repository.
EPA is responsible for sending documents to the repository and ensuring that it is
maintained in an orderly fashion. Refer to Exhibit 4 (at the end of this chapter) for
more information concerning the roles and responsibilities of EPA and the facility.
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The specific chronology and responsibilities for publication of the information
repository are as follows:
The facility suggests locations for the information repository
EPA selects an information repository location and informs the facility
The facility drafts the public notice and submits it to EPA for review and
comment
The facility revises and resubmits until EPA determines that the text is
suitable
The facility confers with EPA regarding the newspaper in which the
notice will be published and the day(s) it should run
The facility coordinates with the newspaper to set up the day(s) of
publication
The facility receives "tear sheets" -- samples of the page(s) on which the
ad ran, from the newspaper and sends a copy to EPA.
Preparing the Notice
Since the repository's main purpose is to serve public information needs, the
public must be informed of its location, purpose, and contents. To accomplish this, the
facility publishes a public notice in a local newspaper. The notice contains information
on the repository, including its location, hours of operation, the types of documents to
be housed there, and the names and phone numbers of contact persons at the
repository location, EPA, and the facility.
All statements that are published must be accurate and error-free.
This procedure applies each time preparation of a public notice is required.
Publishing the Notice
Sunday is usually the best day to run a public notice, as readership is generally
at its peak. At a minimum, the notice should run one day. If there is considerable
community concern about the corrective action, the notice should run at least two days.
The notice should be placed in the news section of the newspaper, where it will
attract the most attention. The facility should ask the newspaper to supply at least two
"tear sheets". One copy is for facility files, the other is sent to EPA.
This procedure applies each time publication of a notice is required.
RFI WORK PLAN FACT SHEET
Fact sheets are an excellent method of communicating information about
specific complex issues to laypeople in the community. Fact Sheets can take 80-120
hours to complete and are generally four to six pages long. They are tailored to the
needs and interests of the affected community.
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The RFI Work Plan Fact Sheet informs citizens of the scope and purpose of the
upcoming investigations and studies at the facility. The facility is required to prepare
an RFI fact sheet and distribute it to the mailing list, making extra copies available at the
information repository, and to EPA and interested parties, as requested. EPA directs
when work on the fact sheet begins, but work usually starts after both the RFI work plan
and the draft CRP are submitted to and approved by EPA. The RFI work plan generally
contains all of the information that needs to be included in the fact sheet.
For more information concerning the roles and responsibilities of EPA and the
facility see Exhibit 4.
Contents of the Fact Sheet
The recommended format for the RFI fact sheet is as outlined below:
j
Introduction
The introduction briefly states the purpose of the fact sheet and the types of
information it contains. The introduction also contains a brief explanation of the RCRA
corrective action process (i.e., RFI, CMS, and implementation). This section should be
one paragraph and should include a sentence stating that the fact sheet was written by
the facility and approved by EPA.
Facility Background
The background section contains a description of the facility, its operations, and
its regulatory history. This one or two-paragraph section includes the following:
Facility location
Facility ownership
Length of time the facility has been operating
Types of operations
Date when the 3008(h) order was issued.
Facility Description
The facility description section gives detailed information on the specific area
scheduled for investigation. Types of information include:
Numbers and types of regulated units and solid waste management
units (SWMUs), if applicable
• Kinds of wastes generated or otherwise handled
Types of known releases contributing to the contamination at the facility.
This section can range from one paragraph to one page in length.
Facility Map
At least one facility map should be included in every fact sheet. The map
should locate the regulated units and SWMUs, if applicable, at the facility. It should
depict all aspects of the regulated units and SWMUs that will be involved in the
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investigation, such as lagoons, swamps, or ponds. The map should include as many
details about the facility as possible, while still being clear and legible.
Scope of RCRA Facility Investigation/Corrective Measures Study
This section contains a general explanation of what the RFI/CMS process is and
how it fits into the general RCRA corrective action process. It includes definitions of
terms and describes the field activities that generally are conducted during the
RFI/CMS process.
Purpose of RFI/CMS
This section contains the facility-specific details of the RFI/CMS. It describes the
purpose of the RFI/CMS as it pertains to the given facility and discusses the specific
information that will be obtained from the field work. The facility should take extra care
in preparing this section to ensure that information is presented in clear, simple
language that can be readily understood by the public.
Projected Schedule
The projected schedule of activities includes field work startup and completion
dates. This information can be presented in paragraph form, or it can be graphically
depicted using a timeline.
EPA/Facility Roles
This section describes the relationship between EPA and the facility. The
facility should make it clear that it conducts and finances remedial and community
relations activities, while EPA provides guidance and oversight throughout the process.
For More Information
A fact sheet is one-way communication from EPA and the facility to the public,
so sources must be provided for further information. This section should include the
names and addresses of EPA and facility contacts, as well as the location of the
information repository.
RFI Kick-Qff Meeting
The fact sheet should contain the date and time for the worK plan Kick-off
meeting, if EPA has scheduled one. This information should be highlighted in some
way, such as placing it in a box or printing it in boldface type.
RFI KICK-OFF MEETING
EPA and the facility organize the public meeting to explain the reasons for and
objectives of the RFI and CMS and associated schedule(s). At the meeting, community
members raise questions, express concerns, and provide EPA with information that the
Agency factors into its technical or procedural decisions about the facility.
As a general guideline, EPA has the major role in determining what information
is communicated to the community and where the meetings are held. Usually EPA acts
as the moderator of the meeting and the facility makes a presentation. The facility
plays a major support role in making the logistical arrangements, presenting
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information at the meeting, and documenting the meeting proceedings. Exhibit 3,
following this page, summarizes these roles and responsibilities.
Meeting Objectives
The RFI kick-off meeting is particularly important because it is conducted early
in the process, providing the first substantive opportunity for the community to learn
about the actions at the facility and provide input. One main objective of the meeting is
to inform citizens of the facility history and status, EPA and facility roles and
responsibilities, and opportunities for public involvement. The other main objective is
for the Agency and the facility to gauge the degree and type of concern that area
residents bring to the public forum.
The EPA RCRA Project Manager sets the agenda and usually runs the meeting.
A typical meeting lasts approximately two hours. The agenda should include:
Introduction and welcome
Purpose
Background and facility status
EPA and facility roles and responsibilities
RFI/CMS description
Opportunities for public involvement
Question and answer period
Conclusion.
Typically these items are addressed by EPA staff, specifically the RCRA Project
Manager or the Public Involvement Coordinator. The RFI description, however, is
generally presented by the facility or its contractors. During the question and answer
period, the EPA RCRA Project Manager may also request that the facility respond to
particular questions.
Public Meeting Components
As soon as possible in the RFI/CMS process, EPA and the facility should
anticipate holding a public meeting. Typically, approval of the RFI work plan triggers
the planning activities for this meeting. It generally takes 32-80 hours to complete
preparations for a public meeting. Preparations for the RFI kick-off meeting include a
planning conference call, logistics, a dry run, and a meeting summary.
Planning Conference Call
The EPA RCRA Project Manager will coordinate a conference call to discuss
details of the kick-off meeting with the facility staff members who will be involved.
Logistics
Following the planning conference call, a number of logistical plans must be
made. They are as follows:
Location/room arrangements/building access
Potential contractual agreements
Audio-visual arrangement
Public notice
Meeting set-up
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EXHIBITS
OVERVIEW OF ROLES AND RESPONSIBILITIES FOR PUBLIC MEETINGS
BASIC PUBLIC MECTNO
ACTIVITIES
FACIUTY&OLB
Planning Conference Call
Coordinate with EPA RCRA project manager
Set up call
Prepare and submit to EPA notes detailing
agreed upon roles and responsibilities for
public meeting
Inform facility of parties to call
Lead the conference call discussion
Decide on agenda, key points, meeting
date, presentation format
Review and confirm assignments for
follow-up meeting planning
Logistics: Meeting Location/Room
Arrangements/Building Access
Check with EPA for meeting location
Make necessary visits to meeting location
and calls to EPA to confirm suitability of
meeting site
Secure confirmation to use meeting
room and arrange for payment if
necessary
Inform facility of preferred meeting
location
Authorize use of selected meeting
room
Logistics: Audio-Visual
Arrangements
Logistics: Potential
Contractual Agreements
Secure needed A-V equipment
Check equipment, electrical suppport
systems to ensure working conditions
Inform facility of preferred meeting
location
Identify EPA personnel with whom
facility may arrange to borrow
equipment
Coordinate with meeting location personnel to
fulfill any contractual agreements necessary for
use of the room
Arrange for payment
Ensure contractual agreements are
properly executed
Logistics: Public Notice
Check with EPA to confirm newspapers) for
notice
Arrange for publication
Prepare draft notice and submit to EPA
Submit final notice to newspaper
Send copies of notice to TV/radio news, public
service departments and mailing list
Confirm appropriate newspaper
Review and approve draft notices for
publication
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EXHIBITS (Cont.)
OVERVIEW OF ROLES AND RESPONSIBILITIES FOR PUBLIC MEETINGS
BASIC PUBLIC MEETING
AcnvrrES
FACILITY ROLE
EPA HOLE
Logistics: Preparation of Meeting
Signs, Attendee List, Handouts, and
other Support Materials
Coordinate with EPA to determine
content of any handout material
Upon EPA approval, prepare handouts
Direct decisions regarding type and
quantity of materials to be produced
Review handout materials
Ensure that materials are produced and
presented at meeting
Logisitics: Prepare
Audio-Visuals
Prepare draft materials and submit to EPA
for review; revise accordingly
Supply necessary information and
resources such as maps
Review draft A-V materials, provide
comments, approve
Logistics: Local Contacts
Check with EPA to determine if facility is
responsible for contacting local officials or
interest groups
Upon direction from EPA, prepare notices
or fact sheets
Upon approval from EPA, send notices or
fact sheets, or inform officials or residents of
meeting by telephone
Determine whether EPA or facility will
contact local officials/interest groups
Coordinate with facility to make or
approve contacts
Meeting Summary
Attend the meeting; take notes of proceedings Prepare Agency notes of meeting
proceedings
Prepare and submit draft meeting summary Review and comment on draft
to EPA summary submitted by facility
Revise draft based on EPA input
Approve final summary prior to
placing in information repository
Meeting Dry Run
Prepare materials to be used in dry run
Attend and comment on dry run
Assist EPA in revision of meeting visuals
and other materials, pending changes
required by dry run
Coordinate with facility to
prepare dry run materials
Prepare and give meeting
presentation
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Meeting sign, sign-in list, agenda, other handout materials
Local contacts
The facility's communication support staff should handle the logistical arrangements for
the meeting in close consultation with the EPA RCRA Project Manager and/or EPA
Public Involvement Coordinator.
Public Meeting Dry Run
To allow time for any necessary reproduction of audio-visuals and to gather
additional information that may prove necessary, the dry run should be held at least
one (1) week prior to the meeting.
Meeting Summary
The facility will attend the meeting, take notes, and prepare a draft summary of
the meeting proceedings, including a paraphrased summary of questions raised and
responses made during the question and answer period. The facility will submit the
summary to EPA two weeks after the meeting and will subsequently revise the
summary based on EPA's review and comment. Upon EPA's approval of the summary,
the facility will place it in the information repository.
PUBLIC NOTICE OF PROPOSED CORRECTIVE ACTION MEASURE
After the CMS is complete and EPA makes a preliminary selection of the
preferred corrective action measure, there is a 30-day public comment period. To
encourage public input prior to the public comment period it is the facility's
responsibility to publish, in a newspaper of general circulation, a public notice that
briefly describes the proposed corrective measure and announces the public comment
period.
PROPOSED CORRECTIVE ACTION MEASURE FACT SHEET
The proposed corrective action measure fact sheet is initiated when the EPA
issues a Statement of Basis (SOB) to the facility.
The SOB includes the following:
Facility background
Facility description
Facility map
Cleanup levels
Points of compliance
Duration of cleanup
EPA's rational for chosing corrective measure
Upon receipt of the SOB, the facility is required to prepare a proposed corrective action
measure fact sheet and distribute it to the mailing list, making extra copies available in
the information repository and to EPA and interested parties, as requested. The
purpose of the proposed corrective action fact sheet is to inform citizens of the results of
the Corrective Measure Study, the alternatives studied to address contamination, and
the corrective measure alternative proposed by EPA. The fact sheet also describes the
opportunity for citizens to comment on the proposed corrective action.
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The CMS report generally contains all of the information that needs to be
included in the fact sheet. The responsibilities and chronology of events for producing
a fact sheet are described in Exhibit 4.
Contents of the Fact Sheet
Appendix B contains general criteria for writing to the public. Following is the
recommended format for the proposed corrective action measure fact sheet. The
sections that are indicated with an asterisk (*) are described previously and will not be
repeated here.
Introduction
The introduction provides a general overview of the document by briefly stating
the purpose of the fact sheet and the types of information it contains. The introduction
should indicate that the fact sheet describes the alternatives analyzed to address the
contamination, identifies the preliminary decision on a preferred measure and explains
the rationale for the preference, highlights key information in the RFI/CMS report to
which the reader is referred for further details, and solicits community input in selection
of the final corrective action measure. The components that make up the treatment
should be explained, as should any engineering or institutional controls necessary,
such as monitoring wells. This section is generally three to four paragraphs in length
and should include a sentence stating that the fact sheet was written by the facility and
approved by EPA.
* The Statement of Basis
Summary of Alternatives
This section briefly highlights each of the alternatives evaluated in the detailed
analysis of the CMS. Quantities of waste and implementation requirements related to
each component should be noted, as well as the estimated construction and
maintenance costs and the estimated implementation time of each alternative.
The Proposed Measure and Evaluation of Alternatives
This section identifies the proposed alternative, emphasizing that the selection
of this measure is preliminary and could change. The section then describes the
criteria against which the alternatives are evaluated. Following this description, the
section presents a summary of the performance of the preferred alternative against the
criteria. This describes the basis for the preliminary selection. Finally, EPA's
preliminary determination that the proposed alternative is the most appropriate choice
is presented.
* EPA and Facility Roles and Responsibilities
* For More Information
Opportunity for Public Meeting
The fact sheet should explain that citizens have the right to request a public
meeting to discuss the proposed corrective action measure and the selection process.
To request a meeting, citizens should call or write the EPA contact person.
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Public Comment Period
The final section of the fact sheet provides a brief explanation of what a public
comment period is, the dates of the public comment period for the proposed corrective
action, and that comments should be made directly to EPA.
PUBLIC COMMENT PERIOD
A 30 day public comment period allows citizens to review and comment on the
Agency's proposed course of action. This public comment period is held after EPA
makes a preliminary selection of its preferred corrective action so that citizen input can
be taken into account before a final remedy is selected. EPA receives oral and written
comments from citizens on the proposed measure, and addresses and compiles them
in the responsiveness summary. Additionally, the public is given the opportunity to
request a meeting with EPA to discuss the corrective action measure.
The facility does not conduct the public comment period. It does, however, play
a role in related activities, such as organizing the public meeting at which comments
are received and arranging for a court reporter to transcribe the meeting. These
activities are discussed in more detail below under "Opportunity for Public Meeting on
the Proposed Corrective Action Measure."
RESPONSE TO COMMENTS
The Response to Comments (RC) is a summary of the written or oral comments
given at public meetings, public hearings, or during the public comment period, and
EPA's responses to them. The purpose of the RC is to document any public concerns
regarding the corrective action and how the Agency responded. The RC becomes part
of the administrative record, the official file that includes all documents to which EPA
referred in selecting the corrective action measure. The administrative record can be
found in the information repository.
The facility's role in developing the RC is to deliver the official transcript of the
public meeting, if one is held, to EPA as soon as possible following the public meeting.
EPA uses the transcript to write the RC.
OPPORTUNITY FOR A PUBLIC MEETING ON THE PROPOSED
CORRECTIVE ACTION MEASURE
If the public requests a meeting to discuss the corrective action measure and
the EPA RCRA Project Manager concludes that interest warrants a public meeting, the
facility will be notified. The facility's support responsibilities are described in Exhibit 4.
Meeting Objectives
The major objective of the meeting is to give the public the opportunity to
discuss the corrective action measure with EPA. An equally important objective is for
the Agency to further describe and explain about the technologies that were evaluated
to address contamination associated with the facility, present the proposed corrective
measure, and explain the rationale for this choice.
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The agenda usually should include:
Introduction and welcome
Purpose
Background and facility status
EPA and facility roles and responsibilities
CMS approach and findings
Next steps
Question and answer period
Conclusion.
EPA staff, specifically the Project Manager and/or the Public Involvement Coordinator,
usually cover these items, except for the CMS description which may be given by the
facility or its contractors.
Public Meeting Components
Preparations for the CMS meeting include a planning conference call, logistics,
a meeting dry run, and a court reporter/meeting transcript. The facility has major
responsibilities for each of these items. The first three requirements are identical to
those described for the RFI kick-off meeting, pages 11-8 to 11-9, and should be followed.
See Exhibit 3 for details.
Court Reporter/Meeting Transcript
A certified court reporter should be hired to attend, record, and prepare an
official transcript of the proceedings. Fees for these services vary, depending on the
region, from $50 to $150 for an appearance fee plus $2.50 to $5.00 per page of the
transcript Facilities should contact at least three services for estimates and references.
NOTE: Only typographical errors can be changed on official transcripts.
The facility's confirmation letter should include the correct spellings of names of
persons making presentations. The facility also should send the reporter a copy of any
fact sheets and meeting announcements. The facility should coordinate with the court
reporter and the EPA RCRA Project Manager in advance of and upon arrival at the
meeting to clarify directions on seating arrangements and on how the court reporter will
handle any problem with hearing speakers.
PUBLIC NOTICE OF FINAL CORRECTIVE ACTION MEASURE
The public notice of the final corrective action measure announces to the public
the measure that will be implemented to address contamination at the RCRA facility.
The facility has no role in this phase of the RCRA corrective action process.
CORRECTIVE ACTION DESIGN FACT SHEET
The corrective action design fact sheet informs citizens of the activities that will
take place at the facility during the corrective design phase. The facility is required to
prepare a corrective action design fact sheet and distribute it to the mailing list, making
extra copies available in the information repository and to EPA and interested parties,
as requested. As directed by EPA, work on the fact sheet begins after the corrective
measure design has been approved and before field work begins. Information to
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include in the fact sheet generally can be found in the Statement of Basis. The
responsibilities and chronology of events for producing a fact sheet are described in
Exhibit 4.
Contents of the Fact Sheet
The recommended format for the corrective action design fact sheet is as
follows:
Introduction*
Facility Background *
Facility Description*
Facility Map*
Corrective Action Design Summary
Projected Schedule
EPA and Facility Roles and Responsibilities*
For More Information.*
Information on each section that is indicated with an asterisk (*) has been provided
previously and will not be repeated here. Because each facility and situation is unique,
these guidelines should be adapted as necessary. Appendix B contains general
criteria for writing to the public.
Corrective Action Design Summary
This section discusses the objectives and purposes of the corrective action
design. It includes information on the selected corrective action such as its basic
components and how it will work to remediate contamination problems at the facility.
Because this section contains definitions of treatment technologies that can be highly
technical and complicated, the facility must ensure that this information is conveyed in
clear, simple language that can be readily understood by the public. Diagrams or
illustrations of technologies often can assist a readers' understanding of the treatment
process, and should be included whenever possible. This section generally is two
paragraphs to one page in length.
Projected Schedule
The fact sheet must contain a projected schedule of design activities, including
field work startup and completion dates. This information can be in paragraph form or
can be graphically depicted using a timeline.
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EXHIBIT 4
OVERVIEW OF COMMUNITY RELATIONS ROLES AND RESPONSIBILITIES
BASIC COMMUNITY ;
RELATIONS ACnvmes
FAOOTYItOLE
Community Relations Plan
Information Repository (IR)
RFI Work Plan Fact Sheet
Draft CRP and supporting information
Submit with RFI work plan
Incorporate EPA comments
Research possible locations
Draft notice of IR location(s)
Research information for public
notice
Publish notice in local newspaper
Draft fact sheet
Incorporate EPA comments
Distribute to mailing list
Review and comment on draft CRP
and supporting information
Determine when final
Select IR location(s)
Review and comment on draft notice
Determine when final
Select newspaper in which notice will
appear
Review and comment on draft
fact sheet
Determine when final
RFI Work Plan Kick Off
Meeting
Research public meeting
locations
Make logistical arrangements
Prepare meeting summary
Select location and date
Provide information on equipment
needs, agenda items, etc.
Invite speakers
Hold the meeting
Review and comment on meeting
summary
Determine when final
Public Notice of Proposed
Corrective Action Measure
Draft public notice
Publish notice in local newspaper
Review and comment on draft notice
Determine when final
Select newspaper in which notice will
appear
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EXHIBIT 4 (Com.)
OVERVIEW OF COMMUNITY RELATIONS ROLES AND RESPONSIBILITIES
BASIC COMMUNITY
RELATIONS ACTIVITIES
FACILITY ROLE
Proposed Corrective Action
Measure Fact Sheet
Draft fact sheet
Incorporate EPA comments
Distribute to mailing lists
EPA ROLE
Review and comment on draft fact sheet
Determine when final
Public Comment Period
None
Determine dates for 30-day comment
period
Receive and review comments
Responsiveness Summary (RS) Submit public meeting
transcript to EPA
Draft RS
Finalize RS
Opportunity for a Public Meeting Make logistical arrangements
Hire court reporter
Publicize meeting, if necessary
Public Notice of Corrective
Action Measure
None
Fact Sheet on Corrective Action
Design
Draft fact sheet
Incorporate EPA comments
Distribute to mailing list
Determine if meeting will be held
Determine meeting date and location
Provide information on equipment
needs, agenda items, etc.
Invite speakers
Hold the meeting
Write public notice
Publish notice in local newspaper
Review and comment on draft fact sheet
Determine when final
Bimonthly Progress Reports
Submit progress reports every
two weeks
Review reports
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CHAPTER III
EXPANDED COMMUNITY RELATIONS
Expanded community relations activities are public outreach efforts that extend
beyond the eleven basic activities described in Chapter II. At some facilities there may
be factors regarding the nature of the corrective action or the community that make
basic community relations insufficient to meet the objectives of community relations
described in Chapter I. In these instances, expanded community relations is
appropriate.
In most circumstances, the facility and EPA jointly decide if expanded
community relations is necessary. Either the facility presents expanded activities in the
draft CRP, or EPA will recommend expanded activities in response to the profile of the
community in the draft CRP and the nature of the corrective action activities. At some
facilities it may not become apparent that expanded activities are necessary until after
the CRP has been prepared. In these instances, the CRP should be updated to include
the expanded community relations activities.
The typical circumstances that require an expanded program are:
Historically high community interest in facility operations
Large population living in close proximity to the facility
Direct or potential community contact with the contamination (e.g.,
contaminated drinking wells)
Organized local groups with a high level of interest.
There may be circumstances in which EPA will require a facility to conduct
expanded community relations. One circumstance would be if the facilty were either a
proposed or final National Priorities List (NPL) site. A corrective action that receives
substantial local or national interest is another instance in which EPA may require
expanded community relations.
Expanded community relations may not include all of the public relations
activities that a facility is conducting. Many facilities have extensive, Jong-standing
public relations activities that would be neither appropriate nor possible for EPA to
oversee. Public involvement activities that are deemed necessary and conducted
solely by EPA are also not considered part of the expanded community relations
program. Therefore, expanded community relations includes only those activities that
EPA and the facility agree are necessary to serve the public interest. All activities that
become part of an expanded program are then subject to EPA oversight.
Roles and responsibilities for each expanded community relations activity
should be defined in the CRP, and be consistent with the general structure in which
EPA conducts oversight and approval.
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This chapter presents twelve expanded community relations activities that have
been effective in meeting public involvement objectives:
Community interviews
Briefings
Door-to-door canvassing
News conferences
Availability sessions
Revised Community Relations Plan
Facility tours
Small group meetings
Additional fact sheets on selected topics
Telephone hotline
Translations
Workshops.
These techniques are by no means all-inclusive. They have been used frequently, but
circumstances may dictate other approaches not mentioned here. More detailed
information on how to conduct these activities can be found in the Guidance for Public
Involvement in RCRA Section 3Q08(h) Actions and in Community Relations in
Superfund: A Handbook, both referred to in the introduction to this guide.
EPA and the facility use the information gathered to write the CRP to assess
whether the interests and concerns of the community warrant expanded community
relations activities. For example, if there is concern about municipal water wells in the
vicinity of a ground-water contamination plume, the facility may want to hold occasional
briefings for local officials. A great deal of media interest would mean organizing
media briefings or facility tours. To explain residential water well testing, facility
representatives might go door-to-door, or hold small group meetings.
COMMUNITY INTERVIEWS
Community interviews are informal, face-to-face interviews held with selected
local residents, government officials, community groups, media representatives, facility
owners and employees, and other individuals interested in facility activities. They are
usually used to assist a facility during the development of the CRP. Community
interviews are sources of first-hand information about the community near a RCRA
3008(h) facility. They enable a facility to gain an understanding of the community's
perception of the facility's history, the community's involvement with the facility, and the
political climate in the area; identify credible sources and disseminators of information;
and learn how the community would like to be involved in the RCRA process.
Interviews should be used only as means of obtaining, not disseminating, information.
BRIEFINGS
Briefing sessions are held with key state and local officials and citizens to inform
them of the status of specific facility activities. Facility staff conduct these sessions in
person, and the briefings usually precede release of information to the media^
Briefings are a good community relations method to inform key officials and citizens
about recent developments at the facility; to provide them with background material on
technical studies, results of the field investigations, and engineering design; and to
report to them on corrective measure action planning and progress.
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Briefings are appropriate when state or local officials or citizens have expressed
a moderate to high level of concern about the facility. Briefings are generally held to
announce specific findings such as test results. If ground-water contamination is an
issue, for example, a briefing could be held to inform citizens of the results of
residential well testing.
DOOR-TO-DOOR CANVASSING
Canvassing is the process of gathering information by calling on individuals
door-to-door. This activity permits the most direct, personal contact with the community,
allowing facility staff to meet with community members individually and directly to
discuss corrective action issues or gather needed information.
This activity is best used when information is needed from a specific group of
individuals. For example, canvassing can be used to gather signatures to gain access
to residential property for soil and water testing. Where the goal is to convey rather
than collect information, such as announcing results of drinking water testing, a more
appropriate approach may be to send a letter with the relevant information and the
name of the facility contact person, and/or to conduct a briefing or public availability
session.
NEWS CONFERENCES
News conferences are information sessions or briefings held for representatives
of the news media, but also open to the general public. They provide the media with
accurate information concerning important developments at the facility, and also can
provide an opportunity to announce plans for any future actions.
News conferences should be used primarily to announce findings at the facility
which are of significant interest to the media and the community. A news conference
announcing preliminary results of technical studies may unnecessarily escalate public
apprehension.
AVAILABILITY SESSIONS
Availability sessions are informal meetings in a public location where people
can talk to facility and EPA contact persons on a one-to-one basis. These sessions
allow citizens to ask questions and express their concerns directly to facility and EPA
technical staff.
An availability session is most appropriate when key milestones have been
reached or major decisions made. For example, release of sampling results or draft
studies are appropriate times to hold availability sessions instead of conducting door-
to-door canvassing.
REVISIONS OF COMMUNITY RELATIONS PLANS
All or part of the CRP can be revised to incorporate new information, reflect
changes in community concerns, or prepare for community activities during corrective
measure design and corrective measure action. Revisions ensure that the CRP
accurately reflects community interest and the activities being performed by the facility
and EPA through final phases of the action.
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CRPs should be revised before the corrective measure design begins, if the
corrective measure design/action is not already addressed in the CRP. If, after the plan
has been prepared, community concerns change focus or increase in intensity, the
plan should be revised accordingly. Also, if EPA and the facility agree that community
relations activities are needed that were not included originally in the CRP, it should be
revised.
FACILITY TOURS
Tours are scheduled trips to the facility for media representatives, local officials,
and citizens, during which facility and EPA technical and community relations staff
describe corrective action activities and answer questions. Tours can increase
community understanding of the nature of the problems at a facility and the corrective
action proposed or underway, as well as diminish fears and demonstrate good will.
Conditions permitting, tours can be conducted at any facility where citizens, the
media, or local officials have expressed an interest. Facility tours may be particularly
appropriate during or after the construction phase, so that citizens can see a corrective
action in progress.
SMALL GROUP MEETINGS
Meetings of small groups held in private homes or in local meeting places
enable facility and EPA staff responsible for the corrective action to get first-hand
information from interested citizens and local officials. Small group meetings are held
to inform citizens and state and local officials of facility activities, answer questions, and
clear up any misconceptions or misunderstandings. They can help develop sensitivity
to citizen concerns and establish a rapport and good working relationship with
residents.
Small group meetings can be used effectively during virtually all phases of a
RCRA corrective action, particularly when test results are announced. These meetings
can also provide a forum for explaining how unexpected events may affect the project
schedule.
If issues are raised at the small group meeting that require follow-up, it is the
facility's responsibility to respond within one week of the meeting. The facility reports
on the meeting in the bimonthly reports submitted to EPA.
ADDITIONAL FACT SHEETS
A fact sheet is a brief report that summarizes the current or proposed activities of
the cleanup program. The fact sheet presents technical information in a clear and
understandable format. This helps ensure that the public is informed of the status and
findings of cleanup actions, and that citizens understand the issues associated with the
corrective action process.
Fact sheets are appropriate whenever new information is available, and
whenever a public comment period is required during the response action. In addition
to corresponding with various stages of the RFI/CMS, fact sheets can be written to
explain the facility inspection, corrective measure design, corrective measure action,
and operation and maintenance.
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TELEPHONE HOTLINE
A toll-free telephone number in a facility office provides citizens with an
opportunity to ask questions and obtain information promptly about facility activities. A
telephone hotline is useful during the RFI or construction phase if concern is high about
contaminant levels or similar issues. A hotline is particularly useful if any unexpected
event, such as a fire or explosion, occurs at a facility. A hotline can also be effective
during the construction phase, when citizens may have complaints regarding
environmental impacts such as excessive dust or noise.
TRANSLATIONS
Translations provide written or verbal information in a foreign language to a
predominantly non-English speaking community to ensure that all community members
are informed about corrective action activities and have the opportunity to participate in
the decision-making process. There are three types of translations:
A written translation of materials originally written in English
A verbal translation of a public meeting or news conference by
translating each sentence after it is spoken
• A simultaneous translation of a public meeting or news conference,
usually with small headsets and a radio transmitter.
A translation is desirable where a large percentage of the community is non-English
speaking. A written translation should be provided for fact sheets or letters. Verbal
translations are recommended at meetings where there is considerable concern about
the corrective action or suspicion of the facility's efforts to communicate with the
community members.
WORKSHOPS
Workshops are seminars or a series of meetings to discuss hazardous
substance issues. They allow citizens to comment on proposed response actions and
provide information on the technical issues associated with the corrective action and
the RCRA program in general. Experts may be invited to explain the problems
associated with releases of hazardous substances and possible remedies for these
problems. Workshops serve to improve the public's understanding of the hazardous
substance problem at the facility and to prevent or correct misconceptions. They also
enable facility and EPA staff to identify citizen concerns and to receive citizen
comments.
Workshops are appropriate for presenting technical information to citizens, such
as the draft CMS. Workshops could also be useful to inform citizens of the RCRA
corrective action process, and to increase their understanding of the potential risks
associated with the contamination at the facility.
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APPENDIX A
PUBLIC MEETING CHECKLIST
A quick scan of this checklist can help prevent unwanted surprises.
MEETING LOCATION:
ADDRESS:
Meeting Date & Time
Directions Distributed
Contact Person & Telephone
Facilitator
Number of People Expected
Panel Members Notified —
Agenda Prepared
Oral Presentation Prepared
Keynote Speaker's Comments Prepared
Visual Presentation (slides/graphics/displays) Prepared
Dry Run Date and Location Scheduled
Ground Rules Established
Contingency Plan for Notice of Cancellation or Postponement Prepared
Court Reporter Scheduled
ROOM ARRANGEMENTS
. Room Layout
Room Setup (tables/chairs/press)
Room Access (time open, close) .
Setup Time
Security
Janitorial Services
Rest Rooms Open
Ventilation
Lecterns
Rental Fee
Access for Physically Impaired Persons
Public Address System
All of the items in the checklist may not be needed for every meeting. The facility
should use this as a guide and coordinate with EPA for specifics.
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ANNOUNCEMENT
Call Key Community Contacts
Print Set of Mailing Labels
Prepare and Distribute Fact Sheet
Prepare Press Release
Prepare and Distribute Press Release
- Date:
Send Materials to Information Repositories
Place Public Notice in Newspapers
- Date:
Distribute Meeting Notice Fliers
- Date:
AUDIO VISUAL EQUIPMENT
Slide Presentation/Projector (Extra Bulb)
Overhead Transparencies/Projector (Extra Bulb)
Video Tape Presentation/Tape Player & TV Set
Film Presentation/Projector (Extra Bulb)
Screen
Microphones (Stationary & Remote)
Cassette Recorder/Tapes/Batteries
Press Hookup
35mm Camera/Flash/Film
Video Camera/Tape
Extension Cord(s)
Pointer for Projection Screen
Tables for Projectors)
Equipment Checked And Functioning
BASIC SUPPLIES
Name Plates/Name Tags
Signs
Copies of Agenda
Copies of Fact Sheet
Other Handouts
3"X5" Index Cards
Pens
Markers
Easel/Flipchart
Poster Paper
Blank Paper
Chalk
Eraser
Tape
Scissors
Response Cards
Sign In Sheet
MEETING FOLLOW-UP
Return Equipment
Prepare and Submit Draft
Meeting Summary to EPA
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APPENDIX B
POINTERS FOR PREPARING PUBLIC INFORMATION MATERIALS
What makes a public information document effective is its ability to convey information to
the public clearly and concisely. Following are some suggestions that will assist in
developing effective materials.
Begin each writing project by developing a detailed outline of the purpose
and content of the material to be covered. The audience for whom the
material is intended also should be clearly defined.
Every information program must operate on at least two levels -- the citizens
who are already interested and involved, and those who are not. The
information directed to the less involved or informed group might be
considered preliminary to participation. These materials should be
attractive and brief, and appeal to the needs and concerns of laypeople.
Therefore, it is important to assess the interests of the readership prior to
writing public information materials.
In headlines and initial paragraphs, attract attention and interest with
thought-provoking statements or questions. Link problems and issues with
the reader's life and experience. Personalize messages; demonstrate how
the agency's programs affect people's lives.
Write clearly, simply, and directly, avoiding technical terminology, acronyms,
and professional jargon. Explain technical terms the first time they are used
in a publication. Write general purpose materials at the same reading level
that the local newspaper is written.
Use short declarative sentences with active verbs to make points. Avoid the
use of long and complex sentences. Say it simply.
Use conversational English. For example, use "do" for "accomplish."
Consider using human scale comparisons rather than technical terms to
communicate a point. For example, "the facility will generate noise
approximately equal to that of a typical city street," or "the cost per family will
be about $100 per year."
Each individual element in an information and education program should be
easily linked to the overall program. The reader should easily see the
relationship between a particular topic or product and the total project or
process.
Pre-test all public information products by asking several lay citizens to read
and evaluate drafts for clarity, order, comprehensiveness, and detail. These
people need not live in the community or be familiar with the facility. This
final review can help ensure high quality publications that meet intended
goals.
Use graphics and illustrations to support the written content of a publication.
Photographs, charts, and drawings can communicate ideas quickly and
directly using few words. To emphasize the most critical information,
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sparing use of a larger or different typeface, italics, underlining, holding, or
capitalization is effective. If these techniques are overused, however, their
impact is lost.
Always let the public know where and when full reports and technical
information are available for public review.
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APPENDIX C
Sample Response Card
- Reverse Side -
Rce Manufacturing Company
Response Card
Date: •
Name:_ Please include your
name and address to:
flddress: — Be added to the mailing list.
City: State: Zip: Recelue a response to the
following question/comment.
Question/Comment:
Sample Response Card
- Front Side -
Mr. Franklin Pratt
RCRfl Public Inuoluement Coordinator
U.S. Enuironmental Protection flgency
Region III
841 Chestnut Street
Philadelphia, PR 19107
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APPENDIX D
Sample Notice of Public Meeting
^ *=% The United States Environmental Protection Agency (EPA)
Will Hold a Public Meeting on the Proposed
Corrective Action Measure at the
ACE Company Facility in Cranston, Pennsylvania
The U.S. EPA will hold a public meeting at 7 pm on the evening of Wednesday,
November 28,1990 to answer questions, provide information and receive comments
on the actions that may be taken to address the environmental contamination
problems at the ACE Company facility. The meeting will take place in the Cranston
High School gymnasium at 115 Southbrook Lane, Cranston, Pennsylvania 19436.
The ACE Company facility is located at 2700 Falmouth Highway, approximately 2
miles southeast of the town of Cranston in upper Montgomery County,
Pennsylvania. In October 1989, EPA cited the company for improperly disposing of
untreated chemical by-products into a pond adjacent to the facility. Recently, a
Corrective Measures Study (CMS) was completed that evaluated four measures for
addressing the contamination problem. EPA is proposing that one of these
measures, a modified conventional treatment, be used to treat the pond water. EPA
is accepting public comment on this proposal through Thursday, December 13,
1990, after which a final decision will be made. At the public meeting, each of the
measures will be described and public comments will be taken.
Copies of facility-related documents, including the CMS and the Statement of Basis
which discuss all four of the measures considered, are available for review prior to
the meeting at the information repository located in the City Clerk's office of the
Cranston City Hall Building, 235 Louden Avenue, Cranston, Pennsylvania 19436.
For further information or to submit comments on the proposed corrective action
measure, please contact: Franklin Pratt, Community Relations Coordinator; U.S.
Environmental Protection Agency; 841 Chestnut Street; Philadelphia, PA 19107;
(215)xxx-xxxx. The Ace Company contact is: Roberta Stiltwell, Public Relations
Officer; Ace Company; 345 Filmont Street, Cranston, PA 19436; (717)xxx-xxxx.
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APPENDIX E
Sample Information Repository Public Notice
The United States Environmental Protection Agency (EPA)
Announces the Opening of a
Public Information Repository
for Documents Related to the Corrective Action at the
ACE Company Facility in Cranston, Pennsylvania
The U.S. EPA and ACE Company have established a public information repository
to provide information on the environmental contamination at the ACE facility and
the actions that may be taken to address these problems. The repository is located
in the City Clerk's office of the Cranston City Hall Building, 235 Louden Avenue,
Cranston, Pennsylvania 19436. Copies of facility related documents will be put in
the information repository as they become available. Repository hours are 8 am to 5
pm - Tuesday through Saturday.
The U.S. EPA recently completed a RCRA Facility Inspection (RFI) of the ACE
Company facility. It is located at 2700 Falmouth Highway, approximately 2 miles
southeast of the town of Cranston, in upper Montgomery County, Pennsylvania. On
the basis of this RFI, EPA proposes that ACE take corrective actions to remedy
existing environmental contamination at the facility site. The contamination is the
result of the improper disposal of untreated chemical by-products of ACE Company's
manufacturing processes into a pond adjacent to the facility site. A corrective
measures study is currently underway to develop, screen, and evaluate potential
corrective measures at the facility.
For further information please contact: Franklin Pratt, Community Relations
Coordinator; U.S. Environmental Protection Agency; 841 Chestnut Street;
Philadelphia, PA 19107; (215)xxx-xxxx. The Ace Company contact is: Roberta
Stiltwell, Public Relations Officer; Ace Company; 345 Filmont Street, Cranston, PA
19436; (717)xxx-xxxx.
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APPENDIX F
Sample Public Notice of Proposed Corrective Action Measure
Tho United States Protection Agency (EPA)
Invites Public Comments on
RCRA Facility Investigation/Corrective Measures Study
and Proposed Corrective Action (Measure
at the ACE Company Facility
In Cranston, Pennsylvania
The U.S. EPA announces the beginning of a thirty day public comment period during which EPA invites
both written and oral comments from the public on the Resource Conservation and Recovery Act
(RCRA) Facility Investigation/Corrective Measures Study and the Proposed Corrective Action Measure
for the ACE Company manufacturing facility near Cranston, Pennsylvania. If there is community
interest, EPA also will hold a public meeting on this matter. Please direct all comments and requests for
a meeting to the EPA contact listed below.
The ACE Company facility is located at 2700 Falmouth Highway, approximately 2 miles southeast of
the town of Cranston, in upper Montgomery County, Pennsylvania. ACE Company manufactures
titanium dioxide pigments at the facility. The principal chemicals used by ACE Company in its
manufacturing activities are: 1,1, 1-trichloroethane, ethylene glycol, sodium hydroxide, xylene and
sulfuric acid. As a result of its operations, ACE Company is subject to EPA's RCRA regulations
governing the handling, storage, treatment and disposal of hazardous wastes. The ACE Company
facility was cited by EPA for improperly disposing of untreated chemical by-products into a pond
adjacent to the facility site.
On October 10, 1989, ACE Company and EPA entered into a Consent Order pursuant to Section
3008(h) of RCRA. Under the terms of this Consent Order, ACE conducted an investigation of its facility
in December 1989 and has recently completed a study which evaluated various cleanup alternatives.
ACE Company has submitted a Corrective Measures Study for responding to the contamination problem
to EPA for approval. The Corrective Measures Study evaluated four measures for addressing
contaminated water in the nearby pond. These are:
No action. This alternative would allow the contaminated water to remain in the pond.
> Conventional Water Treatment. This alternative involves recovering the contaminated water from the
pond and passing it through a cascade aerator, a precipitation unit, and a sand filtration unit.
> Modified Conventional Treatment. This alternative involves passing the recovered water through an
equalization chamber, a cascade aeration unit combined with a blower, a precipitation unit, a
sedimentation chamber, and a sand filter.
> Enhanced Conventional Treatment. This alternative involves passing the recovered water through an
equalization chamber, passing air through it using a high-velocity nozzel aerator, a precipitation unit, a
sedimentation chamber, a granular filter, and an ion exchange polisher ("green sand').
The preferred measure for remedying the contaminated water at the facility is Modified Conventional
Treatment. EPA finds this treatment method is the most proven, cost-effective and thorough alternative
examined.
Although this is the preferred alternative at present, EPA welcomes comments on all measures studied.
EPA will make the final choice after the public comment period has concluded, and may choose a
measure other than the initial preferred measure. More information on EPA's decision can be found in
the Statement of Basis. Additional information concerning the alternatives can be found in the RCRA
Facility Investigation Report and the Corrective Measures Study. All of these reports can be found in
the information repository located in the the City Clerk's office of the Cranston City Hall Building, 235
Louden Avenue, Cranston, Pennsylvania 19436. Repository hours are 8 am to 5 pm - Tuesday through
Saturday.
The public comment period is from Tuesday. November 13,1990 through Thursday, December 13,
1990. Comments may be submitted either orally or in writing. Comments must be submitted to EPA if
they are to be included in EPA's deliberations. Please address all comments to: Franklin Pratt,
Community Relations Coordinator; U.S. Environmental Protection Agency; 841 Chestnut Street,
Philadelphia, PA 19107; (215)xxx-xxxx. The ACE Company contact is: Roberta Stiltwell, Public
Relations Officer; ACE Company; 345 Filmont Street. Cranston. PA 19436; (717)xxx-xxxx.
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